United States 

Department of 

Agriculture 

Animal and 

Plant Health 

Inspection 

Service 

July 2014 

USDA 

Analysis in Support of Certification that the 

Rule will not have a Significant Economic 

Impact on a Substantial Number of Small 

Entities 

Interim Rule 

2014-0058 

Advance seven Michigan Counties to 

Accredited Free TB Status 

Policy & Program Development 

Policy Analysis & Development 
Summary 

Michigan has submitted a request for split-State bovine tuberculosis (TB) status that will 

advance seven counties on the Lower Peninsula of Michigan (Antrim, Charlevoix, Cheboygan, 

Crawford, Emmet, Otsego, and Presque Isle) from modified accredited advanced to accredited 

free status. This status advancement will eliminate pre-movement testing requirements for 

producers in the seven counties, saving them time and money. Based on national statistics and 

Small Business Administration size standards, most if not all of the cattle and dairy operations 

affected are likely to be small entities. 

The number of herds in the seven counties that require surveillance testing will be 

reduced from about 390 to less than 120. TB testing, including veterinary fees, costs about $10 

to $15 per head. Based on an estimated 33 head per herd, total annual cost savings are expected 

to range between $90,000 and $135,000 yearly in the seven counties. 

The average value of cattle and calves in Michigan is about $1, 100 per head. Thus, the 

savings by forgoing TB testing represent about 1.3 percent of the average value of the animals. 

This action will not significantly change program operations and will have no significant effects 

on other Federal agencies, State government or local governments. 

The Administrator of the Animal and Plant Health Inspection Service has determined that 

this action will not have a significant economic impact on a substantial number of small entities. 
Table of Contents 

Summary .............................................................................................................................. i 

Introduction ......................................................................................................................... 1 

Potential Impact on Small Entities ...................................................................................... 2 
Introduction 

This analysis provides the basis, as required by the Regulatory Flexibility Act, for 

certification by the APHIS Administrator that the interim rule, if promulgated, will not have a 

significant economic impact on a substantial number of small entities. 

Bovine tuberculosis (TB) is a contagious and infectious granulomatous disease caused by 

the bacterium Mycobacterium bovis. Although commonly defined as a chronic debilitating 

disease, bovine tuberculosis can occasionally assume an acute, rapidly progressive course. 

While any body tissue can be affected, lesions are most frequently observed in the lymph nodes, 

lungs, intestines, liver, spleen, pleura, and peritoneum. Although cattle are considered to be the 

true hosts of M. bovis, the disease has been reported in several other species of both domestic 

and nondomestic animals, as well as in humans. 

The Cooperative State-Federal Tuberculosis Eradication Program, which began in 1917, 

is administered by APHIS, State animal health agencies, and livestock producers. This program 

has nearly eradicated bovine TB from the Nation's livestock population. Transmission to 

humans has been reduced as a result of the eradication program, advances in sanitation and 

hygiene, the discovery of effective drugs, and pasteurization of milk. 

Based upon the prevalence of bovine TB in cattle and bison and the number of herds 

found to be affected, the bovine tuberculosis regulations (9 CFR part 77) classify States into five 

status stages. These five stages are: non-accredited, accredited preparatory, modified accredited, 

modified accredited advanced, and accredited free. Lower status translates into more restrictive 

movement requirements. Additionally, a zone with a different status can be formed within a State 

on a case-by-case basis (commonly referred to as "split-State status"). 

1 
The State of Michigan has asked that the TB status of seven counties (Antrim, 

Charlevoix, Cheboygan, Crawford, Emmet, Otsego, and Presque Isle) be advanced from 

modified accredited advanced to accredited free. APHIS has determined that Michigan's 

application to change the TB status of the seven counties meets program standards. 

Potential Impact on Small Entities 

The cattle and dairy industries play important roles in Michigan's economy. In 2012, 

there were 10,677 cow-calf farms with a total of 1.1 million head. 1 These totals remained largely 

unchanged in 2013. Sales by the State's beef and dairy sectors totaled $603 million and $1.5 

billion, respectively.2 This rule will directly affect very small shares of these sectors. 

The Small Business Administration (SBA) has established guidelines for determining 

which businesses are considered small. According to SBA size standards for beef cattle ranching 

and farming (NAICS 112111) and for dairy cattle and milk production (NAICS 112120), 

operations with not more than $750,000 in annual sales are considered small entities. Nationally 

in 2012, 98 percent of cattle and calf farms and 73 percent of dairy farms generated less than 

$500,000 in cash receipts.3 Based on these national statistics and the SBA size standards, most if 

not all of the cattle and dairy operations affected are likely to be small entities. 

Herd owners in the seven counties advanced from modified accredited advanced to 

accredited free TB status will save time and money due to elimination of pre-movement 

1 2012 Census of Agriculture- State Data and NASS statistics Livestock, Dairy and Poultry 

http://www.nass.usda.gov/Statistics by State/Michigan/Publications/ Annual Statistical Bulletin/stats 13/li 

vestock.pdf 

2 2012 Census of Agriculture- State Data 

http://www.agcensus.usda.gov/Publications/2012/Full Report/Volume I, Chapter 2 US State Level/st9 

9 2 002 002.pdf 3 2012 Census of Agriculture table 66 

http://www.agcensus.usda.gov/Publications/2012/Full ReportNolume 1, Chapter l US/st99 1 066 066 

.pdf 

2 
surveillance testing requirements. However, the cost savings will be small. TB testing costs are 

low compared to the value of cattle, and relatively few producers will be affected. 

The number of herds in the seven counties that require surveillance testing will be 

reduced from about 390 to less than 120. TB testing, including veterinary fees, costs about $10 

to $15 per head. Based on an estimated 33 head per herd, total annual cost savings are expected 

to range between $90,000 and $135,000 yearly in the seven counties. 

The average value of cattle and calves in Michigan is about $1, 100 per head. Thus, the 

savings by forgoing TB testing represent about 1.3 percent of the average value of the animals. 

This action will not significantly change program operations and will have no significant effects 

on other Federal agencies, State government or local governments. 

The Administrator of the Animal and Plant Health Inspection Service has determined that 

this action will not have a significant economic impact on a substantial number of small entities 

3