Ignoring the elephant in the room


Tuberculosis is an important public health risk, and due to its zoonotic potential, an important regulatory challenge.  Increasing concern about the risk of transmission from animals to humans has led to more stringent regulations.  Nowhere is this more apparent than in the case of elephants.


Elephants live in captive settings, in contact with people, in a number of different ways.  About 1,000 are found in zoos or as performing elephants around the world.  Approximately 1/3 of these are found in institutions accredited by the Association of Zoos and Aquariums.  Elephants that live in the United States are regulated by the United States Department of Agriculture’s Animal Welfare Act, like many other mammals.  One part of this regulation recently updated is Policy #1:  “Control of Tuberculosis in Regulated Elephants”.

Far from the only regulation in place for TB control in captive animals, this is the most heavy-handed and stringent regulation for that purpose.  Previously, the veterinarians who provided daily care performed an annual trunk wash for culture.  This test was imperfect and often failed to detect early disease, and in an effort to improve testing sensitivity and efficiency, a newly developed test was incorporated.  The elephant Stat-Pak, made by Chembio, promises “a significant improvement in the detection of elephant TB”.  While some questions about the extent of these claims have arisen over the past couple of years, this test still remains the best test for elephant TB.

Most of the concerns regarding this test come from the implementation and the ramifications of the test.  New regulations require the blood draw for annual testing to be conducted under direct observation of a Federal veterinarian, and once collected, the test may only be run at one licensed lab (National Veterinary Services Lab or NVSL).  This test* is only produced by Chembio and the cost must be covered by the institution, not the USDA.  Further testing and consequences occur when an animal is found “reactive” or suspect positive on the test.

Many veterinarians who work for zoos and other institutions complete additional training through the USDA (accreditation) in order to be able to perform testing for other regulated diseases, like TB in all other species, chronic wasting disease in deer.  Why can these same veterinarians not be trusted to test their elephants for TB?  Can these veterinarians not be trusted to perform honest and accurate testing, despite concerns about the implications of a possible positive test?  Is alienating such an important stakeholder (zoo veterinarians) by this regulation a good idea for the USDA?

Surely, licensed and USDA accredited veterinarians can be trusted to draw blood without making a Federal case about it.

*At the time of this writing, this test was also on back-order, meaning no annual testing could be scheduled with any Federal veterinarian.

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5 Responses to “Ignoring the elephant in the room”

  1. oforthep Says:

    Very interesting topic. Although these may be common knowledge to veterinarians, but it might be nice to provide proof that:
    1. TB in elephants can be transmitted to human beings and have been shown to cause clinical disease.
    2. Disease burden of TB in elephant, and more importantly, human TB cases that come from elephants.
    3. Competence level of zoo veterinarians in conducting these tests (maybe a comparison of test sensitivity/specificity conducted by different people)

    I believe the addition of these points will make your argument more persuasive and powerful.

    Yen-Yi Juo

  2. sbfphc Says:

    There has always been a concern about bovine TB, so this only makes sense. Humans forget at their peril that they are part of the animal world.

  3. MMClancy Says:

    The links in the blog itself hopefully can provide the answers to 1&2, but for your reading pleasure:
    1) TB in elephants can be transmitted to humans, reported initially only as PPD conversion as seen in LA and Illinois. One individual from this second study was culture positive and DNA fingerprinting showed both human and elephant had the same strain. In Asia where elephants live in close quarters with humans in working conditions, TB is a huge issue.
    The most recent occurrence, at an elephant sanctuary in Tennessee, was linked in the above blog but information can also be found here, and a nice review of the above cases can be read in this powerpoint.
    2) This information is largely lacking, and the new regulations, which funnel all testing through a single lab and using a single test, may help provide more information.
    As for 3… I think it’s hard to convince any profession they need a competency exam, but more often than not, the findings can be unsettling. In this case, however, the concern isn’t so much with the running of the test itself, but of needing to be monitored while performing the blood draw (something most of us do routinely on a number of species with pretty good competency) and labeling it accurately (not fraudulently as is USDA’s concern) before sending it in to be run.

  4. glmurphy Says:

    Great topic (and apparently a good topic for debate 😉 )! I am often amazed at the redundancy and ‘distrust’ that exist between the Federal Veterinarians (USDA/APHIS Area Veterinarian In-Charge), the State Veterinarians, and the ‘rest’ of the veterinarians. I can usually understand why certain rules are promulgated the way they are regarding certain reportable diseases; but this one seems arbitrarily micro-managed. I fully understand the zoonotic potential of TB and the risks that go along with it; but how many of the other creatures at the zoo carry the same (or greater) risk? Is there a requirement for the federal vet to observe all the tests in the primates? (Maybe there is, I don’t know…) Is there something particular or peculiar about elephants that makes the risk of TB transmission higher or are there some nuances about the testing procedure that a zoo veterinarian cannot be made aware of? If there are only 1000 elephants in these facilities around the WORLD, how many are in the US? Furthermore, then, how hard would it be to train the relatively few veterinarians who interact with the animals to conduct the test (or the blood-draw) independently? On the surface of this argument, I certainly agree that this policy seems overbearing; and I would be curious to know the origin of the highly specific policy.

  5. MMClancy Says:

    No similar statute exists for primate TB tests, and primates, actually, are not required to be tested annually (to my knowledge… and I would hope I would know that). The very nature of elephants in captivity, I think, is the source of this highly-regulated nightmare.
    About 300 elephants live in AZA accredited facilities; I would guess about the same in non-AZA accredited facilities. And again, it’s not even that I or another USDA accredited vet couldn’t run the test, it’s that we have to be observed drawing the blood, putting it in the tube and appropriately labeling it for the test.
    The time spent observing these tests must be mind-boggling for APHIS to schedule and coordinate, and the proposition certainly can undermine any relationship between the Federal vets and their counterparts who daily interact with these animals. While I can see a scenario in which a fraudulent test could occur, it just seems so… implausible when I really think about the certain stakeholders involved.

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