March 27, 2020
If you use natural deer-urine products in your hunting strategy, you should pay close attention to developing rules in the states in which you hunt. An increasing number of states are limiting or banning the use of natural deer and other cervid urine, citing concerns about chronic wasting disease (CWD). The bans have not come without controversy over how CWD is transmitted and how it may be controlled.
These bans have been fueled in part by a recommendation from the Association of Fish and Wildlife Agencies (AFWA), which is the governing body of all the state game and fish agencies. AFWA has published a set of best management practices for chronic wasting disease, and one of the recommendations is a ban on natural urine products. A similar recommendation has come from the Southeastern Cooperative Wildlife Disease Study at the University of Georgia College of Veterinary Medicine.
Nick Fortin is the state deer biologist for the Vermont Department of Fish and Wildlife. He said Vermont was one of the first states to put a deer-urine ban into effect. “We passed our ban in 2015, and it took effect in 2016,” he said. “The intent was to minimize the risk of CWD getting into Vermont.”
This ban does not include urine or other body parts from a deer that a hunter has killed in Vermont. “Hunters can use urine or glands from deer they have killed themselves in Vermont,” Fortin said.
The most recent southern state to ban the use of cervid urine by hunters is South Carolina. Jay Cantrell, assistant big game program coordinator for the South Carolina Department of Natural Resources, said while the new rule prohibits the use of any commercially produced natural deer excretion while hunting, it does not prohibit the use of synthetic deer-urine products or anything collected by a hunter from deer legally harvested in South Carolina.
“This is a recommendation from the Association of Fish and Wildlife Agencies, which is the governing body of all the state game and fish agencies,” Cantrell said. “AFWA has best management practices for chronic wasting disease, and one of many things within the recommendations in their BMPs is a ban on natural urine products.”
“There’s plenty of research that demonstrates that the prions that transmit CWD can be passed through urine, saliva and other bodily fluids,” Cantrell said. “Those products can contaminate the environment, and it’s possible for deer to pick those prions up.Even the urine industry acknowledges that it’s a risk. They say it’s a very low risk, and we say we’re not willing to take even a low risk for something like this.”
One of the factors in making this decision, Cantrell said, is what he calls “self-regulation” of the scent industry.
“They’re policing themselves,” he said. “People think they’re buying a product that’s safe, but there are a lot of questions surrounding their testing. And if they do get some urine that tests positive, there’s no way to track it back to where it came from. It’s a risky business, and not something we’re willing to get into.”
Not all hunters are convinced that a total ban on urine products is practical or enforceable. One long-time hunter recently responded to a questionnaire for the Florida Fish and Wildlife Conservation Commission (FWC) by saying, “Deer urine companies that use live animal urine test to ensure that prions are not in their products. The only natural deer urine that could be contaminated is that which has been collected from harvested game animals. By the way, those harvested game animals have been peeing all over the woods to begin with. Not sure what you are trying to accomplish, but this needs to be thought through in terms of realistic rules and enforcement of such.”
Obviously, the scent industry is critical of rules that ban the use of natural deer urine. Industry officials point to a program of standards, developed in cooperation with the Archery Trade Association (ATA), that is more rigorous than that of the USDA. Corey Consuegra, head of marketing at Arcus Hunting, said this program, known as the Deer Protection Program, is made up of key parties whose goal is, as the name suggests, protecting deer. Facilities that are part of this program are certified by the ATA for following the standards established by the Deer Protection Program.
“More than 95 percent of deer urine that’s being sold in the marketplace today is collected from these farms,” Consuegra said. “These farms are highly regulated. Any deer that dies in captivity is tested for CWD to ensure the health of the herd and farm. No deer at any of the 11 farms have ever tested positive for CWD. Participating urine providers undergo annual inspections from an accredited veterinarian. This includes a review of animal records, state and federal documents, an inspection of the perimeter fencing and physical review of 20 percent of the herd. Additionally, every three years veterinarians inspect 100 percent of the herd.”
In addition, Tink’s and Wildlife Research Center have partnered to test every batch of urine they produce with the RT-QuIC procedure.
“This is designed to ensure that every bottle leaving our facility is 100 percent CWD free,” Consuegra said. “RT-QuIC is the most precise testing available and has been used to test for the most minute trace of CWD prions. The amplification of this test makes it precise. No other test to my knowledge is known to be more effective.”
Although some states have banned urine products completely, others have taken a more conservative approach. Alabama, for instance, allows the use of urine that is produced by ATA-certified manufacturers. Louisiana allows products that are ATA certified and that have been RT-QuIC tested.
At the time Vermont put its ban into effect, the ATA program did not exist yet. Fortin said, however, that he knows of no move to relax the ban in response to the ATA program.
“We haven’t received any pressure to change it,” he said. “We’re a relatively small state, so we don’t get very much industry pressure. And we’d rather err on the safe side, so we don’t have a lot of pressure to ‘roll back’ the regulation.”
Fortin said Vermont hunters have accepted the regulation fairly well. “Some of the folks who like to use urine products were upset,” he said. “But, we didn’t and don’t receive much pushback about it; they seem to understand the reasoning and accept it. Most folks have already switched to synthetics.”
Fortin acknowledged that enforcement of the regulation is a challenge. “Folks can still buy urine lures in Vermont,” he said. “We can’t regulate their sale. So, the reality is that some people are probably still using them.”
Virginia’s regulation of deer urine is even stricter. Not only is the use of commercially produced natural urine products illegal, Virginia hunters are not allowed to use anything from deer they have killed.
“You cannot collect and use these fluids afield anywhere in Virginia,” the website of the Virginia Department of Game and Inland Fisheries states. “Harvesting and using body fluids from local deer is prohibited statewide.” Virginia hunters still may use synthetic products.
Although some states have banned urine products completely, others have taken a more conservative approach. Pennsylvania, for instance, has a partial ban on urine products in areas with occurrences of CWD. Most other northeastern states have taken no action limiting the use of urine products—yet. But that can change.
The deer-urine industry takes CWD as seriously as anyone else involved in deer management and deer hunting, noted Consuegra.
“CWD is very scary, and it’s not clear how it’s being transmitted,” Consuegra said. “Biologists often point to saliva as the key to transmitting. Because a lot of agencies are unsure about how to prevent the spread of CWD, they’re banning anything that could possibly be a carrier. Some states have banned urine, some states don’t allow you to put out food, and the list goes on. But there are no facts that point to urine as being the source for CWD transmission.”
The deer urine industry takes CWD as seriously as anyone else involved in deer management and deer hunting, noted Consuegra. “CWD is very scary, and it’s not clear how it’s being transmitted,” he said. “Biologists often point to saliva as the key to transmitting. Because a lot of agencies are unsure about [how] to prevent the spread of CWD, they’re banning anything that could possibly be a carrier. Some states have banned urine, some states don’t allow you to put out food, and the list goes on. But there are no facts that point to urine as being the source for CWD transmission.”
Consuegra said the go-forward plan for the urine industry probably will involve RT-QuIC testing. “That process is the method of being sure that any urine that’s being used is 100 percent CWD free, on top of the already existing procedures on the farms that are certified by the ATA Deer Protection Program,” he said. “We have invested significant amounts of time and energy to make sure that testing procedures such as RT-QuIC are available, to give wildlife agencies and state regulators maximum confidence in the product that we’re putting in the marketplace.”