Bovine Tuberculosis Testing Requirements in Hawaii: What Every Cattle Owner Must Know

If you raise or move cattle in Hawaii, bovine tuberculosis testing requirements in Hawaii are not optional paperwork you can skip. The disease has forced two statewide depopulations, cost the state its federal TB-free status twice, and still lingers in feral swine on Molokai today. Understanding exactly who must test, which methods count, and what happens after a positive result can save your herd and your ability to ship animals off-island.

This guide breaks down the current Hawaii Department of Agriculture (HDOA) and USDA framework for bovine TB control, from classification status to penalties for skipping required tests.

What Is Bovine Tuberculosis and Why It Is Regulated in Hawaii

Bovine tuberculosis is caused by Mycobacterium bovis, a bacterium closely related to the organism that causes human tuberculosis. According to the USDA Animal and Plant Health Inspection Service (APHIS), bovine tuberculosis is a contagious, infectious, communicable disease of animals and humans that is commonly chronic and debilitating, and it spreads through direct contact, inhalation of droplets, and ingestion of contaminated feed or milk. While cattle are the primary host, the disease crosses species lines easily, which is part of why Hawaii’s outbreak history involves more than just cows. Although cattle are considered the true hosts of M. bovis, the disease has been reported in many other domesticated and non-domesticated animals, and it is zoonotic, meaning people can become infected through exposure to infected animals or their products.

The regulatory pressure exists because bovine TB carries both public health and economic consequences. As HDOA has explained, the primary impact of bovine TB is economic due to restrictions on animal movements and additional testing required for movements, and infected animals may also be a public health concern. The federal government has treated this as a national priority for over a century: in 1917, the U.S. Bureau of Animal Industry began the National Tuberculosis Eradication Program due to human and livestock concerns regarding bovine tuberculosis, and that cooperative state-federal effort still governs how Hawaii runs its own program today. For a broader look at how this disease compares to other livestock illnesses tracked in the islands, see this overview of common bovine diseases, and for the avian counterpart that occasionally confuses testing results, review avian tuberculosis in poultry.

Pro Tip: If you are new to raising cattle in Hawaii, ask HDOA’s Animal Industry Division for a copy of the current Molokai quarantine order before you buy or move any animals to or from the island.

Hawaii’s TB Classification Status and Risk Zones

Hawaii’s relationship with bovine TB has been anything but stable. After several infected cattle herds were detected on Molokai in the early 1980s, HDOA made the decision to depopulate all cattle on Molokai in 1985 in an effort to eradicate bovine TB, and more than 9,000 cattle were removed from the island. That drastic step paid off, at least temporarily: following the depopulation, Hawaii received “bovine tuberculosis-free” status from USDA-APHIS in 1993, which allowed interstate movement with no restrictions for TB. The reprieve did not last. In 1997, the state’s TB-free status was suspended again when a 10-year-old Molokai cow was found infected with bovine TB, and after the entire herd was depopulated, Hawaii regained its bovine TB-free status in 1998.

The most recent chapter began in 2021. HDOA reported that a cow in a herd on Molokai had been infected with bovine tuberculosis, the first detection of the disease in a cattle herd in Hawaii in years, and the infected cow originated from a beef cattle herd in Ho’olehua in central Molokai. Investigators traced additional cases quickly: a total of six TB-affected herds were detected between July 2021 and March 2022, including a mixed herd that contained positive detections in both cattle and domestic swine. HDOA responded by placing the island under quarantine, and the Hawaii Department of Agriculture placed a quarantine on the island of Molokai starting April 8, 2022.

Wildlife remains the stubborn reservoir behind these flare-ups. HDOA has confirmed that wildlife surveys have revealed feral swine populations serving as a reservoir of the disease at a prevalence of one percent, or five positive cases out of 482 tested. Axis deer add another layer of risk: during the 2023 program review, HDOA collected 168 field samples from axis deer and submitted 70 samples to the National Veterinary Services Laboratories, with isolation of M. bovis from one axis deer. Because of this, testing obligations are not uniform statewide. HDOA has stated plainly that HDOA and USDA require annual testing of cattle herds from eastern Molokai for bovine tuberculosis, and testing requirements only apply to eastern Molokai since other areas of the state remain free of the disease.

Key Insight: Hawaii operates under a split-state arrangement. Most of the state carries accredited-free status, while eastern Molokai remains under active surveillance and testing because of its documented wildlife reservoir.

Federal rules add a layer of accountability on top of HDOA’s day-to-day management. Under 9 CFR 77.7, accredited-free state or zone status must be renewed annually, and to qualify for renewal, a state must submit an annual report to APHIS certifying compliance with the Uniform Methods and Rules for Bovine Tuberculosis Eradication. HDOA and APHIS formalized this cooperative work through a signed agreement: HDOA and APHIS/VS/FiOps are official signatories of a Memorandum of Understanding comprised of 14 articles outlining the requirements and responsibilities for administering the Hawaii TB program. You can track current program status for Hawaii and other states through the USDA APHIS eradication program status page.

Who Must Test and Which Animals Are Covered in Hawaii

State law casts a wide net over which cattle need tuberculin testing. Hawaii Revised Statutes §142-16 states that all dairy and breeding cattle within the State shall be tuberculin tested by the department of agriculture as often as in its judgment such testing is necessary to prevent, suppress, and eradicate bovine tuberculosis. The same statute gives HDOA broad access: all cattle tested are marked by the department with a distinguishing mark, and the department may go upon any property where such cattle are kept for the purpose of making the tests. On Molokai specifically, testing scope is defined by age. Program documents specify that whole herd testing includes all cattle four months of age and older, which means calves are exempted only briefly before they enter the testing pool.

Not every operation is treated identically. Small hobby-scale operations fall under a separate category called Backyard Beef Herds (BBH), which come with their own compliance conditions. Under current HDOA guidance, Backyard Beef Herds must be isolated from contact with other cattle, must not be situated adjacent to non-BBH cattle, must undergo annual inspection to verify the herd is comprised of six or fewer head, must not breed cattle, and must not move cattle from the BBH to any other premises. Losing that designation through noncompliance carries consequences, since HDOA’s 2024 program review noted specific concerns tied to BBH designation and could result in penalties when standards are not maintained.

Cervids are also part of the covered population where captive herds exist. All captive deer are required to test negative for bTB 30 days prior to movement, with limited exceptions for animals shipped directly to slaughter under permit. Every animal tested needs verifiable identification, which is why Hawaii’s separate livestock ear tag requirements matter just as much as the test itself: a negative test result is only as useful as the tag that proves which animal it belongs to. If you also manage horses on the same property, note that equine infectious anemia carries its own separate testing rules, detailed in this guide to EIA Coggins test requirements in Hawaii.

Approved TB Testing Methods in Hawaii

Hawaii follows the same federally recognized testing sequence used across the National Tuberculosis Eradication Program, starting with a skin test and escalating only if needed. The process begins with the caudal-fold test (CFT), the standard screening tool. As APHIS describes it, the caudal-fold test is used as a presumptive diagnostic procedure, and animals classified as suspect must be evaluated further by the comparative cervical test, gamma interferon test, or sent directly to slaughter under permit. The test itself involves injecting a small amount of purified protein derivative tuberculin into the fold of skin at the base of the tail, then reading the result 72 plus or minus 6 hours later. Only trained personnel can read and confirm results, since accredited and regulatory veterinarians are expected to meet the caudal fold response rates identified in the 2005 Bovine TB Eradication Uniform Methods and Rules.

The table below summarizes the standard testing pathway used in Hawaii and nationally.

Test	Purpose	Reading Window	Follow-Up Requirement
Caudal-Fold Test (CFT)	Initial screening for all herd members	72 (+/-6) hours after injection	Responders require CCT or gamma interferon confirmation
Comparative Cervical Test (CCT)	Confirmatory test for CFT responders	72 hours after paired injections	Must occur within 10 days of CFT, or after a 60-day wait
Gamma Interferon / QuantiFERON	Blood-based confirmatory alternative	Lab-processed; no live re-test needed	Reduces confinement time if validated for herd use

Confirmatory testing has strict timing rules. Per APHIS guidance, follow-up CCT testing must be performed within 10 days of the initial caudal-fold injection in cattle and bison, or the herd owner must wait 60 days after the injection of the CFT before a follow-up CCT can be administered. This window exists because the tuberculin used for screening can desensitize the animal temporarily, skewing a too-early retest.

Hawaii is actively working to add a blood-based option to reduce how long tested animals must stay confined. The 2024 federal program review noted that QFT testing, when validated and incorporated into the TB Program, would allow Hawaii to use Interferon Gamma Release Assay based testing in lieu of CCTs for herd testing, potentially reducing the length of time herds must be kept in confinement and reducing travel for off-island testing. As of the 2024 review, though, the timeline for completion of validation was unknown and dependent on the ability to collect positive control samples for testing.

Important Note: The QuantiFERON Gold blood test is still under validation for herd-level use in Hawaii as of the 2024 federal program review. Cattle owners should confirm current test acceptance with HDOA before relying on it in place of the caudal-fold and comparative cervical sequence.

Every tested animal needs official identification tied to its test record. APHIS requires that all cattle and bison tested shall be individually identified by official eartags, with that identification recorded in its entirety on the test record at the time of injection and confirmed at the time of observation. Hawaii has taken this further on Molokai specifically, where the program calls for all cattle on the island of Molokai to be double-tagged at the time of bovine TB testing with an official electronic identification tag and a secondary HDOA-approved identification tag.

Interstate and Intrastate Movement Testing Requirements in Hawaii

Moving cattle into, out of, or within Hawaii triggers its own layer of paperwork separate from routine herd testing. At the border, state law is unambiguous: no animal shall be allowed to enter the state except after inspection by the department of agriculture and issuance of a permit, and every carrier, owner, or handler bringing animals into the state must present those animals for inspection. HDOA’s current cattle import guidance confirms that the department regulates cattle importation to protect local livestock from infectious disease, and all cattle imports must meet health testing, identification, and permit requirements before entry into the state. You can review the department’s official cattle import guidance page for the current Certificate of Veterinary Inspection (CVI) specifications before shipping any animal to the islands.

Within the state, two documents govern traceability. HDOA explains that the Certificate of Livestock Ownership/Movement (DC-44) accompanies all movements of livestock and was established in 1986 to assist law enforcement with investigations of livestock rustling under HRS 142-29. Quarantined animals need something more restrictive: the Permit to Ship (DC-8) is used specifically to permit movement of livestock quarantined due to significant animal disease, and the requirement to obtain one is communicated through a quarantine hold order. On Molokai, this permit requirement is not optional for any covered species: all live ungulates on the island of Molokai are prohibited from moving unless an approved movement permit is obtained. New rules were established in December 2023 for the intra-state transport of livestock, so producers who last checked movement requirements before that update should confirm current procedures with the Animal Industry Division.

Slaughter-bound movement follows a tighter protocol than routine transfers. Program documents state that all livestock movement to slaughter will be accompanied by an approved movement permit, in an officially sealed conveyance, and moved directly to an approved slaughtering establishment for immediate slaughter. Axis deer face a parallel pre-movement rule: all captive deer are required to test negative for bTB 30 days prior to movement, though they are exempt from pre-movement testing if moved directly to slaughter or if a federal permit for movement has been obtained. Anyone tracking axis deer or feral swine as part of TB surveillance work should also review current hunting license requirements in Hawaii, since hunter-submitted samples are a documented part of the wildlife monitoring program.

What Happens When a Suspect or Positive Result Occurs in Hawaii

A single skin-test response does not confirm infection, but it does trigger a defined chain of events. Regulatory guidance is clear that any reaction matters: if the test produces any type of response, you must immediately notify your APHIS-VS Area Offices and State animal health officials. A positive CFT reading classifies the animal as a “responder,” not a confirmed case, and false positives happen more often than owners might expect. As one state animal health agency notes, these false-positive responses may occur in 1 to 5 percent of tested cattle, and a positive CFT test is a preliminary result requiring additional diagnostic testing. Responders move immediately into confirmatory testing under the timing rules described earlier, and a Comparative Cervical Tuberculin test must be performed within 10 days, or after 60 days, of the CFT by a regulatory veterinarian.

If the CCT itself comes back positive, the animal is reclassified again, and postmortem examination becomes part of the confirmation process. Testing protocols specify that CCT reactors are examined for lesions at postmortem, since visual and laboratory confirmation of tuberculous lesions is what ultimately proves infection rather than just exposure. Throughout this process, reporting obligations fall on veterinarians as much as owners: all accredited veterinarians must immediately report every suspected or diagnosed bovine TB case promptly to both the Assistant District Director and the State Animal Health Official.

Common Mistake: Assuming a single CFT response means your herd is infected. Program data shows a meaningful false-positive rate, which is exactly why the comparative cervical test and postmortem lesion checks exist before any depopulation decision is made.

Quarantine and Herd Depopulation Rules in Hawaii

Once a herd is confirmed exposed or positive, quarantine becomes the default management tool while testing runs its course. HDOA’s own FAQ on the Molokai outbreak states plainly that herds considered exposed to TB remain under quarantine until all exposed animals are tested, and any herd in which a positive is found remains under quarantine until the property has met all requirements set forth by USDA as part of the federal disease eradication program. This authority is formalized through standing quarantine orders; HDOA maintains and enforces Quarantine Order #158, “Bovine Tuberculosis Quarantine, Island of Molokai,” restricting movement of live ungulates except horses to prevent spread of disease, with modification or lifting performed by HDOA in concurrence with USDA APHIS Veterinary Services.

Depopulation remains the preferred response once infection is confirmed, largely because of how insidiously the disease can hide within a herd. HDOA’s guidance notes that if federal indemnity funds are available, depopulation of infected herds is the preferred method for eliminating risk. The 2021 Ho’olehua case illustrates how this plays out in practice: even though the balance of the herd tested negative, due to the insidious nature of bTB a decision was made to depopulate the entire herd to ensure infected animals do not remain in the Molokai cattle population, and HDOA worked with USDA to develop a clean-up plan that included depopulation of the infected herd with indemnity paid to its owner.

The scale of the most recent outbreak required this response repeatedly. Between mid-2021 and early 2022, a total of six TB-affected herds were detected, including a mixed herd that contained positive detections in both cattle and domestic swine. This mirrors the state’s earlier history: Hawaii’s very first eradication effort in 1985 followed the same logic on a larger scale, when all cattle on the island were depopulated followed by a phased restocking once officials were confident the risk had been controlled. For background on how bovine TB compares with other reportable livestock conditions that can trigger similar quarantine responses, see this bovine disease overview.

Penalties for Non-Compliance in Hawaii

Hawaii’s entry and movement rules are backed by clear statutory authority, not just departmental preference. State law requires that no animal shall be allowed to enter the State except after inspection by the department of agriculture and the issuance of a permit, which means unpermitted entry is a violation from the moment the animal arrives without proper clearance. On Molokai, this authority extends to internal movement as well, since all live ungulates on the island are prohibited from moving unless an approved movement permit is obtained.

Noncompliance carries consequences beyond a simple citation. For Backyard Beef Herd operators, failing to meet the isolation, herd-size, and no-breeding conditions outlined in HDOA’s guidance risks losing BBH status altogether, and the department’s own 2024 program review flagged that this BBH designation and could result in penalties when standards slip. Losing that status pushes an operation back into standard herd-testing requirements, with all the added cost and confinement time that implies.

The stakes extend past any individual producer. Because accredited-free status must be renewed annually under federal rule, and if a state or zone does not implement a required tuberculosis management plan within six months, the state or zone will lose its accredited-free status and be reclassified as modified accredited advanced, widespread noncompliance with testing and movement rules threatens every cattle operation in Hawaii, not just the herd that triggered the problem. That reclassification would reintroduce the interstate testing burdens that Hawaii producers have avoided since regaining free status in 1998, making individual compliance a shared responsibility across the state’s cattle industry.

Important Note: This article summarizes publicly available HDOA and USDA APHIS guidance for general informational purposes. Testing schedules, quarantine boundaries, and permit forms change as investigations progress, so confirm current requirements directly with HDOA’s Animal Industry Division before moving or testing cattle.

Staying compliant ultimately protects more than your own herd’s movement privileges. It preserves the accredited-free status that lets Hawaii cattle producers ship animals interstate without the testing delays that eastern Molokai operations currently face, and it supports the decades-long effort HDOA and USDA have invested in keeping bovine tuberculosis contained to a single, well-monitored corner of the state.