Comment from Lee Jan, DVM, Texas Animal Health Commission

The proposal logically uses the rationalization that targeted sampling of cull birds is based on the biological assumption that a change in disease status of a flock will be reflected by an increase in morbidity and/or mortality of birds in the flock. If infections does exist, it is most likely to exist in the population of cull birds. I believe this is a sensible approach; however, I would like to have an assurance that the government salaried veterinarian collects samples only from sick or dead birds that have died, but were not intentionally killed, and the veterinarian selects the birds to be sampled. The producer should not remove sick or dead birds on day 7 and 14 of the 21 day period before the certificate is issued, without first contacting and receiving permission from the government veterinarian, thereby allowing the testing veterinarian to select the appropriate birds to sample. The document proposes testing at least 1 cull bird for each 10,000 live birds occupying each poultry house to be certified to attain detecting infection with 95% confidence; The supporting documents indicate at an infection rate of 0.1%. Why not require sampling at a rate that would detect low level infection with 98% confidence?