Comment from Kenneth Klippen

Document ID: APHIS-2009-0031-0005
Document Type: Public Submission
Agency: Animal And Plant Health Inspection Service
Received Date: October 04 2010, at 12:00 AM Eastern Daylight Time
Date Posted: October 4 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: September 20 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: November 19 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b66f1b
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Regulatory Analysis and Development, PPD APHIS, Station 3A-03.8, 4700 River Road Unit 118 Riverdale, MD 20737-1238. Reference: Docket No. APHIS- 2009-0031. Sparboe Farms is pleased to provide its comments in reference to amendments proposed in the The National Poultry Improvement Plan (NPIP). Sparboe Farms produces table eggs owning chickens and farm complexes located in Minnesota, Iowa, and Colorado. Sparboe Farms is a strong supporter of the NPIP as the best example of coordinated Federal-State-industry cooperation for controlling certain poultry diseases. NPIP clearly identifies States, flocks, hatcheries, dealers, and slaughter plants that meet certain disease control standards specified in the NPIP programs. As a result, customers and importing countries can buy poultry that has tested clean of certain diseases or that has been produced under disease-prevention conditions. Included in the NPIP amendments is a proposal to put in place requirements for testing spent fowl for each of the options for retaining the U.S. H5/H7 Avian Influenza Clean classification for turkey breeding flocks and waterfowl, exhibition poultry, and game bird breeding flocks. This coincides with the egg industry spent fowl testing requirements for chickens spent fowl to be tested only if a sample of 30 birds is being tested and found negative at intervals of 90 days. Testing of spent fowl is a useful addition to surveillance for retaining the U.S. H5/ H7 Avian Influenza Clean classification. Accordingly, Sparboe Farms supports the proposal to add a new paragraph § 145.43(g)(3) to require all spent fowl from turkey breeding flocks, up to a maximum of 30, to be tested serologically and found negative within 21 days prior to movement to slaughter for all of the surveillance options. This includes re-designating paragraph (g)(3), which contains reporting requirements that apply if killed AI vaccine is used, as paragraph (g)(4).) Sparboe Farms also supports the proposal to make another change related to AI in part 145. In § 145.1, the proposal would add a definition of avian influenza as ‘‘an infection or disease of poultry caused by viruses in the family Orthomyxoviridae, genus Influenzavirus A.’’ Sparboe Farms supports including this definition to provide additional clarity regarding AI. The other amendment Sparboe Farms supports relates to Salmonella Negative Status for Primary Meat-Type Chicken Breeding Flocks in the U.S. Salmonella Monitored Classification. The regulations in § 145.83(f) set out provisions for the U.S. Salmonella Monitored classification for primary meat-type chicken breeding flocks and the hatching eggs and chicks produced from it. This classification requires participating flocks to be maintained in compliance with §§ 147.21, 147.24(a), and 147.26, requires feed to be processed, stored, and transported to prevent contamination with Salmonella, and requires chicks to be hatched in a hatchery meeting the requirements of §§ 147.23 and 147.24(b) and sanitized or fumigated. It also contains testing procedures designed to verify the flock’s Salmonella status. In recent years, importing countries have begun to require that baby chicks and hatching eggs originate from breeding flocks free of certain serotypes of Salmonella. The current provisions of the U.S. Salmonella Monitored classification do not provide for serotyping. Sparboe Farms supports the proposal to add a serotyping provision to paragraph (f)(1)(vi). This paragraph currently requires an Authorized Agent to take environmental samples as described in § 147.12 from each flock at 4 months of age and every 30 days thereafter. An authorized laboratory for Salmonella must then examine the environmental samples bacteriologically. Sparboe Farms supports the proposal to require all Salmonella isolates from a flock to be serogrouped and reported to the Official State Agency on a monthly basis. Some importing countries require separate the Salmonella status of the flock from the status of the hatchery containing the hatching eggs and chicks produced from it. A primary meat-type chicken breeding flock can thus be considered to be free of Salmonella, based on regular testing, even if there is environmental Salmonella contamination in the hatchery. However, the current U.S. Salmonella Monitored classification does not provide for this; it applies to both the flock and the hatching eggs and chicks produced from it. To provide flock owners with a means to demonstrate their flock’s Salmonella negative status, Sparboe Farms supports the proposal to add a new paragraph (f)(1)(viii) with provisions under which a flock could be considered ‘‘Salmonella negative.’’ Under proposed paragraph (f)(1)(viii), any flock entering the production period that is in compliance with all the requirements of § 145.83(f) with no history of Salmonella isolations would be considered ‘‘Salmonella negative’’ and could retain this definition as long as no environmental or bird salmonella isolations are identified and confirmed from the flock or flock environment by sampling on 4 separate collection dates over a minimum of a 2-week period. Sampling and testing would have to be performed as described in proposed paragraph (f)(1)(vi). An unconfirmed environmental Salmonella isolation would not change this Salmonella negative status, as the ‘‘Salmonella negative’’ status is intended to reflect only the status of the flock itself. Sincerely, Ken Klippen, Ph.D. candidate, M.S., B.S. Executive Director of Government Relations And Animal Welfare Sparboe Farms Producing eggs in Iowa, Minnesota, and Colorado Direct Tel: 610/415-1055 cell: 484/744-3851

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