Duff L. George - Comment

To whom it may concern: On biosecurity between houses (A. SE Prevention Measures 1.Biosecurity) •One whole ‘multi-house’ complex should be treated as a bio-secure unit where people and equipment can move freely among the houses in the same manner as the egg conveyor does. People and equipment should practice biosecurity between units (complexes) by changing clothes and washing equipment. On removing debris and gravel barriers (A. SE Prevention Measures 2. Rodents, Flies and Other Pest Control) •We support the elimination of vegetative harborages around a house. The PEQAP rule works best. It states grass should be maintained to a maximum height of 6 inches for a 3 ft distance away from the poultry house. •FDA’s guidance of old equipment and debris being 450 ft away from the house is too far. Many houses are located to property lines closer than 450 ft to the house and many farms do not the space to comply to 450 feet. General comments on manure removal. •Built-up manure in deep-pit houses is part of a farm’s pest management program. The built up manure, in some cases 8-10 ft. deep, contains the beneficial beetles and fly predators that control flies. The rodent baiting and indexing is happening regardless of how deep the manure is. Deep pit houses were designed for long term manure storage, sometimes up to two years. Deep manure should not be singled out as an infraction to any FDA sanitation or biosecurity rules. Respectively submitted on behalf of PennAg Poultry Council members; comprised of egg farmers, egg processsors and allied industry. Duff L. George Assistant Vice President PennAg Industries Association-Poultry Council Harrisburg, PA