Eric Neil Gingerich - Comment

I wish to comment on several areas of contention with the guidance document: 1) Biosecurity measures between houses on a multi-age complex do not need to be extensive as the risk of carrying SE on clothing is minimal considering that rodents and air flow are carrying much more of a risk. Changing outer clothing between houses is overkill. Footwear sanitation or change and hand sanitation between houses should be optional and required only if the person is to work in that house but not if they are just walking in between houses in the front of the house. In PEQAP, many complexes had positive houses in which the SE infection never spread to a neighboring house 2) The egg collection scheme shown is one example of a good procedure but is quite labor intensive needlessly. One can utilize the equipment present (the egg collection belts) to gather a good cross section of eggs from across the house and from front to back and top to bottom. Separate the collections by time to assure this. Remember that this is a risk reduction program and not an elimination program. If one makes the protocols too difficult, the result may be a collection method used that is not representative. 3) Inspections of housing need to be practical and considerations made in the frame of mind that these are chicken houses and not processing plants. Flies, rodents, and manure are going to be found in all houses to some degree. Also, the product being produced is not intended to be eaten raw but cooked so there is going to be some degree of contamination found on or in the product at some time or another. 4) I feel SE vaccination with a federally licensed bacterin should be a required practice for the incoming pullets if the previous flock tested manure positive. Thank you.