Commenter:
Hobey Bauhan, Virginia Poultry Federation
Health Requirements Governing Admission of Animals to Virginia [2 VAC 5-141]
Virginia Poultry Federation (VPF) appreciates the opportunity to comment Virginia Department of Agriculture and Consumer Services’ (VDACS) proposed regulation, entitled, “Health Requirements Governing the Admission of Agricultural Animals, Companion Animals, and Other Animals or Birds Into Virginia [2 VAC 5 ? 141].”
VPF is a statewide trade association, founded in 1925, that represents all sectors of the poultry and egg industry in Virginia. Members include poultry farmers, poultry processing companies, and businesses that provide goods and serves to the poultry and egg industry.
VPF generally supports the proposed regulation as an effective means of controlling and preventing introduction of infectious diseases into Virginia poultry flocks. However, we recommend the following changes to improve the regulation and address concerns of our industry.
Our first concern relates to the following section of the proposed regulation:
“2VAC5-141-60. Avian entry requirements.
A.All entry of birds into Virginia must be in compliance with the testing and all other requirements of the State Veterinarian’s Avian Influenza (H5 and H7) Proclamation dated December 2009. Certificates of veterinary inspection as required must be dated in accordance with said proclamation.”
VPF believes that it is problematic to reference the State Veterinarian’s Proclamation dated December 2009. Over the years, the State Veterinarian has reissued the Proclamation several times to address changing circumstances and new issues. Past experience suggests that the State Veterinarian will find legitimate reason to reissue the Proclamation again in the future. If so, the agency would be compelled to amend the regulation to reference the reissued Proclamation. This would amount to unnecessary administrative procedures. Furthermore, the reissuance of the Proclamation and amendment of regulations to correct the reference would always leave a gap in time when the regulation referenced an outdated Proclamation. This would create confusion and questions with regard to compliance. It makes better sense for the proposed regulation simply to reference the Proclamation issued by the State Veterinarian according to the Code of Virginia.
Secondly, VPF asks the agency to consider retaining the following language proposed for deletion:
B.Mycoplasma Gallisepticum. Hatching eggs and poultry shall not be imported into the Commonwealth of Virginia unless such eggs or poultry originate from flocks that are designated free of Mycoplasma Gallisepticum by the livestock health official of the state of origin. Each importer of hatching eggs or poultry into Virginia shall secure from the State Veterinarian an approval number, after having provided evidence that the flocks of origin are free of Mycoplasma Gallisepticum. This approval number shall appear on shipping labels or containers of each lot shipped into Virginia.
Mycoplasma Galisepticum is an ongoing threat to the commercial poultry industry, and VPF is concerned about removing any regulatory mechanisms currently in place to reduce this threat.
