Observation:  Only a fraction of water bodies in Virginia are monitored for algal blooms and toxins, so it’s important for people to become familiar with signs of a bloom, exposures and symptoms by visiting VDH and VDEQ websites and having ready access to information about Harmful Algal Blooms (HABs) through other avenues as well.  The agencies are making good progress in this direction.  More needs to be done.

Comment 1:

One avenue of information recognized in the draft guidance that needs to be made stronger is outreach and communications with the veterinary medicine community.  More consistent coordination with and a reporting mechanism for veterinarians is warranted.  Neither seems to exist based on an online search or in the edits to the guidance.

A process to work with the veterinary community to issue pre-emptive public warnings following reports of dog illnesses or deaths possibly resulting from cyanotoxin exposure is needed.   These pre-emptive warnings will help with identifying immediate next steps to inform the public about the possible presence of cyanobacteria in a water body.

Consistent communication about and reporting of HABs from the veterinary community is needed based on:

• Dogs can get extremely ill, and even die, within minutes to hours of exposure to cyanotoxins from drinking water, licking their wet fur or eating floating mats or dried crust along the shore.  
• Toxin testing is only possible for certain types of cyanobacteria. When testing is done, results are typically available within two weeks.  Reporting of HABs encounters from the veterinary community may be more timely.
• Even with lifted advisories illness in pets can still occur at lower toxin values, so there is a need to continue to exercise caution with pets at these areas.

The guidance on Page 4 is too vague.  Draft generic announcement language should be included in the edits to the Guidance.  The language on page 13 clearly supports the need for reporting of HAB animal mortalities, and suspected mortalities, to VDH and DEQ.

Comment 2:

The edited guidance states “New Zealand has a traffic light system based upon coverage of substrate by attached mats and mats detaching and washing up on shore.”   VDH currently has an online Harmful Algal Bloom Map (Dashboard) that also includes a traffic light system.  The revised guidance should be expanded and enhanced to outline and make use of a simple green/yellow/red local advisory process for the public.  https://www.vdh.virginia.gov/waterborne-hazard s-control/algal-bloom-surveillance-map/

Comment 3:

Any difficulties with accessing information online need to be addressed in a timely and on-going fashion.  For example, 

There is out of date HABS information on the VDH webpages: 

For example, see “Health Topics A-Z” (accessed through Lord Fairfax Health District website )

https://www.vdh.virginia.gov/waterborne-hazards-control/harmful-algal-blooms/harmful-algal-bloom-faqs/

Last Updated: July 28, 2023

Within that FAQ there is a broken link:

“Information on freshwater HAB toxins are available here.”

Better information regarding HABs is found with the VDH cyanobacteria link:

https://www.vdh.virginia.gov/waterborne-hazards-control/harmful-algal-blooms/cyanobacteria/

which might be a much better link for HABS in the “Health Topics A-Z” webpages.

Thank you in advance for your consideration of these comments.