Pond Boss Forums INTRO Questions & Observations Transport restrictions and disease testing of most fish in your state coming soon!

It's only a matter of time before those states that are not involved in the VHSv emergency order by the federal government start coming up with restrictions of their own to prevent this virus from coming into their states. Bottom line: Higher fish costs, some species may not be available, and some fish farms may go out of business. Be prepared this is coming to your state!

This letter from a Michigan trout farmer that got the scoop on the lastest meeting a few days ago regarding the emergency order to halt interstate fish transportation by APHIS explains what I'm talking about:


________________________________________________
1681 South 7 ½ Road, Harrietta, MI 49638
Phone: (231) 389-2514 / Fax: (231) 389-2513
info@harriettahills.com

Memorandum

To: All interested Parties
From: Dan Vogler
Date: November 2, 2006
Regarding: USDA/APHIS VHS meeting


On October 31, 2006, USDA/APHIS held a stakeholder meeting in Washington D.C. to discuss Viral Hemorrhagic Septicemia (VHSv) in the Great Lakes and to take input to be used in the development of an Interim Rule that would potentially govern the interstate movement of fish from the Great Lakes states and possibly nationally.

This meeting was complicated by the fact that USDA/APHIS had issued an Emergency Order on October 24 prohibiting the interstate movement of 37 species of live fish from the 8 Great Lakes States and international imports from Ontario and Quebec. This emergency order was a surprise to virtually every agency and organization outside of USDA/APHIS. APHIS justified its Emergency Order (EO) based on their assertion that new information on the number of species that could be affected by the virus had come to their attention and convinced them of a need to move immediately rather than wait for the development of an Interim Rule.

On October 30, I met with Betsy Hart and board members Mike Freeze and Ken Kline from the National Aquaculture Association (NAA), Charlie Conklin a trout producer and member of the US Trout Farmers Association board, and Dave Robinson a Wisconsin fish farmer and bait fish wholesaler. The NAA representatives assured us that in no way had they requested the Emergency Order and were just as surprised as anyone else that APHIS had taken this action. NAA also assured us that they were working to get the emergency order modified to allow movement of certified fish immediately and that they would push for quick development of the more comprehensive Interim Rule.

The ground rules set out by APHIS for the October 31 meeting allowed comments to be made regarding the Emergency Order, but stressed that the meeting was expressly to give input for the development of the Interim Rule. I believe that the producers and state agencies present had a reasonable opportunity to make their points regarding opposition to the Emergency Order, but APHIS made it clear that they had no intention of rescinding the Order altogether, but might consider amending it if they were convinced that such action was appropriate and provided adequate protection for the aquaculture industry beyond the 8 state Great Lakes region.

I believe that the only possible modification to the Emergency Order that may be considered would be to allow the movement of fish certified free of VHSv by at least Blue Book standards. This is simply my opinion and does not represent any promises made by APHIS. They made it very clear that the purpose of the meeting was strictly to gather input and that APHIS would make any decisions independently at a later date. Industry representatives continually stressed that any delay beyond the immediate relaxation of the EO would cause progressively greater harm to the Great Lakes aquaculture industry and that many businesses could not survive a six month process to develop an Interim Rule.

From the information presented, it is my impression that we are heading for an environment in which all species of fish will require testing and certification for VHSv to move in interstate commerce. I also believe that it is likely that this will eventually apply in some way to all regions of the US because individual states seem likely to apply their own protections even if APHIS holds federal restrictions to a smaller region.

It is clear from discussions that wild caught fishery products are of greatest concern for APHIS, especially bait fish. I anticipate that there will continue to be restrictions on the catching and movement of fish caught in “infected” waters. What the definition of “infected” will be, only time will tell. I believe that the bait fish industry should move as rapidly as possible to develop HACCP principles for VHSv and to develop a testing and certification protocol for both cultured and wild caught bait fish. I anticipate that the bait fish industry will be held under intense scrutiny and can expect considerable difficulties in the future.

I am hopeful that state agencies with authority over aquaculture and wild caught bait fish will establish joint meetings between regulatory agencies that include both industries as well. I also hope that a regional effort can be started that includes natural resource agencies, agriculture agencies, and industry from the eight Great Lakes States to develop a systematic and coordinated approach to dealing with VHSv.

I am also concerned that there will probably be an acute shortage of laboratory capacity to get certification and surveillance testing done. Obviously, testing many new species from many new sources will be a huge logistical challenge that will require new levels of coordination and funding to get the job done.

In conclusion, there is no chance for continuation of “business as usual”. We can expect to operate in an environment that requires testing and certification of all species of fish for both interstate and intrastate movement. The greatest challenge will be in coordination of approach and coordination and development of capacity to process the considerable testing load that this process will require. The timetable is unknown but I expect that there will be incremental relaxation that will allow certified fish to move fairly soon. The industry must not be content to allow this issue to move on its own, but should be proactive and urge policy makers to work rapidly and to include industry in all discussions as things move forward. We also need to commit to securing the resources necessary to move the testing process into reality.

Respectfully,


Dan Vogler

I can't comment too much on the actual issue at hand, but I can say that this Dan Vogler has written what seems to be a well though out and thorough assesment of the situation. He also seems to be keen in his assesment of future needs for the industry in a fashion of trying to address the issues/concerns of the federal agency.
His thoughts on the potential shortage of qualified labs indicates that he is solution oriented. Hopefully, this approach will help benefit and sustain the industry.

I know I need them.

Perhaps there's a way to monitarily support the cause?

Well Done.

Thanks for the post, Cecil.