Emergency ICR Justification Memo

United States
Department of
Agriculture
Marketing and
Regulatory
Programs
Washington, DC
20250

TO:

Brenda Aguilar
Branch Chief, Office of Information and Regulatory Affairs
Office of Management and Budget

THROUGH:

Ruth Brown
Department Clearance Officer
Office of the Chief Information Officer

FROM:

Jennifer Lester Moffitt
Under Secretary
Marketing and Regulatory Programs

JENNIFER
MOFFITT

Kevin Shea
Administrator
Animal and Plant Health Inspection Service
Rosemary Sifford
Deputy Administrator
Veterinary Services

Digitally signed by
JENNIFER MOFFITT
Date: 2022.08.22
18:03:38 -04'00'

signed by
ANTHON Digitally
ANTHONY SHEA
2022.08.17
Y SHEA Date:
09:50:51 -04'00'

ALECIA NAUGLE

Digitally signed by ALECIA NAUGLE
DN: c=US, o=U.S. Government, ou=Department
of Agriculture, cn=ALECIA NAUGLE,
0.9.2342.19200300.100.1.1=12001000106051
Date: 2022.08.15 17:16:35 -04'00'

SUBJECT: Request for Emergency Approval of a New Information Collection for
Conducting a Case-Control Study on Highly Pathogenic Avian Influenza in Poultry 2022
The Animal and Plant Health Inspection Service (APHIS) is submitting to the Office of
Management and Budget (OMB) an information collection request for an emergency 6month approval for a case control survey of highly pathogenic avian influenza (HPAI)
infection on poultry farms. Poultry producers need this information immediately to
mitigate risk for this environmentally hardy foreign animal disease with unprecedented
distribution in wild birds’ migration flyways across the United States. Mortality losses
from this pathogen are high, creating significant economic losses for poultry producers
and expenses for American taxpayers. For example, of the 40 million birds affected by
HPAI in 2022, approximately 78% (31 million) are commercial table egg layers and
breeder birds. To date, APHIS has made an estimated $100 million in indemnity
payments to table egg layer farms alone. Vaccination for this pathogen is not feasible at
this time due to devastating international trade implications. Therefore, the best option for
APHIS and poultry producers is to identify risk factors and develop mitigation strategies
based on these factors to limit future impacts.
APHIS’ main mission is the prevention, control, and eradication of animal diseases to
safeguard animal health. Disease detection and prevention is the most effective method
for maintaining a healthy animal population and for enhancing the United States’ ability
to compete globally in animal and animal product trade. APHIS has determined that in
this situation, traditional information collection and rulemaking procedures could further

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cause public harm, are contrary to the public interest, and that there is good cause under 5
U.S.C. 553.
Between February and June 2022, APHIS mobilized over 1,125 employees to respond to
HPAI. Nearly $800 million in emergency funding has been authorized to address
indemnity, diagnostics, field activities, and other response costs. Despite the significant
burden of this pathogen on poultry operations, there is much to be learned about
preventive measures. Therefore, to limit additional flocks becoming infected in 2022 and
beyond, is it critical for APHIS to develop information on the potential sources of new
HPAI infections.
As the spring and summer season of HPAI winds down, APHIS has plans in place to
immediately gather data in August 2022 to identify risk factors and mitigate future
outbreaks. This information is needed as quickly as September, when the fall season of
wild bird migration begins, and risk of new infections increases. APHIS will collect data
via in-person surveys. APHIS will identify potential study participants from affected and
unaffected poultry producers as stored in our Emergency Management Response System
(EMRS).
To develop the prevention and control recommendations that poultry producers need,
APHIS needs to identify differences in management practices, environmental conditions,
and flock and barn-level factors between affected and unaffected flocks. This information
is a critical component to develop desperately needed science-based prevention and
control measures to stem further economic losses, protect the poultry industry, and secure
our domestic and global food system.
Thank you for your time and consideration.

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