2022 HPAI in Turkeys Study Justification Memo

MAE WU

Digitally signed by MAE
WU
Date: 2022.10.14
08:40:47 -04'00'

to compete globally in animal and animal product trade. Detection of HPAI on a turkey
farm results in loss of all birds. This creates significant economic losses for turkey
producers. Vaccination for this pathogen is not feasible. Were the United States to pursue
vaccination, it could result in negative international trade impacts for the U.S. turkey
industry. Therefore, the best option for APHIS and turkey producers is to identify risk
factors and develop mitigation strategies to limit future impacts. APHIS has determined
that in this situation, traditional information collection and rulemaking procedures could
further cause public harm, are contrary to the public interest, and that there is good cause
under 5 U.S.C. 553 to justify an emergency information collection.
Between February and September 2022, APHIS mobilized over 1,300 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 turkey farms, there is much to be learned about
preventive measures. Therefore, to limit additional flocks becoming infected in 2022 and
beyond, it is critical for APHIS to conduct surveys to identify the potential sources of
new HPAI infections. As the fall season of wild bird migration continues, APHIS has
plans to immediately gather data from turkey producers in November 2022 to identify
risk factors and mitigate future outbreaks. This information is needed as quickly as
January 2023, when the risk of new infections is expected to increase substantially.
APHIS will collect data via phone surveys of both affected (case) and unaffected
(control) turkey farms. APHIS will identify potential study participants from affected
turkey producers as stored in our Emergency Management Response System (EMRS).
Unaffected farms will be selected from the USDA National Agricultural Statistical
Service (NASS) list frame, if NASS is able to provide these, or from EMRS, if NASS is
not able to provide these.
To develop the prevention and control recommendations that turkey 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 turkey industry, and secure
our domestic and global food system.
Thank you for your time and consideration.

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