HPAI questionnaire Supporting Statement

SUPPORTING STATEMENT 0579-0XXX

HIGHLY PATHOGENIC AVIAN INFLUENZA – PREPAREDNESS QUESTIONNAIRES

July 2015

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Animal Health Protection Act (AHPA) of 2002 is the primary Federal law governing the protection of animal health. The law gives the Secretary of Agriculture broad authority to detect, control, or eradicate pests or diseases of livestock or poultry. The Secretary may also prohibit or restrict import or export of any animal or related material if necessary to prevent the spread of any livestock or poultry pest or disease. The AHPA is contained in Title X, Subtitle E, Sections 10401-18 of P.L. 107-171, May 13, 2002, the Farm Security and Rural Investment Act of 2002.

The U.S. Department of Agriculture (USDA) is responsible for preventing the introduction or dissemination of contagious or communicable diseases of animals (including birds and poultry from a foreign country) into the United States, or from one State to another. USDA’s Animal and Plant Health Inspection Service (APHIS), through its Veterinary Services (VS) program, carries out this disease prevention mission.

Highly pathogenic avian influenza (HPAI) is an extremely infectious and often fatal viral disease affecting all types of birds and poultry. There is no effective treatment. Once established, the disease can spread quickly from flock to flock. Influenza can change rapidly by exchanging genetic information with other influenza viruses, which makes it important to swiftly eliminate these viruses to prevent more virulent strains from emerging.

HPAI had not been found in birds or poultry in the United States until mid-December 2014, when ongoing HPAI H5 detections began occurring along the Pacific, Central, and Mississippi Flyways. Cases in wild birds, captive wild birds, backyard poultry, and/or commercial poultry have been reported in 21 States. Three of these States – Iowa, Minnesota, and Wisconsin – have declared states of emergency. To date, nearly 50 million birds have been culled as a result of the confirmed presence of HPAI strains. These depopulation losses represent about 10 percent of the U.S. average layer inventory, over 7 percent of the average U.S. turkey inventory, and about 6 percent of the average pullet inventory.

The disease can be managed to some extent by strong biosecurity at farms through diligent cleaning and disinfection by producers, transporters, processors, and other service providers. Despite industry efforts, farm-to-farm spread occurred during the summer outbreak. Because of this, we are collecting data on biosecurity measures, adoption, and audits. We plan to couple it with demographic data and epidemiological data we gathered during the spring outbreak to identify HPAI-related weaknesses in biosecurity practices on a state, regional or industry basis. This will enable us to better target our response and outreach activities to the industry prior to a fall outbreak.

APHIS anticipates HPAI detections will start again when migratory waterfowl begin flying south from Canada. This could be as early as September 1. Cases could also occur along the Atlantic flyway, where there is a high concentration of commercial poultry operations. Based on the impact of cases from December 2014 to June 2015 – 232 commercial and backyard flocks affected, nearly 50 million birds killed – it is essential that USDA prepare quickly and comprehensively for a large number of HPAI detections. One task is assessing the level of preparedness among producers, and what equipment, personnel, and other resources are available from our industry and State partners for response.

APHIS would like to perform an emergency information collection to assess readiness to prevent and respond to an outbreak of HPAI in the fall. This collection activity will bolster biosecurity and preparedness efforts by raising awareness, identifying gaps that need to be addressed, and assessing available resources and capacity to respond. VS staff has created a standardized assessment to identify State and industry capacity for preventing and responding to HPAI, including biosecurity, depopulation, disposal, and cleaning and disinfecting resources. Questions address biosecurity practices; disposal capacity and locations; depopulation equipment, capacity and methods; and ability to clean and disinfect facilities.

APHIS is asking the Office of Management and Budget (OMB) to approve, for 6 months, its use of these activities in connection with its efforts to collect information to inform future control options and to decrease shedding and spread of HPAI from affected flocks.

2. Indicate how, by whom, how frequently, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

APHIS will use the following information collection activities to inform future control options and to decrease shedding and spread of HPAI from affected flocks.

Questionnaire for States

This is a voluntary survey document/questionnaire. In general, these State respondents will be asked to:

• Describe steps taken by their State to prepare for an HPAI outbreak in the fall of 2015, including having a management plan and team in place.

• Describe in detail State, local, and industry resources (personnel, supplies, equipment, contracts etc.) within the State that could contribute to the response.

• Describe capacity to handle various kinds of depopulation responses (asphyxiation, foaming), travel routing, response supplies, and disposal.

• Provide information about Incident Command System structure and readiness.

• List the number of flocks, sales, markets, and other events in each State that may require response and what State officials think the State can handle.

• Assess current biosecurity practices.

• Assess current ability to monitor responders’ health and current laboratory capacity.

• Provide up-to-date contact lists for the State, including State veterinarians and their backups, poultry specialists, public affairs personnel, emergency coordinators, and key industry contacts within the State, field specialists, or others who would be involved in a response.

• Provide phone numbers, email, and mailing addresses for those contacts.

• Provide information on response mapping and data management.

• Identify additional resources needed by the State to be ready for an outbreak.

Questionnaire for Industry

This is a voluntary survey document/questionnaire for industry that will be approximately the same length as the State questionnaire and ask many of the same or similar questions. However, it will also ask for company identifiers (name, address, phone number, mail address, and company affiliation); location (questions about use of premises ID number(s) or location identification); and production type (species, egg or meat, commercial or breeder, number of birds, number of premises or houses, cage or floor raised, etc.,). In addition, it will include producer specific questions on biosecurity.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

APHIS plans to distribute and monitor the questionnaires electronically using the SurveyMonkey platform. States will also receive instructions for providing specific information on available resources including equipment, personnel by category, key contacts for response activities, and disposal sites. This additional information can be emailed or mailed back to APHIS.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose described in item 2 above.

The information that APHIS collects is not available from any other source. APHIS is the only Federal agency responsible for detecting and controlling contagious animal diseases in the United States. The information needed is specific to the circumstances with this outbreak. VS is working with State departments of agriculture to ensure efforts are not duplicated and uniform data is collected across States.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information APHIS will collect in connection with this program is the minimum needed to protect U.S. birds and poultry from the spread of HPAI. Approximately 5 percent of the respondents in this information collection are small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Collecting this information less frequently or failing to collect it would make it impossible for APHIS to establish an effective line of defense against the continuing spread of HPAI during the current series of outbreaks. If the information was collected less frequently or not collected, it would significantly cripple APHIS’ ability to plan and prepare for an expected fall 2015 resurgence of HPAI. This would undermine APHIS’s ability to decrease shedding and spread of HPAI from affected flocks, with continuing serious effects on the U.S. poultry industry.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

• requiring respondents to report information to the agency more often than quarterly;

• requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

APHIS needs these voluntary responses returned within 10 days of receipt of the questionnaire. This is so APHIS can plan and prepare to implement a strong response plan before the fall migration season, estimated to start by September 1.

• requiring respondents to submit more than an original and two copies of any document;

• requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than 3 years;

• in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

No other special circumstances exist that would require this collection to be conducted in a manner inconsistent with the general information collection guidelines in 5 CFR 1320.5.

8. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting form, and on the data elements to be recorded, disclosed, or reported. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, soliciting comments on the information collection prior to submission to OMB.

APHIS has engaged in productive consultations with the following individuals concerning the information collection activities associated with this program:

Dr. Charles Hatcher

State Veterinarian

Division of Regulatory Services

Tennessee Department of Agriculture

P.O. Box 40627

Nashville, TN 37204

Phone: (615) 837-5120

Fax: (615) 837-5250

Email: charles.hatcher@tn.gov

Lisa Picard

Vice President, Scientific and Regulatory Affairs

National Turkey Federation 

1225 New York Ave NW #400, Washington, DC 20005

Phone: (202) 898-0100

Email: lpicard@turkeyfed.org>

James H. Sumner

President

USA Poultry and Egg Council 

2300 West Park Place Blvd. Suite 100

Stone Mountain, GA 30087

Phone: (770) 413-0006

Fax: (770) 413-0007

Email: jsumner@usapeec.org>

APHIS will follow up this emergency request with a notice of request for a 3-year renewal of this information collection in the Federal Register within the next 6 months. 

9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.

This information collection activity involves no payments or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

No additional assurance of confidentiality is provided with this information collection. However, the confidentiality of information is protected under 5 U.S.C. 552a.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

This information collection activity will ask no questions of a personal or sensitive nature.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

•Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

See APHIS Form 71. Burden estimates were developed from discussions with poultry producers, accredited veterinarians, and State animal health officials.

•Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

APHIS estimates the total annualized cost to the above respondents to be $35,682. APHIS arrived at this figure by multiplying the hours of estimated response time (1,136) by the estimated average hourly wage of the respondents ($31.41).

Poultry producers: $34.89 [Farmers, ranchers, and other agricultural managers]; $12.10 [45-2093 Farm workers, Farm and Ranch Animals]

Veterinarians $47.23

The average hourly rate is derived from the U.S. Department of Labor; Bureau of Labor Statistics May 2014 Report – National Occupational Employment and Wage Estimates United States. See http://www.bls.gov/oes/current/oes_nat.htm#19-0000

13. Provide estimates of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

No annual cost burden is associated with capital and startup costs, operation and maintenance expenditures, and purchase of services resulting from this collection of information.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The annualized cost to the Federal Government is estimated at $30,970. (See APHIS Form 79.)

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

This is a new information collection resulting in 1,136 burden hours.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

APHIS has no plans to publish information it collects in connection with this program.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

This information collection will not use any APHIS forms.

18. Explain each exception to the certification statement identified in the "Certification for Paperwork Reduction Act."

APHIS can certify compliance with all provisions under the Act.

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