Formal Title: Docket No. [APHIS-2012-0058] Data Standards for Electronic Interstate Certificates of Veterinary Inspection December 31, 2012
This USDA-APHIS notice announced the availability of new data standards required to generate an official interstate certificate of veterinary inspection (ICVI). The data standards would define the minimum data elements required to generate an ICVI using an electronic data system, outline the methods by which data can be shared between participating systems, and provide methods of approving data systems for data quality control. The Agency is making these standards available for public review and comment.
Excerpts from the AVMA Response:
After reviewing the APHIS “Data Standards for Interstate Certificates of Veterinary Inspection” document, the AVMA believes that the data types described in the Standards are adequate. However, the AVMA is aware that the NASAHO has been working towards developing standardized ICVI data fields that meet the requirements of all States and NASAHO may not have completed the process. We therefore encouraged APHIS to continue to work with NASAHO, and a USAHA/AAVLD Animal Health Surveillance and Information Systems Subcommittee that is also currently examining optimal data standards systems, until this process is complete. The AVMA noted that the Standards allow for identifying whether animals have been vaccinated. While identifying the vaccination status and, in some cases, the specific product an animal is vaccinated with is important, we offer a cautionary note. With some diseases, an immunocompetent animal (from natural infection or vaccination) can still be a carrier of the infectious agent, and may serve as a reservoir and periodically shed the agent. We therefore believe that any vaccination data required on an ICVI must be carefully considered before being required, particularly in cases where the ICVI is used to certify freedom from disease or a specific pathogen.
The AVMA is pleased to note that the Standards include codes for numerous farmed aquatic animals (aquaculture) and will allow for group identification numbers (GIN). As most aquatic animals are moved in groups or lots, we feel GINs are important. As many aquatic species are farmed under leases of public waters (e.g. salmon net pens, intertidal oyster farms), we encourage APHIS to consider identifying these premises by global positioning system coordinates, and lease-holder in the Person/Location data fields.
The AVMA also noted that APHIS has proposed a large number of Breed Codes (Appendix 5) for aquatic and other species. While we applaud the inclusion of these, we note that these are actual Latin binomial species names and would be better considered as Species Codes. Similarly the Species Codes (Appendix 3) are actually animal types, not species. Moreover, with the large number of aquatic species listed in Appendix 5, APHIS has omitted these in Appendix 3. The AVMA therefore strongly suggested that, along with bovine, caprine, equine, etc., that APHIS includes finfish, crustaceans, molluscs, and amphibians as “Animal Types.”
In addition the AVMA noted that many diseases that affect farmed animals (the primary focus for the use of ICVIs), are also shared by many wild animals that are also moved interstate. In many cases either the U.S. Fish and Wildlife Service (USFWS), or State natural resource or wildlife agencies have regulatory jurisdiction over these species. The AVMA therefore recommend that APHIS work with these agencies to encourage them to utilize ICVIs in moving wild fish and other wildlife and, if possible, encourage these agencies to adopt the same system for ICVIs used for farmed animals. Without a uniform system to document and verify the disease status of all animals, whether farmed or wild, and track their movement, we believe that this will severely undermine and limit the ability of the U.S. to protect its farmed animal industries, or provide a system to adequately trace future outbreaks of animal diseases.
Relevant AVMA Policies: