Harmonized approach to voluntary and regulated aquatic animal health programs

Multiple government agencies claim jurisdiction and oversight over aquatic animal health. This creates confusion and ambiguity for veterinarians, producers, other stakeholders, and state and federal regulatory agencies. This duplication of effort also seriously hampers progress toward developing strong, progressive, and sustainable U.S. aquatic animal industries, working with other managed fisheries, and conservation stewardship of wild fisheries.

Harmonized and coordinated approaches to formulating and implementing regulations or voluntary programs to optimize the health of aquatic animals are pivotal to the future of U.S. commercial aquaculture, wild fisheries, and ornamental, research, and aquatic animal exhibition industries. The AVMA sees benefits to aquatic animals, public health, seafood safety and security, and the environment, by involving all entities, including producer groups, allied organizations, and state and federal agencies, to ensure that:

1. As aquatic animal health programs and regulations are developed for the prevention, mitigation, and eradication of aquatic animal diseases in fisheries, they are harmonized in approach with existing terrestrial farmed and wild animal programs and with regulations at international, national, state, and local levels; and
2. Aquatic animal health regulations and programs are developed based on sound scientific principles and appropriate risk analysis, including components that:
   1. clearly identify specific pathogens or diseases as a hazard and risk to specific industries or sectors, and utilize risk analysis (including risk assessment, decisions on acceptable and reasonable risk, risk management, and communication) before considering any pathogen or disease as being reportable, or otherwise regulated;
   2. maintain sustainable practices that enhance the health and welfare of aquatic animals and address environmental concerns, mitigate zoonotic diseases, manage nuisance species and promote seafood safety;
   3. care transparent, and consider industry and other stakeholder input;
   4. utilize standardized, practical, and justifiable approaches when formulating regulations for aquatic animal disease prevention, control, and eradication; these regulations should apply to appropriate aquatic animal private and public sectors irrespective of which government agency promulgates the regulations;
   5. are effective for their intended purpose(s) without unnecessary requirements or burden to the regulated parties; and,
   6. address the roles and jurisdiction of veterinarians, veterinary technicians, and non-veterinary professionals in delivering veterinary services, such as issuing Certificates of Veterinary Inspection (“health certificates”), performing diagnostic assays, and diagnosing diseases consistent with state practice acts and the National Veterinary Accreditation Program.

To this end, the AVMA supports the National Aquaculture Health Plan and Standards (NAHPS). As a strong and harmonized plan that includes viewpoints of stakeholders in public and private aquaculture, state and federal and tribal regulators, and conservation of fisheries and natural resources, NAHPS represents a consistent, nationwide approach to testing for aquatic pathogens and diseases, managing risk of aquatic animal movements, and meeting inter-state and international trade requirements for aquatic species. AVMA urges the agencies involved to comprehensively budget and fund the program for proper implementation, execution, and long-term maintenance, and to incorporate the program standards into their own regulations.