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Action Plan for a Permits Group in Regional FMD Response

Drafted by Richard P. Horwitz, Consultant for the

NESAASA FMD-Response Exercise In Concord, NH, May 9, 2013

Contents GET ORGANIZED ..................................................................................................................... 2

1. Request support in the Operations Section ..................................................................... 2

2. Establish a Permits Group ............................................................................................... 3

3. Request support from State Veterinarian(s) ..................................................................... 4

4. Request support in the Documentation Unit .................................................................... 4

5. Request support from the Liaison Officer ......................................................................... 4

6. Request support from the Joint Information Center (JIC) ................................................. 4

7. Set a decision-making schedule and appoint a time-keeper for each operational period . 5

ESTABLISH AND IMPLEMENT A PROCEDURE FOR ISSUING PERMITS............................. 6

8. Identify premises that require and are eligible for a Permit .............................................. 6

Summary of Zones and Areas ............................................................................................. 6

Summary of Premises Types .............................................................................................. 7

9. Assess and prepare a response to the reliability of data on farm Readiness ..................10

10. Identify premises that meet the Readiness requirement for a Permit...........................10

11. Establish conditions for expiration of Permits ..............................................................14

12. Issue Permits ..............................................................................................................14

13. Establish an investigation and service capacity ...........................................................15

Appendix 1: Readiness of New England Dairy Farms .........................................................16

Appendix 2: Readiness Section of Farm Survey .................................................................18

Appendix 3: Weighted Criteria for Rating Producer Readiness .........................................21

Appenidix 4: Permit Form ......................................................................................................22

Attachment 5: How to Spot Clinical Signs of Foot-And-Mouth Disease ............................23

Attachment 6: How to Conduct Active Observational Surveillance: ..................................25

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GET ORGANIZED 1. Request support in the Operations Section

a) Recommend that Operations mandate elevated biosecurity in the Control Area, at least

until there are reliable assessments of the scale of the outbreak, the size and location of Control Area, and the epidemiological type of each premises within it.

Quarantine Infected, Suspect, and Contact Premises.

Stop feeding of garbage (including waste, unpasteurized milk or milk products) to swine in the Control Area.

Stop movement of all susceptible livestock (cattle, swine, sheep, goats) to and from premises in the Control Area.

Suspend agri-tourism (e.g., sleigh and hay rides, corn mazes, tours for visitors, field trips for school children) on premises with susceptible livestock in the Control Area.

Stop direct-to-consumer sales of unpasteurized (“raw”) milk and milk products.

Temporarily (only as long as necessary to assign Premises Types, no more than 3 days) stop direct-to-consumer sales (including home delivery) of milk or products made from raw milk that have been processed on-farm or in an abutting processing plant in the Control Area (e.g., Producer-Handlers). Before resuming such direct-to-consumer commerce, strict biosecurity should be required to minimize routes of contamination between (a) those areas, facilities, personnel, supplies, and equipment that touch susceptible livestock and (b) those that may directly or indirectly contact on-premises processing or sales operations.

Temporarily (only as long as necessary to assign Premises Types, no more than 3 days) stop all shipments of unpasteurized milk to and from premises (dairy farms and processing plants) in the Control Area. Resume via premises-specific Permit or exemption.

But do not recall pasteurized milk or products that are made from pasteurized milk or raw milk products that are adequately aged or acidified. (They pose negligible risk to human health.)

b) Recommend to Operations a policy that movement of unpasteurized dairy products

(particularly milk) from farms to off-farm processors may be resumed to and from premises in the Control Area ONLY under permits that Incident Command may authorize for specific, sufficiently biosecure premises or groups of premises.1

c) Request that Operations clarify a procedure for authorizing the issuance of permits to

move raw milk within the Control Area. Recommend that Operations delegate authority for issuing permits to the Permits Group (or that Incident Command delegate such authority to the Operations Section, in consultation with a Permits Group or its equivalent).

d) Request that Operations approve public notice (to be distributed to producers, haulers,

and processors as well as state regulatory officials by the JIC) of the process for permitting movement of unpasteurized milk. (See “Notifications” and “Job Aids” in Attachments to the New England Secure Milk Supply Plan).

1 “Sufficiently biosecure” is to be assessed according to the SMS Performance Standards, as interpreted

and implemented by Incident Command.

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e) Request regular status reports (e.g., updates at least once every 24 hours from the

Disease Management or Surveillance Branch) on the boundaries of the FMD Control Area and the epidemiological status of premises within it.

2. Establish a Permits Group

Request that Incident Command establish a Permits Group within the Operations Section. The Group should include designee(s) of animal-health, agriculture, and/or dairy inspectors from the New England states who are familiar with local operations and the New England Secure Milk Supply Plan as well as liaisons with the dairy industry (e.g., co-ops).2

2 ICS example from USDA-APHIS-VS, National Center for Animal Health Emergency Management

(NCAHEM), Foot-and-Mouth Disease Response Plan: The Red Book (June 2012), B-13.

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3. Request support from State Veterinarian(s)

a) Ask the New England State Veterinarians to allow Incident Command to access to the NESAASA database.

b) Request state support for enforcement of permitting decisions (e.g., investigate alleged violations of quarantine orders or Permit requirements and report back to the Group).

4. Request support in the Documentation Unit Ask the Documentation Unit (in the Planning Section) to maintain (receive and process) records of permitting action (e.g., via Permits Group postings to Activities Log, ICS Form 214 or to Activity Log and Significant Events on WebEOC).

5. Request support from the Liaison Officer

a) Serve as point of contact for dairy industry representatives (e.g., producers, co-ops, haulers, and processors).

b) Reach out to agencies that are affected by the interruption in movement of livestock and livestock products but that may not be represented in the Permits Group (E.g., dairy regulators in Mid-Atlantic states, particularly New York, where producers ordinarily ship unpasteurized milk to New England dairy processing plants), providing access to incident updates and relaying concerns.

6. Request support from the Joint Information Center (JIC)

Objective: Help minimize public panic (e.g., unwarranted concern about “factory farms” or FMD as a hazard to human health) and increase support for emergency response.

a) Request the appointment of a Permits Group Liaison in the JIC. b) Recommend key messages for the public (See How to Communicate with Dairy

Consumers about FMD):

Foot-and-mouth disease is an extremely contagious disease of livestock. o FMD spreads through a virus that can infect cattle and other cloven-hooved

animals such as pigs, sheep, and goats. o The virus does NOT pose a significant risk to other sorts of animals, such as

cats, dogs, hamsters, horses, or humans.

FMD is not a public health concern. o No major scientific or public health organization considers FMD a significant risk

to human health. o Consumers can continue to drink pasteurized milk. Pasteurization of dairy

products effectively eliminates the FMD Virus. Despite its presence in much of the rest of world for centuries, the disease has never been transmitted from pasteurized dairy products to humans.

o FMD should not be confused with “Hand, Foot, and Mouth Disease,” a human disease that it is caused by a completely different virus than FMD.

Public cooperation is important and appreciated in response to this animal-disease emergency.

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o Anticipate restrictions in commerce and travel. They are necessary to reduce the risk of spreading virus among livestock.

o Avoid contact with susceptible livestock and the places where they live, whether they seem healthy or not, for the animals’ own protection.

c) Request that the JIC support dissemination of information about the permitting process.

The Permits Group should (after securing consent of the NESAASA State Veterinarians) share with the JIC contact information for dairy producers, haulers, and processors who operate in the Control Area.

Key messages for producers, haulers, and processors. (See “Notifications” and “Job Aids” in Attachments to the New England Secure Milk Supply Plan). o Livestock owners must learn the symptoms of FMD, check susceptible livestock,

and report suspicious symptoms to the State Veterinarian. (See How to Spot Clinical Signs of FMD and How to Conduct Active Observational Surveillance: A Guide for Herd Health Monitors.)

o Increase biosecurity to minimize the risk of exposure and spreading of FMD virus (e.g., stop feeding garbage to hogs and feeding unpasteurized milk to susceptible species; stop shipments of susceptible animals and – at least temporarily – raw milk; stop agri-toursim, and suspend direct-to-consumer trade, especially raw milk). (See “Job Aids” in the New England Secure Milk Supply Plan, especially How to Reduce Risks to Your Farm and How Drivers Can Reduce the Risk of Spreading Infection.)

o Movement of products from susceptible animals (particularly milk) from farm to market may be resumed within, to, and from the control area only with sufficient biosecurity and under premises-specific permits to be issued by Incident Command. (See the SMS Performance Standards for biosecurity measures.)

d) Request that the JIC establish the capability to field queries about milk movement, to

answer or to redirect questions in an efficient, orderly manner. Recommendation:

Questions about the content of policy (e.g., about the safety of dairy products, the targets of stop movement orders, or the permitting process) should be answered with a minimum of resources (e.g., via redirection to pre-recorded messages, press releases, and on-line postings maintained by the JIC itself).

Reports of violations (e.g., specific sightings of a quarantine failure, unpermitted milk movement, or other incident-relevant biosecurity breeches) should be referred to state or local officials with authority to enforce agricultural regulations.

Reports of changes in herd health, producer or processor challenges to the granting or rejection of a particular Permit, or state-enforcement findings on alleged violations should be referred to the Permits Group.

7. Set a decision-making schedule and appoint a time-keeper for each operational

period

Define and insofar as possible meet step-by-step deadlines to be sure that permitting decisions can be considered, recommended, reviewed, revised, authorized, issued, and transmitted in time for regulators, producers, coops, haulers, and processors to respond (e.g., by 3 PM on the day prior to eligible milk pickup).

Adjust deliberation standards and/or the schedule to achieve optimum balance between careful and decisive action.

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ESTABLISH AND IMPLEMENT A PROCEDURE FOR ISSUING PERMITS 8. Identify premises that require and are eligible for a Permit

a) Review the latest reports (e.g., from the Disease Management or Surveillance Branch of Operations) on the boundaries of the FMD Control Area and epidemiological status of premises within it. (See NAHEMS Guidelines on Continuity of Business and Classification of Phases and Types of a FMD Outbreak and Response and the Ready Reference Guide on Zone, Area, and Premises in an FAD Outbreak.)

Summary of Zones and Areas Note: The size and shape of Zones and Areas depend on the disease agent and epidemiological conditions, and they may be redefined as the outbreak continues.

Zone/Area Definition Size

Infected Zone (IZ)

Zone that immediately surrounds an Infected Premises.

Perimeter should be at least 3 km (~1.86 miles) beyond perimeters of presumptive or confirmed Infected Premises.

Buffer Zone (BZ)

Zone that immediately surrounds an Infected Zone or a Contact Premises.

Perimeter should be at least 7 km (~4.35 miles) beyond the perimeter of the Infected Zone. Width is generally not less than the minimum radius of the associated Infected Zone, but may be much larger..

Control Area (CA)

Consists of an Infected Zone and a Buffer Zone.

Perimeter should be at least 10 km (~6.21 miles) beyond the perimeter of the closest Infected Premises.

Surveillance Zone (SZ)

Zone outside and along the border of a Control Area.

Width should be at least 10 km (~6.21 miles), but may be much larger.

Free Area (FA)

Area not included in any Control Area.

Vaccination Zone (VZ)

Emergency Vaccination Zone classified as either a Containment Vaccination Zone (typically inside a Control Area) or a Protection Vaccination Zone (typically outside a Control Area). This may be a secondary zone designation.

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Summary of Premises Types

Premises Definition Zone

Infected Premises

(IP)

Premises where presumptive positive case or confirmed positive case exists based on laboratory results, compatible clinical signs, FMD case definition, and international standards.

Infected Zone

Contact Premises (CP)

Premises with susceptible animals that may have been exposed to FMD, either directly or indirectly, including but not limited to exposure to animals, animal products, fomites, or people from Infected Premises.

Infected Zone, Buffer Zone

Suspect Premises (SP)

Premises under investigation due to the presence of susceptible animals reported to have clinical signs compatible with FMD. This is intended to be a short-term premises designation.

Infected Zone, Buffer Zone, Surveillance Zone, Vaccination Zone

At-Risk Premises (ARP)

Premises that have susceptible animals, but none of those susceptible animals have clinical signs compatible with FMD. Premises objectively demonstrates that it is not an Infected Premises, Contact Premises, or Suspect Premises. At-Risk Premises seek to move susceptible animals or products within the Control Area by permit. Only At-Risk Premises are eligible to become Monitored Premises.

Infected Zone, Buffer Zone

Monitored Premises

(MP)

Premises objectively demonstrates that it is not an Infected Premises, Contact Premises, or Suspect Premises. Only At-Risk Premises are eligible to become Monitored Premises. Monitored Premises meet a set of defined criteria in seeking to move susceptible animals or products out of the Control Area by permit.

Infected Zone, Buffer Zone

Free Premises (FP)

Premises outside of a Control Area and not a Contact or Suspect Premises.

Surveillance Zone, Free Area

Vaccinated Premises

(VP)

Premises where emergency vaccination has been performed. This may be a secondary premises designation.

Containment Vaccination Zone, Protection Vaccination Zone

b) Recommendation: When Premises Types are unknown, treat every farm in a FMD

Control Area as if it were “FMD infected but undetected,” and hence not yet eligible to receive a milk-pickup permit. (This is to err on the side of disease control.)

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c) Recommendation: When Premises Types are known, use the following decision tree to determine when a permit is required and possible.

d) So, limiting conditions for a permit to ship unpasteurized milk from a farm to a

processing plant should depend on the premises type and its location.

In general, Infected, Suspect, or Contact Premises (including all premises in the Infected Zone) should not be eligible for permits for milk pickup, and Free Premises outside the Control Area should not need permits.

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Eligibility criteria for other premises types may be more or less restricted, depending on the scale of the incident and the associated losses to food supply and business continuity or recovery capacity vs. disease-control gains.

o In a relatively small outbreak – Type 1 (Focal) or Type 2 (Moderate Regional) – Monitored and At-Risk Premises may not be considered eligible for permits.

o In a regional or larger outbreak – Type 3 (Large Regional), Type 4 (Widespread or National), Type 5 (Catastrophic) or Type 6 (North American) – Monitored and At-Risk Premises in the Control Area should be considered eligible, for the sake of sustaining the food supply, environmental protection, farm survival and recovery.

More specific eligibility requirements should depend on biosecurity capacity (“Readiness”) and practices of the farm, the hauler, and the processor. (See also SMS Performance Standards.)

When and where can unpasteurized milk be shipped from a farm during a FMD outbreak?

PREMISES TYPE PREMISES LOCATION PICK UP RAW MILK?

Free Area

Free Premises Beyond the Surveillance Zone Yes, no Permit necessary

Free Premises Surveillance Zone Yes, no Permit necessary

Protection Vaccination Zone

Free Premises Protection Vaccination Zone Yes, if premises is Ready

Vaccinated Premises (at least 14 days post)

Protection Vaccination Zone Yes, if premises is Ready

Control Area

Free Premises Containment Vaccination Zone Yes, if premises is Ready

Vaccinated Premises (at least 14 days post)

Containment Vaccination Zone Yes, if premises is Ready

Monitored Premises Infected Zone or Buffer Zone Yes, if premises is Ready and if response is Regional

At-risk Premises Infected Zone or Buffer Zone Yes, if premises is Ready and if response is Regional

Suspect Premises Infected Zone or Buffer Zone No

Contact Premises Infected Zone or Buffer Zone No

Infected Premises Infected Zone No

In short, in Regional FMD Response, requirement and eligibility for Permits to ship raw milk in the Control Area should be confined to Free, Vaccinated, Monitored, and At-risk Premises that are Ready.3

3 Roughly speaking, a dairy farm is “Ready” when Incident Command determines that its biosecurity

measures are adequate. See SMS Performance Standards for Dairy Premises, Haulers, and Processing Plants (January, 2012) in the SMS Plan Executive Summary with Supporting Documents on FAD PReP.

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9. Assess and prepare a response to the reliability of data on farm Readiness a) Review the quality of existing data (survey results and Readiness Ratings in the

NESAASA database) on the biosecurity capacity of eligible dairy farms). Questions:

Are these data sufficiently complete and up-to-date to be used in timely permitting decisions?

Are there resources (time, people, biosecurity, transportation and information technology) to significantly improve the reliability of the data?

o From the Permits Group? o From Operations (e.g., as an add-on for existing surveillance efforts)? o From the private sector (e.g., co-ops or dairy promotion boards)? o From the state(s) or universities (e.g., Ag Extension, vet schools)?

In the absence of additional resources, are the benefits to continuity of operation (vs. disease protection) sufficient to justify using existing data in permitting decisions until resources are adequate to increase their reliability?

b) When feasible, develop and implement a procedure for verifying, updating, and improving data on farm Readiness, taking into account the resources required (e.g., the number of premises to be overseen), the resources available, and the importance of timely decision-making.

Select an instrument for verifying the completeness and accuracy of Readiness data on eligible premises – e.g., ranging from more to less thorough and demanding:

o On-site Inspection of the premises by an animal-health official; o Telephone call by a response official or designee to a farm manager; o Emailed or FAXed questionnaire to a farm manager; o Mandatory check-off on a Permit form; o Trust in the farm manager, plus spot checks and/or response to

complaints.

Select a scope for using the instrument – e.g., ranging from more to less thorough and demanding:

o All eligible farms; o A stratified sample of farms, including premises that are in the middle and

extremes of the distribution of risk for disease transmission (e.g., number of cattle, frequency of milk pickup, and latest Readiness Rating);

o A random, grab, or opportunistic sample of “representative” farms (e.g., piggy-backing on other incident-response surveillance activity);

o Farms that come to the Group’s attention as the subjects of complaints or as sites for which data are too incomplete or outdated for a permitting decision.

10. Identify premises that meet the Readiness requirement for a Permit.

Using information that the Permits Group has found reliable, identify which eligible premises can sufficiently meet SMS Biosecurity Performance Standards to qualify for a Permit to ship unpasteurized milk to an off-farm processing plant. Procedure:

a) Using the Readiness Rating in the NESAASA Database

1) Access state- or region-level data in the NESAASA Farm Database (currently on a

FAZD server, with passwords issued to State Veterinarians).

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2) Generate a Report, listing eligible farms (e.g., name, Premises ID, address, and contact information) with the Readiness Rating for each premises. Note: it may be necessary to generate a Report on all farms and then select eligible farms by hand in a database application. To identify premises by proximity (e.g., to find the zip code filter for farms within X miles of a particular premises), consider on-line aids such as Zip Code Radius Finder or BatchGeo for mapping them.

3) Choose a “provisional minimum Readiness Rating,” a biosecurity threshold. Recommendation: In a regional event, to qualify for a Permit, a farm should have a Readiness Rating of at least 50. That minimum would allow Permits to be granted to all farms that have documented capacity (at least within a day or two of notice, on their own) to secure their perimeter, provide a clean path to the bulk tank, and operate a wash station at the farm gate. In all, about 85% of surveyed farms claimed that capacity in the presence of a state agent.4

The choice of the required, minimum Readiness Rating is a key, inescapably contestable step. The optimal number is apt to depend on the incident type and the stage of response as well as the priorities of Incident Command in balancing inherently conflicting objectives – on the one hand to protect continuity of operations, the food supply, and prospects for recovery, and on the other to minimize risk of spreading infection that is the cause of the emergency.

The chosen minimum Readiness Rating may well vary inversely with the severity of the outbreak and the size of the Control Area. The smaller the Control Area, the greater the prospects of containing infection at relatively little cost to operations, and hence, the greater the net value of setting a high minimum Readiness Rating. Conversely, the larger the Control Area, the greater the relative cost to continuity of operations or recovery and hence the greater the net value of setting a lower minimum Readiness Rating.

4 As of 4/1/2013, 611 dairy farms were in the NESAASA database, about 40% of all licensed dairy farms

in New England. Note that, in this sample, the share of production is well correlated with the number of farms, and Readiness Ratings are independent of farm size.

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4) Check appropriateness of the provisional minimum Readiness Rating.

E.g., access the NESAASA Farm Database to assess farms with a Rating slightly above and below that provisional minimum (and/or farms known to a member of the Permits Group) to determine if the provisional minimum Readiness Rating makes sense: Given the current status of the incident, would the provisional minimum Readiness Rating properly distinguish qualifying from disqualifying farms? Or would a higher or lower minimum be better?

5) Assuming that this minimum Readiness rating may be required, assess the likely impact on production, the sustainability of farm operations and the food supply (and therefore, conversely, the generation of waste or financial and animal-welfare distress on disqualified farms).

E.g., access the NESAASA Farm Database to generate a report, listing the output of farms that meet the provisional minimum rating (and/or refer to the appendix, “Readiness of New England Dairy Farms”) to estimate these impacts.

6) Adjust the provisional minimum Readiness Rating accordingly -- to be sure the required minimum Reading Rating is reasonably allied with assessments of a grab sample of farms scoring above and below the minimum and with anticipated impacts on dairy production and sustainability.

Recommendation: At least initially, a Premises may qualify for a Permit only if it is eligible and its Readiness Rating is above the adjusted minimum.

b) As time permits, in select cases (premises where the risk of disease transmission

associated with milk movement is distinctly low), allow for the resumption of sales or issue permits based on criteria that are less restrictive than the minimum Readiness Rating.

This action is designed to sustain sales of dairy products where producers and the vehicles that service them are uniquely biosecure.

Examples of when such consideration may be appropriate:

o When particular biosecurity capabilities are apt to be more effective in disease control than the full, weighted mix of practices reflected in the Readiness Rating.

E.g., farms that can load milk off-premises, with negligible risk of contaminating the exterior of the tanker during milk pickup.

E.g., farms, such as Producer-Handlers or artisan cheese makers, who can sustain operations only with direct-to-consumer sales rather than shipments to other farms or plants (congregate sites).

o When clusters of farms within the Control Area warrant different minimum Readiness Ratings (e.g., farms in areas that are, in effect, epidemiologically isolated – separated by distance, prevailing weather, service routes, or traffic patterns).

o When a specific subset of criteria warrant more or less attention than assigned in the composite Readiness Rating, such as steam/hot washers in winter vs. summer. (Note, however: such season-dependent criteria likely represent too small a share of the Readiness Rating to affect rankings).

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Recommendation: Insofar and as soon as possible, allow direct-to-consumer sales (i.e., rescind the initial suspension of sales or issue special permits) on dairy farms that confirm establishment of a biosecure perimeter around livestock operations.

o This policy is designed to allow certain dairy farms (e.g., Producer-Handlers or hard cheese makers) to resume direct-to-consumer sales of dairy products that are properly pasteurized, aged, or acidified on-premises, without shipping raw milk to or from any other premises. (See Dairy Processing Standards to Deactivate FMDV, Articles 8.5.58-39 of the 2012 OIE Terrestiral Animal Health Code).

o Before resuming sales, these farms should be advised and confirm that they have carefully separated livestock operations from direct or indirect contact with processing and sales operations

Recommendation: Insofar and as soon as possible, issue Permits to farms that can ship raw milk without a hauler entering the premises.

o This policy is designed to resume shipments from farms that load milk onto a tanker that remains off-premises, a truck parked outside the farm perimeter, for example, by pumping raw milk through a long, properly sanitized hose. (See Using a Hose to Improve Farm Biosecurity During Milk Pickup in a FAD Emergency.)

o Before being issued such a Permit, these farms should be advised and confirm that they properly secure the perimeter of the premises, sanitize the hose, and disinfect any spilled milk.

Procedure

1) Access state-level data in the NESAASA Farm Database (currently on a FAZD server, with passwords issued to State Veterinarians).

2) Generate a Report, listing eligible farms (at least name, Premises ID, address, and contact information), screened by criteria that are more or less restrictive than the overall Readiness Rating.

This additional screening can be accomplished by adding filters to the Report or by sorting data from an unfiltered Report with a spreadsheet application, such as Excel.

E.g., select farms that do not ordinarily schedule a pickup or that can load milk off-premises.

3) Again, check the reasonableness of these criteria and adjust accordingly.

Does the exclusion of farms that just fail to meet these select-case criteria and the inclusion of those that just meet them make sense?

Are the anticipated impacts on dairy production and sustainability of permitting movement in these select cases acceptable?

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11. Establish conditions for expiration of Permits

a) Permits may be issue for each pick-up, a certain period of time (e.g., the coming week) or indefinitely, for all future pickups. Recommendation: A Permit qualifies a premises for milk pick up from the date of issue forward, until/unless the Permit is revoked or no longer required.

b) Among the reasons that Incident Command may revoke a Permit are:

A change in the boundaries of the Control Area;

A change in the health of the farm’s herd;

A farm’s failure to maintain adequate biosecurity.

12. Issue Permits

a) As necessary, obtain authorization to issue Permits.

b) Compile a list of farms (name, premises ID, address, and contact information) that have the requisite minimum Readiness Rating (plus or minus other, more or less restrictive criteria).

c) Assign a Permit number to each Permitted Premises.

Recommendation: The format for the permit number is XXXX.YYYY, where XXXX is the premises number and YYYY is the order in which a permit was issued. So, the first permit to be issued is number XXXX.0001; the second is XXXX.0002, then XXXX.0003, and so on.

d) Publicize the list of Permitted Premises.

1) FAX the list of Permitted Premises (with permit numbers) to the State Veterinarians and/or Milk Regulators, asking them to notify and confirm notification of (a) the premises that they regulate and (b) the agencies’ enforcement officers.

2) FAX the list to the dispatchers in the major Co-Ops (Agri-Mark, DFA/DMS). o Request that the Co-ops notify and confirm notification of their members

and the haulers who serve them, including members and haulers from outside the Control Area who might otherwise traffic in the Control Area.

o Request that the Co-ops remind affected haulers and processors of the elevated biosecurity requirements. (See “Notifications” and “Job Aids” in Attachments to the New England Secure Milk Supply Plan).

o Notify haulers to pick up unpasteurized milk only from permitted farms, regardless of co-op membership.

o Distribute Permit Forms to haulers, with instruction that forms are to be filled out prior to pickup and that the completed forms must be kept on file and available to Incident Command, upon request. (See Attached and on-line Permit Forms.)

3) Post the list of Permitted Premises to Incident Command via Activities Log, ICS Form 214 or Activity Log and Significant Events in WebEOC.

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13. Establish an investigation and service capacity

Assign a member of the Permits Group to handle queries and challenges of Permits Group actions (e.g., requests for clarification from producers, co-ops, haulers, or processors; complaints about who did or did not get a Permit, reports of biosecurity breeches on farms that have been issued Permits.)

Provide to the JIC contact information for investigation and service from the Permits Group.

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Appendix 1: Readiness of New England Dairy Farms Note: For illustrative purposes in this document. Actual data will be shared during the exercise

Shar

e o

f Fa

rms

Ab

ove

a M

inim

ium

Rea

din

ess

Rat

ing

Minimum Readiness Rating

Readiness of New England Dairy Farms

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Readiness Rating

Share of Farms by Rating

Share of Farms at or above Rating

0-10 % 100.00%

10-15

15-20

20-25

25-30

30-35

35-40

40-45

45-50

50-55

55-60

60-65

65-70

70-75

75-80

80-85

85-90

90-95

95-100

Criterion

Criterion

Weight

Share of Farms

with a Positive

Raw Score

Readiness Rating of

Farms That Are

Capable**

Ready* Capable** Mean Median Minimum

Security of the farm perimeter 19.7

Sanitation of the route from the roadway to the bulk tank 25.7

Capacity to clean and disinfect dairy traffic 54.6

TOTAL 100

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Appendix 2: Readiness Section of Farm Survey READINESS

With some diseases, especially FMD, infection can spread faster than clinical signs of disease. In an infected region, livestock may seem fine long after they have begun hosting and shedding virus. For safety’s sake, then, in aiming to protect your livestock and your neighbors’, at the beginning of an outbreak we plan to treat all dairy traffic in a disease control area as if it could be carrying infection. Precautions will be required. The following questions are intended to anticipate how tough it would be for your farm to elevate its biosecurity appropriately, to reduce the risk of spreading infection as vehicles and visitors come and go. Current state plans require that such precautions be in-place before commercial traffic will be permitted.

PERIMETER

Insofar as possible, preference in permitting emergency milk movement will be granted to premises that present a physical barrier to infection, that could, in effect, wall it off.

About how far is the perimeter of dairy operations from the nearest neighboring premises with FMD-susceptible animals (cloven hoofed animals):

0 (abutting property)

0-2 miles (more than 0 but less than 2)

2-6 miles (more than 2 but less than 6)

6 miles or more

Number of employees in the dairy operation who also work on another farm with FMD-susceptible animals:

Note: Most of the following questions about biosecurity give you three possible answers:

“Yes” means that the precaution is already in-place, ready-to-go.

“Not now, but possible” means that, though the precaution isn’t yet in-place, you could establish it with your own resources, within a day or two.

“No, impossible” means that establishing the precaution would require more resources than you could muster on your own within a couple of days.

Yes

Not now, but possible

No, impossible

Is there a gate that could be closed to restrict access to the entire farm or to the areas where livestock are kept?

Are signs posted and plainly visible to discourage visitors from entering areas where they might come into contact with livestock or manure – where permission, check-in and biosecurity precautions are required?

Could a hauler pick up milk without the tanker entering the farm premises?

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ENTRANCE

Insofar as possible, preference in permitting emergency milk movement will be granted to premises that are best designed to monitor and control traffic and to reduce the risk of picking up or shedding contaminants on the premises.

Yes

Not now, but possible

No, impossible

Is there one entrance to the dairy operation that is clearly posted and visible from the public right-of-way – a spot that could serve as point for controlling, logging in and logging out all vehicles, visitors, and employees?

Is the lane from the entrance to the bulk tank free from agricultural run-off (e.g., from pens or pasture)?

Is the lane from the entrance to the bulk tank separate from (as opposed to shared with) other essential on-farm traffic?

Cattle crossing?

Manure hauling?

Livestock shipments?

Movement of other field equipment?

Feed delivery?

Employee parking?

Visitor parking?

Surface of the lane from the entrance to the milk bulk tank hookup:

Paved (concrete or asphalt)

Permeable (gravel or dirt)

Parking surface for a truck while loading milk from the bulk tank:

Paved (concrete or asphalt)

Permeable (gravel or dirt)

DECONTAMINATION FACILITIES

Insofar as possible, preference in permitting emergency milk movement will be granted to premises that are best equipped to clean and disinfect (C&D) traffic as it enters and leaves the farm .

Yes

Not now, but

possible

No, impossible

Are there functioning foot baths for employees and visitors at entries to areas where they may be exposed to livestock, feed, milk or manure?

Is there a functioning wash station – a facility to clean and disinfect traffic at the entrance?

Even if there is no wash station, is there a place for one near the entrance that is:

Large enough for washing vehicles (e.g., at least as long as the largest tanker expected)?

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Free of run off or other sources of re-contamination (e.g., from routine livestock movement or manure handling) between that site and the public roadway?

Pitched toward a containment area or a ditch that does NOT drain directly into a wetland or waterway?

Capable of containing waste wash water?

Whether there is a wash station or not, are there appropriate supplies and equipment near the entrance:

Water supply?

Electrical power?

A pressure washer?

A steam/hot washer?

Sanitizer (Sufficient inventory for at least 3 days of vehicle C&D?)

Types on-hand:

Acetic Acid (vinegar)

Sodium hypochlorite (household bleach)

Other EPA-approved disinfectant (e.g., Virkon-S)

Personal protective equipment (PPE) that is disposable or waterproof to withstand washing and disinfection while being worn.

Types on-hand:

Gloves

Goggles

Boots

Coveralls (e.g., Tyvex)

Roughly, the more “yes” answers that are documented in this survey and then verified, the safer it would be for authorities to permit traffic to and from your farm in an emergency. Each “no” suggests an opportunity for improving biosecurity and sustainability of your dairy operations. But note, too: In assessing risks and issuing permits, regulators will consider a larger number of factors than this one survey. Some biosecurity measures are more effective than others (e.g., answers may be assigned weights). Given unique locations, management styles, herd sizes and finances, each farm may also be unique in its ability to resist disease transmission. In an actual emergency, information from surveys will be used in combination with other characteristics of the incident.

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Appendix 3: Weighted Criteria for Rating Producer Readiness In 2012, the members of the New England States Animal Agriculture Security Alliance – officials in each of the six states plus the Area Office of USDA/APHIS/VS – assessed the relative importance of biosecurity criteria for emergency milk movement. Through Analytic Hierarchy Process (via Decision Lens) the “readiness” of each producer to move milk was calculated as the sum of the products of the raw scores for the answers to each question in the producer survey (e.g. Yes = 1.0 or Possible = 0.5) times the weight that NESAASA members assigned to that question. Weights were normalized so that the maximum total equals 1.0 – a “Readiness Rating” of 100.

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Appenidix 4: Permit Form

Initial Permit for Movement of Unpasteurized Milk

From a Farm to a Processing Plant PERMIT NUMBER: (PID.Sequence) _____________ DATE PERMIT GRANTED (mm/dd/yyyy): _____________________

This permit is to allow Milk shipped from _________________________________

(farm name) to _______________________________________________ (dairy

processing plant) from this date forward, unless it is revoked by Incident Command.

This permit is valid only if the farm maintains biosecurity standards set by the Incident Command. At the very least, all farm traffic in the Control Area must be minimized, monitored (logged in and out), and decontaminated. The exterior of vehicles – especially tires, wheel wells and undercarriage of milk tankers – must be cleaned and disinfected when leaving the farm. While on the farm, haulers/samplers must avoid contact with livestock, equipment, and manure and disinfect any spilled milk.

I certify that susceptible livestock on this premises have been inspected and found free of clinical signs of infection and that production parameters are within normal range. I will notify the State Veterinarian immediately if I detect any clinical signs of Food-and-Mouth Disease. ________________________/_________________________ __________________ Herd Manager (Printed Name and Signature) Date (mm/dd/yyyy) ________________________/_________________________ __________________ Hauler (Printed Name and Signature) Date (mm/dd/yyyy) The Incident Command Post (ICP) may issue an Initial Permit to a farm manager when the ICP determines that the premises is eligible (e.g., when the risk of infection to or from that premises is negligible). Normally, by issuing an Initial Permit, the ICP grants authority to the farm manager to permit subsequent transport of milk from that premises. The ICP may revoke that authority at any time, especially if there is a significant change in herd health or the premises type (e.g., from Free to Contact or Suspect) or if the farm fails to maintain adequate biosecurity.

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Attachment 5: How to Spot Clinical Signs of Foot-And-Mouth Disease During a FMD outbreak any of the following symptoms may appear in affected animals and should be immediately reported to the State Veterinarian:

Marked rise in body temperature for 2 to 3 days, shivering;

Vesicles (blisters) that rupture and discharge clear or cloudy fluid, leaving raw, eroded areas surrounded by ragged fragments of loose tissue;

Production of sticky, foamy, stringy saliva;

Reduced consumption of feed and weight loss, due to painful tongue and mouth lesions;

Lameness or kicking with reluctance to move;

Abortions;

Low milk production (dairy cows);

Myocarditis (inflammation of the muscular walls of the heart) and sudden death, especially in newborn animals.

The specific signs and their severity vary with animal species and with strain of FMDV (from complete lack of clinical signs to death). In a naïve population, FMDV multiplies rapidly in multiple animals and spreads rapidly throughout the population. Cattle usually develop clinical signs more rapidly and more severely than other domestic species. Sheep and other small ruminants may have few clinical signs. Fever (up to 106°F [41°C]), inappetence, and decreased milk production are generally the first signs observed, followed by shivering, lip smacking, kicking, abortion, and sudden death among young animals. These preliminary signs may be observed prior to the formation of vesicles on the oral and nasal mucosa, teats, mammary gland, coronary band, and interdigital spaces. Vesicles are the classic lesions associated with FMD and cause nasal discharge, excess salivation (in cattle), anorexia, and lameness, leading to weight loss and decreased production.5 Vesicles (blisters) followed by erosions in the mouth or on the feet and the resulting excessive salivation or lameness are the best known signs of the disease. Often blisters may not be observed because they easily rupture, leading to erosions. Animals do not normally regain lost weight for many months. Recovered cows seldom produce milk at their former rates, and conception rates may be low.

FMD can be confused with several similar but less harmful diseases, such as vesicular stomatitis, bluetongue, bovine viral diarrhea, foot rot in cattle, and swine vesicular disease. Whenever mouth or feet blisters or other typical signs are observed and reported, laboratory tests must be completed to determine whether the disease causing them is FMD or not.6

5 USDA-APHIS-VS-CEAH, National Surveillance Unit, Draft Case Definition for Foot and Mouth Disease

(Draft, February 8, 2011), 1.3. 6 USDA-APHIS-VS, Foot-and-Mouth Disease, Factsheet (February 2007), p. 1.

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Model Guides:

Clinical Signs (Food and Agriculture Organization of the United Nations [FAO], European Commission for the Control of Foot-and-Mouth Disease [EuFMD], 2011)

Clinical Signs of Foot and Mouth Disease (The Scottish Government, 2011).

Clinical Signs of Foot and Mouth Disease (U.K. Department of Agriculture and Rural Development [DEFRA], 2011).

Foot and Mouth Disease (General) and Foot and Mouth Disease (Bovine - Scientific), mpg videos (USDA-APHIS-NAHEM, 2011)

Foot and Mouth Disease, Technical Disease Card (World Organisation for Animal Health [OIE], 2011).

Foot-and-Mouth Disease, Factsheet (USDA-APHIS-VS, 2007).

How to Spot Foot and Mouth Disease (U.K. Department for Environment, Food, and Rural Affairs [DEFRA], 2011).

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Attachment 6: How to Conduct Active Observational Surveillance: A Guide for Herd Health Monitors

In response to a FMD outbreak, animal health officials plan to require Active Observational Surveillance (AOS) to reduce the risk that milk will be picked up from farms with cattle that show signs of FMD. An on-farm Herd Health Monitor (HHM) is responsible for conducting and documenting surveillance of each herd.

For each dairy farm, at least one employee must be designated to oversee Active Observational Surveillance (AOS) of the herd. This Herd Health Monitor (HHM) must be prepared to report on the herd’s health, particularly any signs of FMD.

Herd Health Monitors should o Have worked on the dairy for the last several months;

o Be involved in the normal daily activities;

o Be familiar with the normal health problems; and

o Be able to recognize and report a change in the health of the cattle.

Signs of FMD Signs of full-blown FMD in cattle include painful sores and blisters in the mouth, on the feet, and on the teats of animals that quickly rupture into ulcers. If these sores are seen, it means that the FMD virus has been present in the herd for a few days and it is urgent to request that an animal health official, such as a representative of the Office of the State Veterinarian, come inspect the herd. In order to control the spread of FMD virus within the herd and between herds, it is very important that infection in the herd be detected as early as possible. Animal health officials are trained in early detection of FMD and can collect appropriate samples to submit for laboratory testing to detect the FMD virus if present. Many of the clinical signs associated with early stages of FMD infection (fever, lameness, mastitis, slobbering, diarrhea, off-feed, depressed, etc.) may be expected to occur in a herd for a variety of reasons. The designated HHM must be capable of deciding when any of these clinical signs seems more than “normal” and requesting a herd exam by an animal health official.

Early Clinical Signs of FMD:

Off feed

Excessive salivation, drooling or lip-smacking

Dullness, depression, reluctance to move

Lameness: Reluctance to rise, or stamping or shaking of the feet

Fever: Spikes typically between 104F and 106F and lasts 2-3 days

Runny nose

Diarrhea

Mastitis

Shivering

Calf deaths

Abortions

Decreased milk yield

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Fmd Monitoring Documents (in development)

AOS HHM Training Documentation Form Provides written documentation of training for personnel designated as HHM(s) for a specific farm.

AOS Daily Observation Worksheet Provides written documentation that all cattle on a farm have been observed daily by a trained HHM for clinical signs of FMD.

AOS Daily Observation Worksheet-Comment Form (optional) Allows the HHM to supplement the Daily Observation Worksheet by providing additional details regarding concerns or clinical signs of FMD noted, if desired.

AOS Herd Health Record Form (optional) Provides an optional method for the HHM to record observations and treatments associated with potential clinical signs of FMD.

OBSERVATION PROCEDURE

A HHM must regularly monitor animal health and be prepared to document observations at least once each day:

Animals should be observed when they are active, such as: o At milking (lactating cows) or while walking to the milk parlor; o At feeding; o When pushing up feed; o At breeding; o During herd checks; o During heat checks; and o When moving animals between pens.

The best observation will occur in close interaction with livestock in uncrowded areas, when you can observe individual animals

Be prepared to restrain the animal in a safe and humane manner for further examination as necessary.

Be familiar with the AOS Worksheets and how to complete them, along with recording health data on individual animals with suspicious clinical signs.

DOCUMENTATION PROCEDURE

A HHM will be expected to complete an AOS Daily Observation Worksheet for each group of animals on the dairy at least once per day.

Label each worksheet with the appropriate pen or group ID. The listed pen or group ID should be easily identified by other HHMs, managers, veterinarians, workers, etc. on the premises.

Check one and only one of three possible findings: 1. No early clinical signs associated with FMD were observed beyond what

is considered normal for this group. 2. Early clinical signs associated with FMD beyond the normal range for this

group were observed. A herd veterinarian or animal health authorities have been notified to inspect the animals.

3. Blisters or sores were noted on the mouth, feet, or teats. A herd veterinarian or animal health authorities have been notified.

If number 2 or 3 is checked, the HHM should be prepared to provide details of the clinical signs observed to the animal health authorities when they notify them. The animal health authorities will be responsible for making the decision as to whether milk movement should continue while awaiting inspection.

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Sign the worksheet each day and provide additional comments related to their observations on an AOS Daily Observation Worksheet-Comment Form.

Also record health information on individual animals that show clinical signs of FMD, either on the AOS Herd Health Record Form or in the animal health record system normally used on that dairy.

All records related to AOS must be available for inspection by animal health authorities managing the FMD outbreak.