"Domestically farmed fishes that are involved in interstate movement as live animals are already subject to extensive testing and certification requirements."
Dr John R MacMillan, the president of the NAA.
In a letter to the NE Fish Health Committee in response to their Fish Health Management Guidelines, the NAA said that harmonisation between states should help to eliminate regulatory conflict and boost efforts to reduce the spread of dangerous pathogens between stated that are served by common watersheds. "Our association is concerned about the spread of serious pathogens that could negatively impact our aquatic animal production," said Dr John R MacMillan, the president of the NAA in the letter to the committee.
"As part of your harmonization efforts, we suggest it is first critical to thoroughly examine existing state import regulations and certification standards to determine if existent procedures have failed to protect your fishery resources.
"Domestically farmed fishes that are involved in interstate movement as live animals are already subject to extensive testing and certification requirements.
"The question to ask is whether these certification requirements have failed to protect state fishery resources. We suggest that if existent requirements have provided protection from interstate farmed fish movement, to add additional certification requirements cannot be justified from a fishery protection standpoint."
Dr MacMillan said that the NAA is already concerned about the emergence of the Great Lakes strain of VHSv in wild fish, which it says highlights the weaknesses in most state certification requirements.
"Non-inspected feral fishes are frequently moved between watersheds and across state boundaries. We believe it is these movements that should be subject to critical certification efforts, not increasing an already protective certification burden on domestically farmed fishes," he said. The NAA also called for state resources to be targeted on pathogens that are threatening state fishery resources.
"Not all pathogens are significant threats and some pathogens likely in imported farmed fishes have been present for many years without causing harm or becoming established in your state fishery resources," said Dr MacMillan.
He added that it is pointless to create new standards that do not take into account the risk element.
The NAA has now called on the fish health committee to consider whether existing NE region farmed fish health certification standards been effective in protecting state fishery resources from currently required or proposed fish pathogens. "We believe the answer is yes and suggest it is not justifiable to create additional certification standards for farmed domestic fishes involved in interstate movement," the NAA propose.
The NAA also asked that if a pathogen is already present in the state resources, then the committee should look at whether there are statewide efforts to eradicate it and if these are not present , the committee should examine whether the pathogen is likely to become established.
"We believe farmed fishes imported into the NE region have not introduced any pathogens. The reasons for this are likely the effectiveness of existing certifications," Dr MacMillan said in the NAA letter.
He added that they believe that the GReat Lakes strain of the VHSv is the one emerging pathogen that needs to be scrutinized and as there are checks in place for farmed fish, the committee needs to turn its attention to feral fish.
He concluded that the NAA welcomes the efforts for harmonisation, but he repeated that measures to regulate on pathogen import should be according to science-based risk analysis.