Download View article - Robinson+Cole

The Operational Challenge of
Effective Biosecurity Programs
(“Winning the battle without losing the war”)
John R. MacMillan, Ph.D.
President, National Aquaculture Association, and
W. Richard Smith, Jr.
Partner, Robinson & Cole LLP
Biosecurity Objectives
• Protect farm stock
• Protect human health & environment
• Promote public confidence & sustainable
production
Changing Need for Biosecurity
• Increasing interstate & international
product movement
• Increased movement of live fish or round
fish for processing
• Time critical shipment & availability
demands
Commercial Facility Biosecurity
Program Requirements
•
•
•
•
•
•
•
•
•
Operationally compatible security measures
Economically sustainable security measures
Security measures commensurate with risk
Intergovernmental coordination
Facility-adaptable approaches available
Results-driven, not rules-driven
Maximization of effectiveness vs. absolutism
Readily available and reliable diagnostics
Customer, vendor, employee and public acceptance
Biosecurity Program Drivers
• Facility and operational factors
• Regulatory factors
• Market factors
Facility and Operational Factors
• Farm designs control biosecurity options
– (pens, ponds, flow through, recirculation)
• Species-specific management reqts.
– (breeding, development, growth, food,
environment, etc.)
• Biological unknowns
– (sources, pathways, life cycles, controls)
Facility and Operational Factors,
cont.
• New vs. old facility management measures
– Ability to retrofit, existing site limitation
• Water source, treatment, control options
• Ability to modify biosecurity measures,
adapt system and incorporate new
technology and scientific information
Regulatory factors
• Proscriptive regulation challenges
– Addressing facility variables
– Rulemaking hurdles (cost, effectiveness)
– Ensuring rulemaking addresses realities
• Limited ability to modify rules
Regulatory Factors, cont.
• Science-based controls and restrictions
– Stock distribution limitations
– Operating standards
– Product quality
• Enforcement
– Standards are enforced by penalties
– More-detailed plans are harder to maintain
– Violations of regulations and private actions
Market Factors
• Product cost impacts
– Manpower, training, process, time
• Competitor differentials
– Effects of jurisdictional variations
• Impacts on stock or product availability
• Impacts on production volumes
– Density, management
Market Factors, cont.
• “Acceptance” issues
– Employees (personal protection, hygiene,
chemical training)
– Public (chemical use, facility safety)
– Vendor (monitoring, reporting and quality
responsibilities)
– Customer (product availability and quality
impacts)