Possible ban on koi and goldfish?

[Russell Peters]

Quote: Originally Posted by B.Scott So how are you gewtting around the ban Russel? B.Scott

Hi Scott,

Steve is right, it is not a ban. What APHIS has done is set up a system that requires paper work, time and money but I think it is a great idea. IMO it will stop imports from countries that don't have healthy fish. These imports are usually bought by retailers trying to make extra money with cheaper fish that are usually not healthy. The process is that we have to fill out an application, APHIS has set up ports of entry and each port of entry has one certified Vet that is responsible for all shipments. Our Vet is in Sacramento. We have to notify him 72 hours prior to the shipment landing and he has to come inspect the Koi at the cargo area when they come in. Here is the part that hurts, we have to pay him a fee to inspect the Koi and for ALL of his travel time to and from the airport. On the Japanese side we have to get SVC certificates from the breeders we import from. The process of clearing the Koi will take longer, but it will insure that the Koi are free from SVC. We have already spoken with our Vet about the whole process and are ready to IMPORT Koi.

[B.Scott]

I think the big IF in this whole situation is the fact that the preventive measures demanded by the restrictions means that measures of control that meet the US requirements but be in place and working for TWO YEARS before a company is eligible to export to the US. This means if the Japanese protocols have any discrepancy with us requirements they may well be forced to suspend exports to the US for 2 years. This will be bad news for the breeders and very bad news for the US dealers.

B.Scott

[PapaBear]

I have a feeling the short notice may have been purposeful in order to prevent any last minute "dumping" of non-compliant fish from breeders who won't qualify under the new regs.
The added expense involved in testing/clearing is a downside, but in the big scheme of things it had to happen. Too many outbreaks of disease lately to allow it to keep happening.
IMHO the Japanese will barely be affected. The Vietnamese and other SE Asian breeders who are relative newcomers with little or no controls in place will no doubt be taking the brunt of the impact. That is IMO a very GOOD thing. Those who have no regs are the most likely sources of everything we don't want in our ponds anyway.
In the meantime, the cheap "tateshita" market can be filled from domestic sources instead of sick imports dumped on our shores by unscrupulous breeders and brokers with no reputation to lose.

[Russell Peters]

Quote: Originally Posted by B.Scott I think the big IF in this whole situation is the fact that the preventive measures demanded by the restrictions means that measures of control that meet the US requirements but be in place and working for TWO YEARS before a company is eligible to export to the US. This means if the Japanese protocols have any discrepancy with us requirements they may well be forced to suspend exports to the US for 2 years. This will be bad news for the breeders and very bad news for the US dealers. B.Scott

For the Japanese SVC has been reportable for many years and the testing has all been in place long enough that it WILL be NO problem for all of the major Japanese breeders.

Russ

[Nancy M.]

Quote: Originally Posted by Russell Peters Hi Scott, Steve is right, it is not a ban. What APHIS has done is set up a system that requires paper work, time and money but I think it is a great idea. IMO it will stop imports from countries that don't have healthy fish. These imports are usually bought by retailers trying to make extra money with cheaper fish that are usually not healthy. The process is that we have to fill out an application, APHIS has set up ports of entry and each port of entry has one certified Vet that is responsible for all shipments. Our Vet is in Sacramento. We have to notify him 72 hours prior to the shipment landing and he has to come inspect the Koi at the cargo area when they come in. Here is the part that hurts, we have to pay him a fee to inspect the Koi and for ALL of his travel time to and from the airport. On the Japanese side we have to get SVC certificates from the breeders we import from. The process of clearing the Koi will take longer, but it will insure that the Koi are free from SVC. We have already spoken with our Vet about the whole process and are ready to IMPORT Koi.

Russ
My understanding is that, you need a Vet (approved by APHIS) to come out to your place of bussiness and certify that your store does not have SVC and or any other health issues with fish, and that you have a quarantine faclity for newly imported fish. The vet from APHIS, you need them to inspect the fish at the port, and they will charge you for inspection fee, ranging from $375 - $550 per shipment, on top of normal shipping fee's.

[dizzyfish]

I found this on the OIE web site.

CHAPTER 2.1.4.

</B>SPRING VIRAEMIA OF CARP

Article 2.1.4.1.

For the purposes of the Aquatic Code, spring viraemia of carp (SVC) means infection with the viral species SVC virus (SVCV) tentatively placed in the genus Vesiculovirus of the family Rhabdoviridae.

Methods for surveillance and diagnosis are provided in the Aquatic Manual.

Article 2.1.4.2.

Scope The recommendations in this Chapter apply to: common carp (Cyprinus carpio carpio) and koi carp (Cyprinus carpio koi), crucian carp (Carassius carassius), sheatfish (also known as European catfish or wels) (Silurus glanis), silver carp (Hypophthalmichthys molitrix), bighead carp (Aristichthys nobilis), grass carp (white amur) (Ctenopharyngodon idella), goldfish (Carassius auratus), orfe (Leuciscus idus), and tench (Tinca tinca). These recommendations also apply to any other susceptible species referred to in the Aquatic Manual when traded internationally.

<B>

Article 2.1.4.3.

Commodities

1. When authorising importation or transit of the following commodities, Competent Authorities should not require any SVC related conditions, regardless of the SVC status of the exporting country, zone or compartment:
   1. From the species in Article 2.1.4.2., for any purpose:
      1. commercially-sterile canned fish;
      2. leather made from fish skin.
   2. The following commodities destined for human consumption from the species referred to in Article 2.1.4.2. which have been prepared in such a way as to minimise the likelihood of alternative uses:
      1. chemically preserved products (e.g. smoked, salted, pickled, marinated, etc.);
      2. products (e.g. ready prepared meals, fish oil) that have been heat treated in a manner to ensure the inactivation of the pathogen;
      3. eviscerated fish (chilled or frozen) packaged for direct retail trade;
      4. fillets or cutlets (chilled or frozen);
      5. dried eviscerated fish (including air dried, flame dried and sun dried).
   For the commodities referred to in point 1b), Member Countries should consider introducing internal measures to prevent the commodity being used for any purpose other than for human consumption.
2. When authorising importation or transit of the commodities of a species referred to in Article 2.1.4.2., other than those referred to in point 1 of Article 2.1.4.3., Competent Authorities should require the conditions prescribed in Articles 2.1.4.7. to 2.1.4.12. relevant to the SVC status of the exporting country, zone or compartment.
3. When considering the importation or transit of any live commodity of a species not referred to in Article 2.1.4.2. from an exporting country, zone or compartment not declared free of SVC, Competent Authorities of the importing country should conduct an analysis of the risk of introduction, establishment and spread of SVCV and the potential consequences associated with importation of the commodity, prior to a decision. The exporting country should be informed of the outcome of this assessment.

Article 2.1.4.4.

Spring viraemia of carp free country A country may make a self-declaration of freedom from SVC if it meets the conditions in points 1, 2, 3 or 4 below.

If a country shares a zone with one or more other countries, it can only make a self-declaration of freedom from SVC if all the areas covered by the shared water are declared SVC free countries or zones (see Article 2.1.4.5.).

1. A country where none of the susceptible species is present may make a self-declaration of freedom from SVC when basic biosecurity conditions have been met continuously in the country for at least the past 2 years.

OR

1. A country where the species referred to in Article 2.1.4.2. are present but there has never been any observed occurrence of the disease for at least the past 25 years despite conditions that are conducive to its clinical expression, as described in Chapter 2.1.4. of the Aquatic Manual, may make a self-declaration of freedom from SVC when basic biosecurity conditions have been met continuously in the country for at least the past 10 years.

OR

1. A country where the last observed occurrence of the disease was within the past 25 years or where the infection status prior to targeted surveillance was unknown, for example because of the absence of conditions conducive to clinical expression, as described in Chapter 2.1.4. of the Aquatic Manual, may make a self-declaration of freedom from SVC when:
   1. basic biosecurity conditions have been met continuously for at least the past 2 years; and
   2. targeted surveillance, as described in Chapters 1.1.4. and 2.1.4. of the Aquatic Manual, has been in place for at least the last 2 years without detection of SVCV.

OR

1. A country that has made a self-declaration of freedom from SVC but in which the disease is subsequently detected may not make a self-declaration of freedom from SVC again until the following conditions have been met:
   1. on detection of the disease, the affected area was declared an infected zone and a buffer zone was established; and
   2. infected populations have been safely destroyed or removed from the infected zone by means that minimise the risk of further spread of the disease, and the appropriate disinfection procedures (see Aquatic Manual) have been completed; and
   3. targeted surveillance, as described in Chapters 1.1.4. and 2.1.4. of the Aquatic Manual, has been in place for at least the last 2 years without detection of SVCV.
   In the meantime, part of the non-affected area may be declared a free zone provided that it meets the conditions in point 3 of Article 2.1.4.5.

Article 2.1.4.5.

Spring viraemia of carp free zone or free compartment A zone or compartment within the territory of one or more countries not declared free from SVC may be declared free by the Competent Authority(ies) of the country(ies) concerned, if the zone or compartment meets the conditions referred to in points 1, 2, 3 or 4 below.

If a zone or compartment extends over more than one country, it can only be declared an SVC free zone or compartment if all the Competent Authorities confirm that the conditions have been met.

1. A zone or compartment where none of the susceptible species is present may be declared free from SVC when basic biosecurity conditions have been met continuously in the zone or compartment for at least the past 2 years.

OR

1. A zone or compartment where the species referred to in Article 2.1.4.2. are present but there has never been any observed occurrence of the disease for at least the past 25 years despite conditions that are conducive to its clinical expression, as described in Chapter 2.1.4. of the Aquatic Manual, may be declared free from SVC when basic biosecurity conditions have been met continuously in the zone or compartment for at least the past 10 years.

OR

1. A zone or compartment where the last observed occurrence of the disease was within the past 25 years or where the infection status prior to targeted surveillance was unknown, for example because of the absence of conditions conducive to clinical expression, as described in Chapter 2.1.4. of the Aquatic Manual, may be declared free from SVC when:
   1. basic biosecurity conditions have been met continuously for at least the past 2 years; and
   2. targeted surveillance, as described in Chapters 1.1.4. and 2.1.4. of the Aquatic Manual, has been in place for at least the last 2 years without detection of SVCV.

OR

1. A zone previously declared free from SVC but in which the disease is detected may not be declared free from SVC again until the following conditions have been met:
   1. on detection of the disease, the affected area was declared an infected zone and a buffer zone was established; and
   2. infected populations have been safely destroyed or removed from the infected zone by means that minimise the risk of further spread of the disease, and the appropriate disinfection procedures (see Aquatic Manual) have been completed; and
   3. targeted surveillance, as described in Chapters 1.1.4. and 2.1.4. of the Aquatic Manual, has been in place for at least the last 2 years without detection of SVCV.

Article 2.1.4.6.

Maintenance of free status A country, zone or compartment that is declared free from SVC following the provisions of points 1 or 2 of Articles 2.1.4.4. or 2.1.4.5., as relevant, may maintain its status as SVC free provided that basic biosecurity conditions are continuously maintained.

A country, zone or compartment that is declared free from SVC following the provisions of point 3 of Articles 2.1.4.4. or 2.1.4.5., as relevant, may discontinue targeted surveillance and maintain its status as SVC free provided that conditions that are conducive to clinical expression of SVC, as described in Chapter 2.1.4. of the Aquatic Manual, exist and basic biosecurity conditions are continuously maintained.

However, for declared free zones or compartments in infected countries and in all cases where conditions are not conducive to clinical expression of SVC, targeted surveillance needs to be continued at a level determined by the Competent Authority on the basis of the likelihood of infection.

Article 2.1.4.7.

Importation of live animals from a country, zone or compartment declared free from spring viraemia of carp When importing live aquatic animals of the species referred to in Article 2.1.4.2. from a country, zone or compartment declared free from SVC, the Competent Authority of the importing country should require an international aquatic animal health certificate issued by the Competent Authority of the exporting country or a certifying official approved by the importing country, certifying that, on the basis of the procedures described in Articles 2.1.4.4. or 2.1.4.5. (as applicable), the place of production of the consignment is a country, zone or compartment declared free from SVC.

The certificate should be in accordance with the Model Certificate in Appendix 4.1.1.

This Article does not apply to commodities referred to in point 1 of Article 2.1.4.3.

Article 2.1.4.8.

Importation of live animals for aquaculture from a country, zone or compartment not declared free from spring viraemia of carp When importing, for aquaculture, aquatic animals of the species referred to in Article 2.1.4.2. from a country, zone or compartment not declared free from SVC, the Competent Authority of the importing country should assess the risk and apply risk mitigation measures such as:

1. the direct delivery into and holding of the consignment in quarantine facilities;
2. the continuous isolation of the imported aquatic animals and their first generation progeny from the local environment;
3. the treatment of all effluent and waste material in a manner that ensures inactivation of SVCV.

This Article does not apply to commodities referred to in point 1 of Article 2.1.4.3.

Article 2.1.4.9.

Importation of live animals for processing for human consumption from a country, zone or compartment not declared free from spring viraemia of carp When importing, for processing for human consumption, aquatic animals of the species referred to in Article 2.1.4.2. from a country, zone or compartment not declared free from SVC, the Competent Authority of the importing country should require that:

1. the consignment is delivered directly to and held in quarantine facilities for slaughter and processing to one of the products referred to in point 1 of Article 2.1.4.3. or other products authorised by the Competent Authority; and
2. all effluent and waste material from the processing are treated in a manner that ensures inactivation of SVCV.

This Article does not apply to commodities referred to in point 1 of Article 2.1.4.3.

Article 2.1.4.10.

Importation of live animals intended for use in animal feed, or for agricultural, industrial or pharmaceutical use from a country, zone or compartment not declared free from spring viraemia of carp When importing, for use in animal feed, or for agricultural, industrial or pharmaceutical use, aquatic animals of the species referred to in Article 2.1.4.2. from a country, zone or compartment not declared free from SVC, the Competent Authority of the importing country should require that:

1. the consignment is delivered directly to and held in quarantine facilities for slaughter and processing to products authorised by the Competent Authority; and
2. all effluent and waste material from the processing are treated in a manner that ensures inactivation of SVCV.

This Article does not apply to commodities referred to in point 1 of Article 2.1.4.3.

Article 2.1.4.11.

Importation of products from a country, zone or compartment declared free from spring viraemia of carp When importing aquatic animal products of the species referred to in Article 2.1.4.2. from a country, zone or compartment declared free from SVC, the Competent Authority of the importing country should require an international aquatic animal health certificate issued by the Competent Authority of the exporting country or a certifying official approved by the importing country certifying that, on the basis of the procedures described in Articles 2.1.4.4. or 2.1.4.5. (as applicable), the place of production of the consignment is a country, zone or compartment declared free from SVC.

The certificate should be in accordance with the Model Certificate in Appendix 4.2.1.

This Article does not apply to commodities referred to in point 1 of Article 2.1.4.3.

Article 2.1.4.12.

Importation of products from a country, zone or compartment not declared free from spring viraemia of carp When importing aquatic animal products of the species referred to in Article 2.1.4.2. from a country, zone or compartment not declared free from SVC, the Competent Authority of the importing country should assess the risk and apply appropriate risk mitigation measures.

In the case of dead fish, whether eviscerated or uneviscerated, such risk mitigation measures may include:

1. the direct delivery into and holding of the consignment in biosecure/quarantine facilities for processing to one of the products referred to in point 1 of Article 2.1.4.3. or other products authorised by the Competent Authority;
2. the treatment of all effluent and waste material in a manner that ensures inactivation of SVCV.

This Article does not apply to commodities referred to in point 1 of Article 2.1.4.3.

</B>

[ChrisC]

I think it is problematic that these rules were promulgated as INTERIM rules. Ordinarily, rules go through a hearing process to ensure that stakeholders understand all of the ramifications, and that the law makers and regulators have had the opportunity to get the result they want with the least number of unintended consequences.

That process was bypassed here, with the result that even koi importers are obviously unclear about what the rules mean, and whether or not their vendors in Japan can comply.

I don't see why the USDA could not have made some clear rules, put them into effect three years from now, and given the industry a chance to catch up. It is not like the US is currently SVC free, after all.

I intend to write a letter to that effect to the USDA as a hobbyist--I would urge you to do the same.

[bekko]

Quote: For the Japanese SVC has been reportable for many years and the testing has all been in place long enough that it WILL be NO problem for all of the major Japanese breeders.

Russ, wouldn't the Japanese breeders who ship to the EU already be doing this paperwork?

Quote: The vet from APHIS, you need them to inspect the fish at the port, and they will charge you for inspection fee, ranging from $375 - $550 per shipment, on top of normal shipping fee's.