Wednesday, May 6, 2015

Audit of Biosecurity Systems for Canada's Chicken Supply Management System

Small Flockers have completed an audit on the Biosecurity Systems (Regulations, Policy, Procedures, etc.) used by Canada's Chicken Supply Management System.  While much has been written, there are some important holes in the system, and it's disorganized.  Lack of details lead to misunderstandings and non-compliance to the intent.  Ongoing HPAI (Bird Flu) infections are the likely result.  The system needs a high priority overhaul NOW.

Bird Flu (scientifically known as Highly Pathogenic Avian Influenza Type A, H5N1 and others) has been around since first identified in China in 1997, 18 years ago.  Perhaps we can forgive Canada's Poultry experts for assuming that it would stay in China.

However, in 2004 (just 7 years after the Chinese outbreak), BC's Fraser Valley was struck with a devastating Bird Flu outbreak.  So much for the "Only in China" theory about Bird Flu.

Some Bird Flu lessons were eventually learned.  For example, BC mandated some biosecurity requirements for all commercial poultry farms, including an Ante Room, where street clothes are removed and clean barn clothes are donned, further limiting the tracking in of infectious materials from outside.  Good idea!

There are some highly likely methods for infecting a commercial poultry farm, such as one or more of the following:

  1. The farmer or staff steps in some wild bird poo just outside the poultry barn.  Wild birds (eg. ducks, geese, etc.) are known carriers of Bird Flu on a world-wide basis, so that wild bird poo should be assumed to be infectious.  The poo gets tracked inside the poultry barn, and eventually one or more poultry birds are infected.  That infected bird soon spreads the infection to all the other birds due to the congested living conditions inside the poultry barn.
  2. A wetland or wild bird feeding area is nearby the poultry farm, and is often frequented by wild birds, some or most of whom are infected.  The wind can blow infectious dust towards the poultry farm.  The dust enters the barns through the large air intake vents that are not protected by MERV H14 HEPA filters (A-H5N1 and AH7N9 virus is 0.1 microns, with a 99.999% removal efficiency) and/or UV lights.  The infectious dust is breathed in by the poultry, infecting them.
  3. Wild birds or other vermin are attracted by the readily available food for the chickens, and a nice place to live.  Without effective wire screens to exclude the vermin, they will find a way to enter the barns.  Once they enter, there droppings or bodily fluids will bring contamination inside the poultry barns.
  4. Flies are known carriers of Bird Flu.  Flies has a maximum flight radius of 20 miles.  Any wild bird and/or the bird's droppings or bodily fluids are attractive for flies, leading to flies becoming carriers of Bird Flu.  Flies are also attracted to chicken farms due to the smells that indicate food and breeding opportunities.  CAFO chicken farms have up to 83 times the background concentration of flies.  Chickens will eat flies if they can.  If an infected fly is eaten, that chicken is likely to become infected.  Once one chicken is infected, most other chickens will soon be infected.  Wire screens, fly traps, and other fly management systems are needed to minimize this risk.  Fully sealing a large building like a CAFO poultry barn is difficult, and needs constant monitoring and upkeep.
  5. Farm staff or service personnel had previously visited an infected farm, or personnel at an infected farm, then bring the infection home with them.  Lack of biosecurity protocols, or ineffective protocols, or non-compliance to protocols will soon allow that latent infectious materials to enter the poultry barn.
In my opinion, none of these risks are adequately assessed for risk, nor handled effectively in the resulting policies and procedures.  For more details, see Blog posting Chicken Factory Infections with Bird Flu

Figure 1 shows the 4 Risk Zones defined by CFIA.  The size of the infected zone is disease dependent. Based on the risk scenarios described above, the zone sizes are of questionable value, and may increase the risk of the infection spreading.
Figure 1:   Example of CFIA's Risk Zones
(Infected 3 km, Restricted 10 km, Security >10 km,
Control-Province).  What is the scientific basis
for these risk zone boundaries?
The World Health Organization, USDA, CFIA,  and many others have stated that a risk-based management approach should be applied to food production and distribution systems worldwide.

Has Canada's Chicken Supply Management followed these recommendations?  Did they correctly and comprehensively apply the recommended methods; or did they do an erroneous, slipshod, or superficial implementation?  Did they make a mistake, or invalid assumptions somewhere in their implementation?  Without the details shared with everybody, we'll never know the answers to these important questions.  If any of these errors exist, the results (ie. SOP's, policies, procedures, recommendations, etc.) when published and used can mislead everybody into consistently implementing risky behaviours; worse than no recommendations.

Here is the Excel Spreadsheet for USDA's Risk Assessment for CAFO Broiler Growing and the risk of transmitting Bird Flu to humans.  This risk assessment was Peer Reviewed, and was responded to by the USDA.  Public comments were also collected, and responded to by USDA.

There are many risk assessment models and other resources available from

Where are the details for Canada?  How does the risk assessments of USDA and Canada compare?  Unfortunately, we will never know under Canada's Chicken Mafia bureaucracy.

I had previously recommended to OMAFRA for the using of FMEA (Failure Mode Effect Analysis) and/or FTA (Fault Tree Analysis) to help determine the risks in their Meat Regulations (see the May 12, 2013 posting Meat Regulations Gone Wild) .  These techniques would also help focus the use of limited resources on the greatest risk, preventing a trial-and-error approach.  These powerful techniques could have been used here, guarding against Avian Flu, with the same benefits.

FMEA was invented by NASA in the 1960's to help achieve the Moon Shot.  It worked!  An FMEA was also done on the Space Shuttle that predicted catastrophic failure of the solid rocket booster every 25 missions, which was what Challenger was (Launch #25).  Unfortunately, that FMEA report was gathering dust on a shelf due to NASA bureaucracy, and wasn't acted upon until after the fact.

FMEA has been previously used in the food industry, with and without HACCP:

Ioannis S Arvanitoyannis, Theodoros H Varzakas (2008)  Application of ISO 22000 and Failure Mode and Effect Analysis (FMEA) for industrial processing of salmon: a case study.   Crit Rev Food Sci Nutr 48: 5. 411-429 May 2008

Theodoros H Varzakas, Ioannis S Arvanitoyannis (2007)  Application of Failure Mode and Effect Analysis (FMEA), cause and effect analysis, and Pareto diagram in conjunction with HACCP to a corn curl manufacturing plant.   Crit Rev Food Sci Nutr 47: 4. 363-387 , 2008

and non-food, but also important:
FMEA Risk Analysis Lessons from New Orleans and Hurricane Katrina
In spite of this, OMAFRA ignored me then (Meat Regulations), and likely OMAFRA will ignore me again (for Bird Flu).

That will be very unfortunate for Canada.

Detailed Audit of HPAI Biosecurity for Chicken Supply Management

Chicken Farmers of Canada (CFC") produced the On-Farm Food Safety Assurance Standard ("OFFSAS") for chickens, which includes Biosecurity systems.  The applicable parts for Bird Flu says:

2.3 Pest Control

As a minimum standard, you must follow these maintenance routines:
Air inlets for the barn and/or attic require a barrier such as screens to prevent wild birds from accessing the barn. Screens must deny access into the barn but still allow for normal function of the inlets in winter weather conditions (snow, ice, frost etc). All damaged barriers must be repaired immediately.
2.7   Air inlets are screened and damaged air inlet screens are repaired
8.1 Bird Supervision
   A) Dead Bird Removal and Disposal
      The following are guidelines for different types of mortality disposal:
         (4) Composting
            >Composters are to be maintained to minimize the attraction of flies, rodents and other animals.
Note that Section 2.3 calls for a "barrier such as screens".  Is that a screen that will stop a full flight suicidal goose, or a Chickadee, or a fly?  It doesn't say clearly what is expected.  I suggest that CFC personnel have likely been asked for clarification, and there are likely as many different answers as CFC employees.

In Section 2.7, is a man door an air inlet? What about a chicken door?  Again, are they screened to keep out racoons, or flies?  Lack of clarity.  I have had racoons easily push through standard chicken wire screens, and can do the same for fly screens.

In Section 8.1, dead stock composter must be "maintained".  Whether we have poor or excellent design of the composter, this does not seem to be an issue.  The gasses coming off from the compost attracts flies.  If some of those attracted flies were carrying bird flu, uninfected flies coming to the same smell may soon become carriers of Bird Flu too.  Next stop is the poultry barns, causing an outbreak.

Is this Section 8.1 compliant with all recommendations in the available research?
Exposure assessment of carcass disposal options in the event of a notifiable exotic animal disease: Application to avian influenza virus, Cranfield University, Centre for Resource Management & Efficiency, School of Applied Sciences, Cranfield, Bedfordshire, UK MK43 0AL. Environmental Science and Technology (Impact Factor: 5.48). 05/2008; 42(9):3145-54. DOI: 10.1021/es702918d
Caged layers often have large quantities of chicken manure inside the barn.  Broilers live in their own filth for all their lives.  The anaerobic oxidation of those manures produce huge amounts of fragrant gasses that attract flies.  Flies come in the same holes from which those manure gasses leak out.  Eventually they will find a hole that isn't screened.  Again, no details on the risk, and no link to other detailed materials that describe the risks more fully.  Lack of understanding leads to no or incorrect actions.

There is also an Appendix with a fill-in-the-blank SOP's (Standard Operating Procedures).

C) Pest Control
(1) Pest Situation Analysis:  Rate  your  farms’  pest  problems  in the  previous  year (none, some, lots):
Rodents, Wild Birds, Flies, Beetles, Other Pests: _______________________________

(4) Indicate the control measures used for flies: ________________________________
Relative fly counts means nothing.  For example, two years ago, it might have been so thick in flies you couldn't breath.  Last year, it was just a nuisance, so you score it "Some", because 2 years ago was "Lots". As an alternative, there are standard sentinel fly traps, where you can count the flies per hour of trap exposure.  Hard data can be compared, assessed for risk, and leads to action.

In CFC's OFFSAF, they mention referring to the National Farm Animal Care Council Code of Practice.  Unfortunately this Code is silent on flies, vermin, biosecurity, and poultry diseases.

Chicken Farmers of Ontario ("CFO") also offers CFC's OFFSAF

CFO has written up 1 (sometimes 2) page news releases on Bird Flu. I understand the advantage of short & sweet, and people with short attention spans.  It could be done as a quick, on-line quiz, they guess the right answer, and get trained if they guessed wrong, or entered for a prize draw for all who got the right answer.  Links for more in-depth training could have been offered on each key word.  Many things could have been done by CFO, but wasn't.

The same comments for CFO can be applied to the Feather Board Command Centre, Farmer Heightened Biosecurity Advisory, Suspect Avian Influenza in area southwest of Kitchener, April 18, 2015.  Short, sweet, and mis-leading.

FARMER DISEASE ADVISORY:   Suspect Highly Pathogenic Avian Influenza Heightened Biosecurity Notice, Thamesford/Woodstock area Oxford County   April 6, 2015

Here, we are encouraged to "Ensure adequate control of vermin and wild birds."  I'm not sure everybody knows the definition of "vermin", and are not inclined to look it up.  Fly maggots would likely be voted into the classification "vermin", but would a racoon?  Exactly what is meant by "adequate control?  I suspect that every farmer will have a different definition.  Will all of those definitions result in escaping a Bird Flu infection?

Biosecurity Cards contain high density information, and are likely skimmed over, limiting their impact, but at least they have more than superficial "Mom and Apple Pie" type of exhortations for Biosecurity.

Biosecurity Recommendations exists but has limited to no specific information.

Wild Bird connection to Bird Flu is published, but does not give all the necessary facts and mechanisms.  Without that basic understanding of how the mechanisms, people must be given an exhaustive check list, rather than apply some simple mnemonics or "Rules of Thumb".

Ante Room Construction is a font of good information on what and how to construct a biosecurity anteroom, and a little bit of "why".  With some hard data on the advantages of an Ante Room, I could see this type of paper actually motivating people to take action.  Well done!

Biosecurity Protocols for Poultry Service Sector Final with all SOPs has nothing for Broiler farmers.

CFIA’s Avian Biosecurity Technology Development Fund appears to have provided at least $3 Million for on-farm biosecurity system program development.  Did Canadian taxpayers get full vale for their money?

National Avian Biosecurity Advisory Council (NABAC)

CFIA's National Avian On-Farm Biosecurity Standard is one of the best biosecurity documents available.  I was pleasantly surprized to learn that it was based on objective measurement of risk based on David Halvorson's Risk Index Method.  At last, some scientific methodology, rather than educated guesses and subjectivity.  The AI horror in BC's Fraser Valley in 2004 was one of the motivations of Halvorson to develop this risk index, and write this peer reviewed paper.

Mandatory biosecurity requirements have been established for poultry farms in British Columbia. These requirements were developed from the lessons learned from the AI outbreak in 2004.

From this document, we also have the following:
Appendix 2
   4. Farm Management
      4.1 Pest Control
         Mandatory Standard # 12
            4.1.1 An effective pest control program must be in place. 
               Rationale: Pests are active and passive disease transmitting vectors. Minimizing pest populations will reduce the risk of disease transmission. 

Providing some rational is excellent.  Backing these statements with the quantitative data would be even better.

4.1.2 Interpretive Guideline:
a.  Premises should be maintained in a manner that minimizes pest infestations. 
b.  Rodent and insect control programs that are designed to reduce existing pest populations and prevent further establishment of new pests. 

Premises is "minimize", but vermin population is "reduce".  There is a difference between "reduce" and "minimize".

One person with a fly swatter applied for 5 minutes, will "reduce".  Is that what was intended?


A few bright spots, but many holes, superficial, conflicting, ambiguity, subjective, misleading, non-actionable, puzzling, and non-informative.

Canada can do better.

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