White House Office of Information and Regulatory Affairs Regulatory Impact Analysis Case Study: Highly Pathogenic Avian Influenza Shannon Joyce White House Office of Information and Regulatory Affairs Bogota, Colombia April 12, 2018 Any views expressed here are solely those of the presenter, and do not necessarily reflect the position of the Office of Management and Budget or the Executive Office of the President.

The Problem Statement There is the possibility of an introduction of highly pathogenic avian influenza (HPAI) into the United States.

How is this disease different? Should we approach the threat of all diseases the same way? What characteristics matter when making that determination?

Considerations for Regulating Disease Is the disease already prevalent in the U.S.? Would there be a sizeable domestic impact? What is the impact of the disease? How much does the market rely on imports? Do we know how to screen for it effectively? Ask audience what they would have asked themselves when writing the regulation

The Regulatory Solution U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) issued an interim final rule on January 24, 2011 to impose certain restrictions on birds, poultry, and bird and poultry products imported from regions where HPAI is known to exist.

The Regulatory Solution Restrictions on importing birds, poultry and bird and poultry products imported from regions where HPAI is known to exist. Restrictions on imports of live poultry and birds that have been vaccinated for avian influenza. Restrictions on imports of live poultry and birds that have been moved through regions affected by avian influenza.

Benefits U.S. producers of poultry and eggs U.S. consumers protection of domestic poultry flocks against the introduction of avian flu from imported poultry, poultry products, and birds. U.S. consumers A steady supply of poultry and poultry products on the market reduces the likelihood of disease-related price impacts for consumers. because of domestic production and trade volumes –

Costs Compliance costs for importers of poultry and poultry products from affected regions for which there are not existing import restrictions. The cost will be borne by foreign firms exporting poultry and poultry products into the U.S. who are required to obtain a certificate signed by a salaried veterinarian of that region’s national government, specifying that the articles were cooked to a minimum internal temperature of 74 degrees Farenheit prior to shipment to U.S. Since domestic production of poultry and poultry products is high, costs associated with the rule will be small.

Costs While difficult to quantify due to limited data on the market, there is also an inefficiency being introduced to the market. Since quantity supplied is restricted (foreign markets which could compete domestically in the status quo are no longer able to), there is a deadweight loss and a reduction in total economic surplus.

Net Benefits ?

Alternatives Alternative 1: notifying changes in disease status Maintain this list on the ministry website (update real-time) or in the legal code (updated annually) to provide more timely notice of a change in a region’s disease status. Alternative 2: Cooking temperatures One minimum cooking temperature requirement versus two separate cooking temperatures (for HPAI and END diseases) for cooked poultry carcasses or parts or products of carcasses imported into the United States.

Other Alternatives? What does ‘known to exist’ mean? One case? Two? Five hundred? Does the number of meaningful cases change by the size of the country? What does ‘region’ mean? Accept some animals into quarantine Vaccinate domestically to open the market