NOTICE OF INTENT

Department of Agriculture and Forestry

Office of Animal Health and Food Safety

Turtles (LAC 7:XXI.Chapter 19)

In accordance with the Administrative Procedure Act, R.S. 49:950, et seq., notice is hereby given that the Department of Agriculture and Forestry (Department) intends to amend LAC 7:XXI.Chapter 19 relative to turtles in Louisiana. The proposed rule change codifies Act 69 of the 2017 Regular Legislative Session related to turtle farming to include deleting certain requirements for the export of turtles, updating the requirements for licensure as a certified turtle farmer, updating the requirements for turtle farms, and updating the language on inspections. Furthermore, the proposed rule change removes certain turtle egg treatment methods that are obsolete, eliminates certain food and water inspection requirements, repeals a prohibition on the sale of eggs originating outside of Louisiana, and makes additional technical and clarifying changes.

Title 7

AGRICULTURE AND ANIMALS

Part XXI. Animals and Animal Health

Chapter 19. Turtles

  1. In addition to the definitions listed below, the definitions in R.S. 3:2358.3 shall apply to these regulations.

Agent an authorized representative of the Department of Agriculture and Forestry.

Certified Laboratory a laboratory which has a current certification or accreditation by the Federal Food and Drug Administration or other national certifying or accrediting agency to perform microbiological or residue testing of organic or inorganic samples and has a microbiologist on staff, and has been approved by the Department of Agriculture and Forestry.

Certified Turtle Farmer a Louisiana individual, partnership, corporation or entity engaged in the breeding, hatching, propagating, raising, growing, receiving, shipping, transporting, exporting, distribution or sale of farm raised turtles and which have been licensed by the Department of Agriculture and Forestry.

Chain of Custody Form a document approved by the department which verifies species, destination, origin, and turtle lot and which is used for transporting turtles within the state of Louisiana only.

Department the Department of Agriculture and Forestry.

Exporter a person who is licensed by the U.S. Fish and Wildlife Service to engage in the business of exporting groups of turtles or groups of turtle eggs.

Farm-Raised Turtle any reptile of the order Testudines which is bred, born, raised, or kept, by a licensed turtle farmer within a closed circumscribed pond for the purpose of buying, selling, or trading in commerce.

Farmer-Exporter a certified turtle farmer that is also licensed by the U.S. Fish and Wildlife Service to engage in the business of exporting groups of turtles or groups of turtle eggs.

Health Certificate a document which certifies that the turtles or turtle eggs are free of visible signs of infectious, contagious or communicable disease, and which is signed by a veterinarian who is licensed in this state, federally accredited and approved by the Department of Agriculture and Forestry.

Licensed Turtle Farmer a person engaged in the collection, hatching, sale or distribution of farm raised turtles or turtle eggs.

Person any individual, partnership, association, organization, or corporation engaged in any phase of the farm raised turtle industry.

Quarantined Area any area or premises which has been designated as quarantined by the department due to a finding of contamination with Salmonella spp., or other bacteria harmful to other turtles or humans by a Louisiana licensed, accredited veterinarian or agent of the department.

Turtle Farm any area of land or water used to breed, raise or keep farm-raised turtles.

Turtle Lot any amount of turtles or eggs up to 20,000 in number, and may be used interchangeably with the term turtle group.

* * *

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2.

HISTORICAL NOTE: Promulgated by the Department of Agriculture, Office of Animal Health Services, LR 12:224 (April 1986), amended by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:350 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1567 (August 2000), amended by the Department of Agriculture and Forestry, Livestock Sanitary Board, LR 31:2210 (September 2005), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:978 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. Each facility which houses farm-raised turtles or turtle eggs for the purpose of buying, selling, or trading in commerce shall contain the following: turtle pond(s), turtle laying area, egg washing area, treatment areas, hatching area, holding or post-hatching area, and inventory storage.
  2. Each facility shall possess hot and cold water, hand washing facilities, cooling and ventilation capability, be free of rodents and pests, be properly disinfected, utilize stainless steel or non-porous tables, buckets and baskets, and have access to restroom facilities.
  3. The facility shall be free of debris, trash and offensive odors.
  4. Egg Washing and Treatment Areas of the Facility
  5. All egg washing and treatment areas shall be lighted and ventilated.
  6. All floors in the egg washing and treatment areas shall consist of concrete or non-porous covering with drainage sufficient to prevent the accumulation of water.
  7. All surfaces in the egg washing and treatment areas which come in contact with turtles or turtle eggs shall be non-porous.
  8. Hatching, Holding, and Post-Hatching Area of the Facility
  9. The hatching, holding, post-hatching area shall be a separate identifiable room in which the temperature can be maintained and controlled.
  10. The hatching, holding, post-hatching area shall be large enough to accommodate all designated groups of turtles that have not been sold.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1567 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:979 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. All persons, licensed turtle farmers, turtle farms, farmer-exporters, exporters, and certified turtle farmersare subject to inspection by agents of the Louisiana Department of Agriculture and Forestry to insure compliance with this Chapter.
  2. Inspections may include but are not limited to the following actions.
  3. An agent may inspect the premises of persons, turtle farms, farmer-exporters, exporters, and certified turtle farmers to insure that no turtles or eggs belonging to different groups are commingled without first receiving the documentation required by La. R.S. 3:2358.7 and Section1919 of this Chapter.
  4. An agent may inspect the premises of persons, turtle farms, farmer-exporters, exporters, and certified turtle farmersto insure that each turtle lot is clearly identified and is not improperly commingled with saleable or hatchable eggs of other turtle lots.
  5. An agent may inspect the records of persons, turtle farms, farmer-exporters, exporters, and certified turtle farmers to verify that all documentation required by La. R.S. 3:2358.7 and Section1919 of this Chapter is current.
  6. An agent may take samples of water from ponds, turtles, and turtle eggs which shall be transmitted to a certified laboratory for chemical and microbiological analysis, including, but not limited to pH, antibiotic and pesticide contaminants, and potentially pathogenic bacteria.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2.

HISTORICAL NOTE: Promulgated by the Department of Agriculture, Office of Animal Health Services, LR 12:224 (April 1986), amended by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:350 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1568 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:979 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

Repealed.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2, 3:2358.9, 3:2358.10 and 3:2358.12.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:351 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1568 (August 2000), amended by the Department of Agriculture and Forestry, Livestock Sanitary Board, LR 31:2210 (September 2005), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:980 (May 2014), repealed by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. No person may import turtles or turtle eggs of any species from any other state or foreign country unless they are a certified turtle farmer.
  2. Viable turtle eggs and live turtles with a carapace length of less than four inches shall not be sold or offered for any other type of commercial or public distribution within the state of Louisiana.
  3. Exceptions:
  4. the sale, holding for sale, and distribution of viable turtle eggs and live turtles with a carapace length of less than four inches for bona fide scientific, educational, or exhibitional purposes, other than use as pets;
  5. the sale and distribution of viable turtle eggs and live turtles with a carapace length of less than four inches to a certified turtle farmer.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2 and 3:2358.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:351 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1569 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:980 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. All lots of turtles or turtle eggs produced by persons in Louisiana shall be assigned a lot number on a department-approved form.
  2. No turtle lot shall exceed 20,000 viable hatchlings or eggs.
  3. All farm-raised turtle eggs shall originate from certified turtle farmers. They shall be identifiable by lot number.
  4. All farm-raised turtles, including but not limited to turtles raised to replenish pond stock and turtles raised to a four- inch carapace length for the pet trade, shall be placed in a designated lot and remain a component of the same lot until they are sold, destroyed or removed from the facility‘;s premises

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2 and 3:2358.7.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:351 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1569 (August
2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:981 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. Samples of turtles or turtle eggs may be subjected to microbiological examination using approved procedures and techniques based upon procedures used by the certified laboratory.
  2. Turtle lots identified as testing positive for Salmonella spp.or any other microorganisms pathogenic to humans, domestic animals or aquatic species shall be reported to the Office of the State Veterinarian and the lot number verified by the Department.
  3. If any turtle or turtle lot tests positive forSalmonella spp., then the person may request a retest. Samples of the retest must be submitted when requested by agents of the department. The person may request a retest of the lot as a wholeusing the same sampling procedures as used for the original test or the person may subdivide the affected positive lot into a maximum of four equal subgroups. Each such subgroup shall be separately identified, simultaneously randomly sampled and tested. The Louisiana Veterinary Medical Diagnostic Laboratory shall conduct the retesting, whether from the lot as a whole or from any of the subgroups. The Louisiana Animal Disease Diagnostic Laboratory test results, shall be the final and conclusive test results.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:351 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1570 (August 2000), LR 30:1445 (July 2004), amended by the Department of Agriculture and Forestry, Livestock Sanitary Board, LR 31:2210 (September 2005), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:981 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

Repealed.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2, 3:2358.9 and 3:2358.10.

HISTORICAL NOTE: Promulgated by the Department of Agriculture, Office of Animal Health Services, LR 17:352 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1570 (August 2000), amended by the Department of Agriculture and Forestry, Livestock Sanitary Board, LR 31:2211 (September 2005), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:981 (May 2014), repealed by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. Upon testing positive for or other pathogenic bacteria, eggs and turtles shall be subject to quarantine, inventory and verification by agents of the department.
  2. Quarantined turtles and eggs shall be sealed under supervision of agents of the department to prevent the spread of pathogenic bacteria until the person receives notice of either:
  3. the lifting of the quarantine; or
  4. instructions dealing with the disposal of the quarantined turtle or egg lot.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2,

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:352 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1570 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:981 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. All farm-raised turtles imported into this state shall be accompanied by a health certificate and meet the specific requirements of LAC 7:XXI.501.
  2. Any person engaged in the breeding, hatching, propagating, raising, growing, receiving, shipping, transporting, exporting, or sale of farm raise turtles shall maintain the following applicable documentation:
  3. Turtle Group Distribution Document (AHS-24-99);
  4. Daily Record Keeping for Turtles and Eggs (AHS-67-01);
  5. department-issued license;
  6. facility inspection reports;
  7. laboratory results and reports;
  8. S. Fish and Wildlife Service Form 3-177 (for exporters only);
  9. health certificates; b
  10. chain of custody form.
  11. All records shall be maintained for a period of three years.
  12. Falsification or misrepresentation of turtle groups or lots for sampling, testing or retesting is prohibited.
  13. Alteration or falsification of records of turtle groups or lots and providing records for alteration or falsification of turtle groups or lots is prohibited.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2 and 3:2358.7.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:352 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1570 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:982 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. No person shall breed, hatch, propagate, raise, grow, receive, ship, transport, export, or sell turtles or turtle eggs without possessing a turtle farmer license.
  2. Each person applying for a turtle farmer license shall annually complete an application as provided by the department accompanied by an application fee of $250. The application shall include the following information:
  3. name of applicant;
  4. date of application;
  5. address of applicant;
  6. telephone number of applicant;
  7. whether the applicant is an individual, corporation, subchapter "S" corporation, cooperative or partnership;
  8. principal officers of the applicant, if any;
  9. location of applicant's principal office and farming premises;
  10. location of all offices operated by applicant, along with the name of the manager and phone number of each;
  11. the dates upon which the applicant begins and ends its fiscal year;
  12. a map or schematic showing the location of ponds or other breeding habitats, storage, treatment and incubation buildings and facilities shall be included with all applications for a turtle farmer license. Each pond or breeding habitat shall be designated by a letter, beginning with "A", and shall be designated in sequential order and properly labeled on the map or schematic.
  13. Prior to the issuance of an initial turtle farmer license, an inspection of the turtle farm facilities shall be made by an agent of the Department to insure compliance with this Chapter.
  14. Upon issuance of an initial license by the department, certified turtle farmers shall be assigned a permanent licensed farmer identification code for use on all documents related to turtle farming.
  15. In the case of the transfer of ownership of the person or entity that is the certified turtle farmer that person must reapply with the department for licensing as a certified turtle farmer and must meet all of the qualifications required for the issuance of an initial license.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2 and 3:2358.4.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:352 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1571 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:982 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

Repealed.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2, 3:2358.9 and 3:2358.10.

HISTORICAL NOTE: Promulgated by the Department of Agriculture, Office of Animal Health Services, LR 17:353 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1571 (August 2000), amended by the Department of Agriculture and Forestry, Livestock Sanitary Board, LR 31:2211 (September 2005), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:983 (May 2014), repealed by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. Agents of the department are authorized and shall be allowed entry onto any property or premises in the state of Louisiana for the purpose of carrying out the provisions of these regulations. Whenever reasonably possible, agents shall notify the person before performing any inspections.
  2. Agents of the department are authorized to inspect all records and premises in order to enforce the provisions of R.S. 3:2358.1 et seq., and these regulations.
  3. ...

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:353 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1571 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:983 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

Repealed.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2.

HISTORICAL NOTE: Promulgated by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:353 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1571 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:983 (May 2014), repealed by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

  1. A penalty of not more than $1000 may be assessed for any violation of this Chapter, by a ruling of the commissioner based on an adjudicatory hearing held in accordance with the Administrative Procedure Act. Each day on which a violation occurs shall be considered a separate offence.
  2. The commissioner may deny renewal or revoke the license of a certified turtle farmer for any violation of the provisions of R.S. 3:2358.1 et seq.or for any violation of this Chapter after an adjudicatory hearing held in accordance with the Administrative Procedure Act.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2 and 3:2358.14.

HISTORICAL NOTE: Promulgated by the Department of Agriculture, Office of Animal Health Services, LR 12:225 (April 1986), amended by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:353 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1572 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:983 (May 2014), amended by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

Repealed.

AUTHORITY NOTE: Promulgated in accordance with R.S. 3:2358.2.

HISTORICAL NOTE: Promulgated by the Department of Agriculture, Livestock Sanitary Board, LR 11:247 (March 1985), amended LR 11:615 (June 1985), amended by the Department of Agriculture and Forestry, Office of Animal Health Services, LR 17:353 (April 1991), amended by the Department of Agriculture and Forestry, Office of the Commissioner, LR 26:1572 (August 2000), repromulgated by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety and the Board of Animal Health, LR 40:984 (May 2014), repealed by the Department of Agriculture and Forestry, Office of Animal Health and Food Safety, LR 44:

Family Impact Statement

The proposed Rule does not have any known or foreseeable impact on family formation, stability, and autonomy. In particular, the proposed Rule has no known or foreseeable impact on:

  1. the stability of the family;
  2. the authority and rights of persons regarding the education and supervision of their children;
  3. the functioning of the family;
  4. family earnings and family budget;
  5. the behavior and personal responsibility of children;
  6. the ability of the family or a local government to perform the function as contained in the proposed Rule.

Poverty Impact Statement

The proposed Rule does not have any known or foreseeable impact on any child, individual or family as defined by R.S. 49:973(B). In particular, there should be no known or foreseeable effect on:

  1. the effect on household income, assets, and financial security;
  2. the effect on early childhood development and preschool through postsecondary education development;
  3. the effect on employment and workforce development;
  4. the effect on taxes and tax credits;
  5. the effect on child and dependent care, housing, health care, nutrition, transportation, and utilities assistance.

Small Business Analysis

The proposed Rule will have no adverse impact on small businesses as defined in the Regulatory Flexibility Act.

Provider Impact Statement

The proposed Rule does not have any known or foreseeable impact on providers as defined by HCR 170 of the 2014 Regular Legislative Session. In particular, there should be no known or foreseeable effect on:

  1. the effect on the staffing level requirements or qualifications required to provide the same level of service;
  2. the total direct and indirect effect on the cost to the providers to provide the same level of service; or
  3. the overall effect on the ability of the provider to provide the same level of service.

Public Comments

Interested persons may submit written comments via the U.S. mail or hand delivery to John Walther, Assistant Commissioner of Animal Health and Food Safety, Department of Agriculture & Forestry, 5825 Florida Blvd., Suite 4001, Baton Rouge, LA 70806. Public comments must be received no later than 4 p.m. on October 10, 2018. No preamble is available.

Mike Strain, DVM

Commissioner

FISCAL AND ECONOMIC IMPACT STATEMENT FOR ADMINISTRATIVE RULES

RULE TITLE: Turtles

  1. ESTIMATED IMPLEMENTATION COSTS (SAVINGS) TO STATE OR LOCAL GOVERNMENT UNITS (Summary)

The proposed rule change will not result in any costs or savings to state or local governmental units. The proposed rule change codifies Act 69 of the 2017 Regular Legislative Session related to turtle farming to include deleting certain requirements for the export of turtles, updating the requirements for licensure as a certified turtle farmer, updating the requirements for turtle farms, and updating the language on inspections. Furthermore, the proposed rule change removes certain turtle egg treatment methods that are obsolete, eliminates certain food and water inspection requirements, repeals a prohibition on the sale of eggs originating outside of Louisiana, and makes additional technical and clarifying changes.

  1. ESTIMATED EFFECT ON REVENUE COLLECTIONS OF STATE OR LOCAL GOVERNMENTAL UNITS (Summary)

The proposed rule change will have no effect on revenue collections of state or local governmental units.

III. ESTIMATED COSTS AND/OR ECONOMIC BENEFITS TO DIRECTLY AFFECTED PERSONS OR NONGOVERNMENTAL GROUPS (Summary)

The proposed rule change will result in decreased costs for licensed turtle famers by eliminating the requirement of egg immersion and removing certain inspection, health certification, and testing requirements.

  1. ESTIMATED EFFECT ON COMPETITION AND EMPLOYMENT (Summary)

The proposed rule change will allow Louisiana licensed turtle farmers to be more competitive in international markets. Current rules require a health certificate and certified laboratory report to accompany all international shipments, irrespective of whether the country of destination requires the same. Louisiana is the only state in the nation with these exit requirements in lieu of following the entry requirements for the country of destination. By eliminating these requirements, Louisiana turtle farmers will no longer be subject to this trade disadvantage.

Dane Morgan

Evan Brasseaux

Assistant Commissioner

Staff Director

1809#055