September 30, 2025

By Laura A. Agyekumhene

I. Introduction

Influenza pandemics, by nature unpredictable and periodic, pose significant threats to human health and global economic stability. ^[1]  Since January 2022, over 160 million birds across all 50 states in the U.S. have tested positive for avian influenza. ^[2]  By 2025, more than 30 million egg-laying hens were culled, with Ohio alone accounting for 13.5 million of these losses.^[3] These disruptions have contributed to soaring egg prices, with wholesale prices reaching record highs. ^[4] Alarmingly, 70 individuals in the U.S. contracted avian influenza, predominantly farmworkers exposed to infected poultry, with one fatality reported.^[5]  While no evidence of person-to-person transmission has been found, the unpredictability of such pandemics and the heightened risks to farmworkers have raised concerns about occupational exposure. ^[6] Given these risks, swift containment and eradication of avian influenza outbreaks are essential not only to protect poultry populations but also to safeguard worker health, prevent human infections, and stabilize the broader agricultural economy.

This paper examines the economic and health implications of avian influenza on agricultural workers, assesses federal and state policy responses, and proposes targeted policy measures to enhance preparedness and protect workers. Section II provides an overview of avian influenza, including its various strains and transmission pathways, with an emphasis on the increased vulnerability of labor populations, particularly those in agriculture, and the heightened health risks they face. Section III analyzes federal interventions, focusing on the roles of agencies like the USDA, CDC, and OSHA in safeguarding worker health, managing outbreaks, and minimizing disruption in agricultural production. Section IV reviews state-level responses, identifying best practices in regions like California, where statewide regulations have proven effective, and highlighting disparity in enforcement and resources, particularly in rural and underfunded areas. Section V draws on lessons from past zoonotic outbreaks, proposing comprehensive reforms that not only promote coordinated and equitable protection for essential workers but also enhance policy enforcement, ensuring that future outbreaks are met with robust and proactive solutions.

II. The Resurgence of H5N1 in the United States.

The resurgence of highly pathogenic avian influenza (HPAI) in the United States posed significant public health risks, particularly to those in close contact with infected animals.^[7]  In 2009, advances in the development of antivirals and experiences with H5N1 infections in poultry and humans,^[8]  contributed to a growing understanding of influenza pandemics. The emergence of the swine influenza virus that same year provided further insights into the behavior and spread of pandemic influenza strains, ^[9] which helped shape the requirements for pandemic preparedness and response. ^[10]

H5N1 is a highly contagious disease in birds caused by influenza A viruses. ^[11]  These viruses are primarily found in specific species of waterfowl and shorebirds. ^[12] Low pathogenic avian influenza (LPAI) and highly pathogenic avian influenza (HPAI)spread among poultry and wild birds.^[13] LPAI causes mild respiratory symptoms, while HPAI A poses a significant zoonotic threat to birds, dairy cattle, and humans globally.^[14]

In 2015, the  HPAI  H5N1 was first detected in a sample collected from wild migratory birds in the United States.^[15] The virus later reemerged in agricultural poultry stocks across the U.S. in 2022, leading to widespread outbreaks.^[16]  On February 8, 2022, the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (USDA APHIS) Veterinary Services confirmed the presence of H5N1 in a commercial poultry flock in Dubois County, Indiana. ^[17] By February 24, the virus had spread to commercial poultry operations and backyard flocks across seven states: Indiana, Kentucky, Virginia, New York, Maine, Delaware, and Michigan.^[18] The first confirmed human case of H5N1 linked to the 2022 outbreak was reported in 2023, involving direct exposure to infected poultry.^[19]

Following the detection of HPAI H5N1 in 2022, the USDA APHIS initiated the preparation of a draft Environmental Assessment and a draft Finding of No Significant Impact (FONSI), pursuant to the National Environmental Policy Act (NEPA).^[20] The Environmental Assessment, issued in April 2022, evaluated the potential environmental impacts of USDA’s proposed emergency response activities, including depopulation of infected flocks, disposal of carcasses, cleaning and disinfection of premises, and implementation of quarantine measures.^[21] These documents provided the legal foundation for Veterinary Services to implement coordinated emergency actions across the seven states.^[22] The final Environmental Assessment, titled Emergency Response for HPAI Outbreaks in Seven States, together with the final FONSI, was published in September 2022.[23] Despite these measures, HPAI outbreaks continued to affect commercial poultry, backyard flocks,  and dairy cattle throughout the United States.

(a) Occupational Health Risks and Economic Consequences

Workers in the poultry industry face elevated risks of H5N1 infection due to frequent exposure to contaminated birds, surfaces, and environments. ^[24]  Infected birds shed the virus through their saliva, mucus, and feces, creating multiple pathways for human infection,^[25]  primarily through inhalation of aerosolized particles or contact with contaminated surfaces.^[26]  Those most at risk include individuals employed across various sectors of poultry production, such as poultry farmers and their staff, service technicians at poultry-processing plants, caretakers at poultry facilities, workers in layer barns and live bird markets, employees handling chicks at egg production sites, personnel engaged in disease control and eradication efforts, and individuals involved in the bird-fighting industry. ^[27]

Symptoms of HPAI H5N1 in humans can range from mild, such as eye redness or a mild cough, to severe, including pneumonia requiring hospitalization. ^[28]  Common symptoms include fever, sore throat, nasal congestion, muscle aches, and shortness of breath, while less common manifestations may involve diarrhea, nausea, or even seizures. ^[29] While globally, H5N1 carries a high case fatality rate,^[30] the number of deaths in the United States remain low; as of 2025, fewer than 10 confirmed human cases have resulted in death.^[31]

Beyond the health hazards, HPAI outbreaks have caused economic hardship for farmworkers.^[32] The quarantine measures, the culling of diseased birds, and the closure of poultry farms all result in job losses and shortened working hours, leaving many people without  consistent income.^[33] While some workers may be eligible for compensation through federal or state programs, there are notable gaps in these procedures, particularly for workers in control zones (designated areas surrounding infected premises where movement is restricted to contain disease spread) who do not have contaminated flocks but suffer financial losses. ^[34]

The economic burden of the H5N1 outbreak extends beyond individual workers, by affecting entire agricultural operations and contributing to rising food prices and supply chain instability. ^[35]  In the poultry sector, culling over 150 million chickens to contain the virus has reduced the egg supply by 7–10%, driving retail prices as high as $9 per dozen and causing intermittent shortages in grocery stores.^[36] Smaller operations, such as Kakadoodle Farm in Illinois, illustrate the human and financial toll: the farm lost 3,000 pasture-raised hens and over $100,000 in projected revenue.^[37] In the dairy industry, H5N1 has been detected in cattle herds across at least nine states.^[38] This results in short-term milk production declines of 10–20% and higher operational costs related to testing, movement restrictions, and biosecurity upgrades.^[39] Although dairy cows are not culled, the economic impact remains considerable, particularly given the industry’s already thin profit margins. These disruptions contribute to inflationary pressure on food prices and expose structural vulnerabilities in the U.S. food system.^[40]

III. Federal Policy Responses to Avian Influenza

(a) USDA’S APHIS And Veterinary Service

Federal policies have played a critical role in mitigating the impacts of H5N1 on public health, worker safety, and animal welfare. The USDA, through its APHIS and Veterinary Services, is responsible for protecting the health, quality, and marketability of U.S. animals and animal products by preventing, controlling, and eliminating infectious diseases.^[41]  In response to the H5N1 threat, APHIS conducts virus surveillance among commercial and backyard poultry, wild birds, and dairy cattle, and performs confirmatory testing for  HPAI H5N1 in domestic and wild animal populations.^[42] APHIS has measures to prevent the interstate transmission of H5N1 and other livestock diseases.^[43]

APHIS has developed a robust emergency response strategy to combat avian influenza.^[44] This response includes surveillance by Wildlife Services in wild bird populations and Veterinary Services in domestic flocks through the National Poultry Improvement Plan (NPIP).^[45] Guided by the HPAI Preparedness and Response Plan, APHIS coordinates rapid actions like depopulation, disinfection, and quarantine.^[46] To minimize environmental impact, it conducts assessments under NEPA and ensures proper carcass disposal.^[47] As outbreaks expanded, APHIS  has scaled its operations to a nationwide level, offering technical aid, indemnity payments, and federal response teams in close collaboration with state and tribal partners, demonstrating the magnitude of the effort.^[48]

Beyond immediate containment and surveillance efforts, the USDA has invested heavily in long-term strategies to prevent and mitigate the ongoing spread of HPAI H5N1. ^[49]  The agency announced a $100 million research initiative focused on developing vaccines, enhancing biosecurity protocols, and strengthening disease preparedness.^[50] As part of this effort, biosecurity assessments have been conducted at over 130 commercial poultry facilities, with particular attention to the most at-risk egg-laying farms. ^[51]

In parallel, the USDA has increased compensation rates for affected poultry farmers and provided financial support for implementing biosecurity improvements.^[52] Notably, these measures have contributed to a nearly 50% reduction in egg prices, offering some relief to both producers and consumers. The research initiative is being carried out in collaboration with agencies such as the CDC and FDA.^[53]

(b) Center for Disease Control.

The CDC serves as the nation’s primary science-and data-driven organization dedicated to safeguarding public health.^[54] Among its functions, the CDC leads the U.S. influenza surveillance system in collaboration with state, local, and territorial health departments.^[55] This system has played a vital role in monitoring infectious diseases such as HPAI. By collecting data from public health laboratories, healthcare providers, and other sources, the surveillance network tracks influenza activity, identifies circulating viruses, detects changes in viral strains, and assesses the disease’s impact on illness, hospitalizations, and deaths.^[56]

The CDC has expanded its surveillance systems to monitor individuals exposed to infected poultry, dairy cattle, and other animal species, while also providing diagnostic and laboratory support to state and local health departments through its Influenza Division.^[57] In addition, the agency is leveraging its National Syndromic Surveillance Program to track flu-like illnesses and is conducting serology studies in states such as Colorado and Michigan to evaluate exposure levels among farmworkers.^[58] These findings directly inform federal and state responses, guiding public health interventions such as quarantine measures and vaccine distribution efforts.

CDC has also joined forces with the USDA, FDA, the Administration for Strategic Preparedness and Response, state public health and animal health officials, and other partners to implement the One Health approach. ^[59]  This collaborative strategy is gaining widespread recognition both in the United States and internationally, particularly for its effectiveness in addressing zoonotic diseases. ^[60]  Through One Health, the CDC brings together experts from a range of fields—including human and animal health, environmental science, law enforcement, policymaking, agriculture, and community organizations—to monitor, control, and better understand how diseases spread among people, animals, plants, and the environment. ^[61] For example, specialists from the One Health Office organize Zoonotic Disease Prioritization Workshops to help countries allocate limited resources toward the most pressing zoonotic threats, such as HPAI H5N1, which poses a significant national concern. ^[62]

(c) The Occupational Safety and Health Administration

The Occupational Safety and Health Administration (OSHA), a federal agency within the U.S. Department of Labor established under the Occupational Safety and Health Act of 1970, plays a critical role in safeguarding workers from occupational exposure to HPAI H5N1. ^[63] OSHA fulfills its mission of safe and healthy working conditions by setting workplace standards and providing training, outreach, education, and assistance. ^[64] In response to the risks posed by HPAI H5N1, OSHA requires employers to conduct hazard analyses to identify workers at risk and implement appropriate control measures, including engineering controls, administrative practices, safe work procedures, and the use of personal protective equipment (PPE). ^[65]  Specific PPE requirements include gloves, protective clothing, goggles, and respirators to minimize exposure to the virus. ^[66]  Workers must also be trained to use PPE correctly, understand associated risks, and maintain hygiene practices such as regular handwashing and sanitization. Additionally, OSHA emphasizes the importance of protecting workers from heat stress associated with PPE use and ensuring the proper cleaning and disinfection of potentially contaminated areas to prevent further spread of the virus. ^[67]

IV. State and Local Responses to Avian Influenza Outbreaks

While federal agencies provide infrastructure and guidance, state-level policies vary widely in rigor and scope.

California remains the most proactive state, having implemented Title 8, Section 5199.1 of the California Code of Regulations to protect workers from aerosol-transmissible zoonotic diseases.^[68] Through California and OSHA, the state has implemented measures requiring employers in high-risk sectors such as poultry farms, slaughterhouses, and diagnostic laboratories to provide N95 respirators, gloves, full-body protective gear, and eye protection.^[69] These measures are further supported by mandatory sanitation protocols written safe work procedures, and medical monitoring for employees handling infected animals or working in quarantine zones. ^[70] The state also promotes workers’ rights through anti-retaliation laws, paid sick leave mandates, and workers’ compensation benefits for those who contract avian flu on the job. California’s approach exemplifies a public health and labor response that integrates occupational safety with disease containment. ^[71]

In New York, Governor Kathy Hochul has implemented movement restrictions and enforced live bird market closures to prevent further transmission of the virus.^[72] Meanwhile, Michigan has rolled out a Highly Pathogenic Avian Influenza Dairy Surveillance Program to monitor milk samples for the H5N1 virus, with farmers receiving guidance on enhanced biosecurity practices. These state initiatives work in tandem with federal efforts, ensuring targeted protection for farmers and promoting swift containment of outbreaks. ^[73]

Delaware and Maryland have established a joint command structure to coordinate containment efforts, including the culling of infected birds, the enhancement of worker safety protocols, and the implementation of rigorous environmental sampling. This collaborative regional approach was particularly significant given the role of the Delmarva Peninsula as a major poultry-producing area for the eastern United States. ^[74] By working across state lines, Delaware and Maryland demonstrated the importance of rapid, unified action in high-risk agricultural zones to contain avian influenza outbreaks and safeguard both public health and the economy.^[75]

Local agencies, like the Philadelphia Department of Public Health, are actively monitoring bird flu, coordinating with state and local health and animal health agencies to track human cases and contain the spread. The Philadelphia Department of Public Health engages in community outreach and distributes public resources to ensure affected populations are well-informed.^[76]

Similarly, Georgia whose poultry industry is valued at approximately $6.9 billion, highlights the high economic stakes involved.^[77] Following confirmed cases in Elbert County on January 17 and January 22, 2025, the Georgia Department of Agriculture instituted a statewide ban on poultry exhibitions, shows, swaps, meets, and sales, underscoring both the threat to commercial operations and the disruption of important cultural and economic activities.

While federal and state actors have shown urgency, the overall patchwork of occupational protections and biosecurity standards remains insufficient. California’s enforceable framework offers a scalable model for integrating public health and labor safety, but replication across states has been inconsistent. To address these disparities, the federal government should pursue a cohesive, nationally integrated strategy that includes a binding occupational health standard for zoonotic disease exposure, targeted compensation policies for affected workers, and robust coordination across CDC, USDA, OSHA, and state-level agencies. Such reforms would strengthen pandemic preparedness, reduce systemic inequities, and ensure that future outbreaks do not endanger the nation’s most vulnerable agricultural workers disproportionately.

V. Lessons from Previous Outbreaks and Policy Reform Strategies

Past public health crises, particularly the COVID-19 pandemic, have exposed significant systemic weaknesses in worker protection, emergency coordination, and economic resilience. These experiences provide essential lessons for designing more robust and adaptable response strategies to zoonotic threats like H5N1.

Strengthen Health and Safety Protocols

Occupational safety policies must move beyond voluntary guidance to protect workers in high-risk sectors such as the poultry industry. Outside California, currently the only state with a binding standard for zoonotic aerosol transmissible diseases, most protections are discretionary, leading to inconsistent implementation and avoidable risk. A mandatory federal standard is urgently needed for uniform safeguards, including access to PPE, routine health surveillance, strict sanitation protocols, and comprehensive biosecurity training. One immediate path forward is for OSHA to issue a temporary emergency standard under Section 6(c) of the Occupational Safety and Health Act, which permits rulemaking without notice and comment in cases of “grave danger.” Given the demonstrated threat of HPAI H5N1 in agricultural workplaces, such an action would create enforceable protection while long-term regulatory processes advance.

Expand Compensation and Support Systems

Federal compensation programs must be broadened to support all workers economically affected by avian influenza control measures, including those in designated control zones whose poultry flocks are not directly infected. The Healthy Poultry Assistance and Indemnification Act (HPAI Act), introduced in 2025, proposes financial compensation for producers who suffer losses due to depopulation orders.^[78] Still, it does not yet include direct support for displaced workers. The bill has not been enacted; even if passed, it would still fall short of providing comprehensive relief. Workers in control zones may lose income due to suspended operations, movement restrictions, or employer cutbacks during quarantine periods—even if their specific flock remains healthy. A truly equitable policy must recognize that these workers bear economic risks imposed by disease control protocols and should receive income protection, paid quarantine leave, and access to emergency relief funds. Expanding the scope of compensation to include these at-risk workers would promote fairness, improve compliance with biosecurity measures, and reduce pressure on producers to resume operations prematurely.

Improve Coordination Between Federal, State, and Local Authorities:

While federal agencies such as the CDC and USDA have provided surveillance and policy guidance, implementing containment and communication strategies during the H5N1 outbreak has varied widely across states, exposing critical gaps in coordination.^[79] For example, in Illinois, internal emails revealed confusion between public health and agriculture departments over which agency should report H5N1 cases in dairy cattle, resulting in delayed public communication.^[80] In Michigan, conflicting approaches between health and agriculture officials led to inconsistent messaging regarding a second outbreak.^[81] At the same time, Wisconsin’s response was initially hindered by a lack of Spanish-language communication despite the state’s predominantly Hispanic dairy workforce.^[82] These incidents illustrate that while interagency collaboration exists in principle, fragmented communication protocols, unclear jurisdictional responsibilities, and insufficient localized planning still undermine the effectiveness of the national response. Strengthening coordination frameworks—not just encouraging collaboration—will be essential to ensure timely, equitable, and consistent worker protection during future zoonotic disease outbreaks.

These proposed strategies must be proactive, equity-centered, and responsive to the complex interplay between animal health, worker safety, and public health security. By institutionalizing these reforms, the U.S. can move beyond reactive containment toward a more resilient and just public health infrastructure.

[1] Pandemic Influenza Risk Management: A WHO Guide to Inform & Harmonize National & International Pandemic Preparedness and Response, World Health Org. (2017).

[2] Risk to People in the United States from Highly Pathogenic Avian Influenza A(H5N1) Viruses, CDC: CFA: Qualitative Assessments (Feb. 28, 2025).

[3] Egg Markets Overview, USDA (Sept. 26, 2025).

[4] Id.

[5] CDC A(H5N1) Bird Flu Response Update, CDC: Avian Influenza (Bird Flu) (March. 19, 2025).

[6] Id.

[7] Emergency Response for Highly Pathogenic Avian Influenza Outbreaks in the United States Migratory Bird Flyways: Final Supplemental Environmental Assessment, USDA: Animal & Plant Health Inspection Serv. (June 2024).

[8] S.Y. Lee, et al., The Avian Flu (H5N1): One Year On, 8 Public Health Epidemiology Bull. 1, 7 (1999).

[9] Pandemic Influenza Risk Management: A WHO Guide to Inform & Harmonize National & International Pandemic Preparedness and Response, World Health Org. (2017).

[10] Id.

[11] Avian Influenza in Birds: Causes and How It Spreads, CDC: CDC Archive (Mar. 27, 2024).

[12] Kathleen L. MacMahon,et al., Protecting Poultry Workers from Exposure to Avian Influenza Viruses, 123 Pub. Health Rep. 316 (May–June 2008).

[13] Avian Influenza in Birds: Causes and How It Spreads, CDC: CDC Archive (Mar. 27, 2024).

[14] Id.

[15] 2010-2019 Highlights in the History of Avian Influenza (Bird Flu) Timeline, CDC: Avian Influenza (Bird Flu) (Apr. 30, 2024).

[16] Emergency Response for Highly Pathogenic Avian Influenza Outbreaks in the United States Migratory Bird Flyways: Final Supplemental Environmental Assessment, USDA: Animal & Plant Health Inspection Serv. (June 2024).

[17] Id.

[18] Id.

[19] Gayle Mendoza, The Current State of Bird Flu: What You Need to Know, City of Phila.: The latest news + events (Feb. 21, 2025).

[20] Emergency Response for Highly Pathogenic Avian Influenza Outbreaks in the United States Migratory Bird Flyways: Final Supplemental Environmental Assessment, USDA: Animal & Plant Health Inspection Serv. (June 2024).

[21] Id.

[22] Emergency Response for Highly Pathogenic Avian Influenza Outbreaks in the United States Migratory Bird Flyways: Final Supplemental Environmental Assessment, USDA: Animal & Plant Health Inspection Serv. (June 2024).

[23] Id

[24] Bird Flu: Causes and How It Spreads, CDC: Avian Influenza (Bird Flu) (Apr. 23, 2025).

[25]Id.

[26] What Causes Bird Flu Virus Infections in Humans, CDC: CDC Archive (May 3, 2024).

[27] Information for Workers Exposed to H5N1 Bird Flu, CDC: Avian Influenza (Bird Flu) (Jan. 6, 2025).

[28] Avian Influenza, Occupational Safety and Health Admin., U.S. Dep’t of Lab. (last visited Sept. 26, 2025).

[29] Id.

[30]First H5 Bird Flu Death Reported in United States, CDC: CDC Newsroom (Jan. 6, 2025).

[31] Id.

[32] Caitlin Welsh & Zane Swanson, How Bird Flu Is Impacting Agriculture and Food Security in the United States?, Ctr for Strategic & Int’l Stud. (Apr. 17, 2024).

[33]Susanne Rust & Karen Kaplan, Killing 166 million birds hasn’t helped poultry farmers stop H5N1. Is there a better way?, L.A. Times (Feb. 26, 2025).

[34] USDA Invests Up To $1 Billion to Combat Avian Flu and Reduce Egg Prices, USDA (Feb. 26, 2025).

[35] Thomas L. Marsh, Bird Flu, U.S. Cows, and Economic Consequences, Think Glob. Health (May 14, 2024).

[36] David Danelski, Q&A: Soaring Egg Prices, U. Cal. Riverside: News (Feb. 13, 2025).

[37] Suzy Khimm, How Bird Flu Has Devastated One American Farm, NBC NEWS (Mar. 21, 2025).

[38] Marsh, supra note 35.

[39] Id.

[40] Danelski, supra note 36.

[41] Emergency Response for Highly Pathogenic Avian Influenza Outbreaks in the United States Migratory Bird Flyways: Final Supplemental Environmental Assessment, USDA: Animal & Plant Health Inspection Serv. (June 2024).

[42] HPAI Response: Surveillance of Backyard Flocks in a Control Area or Surveillance Zone, USDA: Animal and Plant Health Inspection Serv. (Jan. 14, 2025).

[43] Notice of Availability of a Final Supplemental Environmental Assessment and Finding of No Significant Impact for Emergency Response for Highly Pathogenic Avian Influenza Outbreaks in the United States Migratory Bird Flyways, 89 Fed. Reg. 103769 (Dec. 19, 2024).

[44] Highly Pathogenic Avian Influenza Response Plan: The Red Book, USDA: Animal and Plant Health Inspection Serv. (May 22, 2017).

[45] Id.

[46] Id.

[47] USDA-APHIS-Wildlife Servs., Carcass Disposal in Wildlife Damage Management, in Human Health and Ecological Risk Assessment (May 2023).

[48] Notice of Availability of a Final Supplemental Environmental Assessment and Finding of No Significant Impact for Emergency Response for Highly Pathogenic Avian Influenza Outbreaks in the United States Migratory Bird Flyways, 89 Fed. Reg. 103769 (Dec. 19, 2024).

[49] Victoria Bekiempis, US Agriculture Department Announces $100M in Funding for Bird Flu Vaccine Research, Guardian (Mar. 20, 2025).

[50] Malinda Larkin & R. Scott Nolen, USDA Announces $100M Funding Opportunity in Fight Against Avian Influenza, Am. Veterinary Med. Ass’n (Apr. 18, 2025).

[51] Id.

[52] Bekiempis, supra note 49.

[53] Id.

[54] CDC Priorities, CDC: About CDC (Sept. 17, 2025).

[55] Surveillance Resource Center, CDC: Off. of Pub. Health Data, Surveillance, and Tech. (OPHDST) (July 18, 2025).

[56] U.S. Influenza Surveillance: Purpose and Methods, CDC: FluView (Jan. 14, 2025).

[57] CDC A(H5N1) Bird Flu Response Update August 16, 2024, CDC: Avian Influenza (Bird Flu) (Aug. 16, 2024).

[58] Id.

[59] CDC A(H5N1) Bird Flu Response Update March 19, 2025, CDC: Avian Influenza (Bird Flu) (Mar. 19, 2025).

[60] Id.

[61] Id.

[62] Saving Lives By Taking a One Health Approach, CDC: One Health Office (Sept. 2021).

[63] Occupational Safety and Health Administration (OSHA), usagov (last visited Sept. 29, 2025).

[64] Avian Influenza Control and Prevention, U.S. Dep’t of Lab.: OSHA (last visited Sept. 29, 2025).

[65] Id.

[66] Id.

[67] Id.

[68] Id.

[69] What Workers Need to Know About Bird Flu, State of Cal. Dep’t of Indus. Rels. (last visited Sept. 29. 2025).

[70] Cal. Code Regs. tit. 8, § 5199.1 (2009).

[71] Id.

[72] New York State Announces Further Proactive Measures to Prevent Avian Influenza in Live Bird Markets, N.Y. State Dep’t of Agric. & Markets (Feb. 19, 2025).

[73] Jhyrah DeLapp, Michigan Takes Action: Dairy Surveillance to Observe Avian Flu Risks, Huron Daily Tribune (Feb. 19, 2025).

[74] Michaela Simoneau et al., The U. S. Needs to Step Up Its Response to Bird Flu, CSIS (Dec. 19, 2024).

[75] Id.

[76] Gayle Mendoza, The Current State of Bird Flu: What You Need to Know, City of Phila. (Feb. 21, 2025).

[77] John Drake, Bird Flu Outbreak Costs U.S. Poultry Industry $1.4 Billion, Forbes (Jan. 30, 2025). 

[78] Healthy Poultry Assistance and Indemnification Act of 2025, S. 574, 119th Cong. (2025). As of April 2025, the Healthy Poultry Assistance and Indemnification Act (HPAI Act) has been introduced but not yet enacted. Its provisions focus on compensating producers for depopulated flocks, without addressing income protection for workers in affected control zones.

[79] Michaela Simoneau et al., The U. S. Needs to Step Up Its Response to Bird Flu, CSIS (Dec. 19, 2024).

[80]John McCracken et al., Agencies in Several States Initially Struggled to Coordinate Bird Flu Response, Records Show, MO. Indep. (Oct. 30, 2024). 

[81] Id.

[82] Id.