CYRUS E. PHILLIPS, IV
ATTORNEY AT LAW
1828 L STREET, N.W., SUITE 660
WASHINGTON, D.C. 20036-5112
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VIA OVERNIGHT DELIVERY AND ELECTRONIC MAIL
July 9th, 2003
Docket Number 98-035-3
Regulatory Analysis and Development Branch
Policy and Program Development Division
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
Station 3C71, USDA Riverside
4700 River Road Unit 118
Riverdale, Maryland 20737-1238
Subject:
Docket Numbers 98-035-3, 98-035-4, Requests for Comments
Gentlemen:
I am writing on behalf of the Hawaii Orchid Growers Association. I write in response to the requests,
published in the FEDERAL REGISTER on Friday, May 9th, 2003, <Docket Number 98-035-3.pdf>, and again
on Wednesday, June 11th, 2003, <Docket Number 98-035-4.pdf>, for Comments on a proposed Rule
which will allow, without any quantity restriction, orchids of the genus Phalaenopsis to be imported
from Taiwan in approved growing media. Comments are currently due on or before Wednesday, July
9th, 2003, and these are the Comments of the Hawaii Orchid Growers Association. We are submitting
seven duplicate originals of these Comments. Each duplicate original is accompanied with conforming
electronic copies, in Microsoft® Word 2002 format (.doc), and in Adobe Acrobat format (.pdf). These
conforming electronic copies are contained on seven CD-ROMs.
Hawaii Orchid Growers Association, a non-profit service organization, has 144 members. Hawaii
Orchid Growers Association has doubled its membership in the last two years. Hawaii Orchid Growers
Association is an alliance of professional orchid growers in the state of Hawaii. <Hawaii Orchid Growers
Association.pdf>. Hawaii Orchid Growers Association was formed in 1995 to coordinate efforts among
breeders, propagators, and growers of orchids in Hawaii. Members of the Hawaii Orchid Growers Association generate more than $23,000,000 in annual sales. Growers report production expansion of 25 percent per year, and invest up to $1.5 million per acre in new greenhouses. There is a conservative estimate
of 250 growers throughout the state of Hawaii, with an average of 10 workers per farm, involving about
3,000 people in this industry. Orchids are the pacesetter in Hawaii’s sales of flower and nursery products,
last valued (in 2001) by the Hawaii Department of Agriculture at $87,976,000. <Hawaii Agricultural Statistics Service (Hawaii Flowers & Nursery Products).pdf>.
On September 1st, 1998, Animal and Plant Health Inspection Service published in the FEDERAL REGISTER (Docket Number 98-035-1, 63 Fed. Reg. 46403-46406) a proposal to amend 7 C.F.R. § 319.37-8(e)
to add orchids of the genus Phalaenopsis from all areas of the world to the list of plants that may be imported in an approved growing medium, subject to combinations of growing conditions, approved media, inspections, and other requirements. Included also, in accordance with 5 U.S.C. § 603, was an Initial
Regulatory Flexibility Analysis which announced the Animal and Plant Health Inspection Service’s preliminary view, based on admittedly limited information, that “there is no basis to conclude that the
adoption of this proposed Rule would result in any significant impact on a substantial number of small
entities,” 63 Fed. Reg. 46406 (1998). <Federal Register Notice.pdf>. Animal and Plant Health Inspection
Service then offered, for adoption with the proposed Rule, no specific phytosanitary measures beyond
the general program requirements contained in 7 C.F.R. § 319.37-8(e). 63 Fed. Reg. 46406 (1998).
The Hawaii Orchid Growers Association provided Comments on November 30th, 1998, as later did
the Society of American Florists, the American Nursery and Landscape Association, the Hawaii Department of Land and Natural Resources, the Hawaii Department of Agriculture, the United States Fish and
Wildlife Service, the United States Department of Interior, the United States Geological Survey, the University of Hawaii, and Hawaii’s Congressional Delegation. The Office of the Chief Counsel for Advocacy
of the United States Small Business Administration explicitly responded to the Initial Regulatory Flexibility Analysis <SBA Office of Advocacy.pdf>, and, as well, the Hawaii Orchid Growers Association explicitly responded to the Initial Regulatory Flexibility Analysis.
The Regulatory Flexibility Act, 5 U.S.C. § 603(c), requires “description of any significant alternatives
to the proposed rule which accomplish the stated objectives of applicable statutes and which minimize
any significant economic impact of the proposed rule on small entities.” (emphasis added). In its Initial
Regulatory Flexibility Analysis of 1998, Animal and Plant Health Inspection Service did not consider
economic impact in its analysis of alternatives. Because Animal and Plant Health Inspection Service had
concluded, based only on its Pest Risk Assessment, that Phalaenopsis spp. orchids, if produced in accordance with the combinations of growing conditions, approved media, inspections, and other requirements set out in 7 C.F.R. § 319.37-8(e), “could be safely imported from any country, regardless of specific pest associations,” Animal and Plant Health Inspection Service rejected limited application of the proposed Rule to Phalaenopsis spp. orchids from Taiwan only. 63 Fed. Reg. 46406 (1998).
Animal and Plant Health Inspection Service has nowhere published, or discussed, its analysis of the
Comments that Animal and Plant Health Inspection Service received in 1998. Animal and Plant Health
Inspection Service has narrowed application of the proposed Rule to Phalaenopsis spp. orchids from Taiwan only. Animal and Plant Health Inspection Service does not explain why it has narrowed application
of the proposed Rule, or whether it has changed its previous assessment of specific pest associations.
As required by the “Guidelines for Pathway-Initiated Pest Risk Assessments, Version 5.02, October
th
17 , 2000,” Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Permits and
Risk Assessment, Commodity Risk Analysis Branch, <Guidelines.pdf>, Animal and Plant Health Inspection Service has prepared, and has published, a “Risk Analysis of the Importation of Moth Orchid,
Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th,
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2003” <Pest Risk Assessment.pdf>. Likewise, and as required by 42 U.S.C. § 4332(2)(C), Animal and
Plant Health Inspection Service has prepared an Environmental Assessment (May 2003). <Environmental Assessment.pdf>. This Environmental Assessment has been published as the “Proposed Rule for
the Importation of Moth Orchids (Phalaenopsis spp.) in Approved Growing Media From (sic) Taiwan.”
As so published, the Environmental Assessment describes only general program requirements, combinations of growing conditions, approved media, inspections, and other requirements which must be met
for the entry into the United States from Taiwan of moth orchids of the genus Phalaenopsis rooted in approved growing media. Environmental Assessment, pp. 3-5. <Environmental Assessment.pdf>.
As is explained in “Pest Risk Management Evaluation for Plants in Growing Media, Version 1—May
2002,” Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Phytosanitary Issues Management Branch, at page 7, <Pest Risk Management Evaluation.pdf>, the current approach is
to allow shipping of epiphytic plants only if established solely on tree fern slabs, coconut husks, or coconut fibers, 7 C.F.R. § 319.37-8(d), else as bare-root, ergo non-flowering plants, established in agar or
translucent tissue culture medium, 7 C.F.R. § 319.37-8(c). <7 CFR 319.37-8>. The proposed Rule would
allow, without any quantity restriction, entry into the United States from Taiwan of moth orchids of the
genus Phalaenopsis rooted in approved growing media, and this generally under the regime established
in 7 C.F.R. § 319.37-8(e) established for nine other groups of plants. <7 CFR 319.37-8>. Adoption of the
proposed Rule would allow these potted Phalaenopsis spp. orchids from Taiwan to put out flower spikes
prior to entry into the United States.
The point of domestic re-growing of Phalaenopsis spp. plants is to allow the orchids to put out flower
spikes—orchid plants without flower spikes have little or no retail value. The domestic trade in all species of potted epiphytic orchids focuses on flowering plants, and, if the proposed Rule is adopted, so also
will imports of Phalaenopsis spp. orchids from Taiwan focus on flowering plants. This alone will increase
pest risk because existing international trade in Phalaenopsis spp. orchid plants is limited to bare-root,
ergo non-flowering, plants, 63 Fed. Reg. 46405 (1998); flower spikes increase pest risk because they provide a habitat for mites, mealybugs, blossom midges, thrips, and other blossom-infesting organisms.
Hara, A. H. and Hata, T. Y., “Pests and Pest Management,” pages 34, 35, 36, and 40, in K. Leonhardt and
K. Sewake, Growing Dendrobium Orchids in Hawaii, Production and Management Guide, College of
Tropical Agriculture and Human Resources, University of Hawaii at Manoa (1999). <Growing Dendrobium Orchids in Hawaii.pdf>.
In 1997, the Government of Taiwan requested that Animal and Plant Health Inspection Service consider amending 7 C.F.R. § 319.37-8(e), <7 CFR 319.37-8>, so as to allow importation from Taiwan of
Phalaenopsis spp. orchids established in sphagnum moss as a growing medium. 63 Fed. Reg. 46403
(1998). As reported in the Environmental Assessment, at page 1, <Environmental Assessment.pdf>, Taiwan is the largest exporter of Phalaenopsis spp. orchids to the United States, and allowing entry of moth
orchids potted in sphagnum moss will supposedly alleviate the high mortality of bare-rooted plants, and,
more importantly, will allow Taiwanese orchid growers to provide potted, finished, flowering Phalaenopsis spp. orchids directly to United States retailers.
The American Orchid Society estimates that seventy-five percent of all potted orchids produced in
the domestic trade are of the genus Phalaenopsis. In calendar year 2000, domestic wholesale orchid sales
were approximately $100,000,000, and the only flowering potted plant crop with a higher value was
poinsettia. Orchid growing is an international business; large-scale production of finished, flowering
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Phalaenopsis spp. orchids is occurring in China, Germany, Japan, the Netherlands, the United States,
and Taiwan. Unlike all other ornamental crops, orchid sales have increased during the last five years.
Griesbach, R. J., “Development of Phalaenopsis Orchids for the Mass Market,” pages 458, 463, in J.
Janick and A. Whipkey, Trends in New Crops and New Uses, American Society for Horticultural Science
Press, Alexandria, Virginia (2002). <Development of Mass Market.pdf>.
The issue here is whether, or not, the proposed general program requirements, combinations of
growing conditions, approved media, inspections, and other requirements, will reduce pest risk of importation of finished, flowering Phalaenopsis spp. orchids from Taiwan to a level that is equal to, or less
than, the pest risk of importation from Taiwan of bare-rooted, ergo non-flowering, Phalaenopsis spp.
plants. “Pest Risk Management Evaluation for Plants in Growing Media, Version 1—May 2002,” Animal
and Plant Health Inspection Service, Plant Protection and Quarantine, Phytosanitary Issues Management Branch, at page 7. <Pest Risk Management Evaluation.pdf>. As the Hawaii Orchid Growers Association will now make it abundantly clear, the proposed general program requirements, combinations of
growing conditions, approved media, inspections, and other requirements, will not reduce the pest risk
of allowing entry into the United States from Taiwan of finished, flowering Phalaenopsis spp. orchids established in sphagnum moss as a growing medium to a level that is equal to, or less than, the pest risk of
importation of bare-rooted, ergo non-flowering, Phalaenopsis spp. plants from Taiwan.
Incomplete Identification of Quarantine Pests.
We begin our Comments on the proposed Rule with our appraisal of the published Pest Risk Assessment, “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003.” We do not disagree with the determination therein, <Pest Risk Assessment.pdf>, that Phalaenopsis spp. orchids from Taiwan established in
sphagnum moss as a growing medium do not themselves have weediness potential, recognizing, as we
must, that Animal and Plant Health Inspection Service narrowly defines “weediness potential.” However, and as we pointed out in our Comments of November 30th, 1998, on the earlier version of the proposed Rule, in Taiwan, as in Hawaii, the quality of unused sphagnum moss is not uniform, some sphagnum moss has viable weed seeds mixed within it, and these weed seeds sprout and grow along with the
orchids after potting.
Otherwise, we find the published Pest Risk Assessment to be woefully deficient.
One of the major deficiencies of the published Pest Risk Assessment is its wholesale elimination, at
pages 8 through 9, <Pest Risk Assessment.pdf>, of thirty-three identified arthropod pests of Phalaenopsis
spp. orchids in Taiwan. Indeed, of thirty-five identified arthropod pests of Phalaenopsis spp. orchids in
Taiwan, only two, Planococcus minor (the mealybug) and Spodoptera litura (cluster caterpillar), are
deemed of significance by the Animal and Plant Health and Inspection Service, i.e., only these two arthropod pests of Phalaenopsis spp. orchids in Taiwan are deemed likely to follow the importation pathway. “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing
Media From Taiwan into the United States, May 6th, 2003,” at page 10. <Pest Risk Assessment.pdf>. A
rationale for this wholesale elimination of identified pests is lack of species identification. Id., at page 8.
<Pest Risk Assessment.pdf>. Another rationale for this wholesale elimination is that identified pests are
“listed as either pests of specific genera of orchids other than Phalaenopsis or non-specifically, as pests of
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Orchidaceae,” and in these cases, the likelihood and consequences of introduction “were not analyzed
because no specific host linkages to Phalaenopsis could be found in the scientific literature.” Id., at page
9. <Pest Risk Assessment.pdf>.
Animal and Plant Health Inspection Service supposes that these wholesale eliminations of identified
pests are of little consequence, and that if any of the “incompletely identified species,” if any of these
“biological contaminants,” are intercepted during port-of-entry visual inspections, “quarantine action
will be required.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 9. <Pest Risk Assessment.pdf>.
But having made this wholesale elimination of identified arthropod pests on the lack of species identification, or on the lack of identified host linkages to the genus Phalaenopsis, it is invalid science for
Animal and Plant Health Inspection Service to diminish the significance of this wholesale elimination by
supposing that future quarantine action, based on interceptions during port-of-entry inspections, will
suffice. Port-of-entry inspections are limited to only a small percentage of plants offered for entry, and
these visual inspections miss many quarantine pests.
As is explained in the National Plant Board’s Report, “Safeguarding American Plant Resources, July
st
1 , 1999,” at 9, Animal and Plant Health Inspection Service is moving away from interdiction as its primary safeguarding strategy, and instead will rely instead on risk analysis and assessment. <Main Report.pdf>. Animal and Plant Health Inspection Service here rejects a thorough risk assessment in favor
of interdiction, but interdiction is a strategy which Animal and Plant Health Inspection Service will now
abandon: “It is clear that while port-of-entry inspection must continue to play an important role, the
historic view that this activity can function as the focal point for exclusion must be abandoned.” Id., at xix
(emphasis added).
Likewise, it is invalid science for Animal and Plant Health Inspection Service to eliminate identified
pests due to the supposed absence in the scientific literature of linkages to the genus Phalaenopsis. Scientific publications routinely report “orchid,” or Orchidaceae, in insect host records, and do not specify the
orchid species, such as Phalaenopsis spp. See, e.g., Kumashiro, B. R., R. A. Heu, G. M. Nishida, and J. W.
Beardsley, “New State Records of Immigrant Insects in the Hawaiian Islands for the Year 1999,” PROC.
HAWAII. ENTOMOL. SOC. 35: 170-84 (2001), and Survey Program, Plant Pest Control Branch, Plant Industry Division, “Distribution and Host Records of Agricultural Pests and Other Organisms in Hawaii,”
Hawaii Department of Agriculture (2000).
Comments that Animal and Plant Health Inspection Service has already received from the Society of
American Florists, the Florida Nurserymen & Growers Association, and the American Nursery & Landscape Association, Comments on Docket Number 98-035-3, June 9th, 2003, make this same point:
Orchids are not a major agricultural commodity and, as such, have not had the extensive research that such major products typically endure. Since research has not adequately addressed
pest problems associated with orchids, few literature citations exist in the databases used by
APHIS’ Biological Assessment and Taxonomic Support (BATS). In fact, there is a considerable
lack of data for many of the pest species. Thus, the PRA [Pest Risk Assessment] cannot address
them, especially since the authors use literature citation to develop the pest list.
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SAF/ANLA Comments, at pages 2-3 (parenthetical added). <SAF-ANLA Comments.pdf>.
Consider just one of the eliminated arthropod quarantine pests, Thrips palmi Karny, the melon
thrips. Thrips palmi Karny is a well-known pest of orchids that attacks inflorescences and flower spikes.
The United Kingdom’s Department for Environmental, Food and Rural affairs notes that Thrips palmi
Karny can only be distinguished from other thrips species by laboratory examination. <Thrips palmi.pdf>. Thus lack of species identification is no valid rationale for elimination of this arthropod quarantine pest from consideration, particularly so since existing trade is limited to bare-root, ergo non-flowering, Phalaenopsis spp. plants, and adoption of the proposed Rule will result in imports of finished,
flowering Phalaenopsis spp. orchids.
The proposed general program requirements, combinations of growing conditions, approved media,
inspections, and other requirements which must be met for the entry into the United States from Taiwan
of finished, flowering Phalaenopsis spp. orchids, nowhere address the certainty that Thrips palmi Karny
will spread along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids
from Taiwan. Again, and as we pointed out in our Comments of November 30th, 1998, on the earlier version of the proposed Rule, identified Thripidae quarantine pests of Phalaenopsis spp. orchids in Taiwan,
including Dichromothrips sp., Frankliniella intonsa (Trybom), Frankliniella schultzei (Trybom), and
Thrips palmi Karny, will not be excluded from the proposed “pest-exclusionary” greenhouse by screening (the requirement is that the pest-exclusionary greenhouse must have screens on all vents and openings with hole sizes not more than 0.6 mm—“Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at
page 19, <Pest Risk Assessment.pdf>) even with hole sizes as small as 0.073 mm2. Indeed, neither will the
required 0.6 mm screen whole size exclude the mealybug, Planococcus minor, one of the only two of
thirty-five identified arthropod pests of Phalaenopsis spp. orchids in Taiwan now deemed of significance
by the Animal and Plant Health Inspection Service because Planococcus minor will spread along the
pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan.
And although identified Thripidae quarantine pests and another quarantine pest, the mealybug,
Planococcus minor, will invade the required “pest-exclusionary” greenhouses, there is no proposed, effective postproduction or post-harvest treatment in Taiwan for finished, flowering Phalaenopsis spp. orchids. An example of an effective postproduction treatment, one that will demonstrate the absence, or
not, of even low population levels of Thripidae, is use of a modified Berlese funnel to examine samples of
finished, flowering Phalaenopsis spp. orchids that are to be exported from Taiwan. This involves placement of an incandescent light above a funnel containing inflorescences and flower spikes taken from a
sample of the finished, flowering Phalaenopsis spp. orchids that are to be exported. The heat from the
light drives any Thripidae present down the funnel and into a jar beneath containing alcohol or other
preservative. Hara, A. H. and Hata, T. Y., “Pests and Pest Management,” page 41, in K. Leonhardt and K.
Sewake, Growing Dendrobium Orchids in Hawaii, Production and Management Guide, College of Tropical Agriculture and Human Resources, University of Hawaii at Manoa (1999). <Growing Dendrobium
Orchids in Hawaii.pdf>.
Likewise to be considered, as regards omission of the likely spread of Thrips palmi Karny, should the
proposed Rule be adopted, is the certainty that viral diseases, like Impatiens necrotic spot virus, or the
closely-related Tomato spotted wilt virus, will be vectored (spread) with the complex of thrips species
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that will certainly attack finished, flowering Phalaenopsis spp. orchids in Taiwan. <INSV or TSW Virus
and the vector Western Flower Thrips.pdf>.
Doctor Janice Y. Uchida, Professor and Plant Pathologist, Department of Plant Pathology, University
of Hawaii at Manoa, tells us that it was wrong for Animal and Plant Health Inspection Service to dismiss
the fungus Colletotrichum phalaenopsidis as a quarantine pest of Phalaenopsis spp. orchids from Taiwan,
this because Colletotrichum phalaenopsidis was synonymized with Colletotrichum gloeosporiodes (Penz.)
in 1957, and Colletotrichum gloeosporiodes (Penz.) is widely distributed in the United States. “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From
Taiwan into the United States, May 6th, 2003,” at page 9. <Pest Risk Assessment.pdf>. (A “quarantine
pest” is a pest of potential economic importance to the area endangered thereby and not yet present
there, or present but not widely distributed and being officially controlled. “Guidelines for Pathway-Initiated Pest Risk Assessments, Version 5.02, October 17th, 2000,” at page 4, <Guidelines.pdf>; 7 C.F.R. §
319.37-8(g)(2). <7 CFR 319.37-8>.)
Doctor Uchida explains that the massive combination of over six-hundred Colletotrichum species into Colletotrichum gloeosporiodes (Penz.) is not without problems. The morphological range is necessarily
wide to accommodate the many former species that now fall into this one species. However, for several
plant diseases only certain Colletotrichum gloeosporiodes (Penz.) isolates or strains will cause disease on
hosts such as basil, Schefflera, red sealing wax palm, papaya, and Anthurium. Thus the Colletotrichum
gloeosporiodes (Penz.) strain that infects basil will not infect Schefflera. This means that strains of Colletotrichum gloeosporiodes (Penz.) able to infect Phalaenopsis spp. orchids in Taiwan may not be in the United States, and thus are in fact an appropriate quarantine pest. And the potential for Colletotrichum gloeosporiodes (Penz.) to spread rapidly and widely is great. Some of the Colletotrichum gloeosporiodes (Penz.)
strains have a perfect or sexual stage, called Glomerella cingulata. This stage of the pathogen produces
sexual spores that are discharged into the air and carried throughout a greenhouse by air movement.
The limitations of the use of literature citation, used here by Animal and Plant Health Inspection
Service to develop the pest list, are most obvious by the omission of many known mollusk pests that will
spread along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from
Taiwan. Animal and Plant Health Inspection Service has separately received comments from Doctor
Robert H. Cowie, a researcher in the Center for Conservation Research and Training at the University of
Hawaii. Doctor Cowie is the acknowledged world expert in the introduction, spread, and impacts of invasive snails and slugs, particularly in the islands of the Pacific.
Doctor Cowie writes that many mollusk species beyond the four listed in the published Pest Risk Assessment (Acusta (=Bradybaena) tourranensis, Bradybaena sp., Succinea sp., and Vaginulus alte Ferrussae), “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing
Media From Taiwan into the United States, May 6th, 2003,” at page 6, <Pest Risk Assessment.pdf>, have
the potential to spread along the pathway initiated by importation of finished, flowering Phalaenopsis
spp. orchids from Taiwan. These include Achatinidae (e.g., Achatina fulica, the giant African snail),
Meghimatum species (slugs in the family Philomycidae), as well as various species of Subulinidae (especially species in the genus Opeas), Veronicellidae, Camaenidae, Helicarionidae, and Ariophantidae. Just
as is later recognized in the published Pest Risk Assessment, “Risk Analysis of the Importation of Moth
Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States,
May 6th, 2003,” at page 14, <Pest Risk Assessment.pdf>, Doctor Cowie points out that these species are
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all hermaphrodites, that some of them may be able to self-fertilize; that others, even through cross-fertilizing, very probably are able to store sperm for long periods; and thus just a single individual can start a
population.
Doctor Cowie says that the potential impacts of these overlooked mollusk species are diverse. He
says that Achatina fulica, notorious as a garden and agricultural pest, once became established in Florida,
and was eradicated only after an intensive, and costly, six-year campaign. Philomycids and veronicellids
are voracious slugs that feed on a wide range of plants. Subulinids, potential plant pests, may have caused
the decline of native litter-dwelling snails by out-competing them. And various camaenids, helicarionids,
and ariophantids are plant pests that may also have impacts on native ecosystems.
Consequences of Introduction Are Not Properly Assessed.
Animal and Plant Health Inspection Service assesses the consequences of introduction through an
analysis of five risk elements: climate-host interaction, host range, dispersal potential, economic impact,
and environmental impact. “Guidelines for Pathway-Initiated Pest Risk Assessments, Version 5.02, October 17th, 2000,” at pages 6 through 8. <Guidelines.pdf>.
Noting that the subtropical and tropical orchid-growing areas of Taiwan correspond to United States
Department of Agriculture Plant Hardiness Zone 11 (average annual minimum temperature above 40°
F), Animal and Plant Health Inspection Service writes that this Plant Hardiness Zone 11 “is limited to
the southern part of Florida,” <USNA - USDA Plant Hardiness Zone Map - Hawaii.pdf>, and thus Animal and Plant Health Inspection Service supposes that any quarantine pests spread, should the proposed
Rule be adopted, along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan, “will be unable to establish or spread in the out-of-doors environment.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From
Taiwan into the United States, May 6th, 2003,” at page 10. <Pest Risk Assessment.pdf>. Hawaii (when last
we checked, Hawaii is within the United States) is located in United States Department of Agriculture
Plant Hardiness Zones 10a through 11 (average annual minimum temperature, above 30° F), and in Hawaii, most orchids are grown outdoors or under shade houses, and almost never in completely enclosed,
temperature-controlled greenhouses.
Thus this assumption, that any quarantine pests that spread along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan “will be unable to establish or spread
in the out-of-doors environment,” is a fundamental error. Doctor Uchida points out that in addition to
the state of Hawaii, the Territory of American Samoa, the Commonwealth of the Northern Mariana Islands, the Territory of Guam, the Federated States of Micronesia, the United States Virgin Islands, and
the Commonwealth of Puerto Rico, all associated with the United States, are likewise located in United
States Department of Agriculture Plant Hardiness Zone 11, and all will suffer similar, unabated plant
pest and disease invasions from quarantine pests that spread along the pathway initiated by importation
of finished, flowering Phalaenopsis spp. orchids from Taiwan. Nor can we understand why Animal and
Plant Health Inspection ignores the impact on south Florida. South Florida, like Hawaii, the territories
administered by the United States, and the commonwealths in free association or union with the United
States, is particularly vulnerable to invasive pests and diseases.
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Doctor Arnold H. Hara, Professor and Entomologist, University of Hawaii at Manoa, has prepared a
study which demonstrates that the rate of invasion by non-indigenous, or alien, species in Hawaii is
more than a million times the natural colonization rate, and nearly twice the number absorbed each year
by the entire North American continent. A copy is attached as <Enclosure 1>. Because Animal and Plant
Health Inspection Service’s safeguarding activities focus almost exclusively (as the published Pest Risk
Assessment here) on United States mainland regions with temperate climates, there has been a failure to
protect Hawaii’s diversified agriculture and fragile natural environment. And it is not just the state of
Hawaii; it is also south Florida, the territories administered by the United States, and the commonwealths in free association or union with the United States, that will suffer similar, unabated plant pest and
disease invasions from quarantine pests that will spread along the pathway initiated by importation of
finished, flowering Phalaenopsis spp. orchids from Taiwan.
Because of this fundamental error, the pest risk rating for climate-host interaction is properly assessed as High (3), for all of the identified pests of Phalaenopsis spp. orchids in Taiwan. “Risk Analysis of
the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan
into the United States, May 6th, 2003,” at page 15. <Pest Risk Assessment.pdf>.
The published Pest Risk Assessment appropriately assigns a High (3) risk rating as to host range for
both of the identified arthropod quarantine pests of Phalaenopsis spp. orchids in Taiwan, Planococcus
minor (the mealybug) and Spodoptera litura (cluster caterpillar), and to the identified mollusk quarantine pests, Acusta (=Bradybaena) tourranensis and Bradybaena sp., that are deemed by Animal and Plant
Health Inspection Service as likely to follow the importation pathway. “Risk Analysis of the Importation
of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United
States, May 6th, 2003,” at page 10 through 11. <Pest Risk Assessment.pdf>. But there is nonetheless a
problem, and the problem with this analysis of host range risk in the published Pest Risk Assessment is
the wholesale elimination of thirty-three of thirty-five identified arthropod pests of Phalaenopsis spp. orchids in Taiwan, the elimination of three of four identified mollusk pests of Phalaenopsis spp. orchids in
Taiwan, the elimination of all but three of the identified fungi pests of Phalaenopsis spp. orchids in
Taiwan, and the elimination of all of the identified virus pests of Phalaenopsis spp. orchids in Taiwan.
We have previously discussed the invalid science on which these wholesale eliminations are premised.
The published Pest Risk Assessment inappropriately assigns a Low (1) risk as to host range of the
three identified fungi pests of Phalaenopsis spp. orchids in Taiwan, i.e., Cylindrosporium Phalaenopsis,
Sphaerulina Phalaenopsis, and Phomopsis orchidphila, which are deemed by Animal and Plant Health
Inspection Service as likely to follow the importation pathway. “Risk Analysis of the Importation of
Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United
States, May 6th, 2003,” at page 11. <Pest Risk Assessment.pdf>. Per the published Pest Risk Assessment
“the host range for the pathogens Cylindrosporium Phalaenopsis and Sphaerulina Phalaenopsis was assumed to be only Phalaenopsis.” Id., (emphasis added). Here, Doctor Uchida tells us that host range, if
not known, should not be assumed to be restricted to orchids. Many pathogens attack more than one
species, and if only one host is known, this is often only because plant pathologists do not have time or
funds to undertake costly cross-inoculation studies.
As for Phomopsis orchidphila, the Animal and Plant Health Inspection Service says its host range includes only four species (Catasetum, Cattelya, Coelogyne, and Cymbidium) in addition to the genus Phalaenopsis, and since there are approximately one-hundred and nine species of Phomopsis orchidphila in
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the United States, and only three of these are reported to infect more than three plant host genera, Animal and Plant Health Inspection Service supposes that the species of Phomopsis orchidphila identified as
a quarantine pest of Phalaenopsis spp. orchids in Taiwan is not a “new generalist [i.e., it does not have
the ability to infect a wide range of plant hosts] because reports of it infecting more plants would be seen
in the literature.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 11 (parenthetical
added). <Pest Risk Assessment.pdf>.
Doctor Uchida tells us otherwise, tells us that the identified host range of Phomopsis orchidphila is
nothing more than the extent of scientific observations, and not a biological limit. It is extremely unlikely
that the nearly six-hundred to eight-hundred genera, or over one-thousand, seven-hundred species of
orchids, have been tested and found to be non-host for Phomopsis orchidphila, and, to the contrary of
the published Pest Risk Assessment, it is very likely that other orchid genera will be hosts for Phomopsis
orchidphila, but simply have not been observed as yet.
The Comments already received from the Society of American Florists, the Florida Nurserymen &
Growers Association, and the American Nursery & Landscape Association, Comments on Docket Number 98-035-3, June 9th, 2003, confirm just what Doctor Uchida tells us:
It is extremely difficult to understand why, in light of the admitted shortcomings and gaps of
the information contained in the PRA [Pest Risk Assessment], and the facts that where risks
were identified, they were rated “high,” APHIS continued with this proposal. It is, surely, a leap
of faith, and most likely an unwise leap, to assume that in the face of known “high” risk ratings,
mitigation will reduce the risk to acceptable levels. Yet this is what APHIS has done. We strongly disagree.
SAF/ANLA Comments, at page 3. <SAF-ANLA Comments.pdf>.
The rating properly assigned to the host range of the three identified fungi pests of Phalaenopsis spp.
orchids in Taiwan is High (3), not Low (1). “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at
page 15. <Pest Risk Assessment.pdf>.
Likewise, the published Pest Risk Assessment inappropriately assigns a Low (1) risk rating to the dispersal potential of the identified mollusk pests of Phalaenopsis spp. orchids in Taiwan. “Risk Analysis of
the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan
into the United States, May 6th, 2003,” at page 11. <Pest Risk Assessment.pdf>. Hawaii Orchid Growers
Association does not contest the observation that adult mollusks are large and easily detected, but this is
provided that the mollusks remain above ground. Doctor Hara tells us that mollusks are transported undetected on the roots of orchid plants. Mollusks, including Bradybaena sp., are known to occur on roots
of potted orchids. Hara, A. H. and Hata, T. Y., “Pests and Pest Management,” page 45, in K. Leonhardt
and K. Sewake, Growing Dendrobium Orchids in Hawaii, Production and Management Guide, College of
Tropical Agriculture and Human Resources, University of Hawaii at Manoa (1999). <Growing Dendrobium Orchids in Hawaii.pdf>. Sublina octona and the bush snail, Bradybaena similaris, have been observed on orchids in Hawaii, stunting potted orchid plants. Mollusks have been intercepted by Animal
and Plant Health Inspection Service on bare-rooted orchid plants from Taiwan.
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And just as the proposed general program requirements, combinations of growing conditions, approved media, inspections, and other requirements which must be met for the entry into the United
States of finished, flowering Phalaenopsis spp. orchids from Taiwan, nowhere address the identified
Thripidae quarantine pests of finished, flowering Phalaenopsis spp. orchids in Taiwan, neither do these
proposed general program requirements, combinations of growing conditions, approved media, inspections, and other requirements, appropriately address the dispersal potential of the identified mollusk
pests of Phalaenopsis spp. orchids in Taiwan. The requirement is that the Phalaenopsis spp. orchid plants
in Taiwan must be “[r]ooted and grown in approved in growing media on benches supported by legs
and raised at least 46 cm off the floor.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis
spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 20.
<Pest Risk Assessment.pdf>. Doctor Uchida tells us that this bench height will not prevent mollusks,
snails, and slugs from infesting the plants on the bench. In Hawaii, snails and slugs easily travel ninety
centimeters to infest plants on benches of that height.
The only effective growing condition that will eliminate mollusk infestation of plants on benches in
greenhouses is to require copper flashing affixed to vertical structural components, to side walls, and
to bench legs. Hara, A. H. and Hata, T. Y., “Pests and Pest Management,” page 45, in K. Leonhardt and
K. Sewake, Growing Dendrobium Orchids in Hawaii, Production and Management Guide, College of
Tropical Agriculture and Human Resources, University of Hawaii at Manoa (1999). <Growing Dendrobium Orchids in Hawaii.pdf>.
The published Pest Risk Assessment inappropriately assigns a Low (1) risk as to dispersal potential of the identified mollusk pests of Phalaenopsis spp. orchids in Taiwan. “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into
the United States, May 6th, 2003,” at page 11. <Pest Risk Assessment.pdf>. A Low (1) risk as to dispersal
potential is inappropriate because the proposed general program requirements, combinations of growing conditions, approved media, inspections, and other requirements which must be met for the entry into the United States of finished, flowering Phalaenopsis spp. orchids from Taiwan, do not appropriately address the dispersal potential of the identified mollusk pests of Phalaenopsis spp. orchids
in Taiwan. Only greenhouses with copper flashing affixed to vertical structural components, to side
walls, and to bench legs will eliminate mollusk infestation of plants on benches; no such copper flashing is required. And once the benched Phalaenopsis spp. orchid plants are infested in Taiwan with
mollusks, safeguarding (port-of-entry visual inspections) will be ineffective because the mollusks will
travel undetected on the roots of these plants. The proper pest risk rating is High (3), not Low (1).
Likewise, the published Pest Risk Assessment inappropriately assigns a Medium (2) risk as to dispersal potential of one of the identified arthropod pests of Phalaenopsis spp. orchids in Taiwan, Planococcus minor (the mealybug), deemed by Animal and Plant Health Inspection Service as likely to follow
the pathway opened by importation from Taiwan of finished, flowering Phalaenopsis spp. orchids. “Risk
Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 11. <Pest Risk Assessment.pdf>. Indeed, as is supposed in the published Pest Risk Assessment, the primary mode of long distance dispersal of Planococcus minor is commercial movement of plants. But finished, flowering Phalaenopsis spp.
orchids from Taiwan have not heretofore moved in international commerce (and will not, unless the
proposed Rule is adopted). Thus the absence of a record of interceptions of Planococcus minor on plants
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of the genus Phalaenopsis is proof of nothing, given that such movements are of bare-rooted Phalaenopsis spp. plants, not finished, flowering Phalaenopsis spp. orchids. The presence of mealybugs is a major cause of quarantine rejections of potted, ergo flowering, orchid plants. Hara, A. H. and Hata, T. Y.,
“Pests and Pest Management,” page 35, in K. Leonhardt and K. Sewake, Growing Dendrobium Orchids in
Hawaii, Production and Management Guide, College of Tropical Agriculture and Human Resources,
University of Hawaii at Manoa (1999). <Growing Dendrobium Orchids in Hawaii.pdf>. The proper
pest risk rating is High (3), not Medium (2).
The published Pest Risk Assessment appropriately assigns a High (3) risk to dispersal potential of
Spodoptera litura (cluster caterpillar). “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th,2003,” at
page 11. <Pest Risk Assessment.pdf>.
It is incorrect to assume, as a basis to assign a Medium (2) risk to the dispersal potential of the
three identified fungi pests of Phalaenopsis spp. orchids in Taiwan, i.e., Cylindrosporium Phalaenopsis, Sphaerulina Phalaenopsis, and Phomopsis orchidphila that “spores are not likely to be widely dispersed over long distances.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants
in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 11. <Pest
Risk Assessment.pdf>. Doctor Uchida tells us that a new species of Colletotrichum gloeosporiodes
(Penz.) (it has longer spores) commonly attacks orchids in Hawaii, and that two “wild” orchids growing near orchid nurseries or arboretums have leaf spots caused by this new Colletotrichum gloeosporiodes (Penz.) species. These wild orchids are Arundina bambusifolia (bamboo orchid) and Spathoglottis
plicata (ground orchid), both escapes. The new species of Colletotrichum gloeosporiodes (Penz.) easily
travels many miles as long as a host is available. Miles of Arundina bambusifolia plants growing
along the roads and into the forests are infected in Hawaii. The pathogen infects a plant and produces spores in a week. These spores are carried by rain splashes for a few yards, infect the next plant,
and continue to move.
Compared to other genera of orchids, Arundina bambusifolia is tolerant of this new Colletotrichum gloeosporiodes (Penz.) species, and while leaf spots and blights are common, the plants are not
killed. Other genera of orchids, e.g., Dendrobium, can be killed by this pathogen when they are
young. Simple observation of the road sides in Hawaii puts the lie to this foolish assertion that
spores are not likely to be widely dispersed, either by rain splashes, or in the air.
The proper pest risk rating to be assigned to the dispersal potential of the three identified fungi
pests of Phalaenopsis spp. orchids in Taiwan is High (3), not Medium (2). “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into
the United States, May 6th, 2003,” at page 15. <Pest Risk Assessment.pdf>.
The economic impact ratings, in the published Pest Risk Assessment, of spread along the pathway
initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan, of the thirtyfive identified arthropod pests, as well as of the four identified mollusk pests, the four identified bacterial pests, the thirteen identified fungi pests, and the three identified viruses, are woefully understated. “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved
Growing Media From Taiwan into the United States, May 6th, 2003,” at page 12. <Pest Risk Assessment.pdf>. This woeful understatement results from the wholesale elimination of thirty-three of thirty-five identified arthropod pests of Phalaenopsis spp. orchids in Taiwan, the elimination of three of
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four identified mollusk pests of Phalaenopsis spp. orchids in Taiwan, the elimination of all but three
of the identified fungi pests of Phalaenopsis spp. orchids in Taiwan, and, as well, the elimination
from consideration of the economic impact of spread of the three identified viruses of Phalaenopsis
spp. orchids in Taiwan.
Likewise, this woeful understatement of economic impact results from lack of consideration, by
Animal and Plant Health Inspection Service, of the spread, along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan, of the identified pests of Phalaenopsis spp. orchids in Taiwan into south Florida, the state of Hawaii, the Territory of American Samoa, the Commonwealth of the Northern Mariana Islands, the Territory of Guam, the Federated
States of Micronesia, the United States Virgin Islands, and the Commonwealth of Puerto Rico
In our response of November 30th, 1998, to the Initial Regulatory Flexibility Analysis, we pointed
out that adoption of the proposed Rule will devastate growers in Hawaii of all species of potted epiphytic orchids, all of whom operate as small businesses, and many of whom are minorities. We explained that many of these growers of potted epiphytic orchids operate with minimal capitalization.
Economic devastation will surely come if new competition from Taiwan is allowed, if Taiwanese
growers are allowed to provide potted, finished, flowering Phalaenopsis spp. orchids directly to United States retailers. But economic devastation will also surely come from the need to invest in expensive, and labor-intensive, treatments of existing greenhouse orchid stocks to combat the identified
pests of Phalaenopsis spp. orchids in Taiwan, pests that will be spread into south Florida, into Hawaii,
and into the territories and commonwealths associated with the United States, along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan.
And it is not just the growers of potted epiphytic orchids in Hawaii who will suffer economic devastation. Several families in Hawaii have started to grow vanilla orchids to start a new industry (vanilla is the only edible fruit of the orchid family). <Growing Vanilla in Hawaii.pdf>. And minority
groups in the territories and commonwealths associated with the United States are trying to grow orchids. Just as the growers of potted epiphytic orchids in Hawaii, these people will also suffer economic devastation from spread of the identified pests of Phalaenopsis spp. orchids in Taiwan, pests that
will be spread along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan.
“Guidelines for Pathway-Initiated Pest Risk Assessments, Version 5.02, October 17th, 2000,” at page
8, <Guidelines.pdf>, teach that economic impact is properly based on introduced pests causing: (1)
lower yield of the host crop as a result of plant mortality, (2) lower value of the commodity by increasing costs of production, and (3) loss of foreign or domestic markets due to the presence of new
quarantine pests. Here, all three eventualities are the likely result of adoption of the proposed Rule,
most particularly in Hawaii, in south Florida, and in the territories and commonwealths associated
with the United States, and thus the proper assessment of the risk of economic impact is High (3)
for all of the identified quarantine pests of finished, flowering Phalaenopsis spp. orchids from Taiwan.
Likewise, the published Pest Risk Assessment woefully understates the environmental impact as
Low (1), of spread, along the pathway initiated by importation of finished, flowering Phalaenopsis spp.
orchids from Taiwan, of two of the three identified fungi pests of Phalaenopsis spp. orchids in Taiwan.
“Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing
Media From Taiwan into the United States, May 6th, 2003,” at page 14. <Pest Risk Assessment.pdf>. No
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one is arguing that the pathogens Cylindrosporium P h a l a e n o p s i s and Sphaerulina Phalaenopsis will
infect hosts plants ad infinitum. But neither is it correct to assume that “host specificity is the
norm.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved
Growing Media From Taiwan into the United States, May 6th, 2003,” at page 14. <Pest Risk Assessment.pdf>.
Simply put, Doctor Uchida says that Flor’s gene-for-gene theory does not support Animal and
Plant Health Inspection Service’s assumption. Flor’s studies are studies of fungal pathogen races within a species, and not a comparison among species or genera of fungi. For some pathogens, such as
Puccina graminis, or cereal rust, many of the strains look the same, but only some are able to infect
wheat. Wheat has many varieties, and the gene-for-gene theory states that if a wheat variety has a
gene resistant to cereal rust, then the cereal rust has a gene that makes it unable to infect the wheat.
If the wheat variety does not have a gene that protects it (it is susceptible), then the cereal rust has a
gene that allows it to infect this wheat. This is enormously different from arguing, as here does Animal and Plant Health Inspection Service that “host specificity is the norm.”
Thus, again, it is extremely unlikely that the nearly six-hundred to eight-hundred genera, or over
one-thousand, seven-hundred species of orchids, have been tested and found to be non-host for Cylindrosporium Phalaenopsis, or for Sphaerulina Phalaenopsis, and, to the contrary of the published
Pest Risk Assessment, it is very likely that other orchid genera will be hosts for Cylindrosporium
Phalaenopsis, or for Sphaerulina Phalaenopsis, but these simply have not been observed as yet. The
environmental impact of the spread of these two fungi pests of Phalaenopsis spp. orchids in Taiwan is properly assessed as High (3), not Low (1).
Summing up, the Cumulative Risk Rating, which is the biological indicator of the potential of
the identified pests to establish, spread, and cause economic and environmental impacts, “Guidelines for Pathway-Initiated Pest Risk Assessments, Version 5.02, October 17th, 2000,” at page 8,
<Guidelines.pdf>, should be High (14), not Medium (10), for the identified mollusk pests of Phalaenopsis spp. orchids in Taiwan; should be High (14), not Medium (11), for Planococcus minor; is
properly High (15) for Spodoptera litura; should be High (15), not Low (7) for two of the three
identified fungi pests of Phalaenopsis spp. orchids in Taiwan, Cylindrosporium Phalaenopsis and
Sphaerulina Phalaenopsis; and should be High (13), not Low (7) for the remaining fungi pest of
Phalaenopsis spp. orchids in Taiwan, Phomopsis orchidphila. “Risk Analysis of the Importation of
Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the
United States, May 6th, 2003,” at page 15. <Pest Risk Assessment.pdf>.
For purposes of its assessment of introduction potential, it is commendable that Animal
and Plant Health Inspection Service recognizes, regarding the quantity of commodity that will
be imported annually, that it is adopting the projections of the Government of Taiwan, viz.,
that “no more than 10 [40-foot long shipping containers] containers per year have ever been
exported or are expected to be exported from Taiwan into the United States.” “Risk Analysis of
the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 15 (parenthetical added). <Pest Risk Assessment.pdf>. Commendable as this recognition may be, it is also demonstrably in error. This recognition can be demonstrated on its face to be erroneous by simply reading its preface, viz.,
that “[p]ermission to import into the United States is likely to be linked with an increase in pro-
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duction in the future and subsequent increases in the volume of imports.” Id. This being so, then it
cannot also be, as Animal and Plant Health Inspection Service supposes, that future exports will not
rise above the present level of ten forty-foot long shipping containers per year.
Contrast this foolish understatement of the quantity of product to be imported annually with the description of the developing mass market for potted Phalaenopsis spp. orchids that has been made by Doctor Robert J. Griesbach. (page 3 of these Comments). Doctor Griesbach is a Research Geneticist, Floral
and Nursery Plants Research Unit, The United States National Arboretum. Like the Animal & Plant Health Inspection Service, The United States National Arboretum is a part of the United States Department of
Agriculture. Unlike the Animal and Plant Health Inspection Service, Doctor Griesbach relies on published and readily-available economic data, and not on the words of a party, the Government of Taiwan, that
is promoting the proposed Rule.
Likewise, this assessment of introduction potential, particularly concerning the foolish understatement of the quantity of commodity that will be imported annually, ignores the extensive commentary on the capabilities of Taiwanese orchid growers that we provided in our Comments of
November 30 th , 1998, on the earlier version of the proposed Rule. There is nothing in the proposed Rule as announced on Friday, May 9th, 2003, which would invalidate any of our earlier
commentary on the capabilities of Taiwanese orchid growers. Indeed, the modification of the
earlier version of this proposed Rule, which would have allowed imports of potted orchids of the
genus Phalaenopsis from all areas of the world, to the version of the proposed Rule now under
consideration, which will allow the importation of finished, flowering Phalaenopsis spp. orchids
from Taiwan only, can easily be said to be a modification that will likely promote even more imports from Taiwan than would the earlier proposed Rule have promoted. The pest risk concerning the quantity of product that will be imported annually is properly assessed as High (3), not as
Low (1). “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved
Growing Media From Taiwan into the United States, May 6th, 2003,” at page 17. <Pest Risk Assessment.pdf>.
When an agency ignores the existing record, and adopts one of several conflicting views without an explanation of its resolution of the conflict, it runs the risk that its decision-making will
be challenged, and that its decision-making will be rejected in the courts as “arbitrary, capricious,
an abuse of discretion, or otherwise not in accordance with law.” 5 U.S.C. § 706(2)(A). Animal and
Plant Health Inspection Service should be mindful of its statutory obligations.
We agree with the assessment that the identified pests of Phalaenopsis spp. orchids in Taiwan will
likely survive shipment, and that this risk element is properly assessed as High (3). “Risk Analysis of
the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 16. <Pest Risk Assessment.pdf>.
We disagree with the assessment as Low (1) of the risk that the identified mollusk pests of Phalaenopsis spp. orchids in Taiwan will not be detected by standard visual inspection at ports of entry.
Animal and Plant Health Inspection Service makes this assessment based on what it supposes to be
the “pest-exclusionary” conditions that it has imposed. “Risk Analysis of the Importation of Moth
Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States,
May 6th, 2003,” at page 16. <Pest Risk Assessment.pdf>. We have previously explained that the proposed general program requirements, combinations of growing conditions, approved media, inspections,
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and other requirements which must be met for the entry into the United States of finished, flowering
Phalaenopsis spp. orchids from Taiwan, do not appropriately address the dispersal potential of the
identified mollusk pests of Phalaenopsis spp. orchids in Taiwan. Only greenhouses with copper
flashing affixed to vertical structural components, to side walls, and to bench legs will eliminate mollusk infestation of plants on benches; no such copper flashing is required. And once the benched
Phalaenopsis spp. orchid plants are infested in Taiwan with mollusks, safeguarding (port-of-entry visual inspections) will be ineffective because the mollusks will travel on the roots of these Phalaenopsis
spp. orchid plants from Taiwan. Standard port-of-entry visual inspections will not detect these mollusks.
The pest risk concerning the likelihood that the identified mollusk pests of Phalaenopsis spp. orchids in Taiwan will not be detected by standard visual inspection at ports of entry is properly assessed
as High (3), not as Low (1).
We do not disagree with the assessment that eggs of Spodoptera litura (cluster caterpillar) are
difficult to detect on finished, flowering Phalaenopsis spp. orchids in Taiwan. “Risk Analysis of
the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 16. <Pest Risk Assessment.pdf>.
We agree with the assessment that latent infections of the three identified fungi pests of Phalaenopsis spp. orchids in Taiwan, i.e., Cylindrosporium Phalaenopsis, Sphaerulina Phalaenopsis, and Phomopsis orchidphila, are unlikely to be detected at ports of entry. “Risk Analysis of the Importation of
Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan into the United
States, May 6th, 2003,” at page 16. <Pest Risk Assessment.pdf>.
We agree with the assessment that the identified pests of Phalaenopsis spp. orchids in Taiwan will
likely move to a suitable habitat, particularly so in Hawaii, in south Florida, and in the territories
and commonwealths associated with the United States, and thus we agree this risk element is properly assessed as High (3). “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants
in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 16. <Pest Risk
Assessment.pdf>.
We agree with the assessment that the identified pests of Phalaenopsis spp. orchids in Taiwan will
likely come into contact with suitable host material, and we agree that this risk element is properly assessed as High (3). “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in
Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 16. <Pest Risk
Assessment.pdf>.
Because we believe that the pest risk concerning the quantity of product that will be imported
annually is properly assessed as High (3), not as Low (1), for all of the identified pests of Phalaenopsis spp. orchids in Taiwan, we believe also that the Summary of the Risk Ratings as to the likelihood
of introduction of the identified pests of Phalaenopsis spp. orchids in Taiwan, other than the identified
mollusk pests of Phalaenopsis spp. orchids in Taiwan, should be High (17). Likewise, we believe that the
pest risk concerning the likelihood that the identified mollusk pests of Phalaenopsis spp. orchids in
Taiwan will not be detected by standard visual inspection at ports of entry is properly assessed as
High (3), not as Low (1). Thus we believe that the Summary of the Risk Ratings as to the likelihood of
introduction of the identified mollusk pests of Phalaenopsis spp. orchids in Taiwan is High (18), not
High (14). “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved
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Growing Media From Taiwan into the United States, May 6th, 2003,” at page 17. <Pest Risk Assessment.pdf>.
“Guidelines for Pathway-Initiated Pest Risk Assessments, Version 5.02, October 17th, 2000,” at page
11, <Guidelines.pdf>, provide for a summary rating, the Cumulative Risk Rating, to estimate the pest
risk potential for each identified quarantine pest. Guidelines are offered as an interpretation of the
Low, Medium, and High pest risk potential ratings. Of interest here are two of these three Guidelines:
for Medium pest risk potential ratings, “[s]pecific phytosanitary measures may be necessary;” and for
High pest risk potential ratings, “[s]pecific phytosanitary measures are strongly recommended. Port-ofentry inspection is not considered sufficient to provide phytosanitary security.” Id. (emphasis added).
The published Pest Risk Assessment provides a Medium (24) pest risk potential rating for the identified mollusk pests of Phalaenopsis spp. orchids in Taiwan; a Medium (22) pest risk potential rating for
the three identified fungi pests of Phalaenopsis spp. orchids in Taiwan; a Medium (26) pest risk potential
rating for one of the two identified arthropod pests of Phalaenopsis spp. orchids in Taiwan that is deemed likely to follow the importation pathway, Planococcus minor (the mealybug); and a High (30) pest risk
potential rating for the other identified arthropod pest of Phalaenopsis spp. orchids in Taiwan, Spodoptera litura (cluster caterpillar), that is also deemed likely to follow the importation pathway. “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media
From Taiwan into the United States, May 6th, 2003,” at page 17. <Pest Risk Assessment.pdf>.
Hawaii Orchid Growers Association has shown that if pest risk potential is properly assessed, even as
to the very few identified pests of Phalaenopsis spp. orchids in Taiwan that are deemed likely to follow
the importation pathway, the pest risk potential rating for the identified mollusk pests of Phalaenopsis
spp. orchids in Taiwan should be High (32), not Medium (24); the pest risk potential rating for one of
the two identified arthropod pests of Phalaenopsis spp. orchids in Taiwan that is deemed likely to follow
the importation pathway, Planococcus minor (the mealybug), should be High (31), not Medium (26); the
pest risk potential rating for the other identified arthropod pest of Phalaenopsis spp. orchids in Taiwan
that is deemed likely to follow the importation pathway, Spodoptera litura (cluster caterpillar), should be
High (32), not High (30); the pest risk potential for two of the three identified fungi pests of Phalaenopsis
spp. orchids in Taiwan, Cylindrosporium Phalaenopsis and Sphaerulina Phalaenopsis, should be High
(32), not Medium (22); and the pest risk potential for the other identified fungi pest of Phalaenopsis
spp. in Taiwan, Phomopsis orchidphila, should be High (30), not Medium (22).
Animal and Plant Health Inspection Service’s published Pest Risk Assessment is invalid. The invalidity of this published Pest Risk Assessment is demonstrated by “Guidelines for Pathway-Initiated Pest
Risk Assessments, Version 5.02, October 17th, 2000,” at page 11. <Guidelines.pdf>. As we have previously explained, Animal and Plant Health Inspection Service has made wholesale eliminations of identified
pests of Phalaenopsis spp. orchids in Taiwan, and Animal and Plant Health Inspection Service justifies
these wholesale eliminations of identified pests of Phalaenopsis spp. orchids in Taiwan by supposing that
future quarantine action, based on interceptions during visual port-of-entry inspections, will suffice. Contrary to the published Pest Risk Assessment, we have shown that if pest risk potential is properly assessed,
then all of the identified quarantine pests of Phalaenopsis spp. orchids in Taiwan that are deemed likely to
follow the importation pathway will be rated as High pest risk potential. Since “Guidelines for PathwayInitiated Pest Risk Assessments, Version 5.02, October 17th, 2000,” at page 11, <Guidelines.pdf>, in fact
provide that port-of-entry inspection is not considered sufficient to provide phytosanitary security for pests
- 17 -
rated as High pest risk potential, then Animal and Plant Health Inspection Service’s wholesale eliminations of identified pests of Phalaenopsis spp. orchids in Taiwan are invalid under these same Guidelines,
and the published Pest Risk Assessment is illegal.
The Proposed “Systems Approach” is Inadequate.
Once again, and just as in 1998, Animal and Plant Health Inspection Service has offered, for adoption with the proposed Rule, no specific phytosanitary measures beyond the general program requirements contained in 7 C.F.R. § 319.37-8(e). <7 CFR 319.37-8>, 68 Fed. Reg. 24915, 34898-899 (2003).
<Docket Number 98-035-4.pdf>. Our analysis of the Pest Risk Assessment, as well as our analysis of the
general program requirements contained in 7 C.F.R. § 319.37-8(e), demonstrates, beyond cavil, that the
mitigation measures currently in use as general program requirements of 7 C.F.R. § 319.37-8(e) will not
allow safe importation of finished, flowering Phalaenopsis spp. orchids from Taiwan, nor can these general program requirements reduce pest risk to a level equal to, or less than, the pest risk of importation
from Taiwan of bare-rooted, ergo non-flowering, Phalaenopsis spp. plants. 7 C.F.R. § 319.37-8(g)(4)(ii).
<7 CFR 319.37-8>.
The general program requirement to use approved growing media, 7 C.F.R. § 319.37-8(e)(1), will not
mitigate pest risk. <7 CFR 319.37-8>. The Government of Taiwan has requested approval of the use of
sphagnum moss as a growing medium. 63 Fed. Reg. 46403 (1998). Sphagnum moss, unlike peat, is a living organism. Sphagnum moss hosts a fungal pathogen, Sporothrix schenckii. <Sphagnum Moss vs
Sphagnum Peat Moss.pdf>. Sporothrix schenckii is the causative agent of lymphocutaneous Sporotrichoris (rose handler’s disease). Sporotrichoris is sometimes fatal to immunocompromised persons, and sometimes fatal to persons with diabetes mellitus and alcoholism. <Sporothrix Species.pdf>. While Sporotrichoris is typically caused by handling sphagnum moss that hosts Sporothrix schenckii, the spores of this
fungal pathogen, if simply inhaled by an immunocompromised person, can cause Sporotrichoris.
Sporotrichoris can be chronic for years. <Mycology - Lifecycles and Pathogenesis.pdf>.
We included with our Comments submitted on November 30th, 1998, copies of letters sent by Animal and Plant Health Inspection Service field representatives investigating the request by the Government of Taiwan to allow importation from Taiwan of Phalaenopsis spp. orchids established in sphagnum
moss as a growing medium. One of these Animal and Plant Health Inspection Service field representatives reported that the proposed sphagnum moss growing medium is imported from New Zealand.
Sphagnum moss from New Zealand has been found to host Sporothrix schenckii. <The Carnivorous
Plant FAQ - Sporotrichosis.pdf>.
Bill Callison, Assistant Director, Plant Health and Prevention Services, California Department of
Agriculture ([email protected]), reports that his organization has found plant parasitic nematodes
and arthropod pests in sphagnum moss imported from Canada, and he says that if this growing medium
is not heat-treated, fumigated, or in some other way processed to render it virtually pest free, and then
kept protected from recontamination, there might be significant pest risk. Bill Callison is also the President of the National Plant Board. Glen Barfield, a member of the Hawaii Orchid Growers Association,
and an orchid grower in Hakalau, Hawaii <The Orchid Works.pdf>, tells us that he had difficulties some
six years ago when he attempted to use sphagnum moss imported from Taiwan as a growing medium
(this sphagnum moss was compressed into a small wafer and when wetted would expand and fill a cell in
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a seventy-two cell plug tray). He experienced massive root die-off, and when he obtained a laboratory
examination of one of the wetted sphagnum moss wafers, the laboratory reported that it had found Aphelenchoides nematodes, a heavy infestation of Pythium sp., and Rhizoctonia fungi. Glen Barfield tells us
also that these sphagnum moss wafers from Taiwan that he was using are a common product used in orchid propagation in Taiwan.
If sphagnum moss is used a growing medium, the only general program requirement, and the only
requirement applicable here, is that this sphagnum moss “must not have been previously used.” 7 C.F.R.
§ 319.37-8(e)(1). <7 CFR 319.37-8>.
“Pest Risk Management Evaluation for Plants in Growing Media, Version 1—May 2002,” at pages 21
and 24, <Pest Risk Management Evaluation.pdf>, assumes, wrongly, that the systems approach will achieve a medium to high risk reduction for arthropods and pathogens, and, for each, wrongly, that “[t]here
is no scientific or experimental evidence indicating a potential pest risk with any of the organic and artificial media approved for growing plants under the systems approach.” We have just cited Animal and
Plant Inspection Service to well-known scientific evidence that sphagnum moss, including sphagnum
moss from New Zealand, hosts a fungal pathogen.
“Pest Risk Management Evaluation for Plants in Growing Media, Version 1—May 2002,” at page 34,
<Pest Risk Management Evaluation.pdf>, supposes, wrongly, that “[a]pproved growing media are free of
parasitic nematodes. Again, we have just cited observations from two credible sources that sphagnum
moss, an approved growing medium, contains arthropod pests and parasitic nematodes.
Likewise, “Pest Risk Management Evaluation for Plants in Growing Media, Version 1—May 2002,”
at pages 25 and 26, <Pest Risk Management Evaluation.pdf>, assumes, wrongly, that one of the general
program requirements for the sphagnum moss growing medium is that this sphagnum moss growing
medium be “sterilized or pasteurized.” In fact, there is no such general program requirement. There
ought to be, and Animal and Plant Health Inspection Service should impose such a requirement, but
only after Animal and Plant Health Inspection Service assures itself, based on scientific or experimental
evidence, that this specific phytosanitary requirement for treatment of the sphagnum moss growing medium is in fact effective.
No specific phytosanitary measures beyond the general program requirements contained in 7 C.F.R.
§ 319.37-8(e)(1), <7 CFR 319.37-8>, are proposed for the sphagnum moss growing medium. Without
specific phytosanitary measures beyond these general program requirements, use of sphagnum moss as a
growing medium will not mitigate pest risk. Indeed, well-known scientific evidence shows that use of
untreated sphagnum moss will vector fungal pathogens other than the fungal pathogens that have been
already identified as pests of Phalaenopsis spp. orchids in Taiwan.
And even the use of sterilized or pasteurized sphagnum moss as a growing medium is not without
risk. Use of treated sphagnum moss as a growing medium in Taiwan can also vector a “hitch-hiker,” a
blood-sucking midge, Forcipomyia taiwana. This blood-sucking pest is very small (a very narrow body,
and some 1.4 mm in length), and is distributed island-wide. A recent article in the JOURNAL OF MEDICAL
ENTOMOLOGY, Volume 37, Number 2 (2000), “Distribution and Seasonal Occurrence of Forcipomyia taiwana (Diptera: Ceratopogonidae) in the Nantou Area in Taiwan,” at pages 205-09 <Forcipomyia
taiwana.pdf>, teaches that populations of Forcipomyia taiwana have increased rapidly, that Forcipomyia
taiwana females deposit eggs on moist substrate, and that Forcipomyia taiwana adults aggregate in
hedgerows and agricultural fields. Just as the required 0.6 mm screen opening for the supposed “pest ex-
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clusionary” greenhouse will exclude neither identified Thripidae quarantine pests of Phalaenopsis spp.
orchids in Taiwan, nor the mealybug, Planococcus minor, so also will this required 0.6 mm screen opening not exclude Forcipomyia taiwana adult females, and these Forcipomyia taiwana adult females will
find even the treated sphagnum moss growing medium, kept moist to support ideal orchid culture, an
inviting place to deposit their eggs.
Forcipomyia taiwana is just one species of blood-sucking midge endemic to Taiwan, and to China.
The larger genus is Culicoides, with 30 species in Taiwan, and another 80 species in China. Of the 1,400
Culicoides species known worldwide, 96 percent are obligate blood suckers. Only a screen opening smaller than 0.203 mm will prevent entry of Culicoides. Chemical control is usually futile. These blood-sucking midges are known to transmit both human pathogens and pathogens of domesticated and non-domesticated animals. Culicoides species are vectors of arboviruses, such as the West Nile virus. <Arboviruses - DrGreene.com.pdf>.
The general program requirement to use a supposed “pest-exclusionary” greenhouse, 7 C.F.R. §
319.37-8(e)(2)(ii), <7 CFR 319.37-8>, will not mitigate pest risk. We have already explained that the required 0.6 mm screen opening will not exclude identified Thripidae quarantine pests of Phalaenopsis
spp. orchids in Taiwan, and neither will this required 0.6 mm screen opening exclude the mealybug,
Planococcus minor, one of the only two of thirty-five identified arthropod quarantine pests of Phalaenopsis spp. orchids in Taiwan now deemed of significance by the Animal and Plant Health Inspection Service because Planococcus minor will spread along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan.
Indeed, it is obvious from the Pest Risk Assessment that Animal and Plant Health Inspection Service
has elected to ignore our Comments of November 30th, 1998, on the earlier version of the proposed Rule:
“The greenhouse enclosure provides a physical barrier to plants’ exposure to mealybugs from outside.”
“Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing
Media From Taiwan into the United States, May 6th, 2003,” at page 24. <Pest Risk Assessment.pdf>. This
is simply not true, as we have already demonstrated. If Animal and Plant Health Inspection Service has evidence to the contrary, Animal and Plant Health Inspection Service has not described this evidence, nor has
Animal and Plant Health Inspection Service explained just why it has chosen to believe this evidence, instead
of the evidence that we have already provided.
We have not suggested an impossible-to-achieve phytosanitary measure. For one of the nine groups of
plants established in an approved growing medium that is allowed entry into the United States, Rhododendron
spp. from Europe, the required screen opening is reduced to 0.2 mm. 7 C.F.R. § 319.37-8(e)(2)(ii). <7 CFR
319.37-8>. Rutgers Cooperative Extension reports that greenhouse screening with a hole size no larger
than 0.0075 inches/0.1905 mm is required to exclude flower thrips. <Greenhouse screening.pdf>. A
commercial product, the “No-Thrips” insect screen, offers hole size no larger than 0.0059 inches/0.1499
mm. <No-Thrips.pdf>.
If decision-making is to be upheld as rational, decision-making must respond to significant points made at
some point in the public comment period. Home Box Office, Inc. v. FCC, 567 F.2d 9, 35-36 (D.C. Cir. 1977).
Such decision-making is otherwise likely to be challenged, and such decision-making will be rejected in the courts as “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance
with law.” 5 U.S.C. § 706(2)(A). Animal and Plant Health Inspection Service is ignoring evidence al-
- 20 -
ready before it, and, just as well, Animal and Plant Health Inspection Service is ignoring its statutory
obligations.
Beyond this required screening, screening with a hole size too large to exclude identified quarantine
pests of Phalaenopsis spp. orchids in Taiwan, there is the matter of the general program requirement that
the supposed “pest-exclusionary” greenhouse be equipped (at all entryways) with “automatic closing doors.” Doctor Uchida tells us that automatic doors, even a single set of automatic double doors, cannot
prevent insect entry into a greenhouse, and that a truly “pest-exclusionary” greenhouse must have only
one entryway, that two sets of automatic doors (either single or double) must be used, and that there
must be some type of insect mitigation system between the two sets of automatic doors. Such a configuration is required by the general program requirements for Rhododendron species only, 7 C.F.R. §
319.37-8(e)(2)(x), <7 CFR 319.37-8>, and the same such configuration should be required here.
One again, the Comments already received from the Society of American Florists, the Florida Nurserymen & Growers Association, and the American Nursery & Landscape Association, Comments on
Docket Number 98-035-3, June 9th, 2003, confirm just what Doctor Uchida tells us:
Equipping entryways with automatic closing doors is of little protection, unless these are double
door systems, and the production areas are under positive pressure.
SAF/ANLA Comments, at page 3. <SAF-ANLA Comments.pdf>.
General program requirements for greenhouse sanitation, 7 C.F.R. § 319.37-8(e)(2)(ii) (“sanitary
procedures adequate to exclude plant pests and diseases are always employed, including cleaning and
disinfection of floors, benches and tools”), <7 CFR 319.37-8>, will not mitigate pest risk. It turns out that
Animal Plant and Health Inspection Service has recent experience with spread, this time into United
States mainland regions with temperate climates, of a bacterial pathogen, a bacterial pathogen that has
spread not unlike the identified pests of Phalaenopsis spp. orchids in Taiwan will be spread into south
Florida, into Hawaii, and into the territories and commonwealths associated with the United States,
along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan. This bacterial pathogen is Ralstonia solanacearum race 3 biovar 2, and Ralstonia solanacearum
race 3 biovar 2 has spread into United States mainland greenhouses that received geranium plants,
Pelargonium spp., imported from Kenya.
Animal and Plant Health Inspection has recently promulgated an “Action Plan” that incorporates
specific phytosanitary requirements for United States mainland greenhouses that receive imported
geranium plants. These specific phytosanitary requirements include:
Sanitation is essential in the geranium industry to protect against vascular pathogens. Limited access to greenhouses is accomplished through a single entry with double doors. Production
greenhouses have concrete or rock floors, raised benches and drip irrigation (Klopmeyer, 2002).
There is no water flow between plants. Water quality is ensured through different treatments
(UV, chemical or heat treatment) and routine testing (Anonymous, 2002b). Wash basins with
soap and water located at the entry way help prevent the movement of organisms in and out of
the greenhouse structure. Workers are clothed with lab coats or aprons and wear latex gloves.
Gloves are changed or disinfected between every plant (Klopmeyer, 2002). Knives and other
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tools are disinfested between plants either with quaternary ammonium, sodium hypochlorite or
flame sterilization (Anonymous, 2002b; Klopmeyer, 2002). Foot baths at greenhouse entries are
used to prevent organisms from being tracked in and out of the greenhouse. Soilless, sterilized
media is used. Greenhouses are cleaned at the end of the season with hypochlorite or quaternary ammonium, and in some regions, with a formaldehyde drench (Anonymous, 2002b; Klopmeyer, 2002). Also, at the end of the season irrigation systems are cleaned with ammonium
compounds, nitric acid or hypochlorite solution (Anonymous, 2002b). The plant material is
culture indexed over 1-3 years under temperatures that favor expression of R. solanacearum
(and X. campestris pv. pelargonii) symptoms. This ensures that stock is pathogen free. Throughout the production process, greenhouses are scouted and ELISA assays routinely run to ensure
clean stock (Klopmeyer, 2002). Weed control programs are in place within and around greenhouses (Anonymous, 2002b).
“Pest Data Sheet, Ralstonia solanacearum race 3, biovar 2,” February 12th, 2003, at pages 5 through 6,
United States Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Plant Epidemiology and Risk Analysis Laboratory, Raleigh, North Carolina.
<Ralstonia Data Sheet.pdf>.
As is confirmed by “Pest Risk Management Evaluation for Plants in Growing Media, Version 1—
May 2002,” at page 14, <Pest Risk Management Evaluation.pdf>, there are no explicit general program
requirements for greenhouse sanitation (e.g., “suitable disinfectant should, procedures should, grower
should,” emphasis added). Yet this same Guideline also recognizes that “highly publicized measures used
in regular practice are among the most effective means to effectively maintain security against plant disease.” “Pest Risk Management Evaluation for Plants in Growing Media, Version 1—May 2002,” at page
25. <Pest Risk Management Evaluation.pdf>. Without specific phytosanitary measures to regulate sanitation of the greenhouses used for production of finished, flowering Phalaenopsis spp. orchids to be imported from Taiwan, the general program requirements for greenhouse sanitation, 7 C.F.R. § 319.378(e)(2)(ii), <7 CFR 319.37-8>, will not mitigate pest risk.
A good example of specific phytosanitary measures to regulate greenhouse sanitation are those
specific phytosanitary measures recently imposed by Animal and Plant Health Inspection Service for
United States mainland greenhouses that receive imported geranium plants. These specific phytosanitary requirements should also be imposed on the greenhouses used for production of finished, flowering Phalaenopsis spp. orchids to be imported from Taiwan.
The general program requirement to use benches “raised at least 46 cm above the floor,” 7 C.F.R. §
319.37-8(e)(2)(vi), <7 CFR 319.37-8>, will not mitigate pest risk. We have already explained that only
greenhouses with copper flashing affixed to vertical structural components, to side walls, and to bench legs will eliminate mollusk infestation in Taiwan of benched Phalaenopsis spp. orchid plants. “Pest
Risk Management Evaluation for Plants in Growing Media, Version 1—May 2002,” at page 31, <Pest
Risk Management Evaluation.pdf>, simply posits that “[b]ench heights as prescribed in the regulations
are intended to discourage mollusks from reaching plants.” This is not the assumption in the published
Pest Risk Assessment, where Animal and Plant Health Inspection Service supposes that “[g]rowing the
plants on raised benches is an additional physical barrier to snails that might inhabit the cool damp floor
of the greenhouse.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in
- 22 -
Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 23. <Pest Risk
Assessment.pdf>. A snail or slug that is merely discouraged is one thing, and a snail or slug that encounters
“an additional physical barrier” is another. Under the proposed general program requirement, Taiwanese
snails or slug will not encounter a physical barrier. Only greenhouses with copper flashing affixed to
vertical structural components, to side walls, and to bench legs present a physical barrier to snail or
slug infestation.
The general program requirement that allows the importation of mother plants into Taiwan and
requires that these mother plants imported into Taiwan must be grown at least twelve months prior
to importation into the United States of descendant plants from Taiwan, 7 C.F.R. § 319.37-8(e)(2)(iv)(A), <7 CFR 319.37-8>, will not mitigate pest risk. Doctor Uchida tells us that use of imported plants has
great potential for contamination of Phalaenopsis spp. plants in greenhouses in Taiwan with symptomless viral pathogens, with bacterial pathogens that require years to show clear symptoms, or with fungal
pathogens that cannot be observed in plant roots. The longer imported mother plants are kept in Taiwan, the worse the contamination will be to other plants in the same Taiwanese greenhouses. Long retention periods do not increase the likelihood of disease detection; rather, long retention periods increase the likelihood of disease spread in Taiwan. To mitigate pest risk, that which is required is culture indexing of mother plants over terms up to three years, and this under conditions that favor expression of
symptoms, just as Animal and Plant Health Inspection Service requires culture indexing for United
States mainland greenhouses that receive imported geranium plants. “Pest Data Sheet, Ralstonia solanacearum race 3, biovar 2,” February 12th, 2003, at page 6. <Ralstonia Data Sheet.pdf>.
It is simply not the case, as Animal and Plant Health Inspection Service supposes in the published
Pest Risk Assessment, that inspections of mother plants, when these mother plants are only required
to be held for twelve months, will establish the “use of disease-free propagating material.” Per the
published Pest Risk Assessment, this retention period for imported mother plants is “a primary measure to prevent the introduction of fungal pathogens into greenhouse crops.” “Risk Analysis of the
Importation of Moth Orchid, Phalaenopsis spp., Plants in Approved Growing Media From Taiwan
into the United States, May 6th, 2003,” at page 26. <Pest Risk Assessment.pdf>. This “primary measure”
will fail. Inspections of imported mother plants, when these mother plants are only required to be held
for twelve months, and there is no requirement that these mother plants be held under conditions
that favor expression of symptoms, and there is no requirement for culture indexing of mother
plants, will not mitigate pest risk.
The general program requirement that finished, flowering Phalaenopsis spp. orchids be “[i]nspected
in the greenhouse and found free from evidence of plant pests and diseases . . . no more than 30 days
prior to date of export to the United States,” 7 C.F.R. § 319.37-8(e)(2)(viii), <7 CFR 319.37-8>, will not
mitigate pest risk. Doctor Uchida tells us that foliar pathogens require periods longer than three months
before symptoms develop. Foliar pathogens from the genus Phyllosticta require some four months for
clear symptoms to from, and while pathogens from the genus Phyllosticta are not identified as pests of
Phalaenopsis spp. orchids in Taiwan, the genus Phyllosticta, and one of the identified fungi quarantine
pests of finished, flowering Phalaenopsis spp. orchids from Taiwan, Phomopsis orchidphila, are both
members of the Coelomycetes family of fungi pests. The published Pest Risk Assessment assumes that
visual inspections in the greenhouses will suffice, since identified fungi quarantine pests of finished,
flowering Phalaenopsis spp. orchids from Taiwan “infect leaves causing leafspots that are easily detected
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by trained inspectors.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis spp., Plants in
Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 26. <Pest Risk
Assessment.pdf>. True enough, but Animal and Plant Health Inspection Service omits consideration of the
likely importation of finished, flowering Phalaenopsis spp. orchids from Taiwan that are infected with
fungi pests, and yet are imported before clear symptoms of infection can form.
General program requirements, 7 C.F.R. § 319.37-8(e), <7 CFR 319.37-8>, do not impose control
measures (e.g., applying effective chemical insecticides) during the growing period or season for these
Phalaenopsis spp. plants that are to be established on benches in Taiwanese greenhouses. Neither do
these general program requirements require postproduction disinfestation treatment of finished,
flowering Phalaenopsis spp. orchids. Doctor Hara tells us that a proper “systems approach” would include both control measures during the growing period or season, and postproduction treatments—
these control measures could reduce pests to a level at which a postproduction disinfestation treatment would be effective. Without required control measures and postproduction disinfestation
treatment, there will be no effective mitigation of pest risk.
The Environmental Assessment.
The specific risk mitigation measures discussed under the preferred alternative in the Environmental
Assessment, Environmental Assessment, at pages 3 through 5, <Environmental Assessment.pdf>, are the
same risk mitigation measures discussed in the published Pest Risk Assessment. Our Comment on the
risk mitigation measures discussed in the published Pest Risk Assessment is fully applicable to the risk
mitigation measures discussed under the preferred alternative in the Environmental Assessment.
There is, however, one necessary addition to the specific risk mitigation measures discussed under
the preferred alternative in the Environmental Assessment. The published Pest Risk Assessment mentions that a leaf beetle, Medythis suturalis, was intercepted on a shipment of bare-rooted Phalaenopsis
spp. plants exported from Taiwan. The published Pest Risk Assessment dismisses the significance of this
interception because this quarantine pest “was likely present as an accidental hitchhiker,” and “operational procedures, such as prohibiting packing at night under lights, can be immediately implemented in
order to eliminate its occurrence.” “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis
spp., Plants in Approved Growing Media From Taiwan into the United States, May 6th, 2003,” at page 2.
<Pest Risk Assessment.pdf>.
Given this interception, and given that the focus of Animal and Plant Health Inspection Service activities is now to be on risk analysis and assessment, and not on port-of-entry interdiction, it is wrong
not to include, as a specific risk mitigation measure discussed under the preferred alternative in the Environmental Assessment, a requirement that specifically prohibits packing at night under lights, and, as
well, prohibits packing outside the confines of the supposed “pest-exclusionary” greenhouse, 7 C.F.R. §
319.37-8(e)(2)(ii). <7 CFR 319.37-8>.
Our Comment on the “Risk Assessment” section of the published Pest Risk Assessment is fully applicable to the “Affected Environment” discussed in the Environmental Assessment, Environmental Assessment, at pages 5 through 8, <Environmental Assessment.pdf>, and, as well, our Comment on the
“Risk Management” section of the published Pest Risk Assessment is fully applicable to the “Risk Man-
- 24 -
agement” section of the Environmental Assessment, Environmental Assessment, at pages 12 through 18.
<Environmental Assessment.pdf>.
Just as we do not disagree with the determination, in the published Pest Risk Assessment, that Phalaenopsis spp. orchids from Taiwan established in sphagnum moss as a growing medium do not themselves have weediness potential, neither do we disagree with the determinations in the Environmental Assessment that “moth orchids are not expected to become invasive,” that “it is unlikely that Phalaenopsis
species will become invasive in the future,” and that “it is unlikely that moth orchids would compete
with [identified endangered orchid species found in the Commonwealth of Puerto Rico and in the state
of Hawaii] for habitat.” Environmental Assessment, at pages 9 through 11 (parenthetical added). <Environmental Assessment.pdf>.
A penultimate conclusion of the Environmental Assessment is that if “quarantine pests accompanying Phalaenopsis shipments were to become established in the United States, an eradication program
would likely be initiated.” Environmental Assessment, at page 18. <Environmental Assessment.pdf>.
Such “eradication programs” may be effective against arthropod pests, but, surely, Animal and Plant
Health Inspection Service has never eradicated a fungal disease, or a viral disease, without destroying the
host(s). New non-orchid hosts in the United States may be infected also. In south Florida, the state of
Hawaii, the Territory of American Samoa, the Commonwealth of the Northern Mariana Islands, the
Territory of Guam, the Federated States of Micronesia, the United States Virgin Islands, and the Commonwealth of Puerto Rico, all of the later associated with the United States, we often see little or no
change of seasons. Thus introduced pathogens will thrive as long as the host(s) is available. This host, as
previously mentioned, may not be an orchid.
We have demonstrated that there is no good scientific basis for Animal and Plant Health Inspection
Service to suppose that the importation of finished, flowering Phalaenopsis spp. orchids from Taiwan
under the general program requirements of 7 C.F.R. § 319.37-8(e), <7 CFR 319.37-8>, “poses no greater
pest risk than the risk presented by other epiphytic orchid material currently allowed entry as bare rooted plants.” Environmental Assessment, at page 18. <Environmental Assessment.pdf>. Neither is there a
good scientific basis for Animal and Plant Health Inspection Service to suppose that “the application of
additional safeguards [none are specified] will reduce the risk posed by importation of Phalaenopsis spp.
orchids to a low level, that will be the same level or below that posed by currently permitted bare root
importations.” Environmental Assessment, at page 18 (parenthetical added). <Environmental Assessment.pdf>.
Conclusion.
Clearly, the pest risk of importing finished, flowering Phalaenopsis spp. orchids from Taiwan is
greater than the pest risk of importation from Taiwan of bare-rooted, ergo non-flowering, Phalaenopsis
spp. plants. Mitigation measures currently in use as general program requirements of 7 C.F.R. § 319.378(e), <7 CFR 319.37-8>, will not allow safe importation of finished, flowering Phalaenopsis spp. orchids
from Taiwan. Animal and Plant Health Inspection Service has shown no particular mitigation measures
that could reduce pest risk to a level equal to, or less than, the pest risk of importation from Taiwan of
bare-rooted, ergo non-flowering, Phalaenopsis spp. plants. 7 C.F.R. § 319.37-8(g)(4)(ii). <7 CFR 319.378>.
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Animal and Plant Health Inspection Service has yet to comply with the Regulatory Flexibility Act requirement for a proper Initial Regulatory Flexibility Analysis, 5 U.S.C. § 603, and this is just the point
that was made in 1998 by the Office of the Chief Counsel for Advocacy of the United States Small Business Administration. <SBA Office of Advocacy.pdf>. Animal and Plant Health Inspection Service did
not then, and has not since, discussed the likely impact of adoption of the proposed Rule, now narrowed
to apply only to importation from Taiwan of finished, flowering Phalaenopsis spp. orchids, on growers
in Hawaii of all species of potted epiphytic orchids, all of whom, as we have explained, operate as small
businesses, and many of whom are minorities.
Animal and Plant Health Inspection Service has not analyzed factors that contribute to the likelihood
that the domestic market will be overwhelmed, and dominated, by Taiwanese businesses. These factors
include the overwhelming size of the Taiwanese orchid industry compared to the Hawaii orchid growers,
63 Fed. Reg. 46405 (1998), low production costs in Taiwan, and, as we pointed out in our earlier Comments, that growers in Taiwan have been subsidized by the Government of Taiwan through the efforts of
Taiwan Sugar Corporation, a state enterprise under the ministry of Economic Affairs of the Republic of
China. <Taiwan Sugar Corp..pdf>. The Department of Horticulture, Taiwan Sugar Research Institute,
employs nineteen researchers and thirteen technicians, and it pursues a business-oriented research
program on the breeding of Phalaenopsis spp. The yearly research budget is $1,500,000. <HORTICULTURAL RESEARCH IN TAIWAN - WUL, CHENG - WCHR.pdf>.
Nor has Animal and Plant Health Inspection Service considered significant alternatives to the proposed Rule, as required by 5 U.S.C. § 603(c). To date, Animal and Plant Health Inspection Service has
considered alternatives based on pest risk, not economics. 63 Fed. Reg. 46405-06 (1998). <Federal Register Notice.pdf>. Contrariwise to these deliberations, it is economics, not perceived pest risk, which is required by the Regulatory Flexibility Act to be considered. We have previously analyzed here Animal and
Plant Health Inspection Service’s woefully deficient estimate of the annual quantity of finished, flowering Phalaenopsis spp. orchids that will be imported from Taiwan under the proposed Rule. And even if
Animal and Plant Health Service had its own estimate of annual quantities (instead, Animal and Plant
Health Inspection Service has simply adopted the projections of the Government of Taiwan), nowhere
has Animal and Plant Health Inspection Service analyzed the economic impact of these imports of finished, flowering Phalaenopsis spp. orchids from Taiwan on small businesses in Hawaii, domestic growers
of all species of potted epiphytic orchids.
Rational decision-making requires that an agency “respond to significant points raised during the
public comment period,” and, likewise, that an agency “consider significant alternatives to the course it
ultimately chooses.” Allied Local & Regional Manufacturers Caucus v. EPA, 215 F.3d 61, 80 (D.C. Cir.
2000), cert. denied, 532 U.S. 1018 (2001).
Adoption of the proposed Rule will generate a dramatic increase in the sales of Taiwanese orchid
growers, Taiwanese orchid growers who will now be allowed, without any quantity restriction, to provide potted, finished, flowering Phalaenopsis spp. orchids directly to United States retailers. It is likely
that the whole panoply of Hawaii-grown potted orchids will be displaced in our mainland markets by
cheap potted, finished, flowering Phalaenopsis spp. orchids furnished by Taiwanese growers directly to
United States retailers. Growers of all species of potted epiphytic orchids in Hawaii will suffer economic
devastation as a result.
- 26 -
Beyond economic devastation from this new competition, domestic growers of all species of potted
epiphytic orchids will also suffer economic devastation as a result of the need to invest in expensive, and
labor-intensive, treatments of existing greenhouse orchid stocks to combat the identified pests of Phalaenopsis spp. orchids in Taiwan, pests that will be spread into south Florida, into Hawaii, and into the
territories and commonwealths associated with the United States, along the pathway initiated by importation of finished, flowering Phalaenopsis spp. orchids from Taiwan.
The environmental impact of pests spread along the pathway initiated by importation of unlimited
quantities of finished, flowering Phalaenopsis spp. orchids from Taiwan will likewise be severe. This environmental impact will not be remedied, after the pathway is initiated, by initiation of interdiction. Recall the basic premise adopted by Animal and Plant Health Inspection Service: “Port-of-entry inspection
is not considered sufficient to provide phytosanitary security.” “Guidelines for Pathway-Initiated Pest
Risk Assessments, Version 5.02, October 17th, 2000,” at page 11. (emphasis added). <Guidelines.pdf>.
The proposed Rule must not be adopted.
Sincerely,
Cyrus E. Phillips, IV
Cc:
Hawaii Orchid Growers Association
- 27 -
Enclosure 1
Docket No. 98-035-3
Regulatory Analysis and Development Branch
Policy and Program Development Division
Animal and Plant Health Inspection Service
Station 3C71
4700 River Road, Unit 118
Riverdale, Maryland 20737-1238
June 01, 2003
Dear Sirs/Madams,
The following are comments in regards to the “Proposed Rule for the Importation of
Moth Orchids (Phalaenopsis spp.) in Growing Media from the Republic of China (Taiwan)”
(Docket No. 98-035-3) and “Risk Analysis of the Importation of Moth Orchid, Phalaenopsis
spp., Plants in Approved Growing Media from Taiwan into the United States, May 06,2003.”
Based on scientific evidence, I have major concerns regarding this proposed rule, and
highly recommend that it NOT be approved for the following reasons:
1) Hawaii is in the same Plant Hardiness Zone 11 as the orchid-growing areas of
Taiwan, and since most orchids in Hawaii are grown outdoors or in only semienclosed shadehouses or greenhouses, the risk rating for climate-host interaction for
any pests found on orchids in Taiwan is extraordinarily high (3),
2) There is a high dispersal potential of many pests found on Phalaenopsis in Taiwan
because visual quarantine inspection of potted orchids is grossly inadequate for
detecting small insects and insect stages, cryptic insect stages, and subterranean pests
such as nematodes and snails.
3) Both the economic impact and environmental impact on Hawaii are gravely
underestimated in the EA and RA because only a small fraction (<12%) of the known
quarantine pests in Taiwan were considered. Some insect pests were not considered
by APHIS because the insect plant host records did not specify Phalaenopsis spp.,
even though such records generally do not specify Orchidaceae species.
4) Risk management measures implemented by Taiwan are inadequate. The use of
sphagnum moss that has been found to harbor plant parasitic nematodes and insects.
There is no specific systems approach protocol or postproduction (just prior to market
or at port of entry) disinfestation treatment.
5) The record of the alien invasion in Hawaii, with a colonization rate 500 times that of
the continental US, is a testament to the inadequacy of the federal quarantine system.
Improvements to regulations, manpower, and inspection techniques must be
implemented to stop or slow the influx of alien pests into Hawaii. This proposed rule
will not be a step in that direction.
Background
In October to December 1998, over 35 separate comments from nurseries, growers’
associations, Society of American Florists, American Nursery and Landscape Association,
Hawaii Dept. of Land and Natural Resources, Hawaii Dept. of Agriculture, U.S. Fish and
Wildlife Service, U. S. Dept. of Interior, U.S. Geological Survey, University of Hawaii, and the
Hawaii Congressional Delegation were sent to Docket No. 98-035-1 regarding “Importation of
Moth Orchid (Phalaenopsis spp.) Seedlings from Taiwan in Growing Media into the United
States – A Qualitative, Pathway-Initiated Pest Risk Assessment” (USDA 1997). To date, we
1
are unaware of any published responses or discussions of comments in Docket No. 98-035-1
(USDA 1998). However, on May 9, 2003 the Federal Register (Vol. 68, No. 90, 24915)
published “Importation of Phalaenopsis spp. from Taiwan in Growing Media: Availability
of Environmental Assessment and Request for Comments” (USDA 2003b). In reviewing the
literature cited in the Environmental Assessment (EA), another official document titled “Risk
Analysis of the Importation of the Moth Orchids, Phalaenopsis spp., Plants in Approved
Growing Media from Taiwan in the United States” was uncovered (USDA 2003a).
Because of time constraints and the request in the Federal Register (68: 24915) for
comments specifically on the Environmental Assessment (EA 05.03), our comments will be
focused on the EA, with references to the Risk Analysis (RA 05.06.03). Subsequently, we are
highly expectant for a comment period on the more comprehensive RA to be announced in the
near future.
Analysis of Quarantine Pests
The major flaw in the EA and the RA is that only two (2) of the 35 species of arthropod
quarantine pests (EA, pp. 6; RA, pp. 9-10) identified on Phlaenopsis spp. orchids in Taiwan
were determined to possibly follow the pathway on unmitigated importation into the U.S. based
on APHIS Guidelines for Pathway-Initiated Pest Risk Assessments Version 5.02 (USDA 2000).
APHIS rated the potential consequences of introduction of quarantine pests on five risk
elements: climate-host interaction, host range, dispersal potential, economic impact and
environmental impact:
CONSEQUENCES OF INTRODUCTION
1. Climate-Host Interaction: The subtropical and tropical orchid-growing areas of Taiwan
correspond to USDA Plant Hardiness Zone 11 (areas where the average annual minimum
temperature is over 40o F), and the RA concluded that Zone 11 is “limited to the southern part of
Florida” (RA, pp. 10). DOESN’T THIS ENVIROMENTAL ASSESSMENT AND PEST RISK
ANALYSIS CONSIDER HAWAII TO BE PART OF THE UNITED STATES? Is Hawaii in
Zone 11? YES! APHIS implied that those quarantine pests associated with orchid plants will be
able to establish and spread in the out-of-doors environment in Zone 11, and concluded that
“while orchids may be grown outdoors in the southern tier of the U.S., generally, they are grown
indoors and/or in temperature controlled production facilities” (RA, pp. 10). In Hawaii, most
orchids are grown outdoors or under shadehouses and almost never in completely enclosed
temperature-controlled greenhouses. Therefore, for Hawaii, the risk rating for climate-host
interaction for any pests found on orchids in Taiwan is extraordinarily High (3).
2. Host Range: APHIS rationalized that thrips were NOT analyzed as quarantine pests because
plant host records were not specifically linked to Phalaenopsis (RA, pp. 9). This is totally
invalid, because scientific publications routinely report “orchid” or Orchidaceae in insect host
records and do not specify the orchid species, such as Phalaenopsis (Kumashiro et al. 2001,
Hawaii Dept. of Agriculture 2000).
3. Dispersal Potential: APHIS concluded that Acuta (=Bradybaena) tourranensis and
Bradybaena sp. have limited natural dispersal capabilities (RA, pp. 11) but totally ignores the
2
fact that the snails can be transported undetected on roots of orchid plants. Snails, including
Bradybaena sp., are known to occur on roots of potted orchids (Hara and Hata 1999). Mersino
(1998) observed Sublina octona and the bush snail, B. similaris on orchids in Hawaii, stunting
potted orchid plants. Snails have been intercepted on bare-rooted Phalaenopsis orchids from
Taiwan (Okada and Reimer 1998).
4. Economic Impact: Economic impact derived in the EA and RA is profoundly invalid
because the EA and RA addressed the concerns of only one specific species of mollusk, two
arthropod species and three fungi (EA, pp. 6; RA, pp. 9-10). There are >33 other arthropod
species, an unknown number of mollusk species, and at least 14 species of fungi and bacteria
that are known quarantine pests in Taiwan. These quarantine pest species could without
difficulty cause major economic impact, because Hawaii is in Zone 11, the same zone as the
orchid-growing areas of Taiwan.
5. Environmental Impact: Similarly, the EA and RA are severely invalid because only one
specific species of mollusk, two arthropod species and three fungi are considered as quarantine
pests that may follow the pathway on Phalaenopsis spp. from Taiwan (See above No. 4,
Economic Impact).
RISK MANAGEMENT
No Specific Systems Approach and Post-Harvest Treatment
The RA and EA mentioned systems approach only in theory without a specific protocol
for Phalaenopsis spp. from Taiwan (RA, pp. 18; EA, pp. 14). The RA also reported that there is
no specific postharvest disinfestation treatment for Phalaenopsis spp. orchids from Taiwan and
rates this risk element High (3) for all quarantine pests (RA, pp. 15). This is a major deficiency
as most systems approach to quarantine security has an effective postharvest or postproduction
(i.e., just prior to market) treatment (Hata el al. 1992). Pest control during the growing period or
season of orchid plants, and an efficacious disinfestation treatment prior to shipment are both
essential to assure pest-free orchid plants. It is highly recommended that a systems approach
program that includes an effective postproduction treatment be developed prior to the approval
of allowing Phalaenopis spp. in growing media from Taiwan into the U.S.
Fig. 1 presents a flow chart for developing a systems approach program to assure pestfree products for export. The systems approach is based on the fact that control measures during
the growing period or season (e.g., applying effective chemical insecticides) can reduce pests to
a level at which a postharvest disinfestation treatment (e.g., an insecticidal dip or a heat
treatment) is 100% effective.
3
Fig. 1. A system approach to quarantine security (Hara 1994).
Production Pest
Management
Biological Control
Cultural Control
Chemical Control
Physical Control
Postharvest or Postproduction*
Disinfestation
Heat or Cold
Controlled
Atmosphere
Insecticidal dip
Irradiation
Other safe fumigants?
Pest-Free Products
for Exports
*Postharvest designates the interval just after harvest for cut flowers and foliage; Postproduction
designates the interval just prior to market for potted plants
Quarantine Pests are Not Detected by Inspections
The RA concluded that standard inspection techniques (initial human visual inspection
only) will be highly ineffective at detecting small insect or mollusk eggs, crawlers and nymphs
hidden in soil, between leaves and within flowers (RA, pp. 16). In addition, many insect species
(leafhoppers, planthoppers, plant bugs, katydid, leafminers) insert their eggs into tissue of plants,
and these eggs cannot be detected even with the aid of a magnifer or microscope. Mr. Bill
Callison, Assistant Director, Plant Health and Pest Prevention Services, California Dept. of Food
and Agriculture, emphasizes that visual inspection represents one of the fundamental flaws in the
whole issue of plant imports: risk mitigation is most often dependent on visual inspection as the
basis for pest/pathogen detection. The problem is that most pest pathogens, many soil-borne
insects, and nematodes are not visually detectable. The fact that no pest problems have been
encountered might well be a function of the weakness of visual inspection as a detection method.
(Callison 2003).
Sphagnum Moss is Not Pest-Free
Sphagnum moss is one of the approved growing media (7 CFR § 319.37-8 (e) (1)),
provided the media was not previously used. The EA concluded that the relatively low pH of
sphagnum moss is associated with conditions that do not favor bacterial and some types of
fungal growth, and studies on APHIS-approved growing media found that pathogens are not
present (EA, pp. 14-15). However Callison (2003) reported “We have found plant parasitic
nematodes, insect pests, etc in sphagnum moss from Canada.” Has sphagnum moss in Taiwan
been thoroughly inspected for nematodes and insect pests?
4
IS THE FEDERAL QUARANTINE SYSTEM PROTECTING HAWAII’S NATURAL
RESOURCES AND DIVERSIFIED AGRICULTURE?
Hawaii, the Alien Species Capital of the United States: A Case Study
The rate of invasion by non-indigenous or alien species in Hawaii is more than a million
times the natural colonization rate and nearly twice the number absorbed each year by the entire
North American continent (Mooney and Drake 1987). From 1942 to 1972, there were 250 and
244 immigrant species of insects and mites that invaded the 48 contiguous states and Hawaii,
respectively (McGregor 1973), which translates to a colonization rate in Hawaii (40 species per
thousand square miles) that is 500 times the rate in the continental U.S. (excluding Alaska). Of
the approximately 5,848 that have been introduced in the U.S., 2,848 species are in Hawaii and
the other 3,000 species in continental U.S. (Allison and Evenhuis 2001; Pimentel et al. 2002).
Alien species account for >34% of all insect species in Hawaii and only 3.2% of all insect
species in the continental U.S. (Fig. 2). These alien species arrive equally from east and west of
Hawaii (Fig 3).
Fig. 2. Proportion of alien insect species in continental U.S. versus Hawaii.
Alien = 3.2% (3,000)
Native
Alien
Alien = 34.4% (2,848)
Continental U.S.
Total = 93,000
Hawaii
(Allison & Evenhuis 2001)
Total = 8,281
Fig. 3. Origin of alien insect species in Hawaii (Nakahara 2002).
North
America
24%
Other areas
20%
Tropical
America
16%
Southeast
Asia
24%
Southwest
Pacific
16%
(Nakahara 2002)
5
Although, Hawaii does not have any direct flights or shipments from tropical regions of
North, South and Central America, 16% of all alien insect pest species established themselves in
Hawaii from those regions. Most of these species required a plant host for survival, therefore it
is believed that these pests entered Hawaii on infested plants that transited through continental
U.S. (Nakahara 2002).
Interestingly, most of the alien species in Hawaii are in the order Homoptera, which are
sucking plant feeders (Heu 2002) (Fig 4). These plant feeders could hardly have established in
Hawaii without being carried in or on living plant material. Most homopterans are weak flying,
cryptic and sedentary insects (aphids, leafhoppers, mealybugs scale insects, whiteflies).
Hymenopterans (parasitic wasps) are second to homopterans in the greatest number of alien
species in Hawaii. These parasitic species apparently were accidentally introduced along with
their hosts, the pestiferous sucking plant feeders, on plant material.
Fig. 4. Alien species (by insect order) invading Hawaii 1981-2002.
70
Orthoptera
Heteroptera
No. Species
60
50
Lepidoptera
40
Acari
Thysanoptera
30
Diptera
20
Coleoptera
Hymenoptera
10
Homoptera
0
(Heu 2002)
Insect Orders
Three major characteristics of Hawaii that make it ideal for successful invasion by alien
species are: 1) its island ecology, 2) its tropical climate, and 3) its role as a major transportation
hub. Prior to human settlement, Hawaii’s isolation in the middle of the Pacific Ocean acting as a
2,500 mile-wide moat limited the rate of colonization to only a few plants, insects, birds and
other organisms (OTA 1993, Holt 1996). At the same time, a variety of ecological niches were
open for alien species to successfully colonize in the absence of natural enemies (predators,
parasites, pathogens) to control their populations (Loope et al. 1988). Honolulu International
Airport is the 15th busiest airport in the world, averaging one arriving flight every 1.3 min with a
flying time averaging 4 to 7 h, which probably allows survival of alien organisms hitchhiking in
cargo shipments, smuggled goods and visually-inspected or untreated commodities (Holt 1996,
OTA 1993, AHH unpublished data). Ocean freight containers with sophisticated temperature
and humidity control for huge quantities of fresh commodities allow survival of alien species
during the 7 to 14 day journey to Hawaii. Lack of adequate state funding for quarantine
programs and poorly coordinated quarantine efforts between state and federal agencies (OTA
6
1993; AHH personal observations) exacerbate these as major pathways for the entry of alien
species. Federal quarantines have high priorities for protecting mainland agriculture
(major emphasis only on fruit flies) and enforcing international trade agreements,
sometimes at the expense of Hawaii’s natural resource and diversified agriculture (OTA
1993). Federal quarantine regulations stipulate that cargo and passengers from Hawaii to the
U.S. mainland are to be inspected by USDA’s Animal and Plant Health Inspection Service
(APHIS) for prohibited materials (fresh produce, cut flowers, and other plant materials) to
prevent pests from reaching the mainland; this accounts for about 85% of APHIS plant
quarantine activities in Hawaii, while inspection of ships and planes arriving from foreign
countries accounts for only 15% of APHIS activities in Hawaii (OTA 1993). Moreover,
agricultural inspection for foreign arrivals in Hawaii is now under the U.S. Dept. of Homeland
Security with emphasis on terrorism and not quarantine pests.
Because Federal quarantine inspection of foreign arrivals focuses almost exclusively on
“federally prohibited agricultural pest species” that are found predominantly in U.S. mainland
regions with temperate climates, and therefore, would probably not become established in
Hawaii, this policy fails to intercept new pests from subtropical and tropical regions (including
Taiwan) into Hawaii. For example, state officials tried unsuccessfully to have the Jack
Beardsley mealybug, Pseudococcus jackbeardsleyi Gimpel and Miller, a pest on banana,
declared a federally prohibited species after it repeatedly turned up in the mid-1980’s on bananas
from Central America that were shipped from the U.S. mainland to Hawaii (Gill 1996). This
mealybug, with a wide host range, eventually slipped in and established itself in Hawaii,
becoming a serious pest on dendrobium orchids (Hara and Hata 1999). Because it was a serious
pest of bananas in Central America requiring repeated chemical insecticide applications, this
mealybug was already resistant to many of the common organophosphate, carbamate and
pyrethroid insecticides when it arrived in Hawaii (AHH, unpublished data). Dendrobium orchids
exported to California are now commonly rejected because of mealybug infestations (Hara and
Hata 1999).
Without major state and federal budget increases to specifically support exclusion of
alien species into Hawaii, and appropriate changes to state and federal quarantine legislations,
alien species will continue to invade Hawaii at the normal, alarming rate of 20 alien species per
year. We all seem to disturbingly accept the consequences of alien species destroying
agriculture and devastating our fragile natural environment.
The status quo in the alien species exclusion policy in Hawaii for the past 55 years or
longer is exemplified by the recent invasion of eight new alien pest species that seriously
threatens Hawaii’s diversified agriculture, fragile island ecosystem, and the high quality of life.
These alien species and its origin include: the coqui frog, Eleutherodactylus coqui Thomas,
(Anura: Leptodactylidae) from Puerto Rico (Kraus 1999); the stinging nettle caterpillar, Darna
pallivitta Moore (Lepidoptera: Limacodidae) from Taiwan (Conant et al. 2001); the little fire ant,
Wasmannia auropunctata (Roger) (Hymenoptera: Formicidae) from Central America (Conant
and Hirayama 2000); another fire ant, Solenopsis sp. from an unknown origin (Heu and Chun
2001); the red gum lerp psyllid, Glycaspis brimblecombei Moore (Homoptera: Psyllidae) from
Australia (Nagamine and Heu 2001a); the citrus leafminer, Phyllocnistis citrella Stainton
(Lepidoptera: Gracillariidae) from southeast Asia (Nagamine and Heu 2001b); the citrus
blackfly, Aleurocanthus woglumi Ashby (Homoptera: Aleyrodidae) from India (Heu and
Nagamine 2001) and the aster leafhopper, Macrosteles fascifrons (Stal) (Homoptera:
Cicadellidae) from North America (Heu et al. 2002).
7
The proposal to allow orchids of the genus Phalaenopsis to be imported from
Taiwan in growing media should be receded until APHIS conducts a major review,
evaluation, and overhaul of Q37 and all other quarantine programs to effectively safeguard
America’s (which includes Hawaii’s) agriculture and natural resources.
For any comments or questions, please contact Arnold Hara at: Ph: (808) 974-4105, Fax:
(808)974-4110, email: [email protected].
Sincerely,
Arnold H. Hara, Ph.D.
Professor & Entomologist
University of Hawaii at Manoa
College of Tropical Agriculture and Human Resources
cc:
Hawaii Orchid Growers Association
Big Island Dendrobium Growers Association
Hawaii Dept. of Agriculture
Hawaii Farm Bureau
Society of American Florist
American Nursery & Landscape Association
References Cited
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Hawaii’s invasive species, a guide to invasive plants and animals in the Hawaiian Islands. A
Hawaii Biological Survey Handbook, Mutual Publishing and Bishop Museum Press,
Honolulu, HI.
Callison, B. 2003. Personal communication (e-mail May 19, 2003) re: Importation of potted
orchids from Taiwan.
Conant, P. and C. Hirayama. 2000. Wasmannia auropunctata (Hymenoptera: Formicidae):
established on the Island of Hawaii. In: N.L. Evenhuis and L.G. Eldredge (eds.) Bishop
Museum Occasional Papers - Records of the Hawaii Biological Survey for 1999-Part 2:
Notes. No. 64. 63 pp.
Conant, P., A.H. Hara, L.M. Nakahara and R.A. Heu. 2001. Nettle Caterpillar, Undetermined
species, (Lepidoptera: Limacodidae). New Pest Advisory No. 01-03. Hawaii Dept. of Agric.
Plant Pest Control Branch, Division of Plant Industry, Honolulu, HI. 2 pp.
Gill, R. J. (ed.). 1996. Mealybugs: Name changes and new species information California Plant
Pest and Disease Report (CPPDR) 15: 69-70. California Dept. of Food and Agriculture,
Plant Pest Diganostics Center, Sacramento, CA.
Hara, A. H. 1994. Ornamental and flowers, pp. 329-347, In R. E Paull & J. W. Armstrong
[eds.], Insect Pests and Fresh Horticultural Products: Treatments and Responses. CAB
8
International, Wallingford, UK.
Hara, A. H. and T. Y. Hata. 1999. Pests and pest management, pp. 29-45, In K. Leonhardt and
K. Sewake, Growing Dendrobrium Orchids in Hawaii, Production and Management Guide,
College of Tropical Agriculture and Human Resources, University of Hawaii at Manoa, ,
Honolulu, HI.
Hata, T. Y., A. H. Hara, E. B. Jang, L. S. Imaino, B. K. S. Hu & V. L. Tenbrink. 1992. Pest
management before harvest and insecticidal dip after harvest as a systems approach to
quarantine security for red ginger. J. Econ. Entomol. 85: 2310-2316.
Hawaii Department of Agriculture. 2000. Distribution and host records of agricultural pests and
other organisms in Hawaii. Survey program, Plant Pest Control Branch, Plant Industry
Division, Honolulu, HI.
Heu, R.A. and M. Chun. 2001. A new ant found in Hawaii, Solenopsis sp. (Hymenoptera:
Formicidae). New Pest Advisory No. 00-02. Hawaii Dept. of Agric. Plant Pest Control
Branch, Division of Plant Industry, Honolulu, HI. 2 pp.
Heu, R.A. and W.T. Nagamine. 2001. Citrus blackfly, Aleurocanthus woglumi Ashby
(Homoptera: Aleyrodidae). New Pest Advisory No. 99-03. Hawaii Dept. of Agric. Plant Pest
Control Branch, Division of Plant Industry, Honolulu, HI. 2 pp.
Heu, R. 2002. Alien species (by order) invading Hawaii 1981-2002. Personnel communication.
Hawaii Dept. of Agriculture, Plant Pest Control Branch, Honolulu, HI.
Heu, R. A., R.T. Hamasaki, B. R. Kumashiro and S.K. Fukuda. 2002. Aster Leafhopper
Macrosteles quadrilineatus Forbes [=Marosteles fascifrons (Stal)] (Homoptera:
Cicadellidae) New Pest Advisory no. 02-01 Hawaii Dept. of Agriculture, Plant Pest Control
Branch, Honolulu, HI.
Holt, A. 1996. An alliance of biodiversity, agriculture, health, and business interests for
improved alien species management in Hawaii. Presented at Norway/U.N. Conference on
Alien Species. http:www.hear.org/AlienSpeciesInHawaii/articles/Norway.pdf
Kraus, F., E. W. Campbell, III, A. Allison, and T. Pratt. 1999. Eleutherodactylus frog
introductions to Hawaii. Herpetological Review 30:21-25.
Kumashiro, B. R., R. A. Heu, G. M. Nishida and J. W. Beardsley. 2001. New state records of
immigrant insects in the Hawaiian islands for the year 1999. Proc. Hawaii. Entomol. Soc.
35: 170-184.
Loope L.L., O. Hamann and C.P. Stone. 1988. Comparative biology of oceanic archipelagoes.
Bioscience 38: 272-282.
McGregor, R.C. 1973. The Emigrant Pests. A Report to Animal and Plant Health Inspection
Service. 167 pp.
Mersino, E. 1998. Personal communication (e-mail 08/11/98) re: Dendrobium IPM manual.
Mooney, H.A. and J.A. Drake. 1987. The ecology of biological invasions. Environment 29: 12.
Nagamine, W.T. and R.A. Heu. 2001a. Red gum lerp psyllid, Glycaspis brimblecombei Moore
(Homoptera: Psyllidae) New Pest Advisory No. 01-02. Hawaii Dept. of Agric. Plant Pest
Control Branch, Division of Plant Industry, Honolulu, HI. 2 pp.
Nagamine, W.T. and R.A. Heu. 2001b. Citrus leafminer, Phyllocnistis citrella Stainton
(Lepidoptera: Gracillariidae). New Pest Advisory No. 00-01. Hawaii Dept. of Agric. Plant
Pest Control Branch, Division of Plant Industry, Honolulu, HI. 2 pp.
Nakahara, L.M. 2002. Plant pest control in Hawaii. Micronesica Suppl. 6: 93-103.
Okada, C. and Reimer, N. 1998. Personal communication (meeting 10/06/98), Hawaii Dept. of
Agriculture, Plant Quarantine Branch, Honolulu, HI.
Office of Technology Assessment (OTA). 1993. Harmful Non-Indigenous Species in the United
States. U.S. Congress, OTA-F-565. U.S. Govt. Printing Office, Washington DC. 362 pp.
9
Pimentel, D., L. Lach, R. Zuniga and D. Morrison. 2002. Environmental and economic costs
associated with non-indigenous species in the United States, pp. 285-303 In D. Pimental (ed.)
Biological invasions: economical and environmental cots of alien plant, animal and microbe
species, CRC Press, Boca Raton, FL.
U.S. Department of Agriculture, Animal and Plant Health Inspection Service. 2003a. Risk
analysis of the importation of moth orchids, Phalaenopsis spp., plants in approved growing
media from Taiwan into the United States, 05.06.03. http://www.aphis.usda.gov/ppq/pim
U.S. Department of Agriculture, Animal and Plant Health Inspection Service. 2003b. Proposed
rule for the importation of moth orchids (Phalaenopsis spp.) in growing media from the
Republic of China (Taiwan) into the United States, 05.03. http://www.aphis.usda.gov/
ppd/es/ppqdocs.html.
U.S. Department of Agriculture, Animal and Plant Health Inspection Service. 2000. Guidelines
for pathway-initiated risk assessments, version 5.02, Riverdale, MD, 31 pp.
U.S. Department of Agriculture, Animal and Plant Health Inspection Service. 1997.
Importation of moth orchid (Phalaenopsis spp.) seedlings from Taiwan in growing media
into the United States, A qualitative, pathway-initiated pest risk assessment, April 1997.
USDA, APHIS, PPQ, BATS, Riverdale, MD.
U.S. Department of Agriculture, Animal and Plant Health Inspection Service. 1998.
Importation of orchids in growing media. 7CFR319, Docket No. 98-035-11, USDA, APHIS.
Federal Register 63 (169).
taiwanorchidhara0503.doc
10
Referenced Documents
http://frwebgate6.access.gpo.gov/cgi-bin/waisgate.cgi?WAISdocID=436031521015+2+0+0&WAISaction=retrieve
[Federal Register: May 9, 2003 (Volume 68, Number 90)]
[Notices]
[Page 24915]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr09my03-40]
========================================================================
Notices
Federal Register
________________________________________________________________________
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or proposed rules that are applicable to the public. Notices of hearings
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[[Page 24915]]
DEPARTMENT OF AGRICULTURE
Animal and Plant Health Inspection Service
[Docket No. 98-035-3]
Importation of Phalaenopsis spp. From Taiwan in Growing Media;
Availability of Environmental Assessment and Request for Comments
AGENCY: Animal and Plant Health Inspection Service, USDA.
ACTION: Notice of availability and request for comments.
----------------------------------------------------------------------SUMMARY: We are informing the public that the Animal and Plant Health
Inspection Service has prepared an environmental assessment for a
proposal to allow orchids of the genus Phalaenopsis to be imported from
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Taiwan in approved growing media. The environmental assessment
documents our review and analysis of environmental impacts associated
with the proposed action. We are making the environmental assessment
available to the public for review and comment.
DATES: We will consider all comments that we receive on or before June
9, 2003.
ADDRESSES: You may submit comments by postal mail/commercial delivery
or by e-mail. If you use postal mail/commercial delivery, please send
four copies of your comment (an original and three copies) to: Docket
No. 98-035-3, Regulatory Analysis and Development, PPD, APHIS, Station
3C71, 4700 River Road Unit 118, Riverdale, MD 20737-1238. Please state
that your comment refers to Docket No. 98-035-3. If you use e-mail,
address your comment to [email protected]. Your comment must
be contained in the body of your message; do not send attached files.
Please include your name and address in your message and ``Docket No.
98-035-3'' on the subject line.
You may read any comments that we receive on this docket in our
reading room. The reading room is located in room 1141 of the USDA
South Building, 14th Street and Independence Avenue SW., Washington,
DC. Normal reading room hours are 8 a.m. to 4:30 p.m., Monday through
Friday, except holidays. To be sure someone is there to help you,
please call (202) 690-2817 before coming.
APHIS documents published in the Federal Register, and related
information, including the names of organizations and individuals who
have commented on APHIS dockets, are available on the Internet at
http://www.aphis.usda.gov/ppd/rad/webrepor.html.
FOR FURTHER INFORMATION CONTACT: Mr. William Thomas, Import Specialist,
Phytosanitary Issues Management, PPQ, APHIS, 4700 River Road Unit 140,
Riverdale, MD 20737-1236; (301) 734-6799.
SUPPLEMENTARY INFORMATION:
Background
The Animal and Plant Health Inspection Service (APHIS) of the
United States Department of Agriculture regulates the importation of
plants and plant parts into the United States to guard against the
introduction of plant pests and noxious weeds into the United States.
The regulations pertaining to the importation of plants and plant parts
are set forth in the Code of Federal Regulations (CFR), title 7,
chapter III, part 319.
On September 1, 1998, we published in the Federal Register (63 FR
46403-46406, Docket No. 98-035-1) a proposal to amend the regulations
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to add orchids of the genus Phalaenopsis to the list of plants that may
be imported from all areas of the world in an approved growing medium
subject to specified growing, inspection, and certification
requirements. We accepted comments on our proposal for a total of 90
days, ending December 1, 1998.\1\
--------------------------------------------------------------------------\1\ The comment period on the proposed rule was extended from 60
to 90 days in a notice published in the Federal Register on October
29, 1998 (63 FR 57932).
--------------------------------------------------------------------------In response to comments received on the proposed rule, APHIS
narrowed the application of the rule to Phalaenopsis spp. from Taiwan
only and entered into formal section 7 consultation with the U.S. Fish
and Wildlife Service (FWS) to assess the potential effects of the
proposed action on endangered or threatened species, as required under
the Endangered Species Act. On April 7, 2003, FWS concluded the section
7 consultation process by concurring with APHIS's determination that
the importation of Phalaenopsis spp. from Taiwan in growing media will
not adversely affect federally listed or proposed endangered or
threatened species or their habitats.
Upon receiving concurrence from FWS, APHIS prepared an
environmental assessment in accordance with: (1) The National
Environmental Policy Act of 1969, as amended (NEPA) (42 U.S.C. 4321 et
seq.), (2) regulations of the Council on Environmental Quality for
implementing the procedural provisions of NEPA (40 CFR parts 15001508), (3) USDA regulations implementing NEPA (7 CFR part 1b), and (4)
APHIS' NEPA Implementing Procedures (7 CFR part 372).
This notice announces the availability of the environmental
assessment for public review and comment. The assessment, titled
``Proposed Rule for the Importation of Moth Orchids (Phalaenopsis spp.)
in Growing Media From the Republic of China (Taiwan),'' and dated April
2003, may be viewed on the Internet at http://www.aphis.usda.gov/ppd/es/
ppqdocs.html.
You may request paper copies of the environmental
assessment from the person listed under FOR FURTHER INFORMATION
CONTACT. Please refer to the title of the environmental assessment when
requesting copies.
The environmental assessment is also available for review in our
reading room (the location and hours of the reading room are listed
under the heading ADDRESSES at the beginning of this notice).
Done in Washington, DC, this 6th day of May 2003.
Peter Fernandez,
Acting Administrator, Animal and Plant Health Inspection Service.
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[FR Doc. 03-11538 Filed 5-8-03; 8:45 am]
BILLING CODE 3410-34-P
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34898
Notices
Federal Register
Vol. 68, No. 112
Wednesday, June 11, 2003
This section of the FEDERAL REGISTER
contains documents other than rules or
proposed rules that are applicable to the
public. Notices of hearings and investigations,
committee meetings, agency decisions and
rulings, delegations of authority, filing of
petitions and applications and agency
statements of organization and functions are
examples of documents appearing in this
section.
DEPARTMENT OF AGRICULTURE
Animal and Plant Health Inspection
Service
[Docket No. 98–035–4]
Importation of Phalaenopsis spp.
From Taiwan in Growing Media;
Availability of Environmental
Assessment and Request for
Comments
AGENCY: Animal and Plant Health
Inspection Service, USDA.
ACTION: Notice of reopening and
extension of comment period.
SUMMARY: We are reopening and
extending the comment period for an
environmental assessment for a
proposal to allow orchids of the genus
Phalaenopsis to be imported from
Taiwan in approved growing media.
This action will allow interested
persons additional time to prepare and
submit comments.
DATES: We will consider all comments
that we receive on or before July 9,
2003.
You may submit comments
by postal mail/commercial delivery or
by e-mail. If you use postal mail/
commercial delivery, please send four
copies of your comment (an original and
three copies) to: Docket No. 98–035–3,
Regulatory Analysis and Development,
PPD, APHIS, Station 3C71, 4700 River
Road Unit 118, Riverdale, MD 20737–
1238. Please state that your comment
refers to Docket No. 98–035–3. If you
use e-mail, address your comment to
[email protected]. Your
comment must be contained in the body
of your message; do not send attached
files. Please include your name and
address in your message and ‘‘Docket
No. 98–035–3’’ on the subject line.
You may read any comments that we
receive on this environmental
assessment in our reading room. The
reading room is located in room 1141 of
ADDRESSES:
VerDate Jan<31>2003
23:27 Jun 10, 2003
Jkt 200001
the USDA South Building, 14th Street
and Independence Avenue SW.,
Washington, DC. Normal reading room
hours are 8 a.m. to 4:30 p.m., Monday
through Friday, except holidays. To be
sure someone is there to help you,
please call (202) 690–2817 before
coming.
APHIS documents published in the
Federal Register, and related
information, including the names of
organizations and individuals who have
commented on APHIS dockets, are
available on the Internet at http://
www.aphis.usda.gov/ppd/rad/
webrepor.html.
FOR FURTHER INFORMATION CONTACT: Mr.
William Thomas, Import Specialist,
Phytosanitary Issues Management, PPQ,
APHIS, 4700 River Road Unit 140,
Riverdale, MD 20737–1236; (301) 734–
6799.
SUPPLEMENTARY INFORMATION:
Background
On September 1, 1998, we published
in the Federal Register (63 FR 46403–
46406, Docket No. 98–035–1) a proposal
to amend the regulations in 7 CFR
319.37–8 to add orchids of the genus
Phalaenopsis to the list of plants that
may be imported from all areas of the
world in an approved growing medium
subject to specified growing, inspection,
and certification requirements. We
accepted comments on our proposal for
a total of 90 days, ending December 1,
1998.1
In response to comments received on
the proposed rule, APHIS narrowed the
application of the rule to Phalaenopsis
spp. from Taiwan only and entered into
informal section 7 consultation with the
U.S. Fish and Wildlife Service (FWS) to
assess the potential effects of the
proposed action on endangered or
threatened species, as required under
the Endangered Species Act. On April 7,
2003, FWS concluded the section 7
consultation process by concurring with
APHIS’s determination that the
importation of Phalaenopsis spp. from
Taiwan in growing media will not
adversely affect federally listed or
proposed endangered or threatened
species or their habitats.
Upon receiving concurrence from
FWS, APHIS prepared an environmental
1 The comment period on the proposed rule was
extended from 60 to 90 days in a notice published
in the Federal Register on October 29, 1998 (63 FR
57932).
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Frm 00001
Fmt 4703
Sfmt 4703
assessment in accordance with: (1) The
National Environmental Policy Act of
1969, as amended (NEPA) (42 U.S.C.
4321 et seq.), (2) regulations of the
Council on Environmental Quality for
implementing the procedural provisions
of NEPA (40 CFR parts 1500–1508), (3)
USDA regulations implementing NEPA
(7 CFR part 1b), and (4) APHIS’’ NEPA
Implementing Procedures (7 CFR part
372).
On May 9, 2003, we published in the
Federal Register (68 FR 24915, Docket
No. 98–035–3) a notice announcing the
availability of the environmental
assessment. In that notice, we requested
public comments on the environmental
assessment, which is titled ‘‘Proposed
Rule for the Importation of Moth
Orchids (Phalaenopsis spp.) in Growing
Media From the Republic of China
(Taiwan)’’ and dated April 2003.
Comments on the environmental
assessment were required to be received
on or before June 9, 2003. We are
reopening and extending the comment
period on Docket No. 98–035–3 until
July 9, 2003. This action will allow
interested persons additional time to
prepare and submit comments. We will
also consider all comments received
between June 9, 2003 (the day after the
close of the original comment period)
and the date of this notice.
Please note that on June 4, 2003, we
made a correction to the version of the
environmental assessment that had been
posted on our website since May 9,
2003. This correction involved
removing references to a specific
document (U.S. Department of
Agriculture, Animal and Plant Health
Inspection Service, Policy Analysis and
Development. 2002. PAD Response to
Public Comments on NPR in Docket 98–
035–1, 8 pp.) and replacing them with
references to a personal communication.
This correction has no substantive
bearing on the environmental
assessment, and is reflected in the
version currently posted on APHIS’s
website.
The environmental assessment may
be viewed on the Internet at http://
www.aphis.usda.gov/ppd/es/
ppqdocs.html. You may request paper
copies of the environmental assessment
from the person listed under FOR
FURTHER INFORMATION CONTACT. Please
refer to the title of the environmental
assessment when requesting copies. The
environmental assessment is also
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11JNN1
Federal Register / Vol. 68, No. 112 / Wednesday, June 11, 2003 / Notices
available for review in our reading room
(the location and hours of the reading
room are listed under the heading
ADDRESSES at the beginning of this
notice).
Done in Washington, DC, this 5th day of
June 2003.
Peter Fernandez,
Acting Administrator, Animal and Plant
Health Inspection Service.
[FR Doc. 03–14722 Filed 6–10–03; 8:45 am]
BILLING CODE 3410–34–P
DEPARTMENT OF AGRICULTURE
Food and Nutrition Service
Agency Information Collection
Activities: Proposed Collection;
Comment Request; Generic Clearance
To Conduct Formative Research for
Development of Nutrition Education
Materials and Related Tools for Food
and Nutrition Service Population
Groups
AGENCY: Food and Nutrition Service,
USDA.
ACTION: Notice.
SUMMARY: In accordance with the
Paperwork Reduction Act of 1995, this
notice invites the general public and
other interested parties to comment on
a proposed information collection. This
information collection will conduct
research in support of FNS’ goal of
delivering science-based nutrition
education to targeted audiences. From
development through testing of
materials and tools with the target
audience, FNS plans to conduct data
collections that involve formative
research including focus groups,
interviews (dyad, triad, telephone, etc.),
surveys and web-based collection tools.
DATES: Written comments must be
received on or before August 11, 2003.
ADDRESSES: Comments are invited on:
(a) Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information has practical utility; (b) the
accuracy of the agency’s estimate of the
burden of the proposed collection of
information, including the validity of
the methodology and assumptions used;
(c) ways to enhance the quality, utility,
and clarity of the information to be
collected; and (d) ways to minimize the
burden of the collection of information
on those who are to respond, including
use of appropriate automated,
electronic, mechanical, or other
technological collection techniques or
other forms of information technology.
VerDate Jan<31>2003
23:27 Jun 10, 2003
Jkt 200001
Comments may be sent to Judy F.
Wilson, Director, Nutrition Services
Staff, Food and Nutrition Service, U.S.
Department of Agriculture, 3101 Park
Center Drive, Room 1012, Alexandria,
VA 22302. Comments may also be faxed
to the attention of Judy F. Wilson at
(703) 305–2576.
All written comments will be open for
public inspection at the office of the
Food and Nutrition Service during
regular business hours (8:30 a.m. to 5
p.m., Monday through Friday) at 3101
Park Center Drive, Alexandria, Virginia
22302, Room 1012.
All responses to this notice will be
summarized and included in the request
for Office of Management and Budget
(OMB) approval. All comments will be
a matter of public record.
FOR FURTHER INFORMATION CONTACT:
Requests for additional information
should be directed to Judy F. Wilson,
(703) 305–2585 or Marion Hinners,
(703) 305–2116.
SUPPLEMENTARY INFORMATION:
Title: Generic Clearance to Conduct
Formative Research for Development of
Nutrition Education Materials and
Related Tools for FNS Population
Groups.
OMB Number: Not yet assigned.
Expiration Date: N/A.
Type of Request: New collection.
Abstract: This information collection
is based on the Child Nutrition Act of
1966, as amended, the National School
Lunch Act of 1966, as amended, the
Food Stamp Act of 1977, as amended,
the Agriculture and Consumer
Protection Act of 1973, as amended, and
the Emergency Food Assistance Act of
1983, as amended. This request for
approval of information collection is
necessary to obtain input into the
development of nutrition education
interventions for population groups
served by the U.S. Department of
Agriculture—Food and Nutrition
Service (USDA–FNS).
Diet has a significant impact on the
health of citizens and is linked to four
leading causes of disease, which can
reduce the quality of life and cause
premature death. While these dietrelated problems affect all Americans,
they have a greater impact on the
disadvantaged populations reached by
many of the FNS programs. One of FNS’
goals includes improving the nutrition
of children and low-income families by
providing access to program benefits
and nutrition education. The FNS
programs include Child Nutrition, Food
Distribution, Food Stamp and
Supplemental Foods Programs.
The basis of our approach rests on the
philosophies that all health
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Sfmt 4703
34899
communications and social marketing
activities must be science-based,
theoretically grounded, audiencedriven, and results-oriented. Secondly,
consumer-based health communications
require a focus on specific target
audiences, encouraging positive
behaviors in culturally relevant ways,
unique benefits and supports for
adopting the new behavior, insights into
the most appropriate time and place to
deliver messages, and striking the right
tone to enhance attention and action to
the message. Interventions need to be
crafted in such a way that they can be
delivered through different types of
media and in an array of formats for
diverse audiences.
FNS initiated a nutrition education
and promotion campaign, entitled Eat
Smart. Play Hard.TM (the Campaign) in
FY 2000 (OMB number 0584–0502). The
Campaign is designed to convey
science-based, behavior-focused
nutrition messages about healthy eating
and physical activity to children eligible
to participate in FNS nutrition
assistance programs and their
caregivers. The messages are based on
the 2000 Dietary Guidelines for
Americans (DGAs) and the Food Guide
Pyramid. A most recent approval was
granted for information collection (OMB
number 0584–0517) for four projects:
Phase II of Eat Smart. Play Hard.TM,
Campaign Web Site Development,
Cultural Adaptation of Campaign
Materials for Hispanic Audiences and
Dietary Guidelines Low-Literacy
Materials Development. Future projects
will support the Eat Smart. Play Hard.TM
Campaign, which has been designated
as a specific administration action in the
President’s Healthier US initiative.
Fundamental to FNS’ success in
delivering science-based nutrition
messages and reaching diverse and low
literacy segments of the population is
obtaining qualitative feedback from key
components of the target audience on
the communication strategies and
interventions that will be developed.
This formative research is essential to
advancing Eat Smart. Play Hard.TM as
well as other FNS nutrition education
efforts. Formative input and testing
activities described will help in the
development of more effective tools and
communication strategies. Collection of
this information will increase FNS’
ability to formulate nutrition education
interventions that resonate with the
target population of low-income
American families, who have the
highest need and can derive the most
benefit.
Formative research methods and
information collection will include
focus groups, interviews (dyad, triad,
E:\FR\FM\11JNN1.SGM
11JNN1
Hawaii Orchid Growers Association
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About HOGA
HOGA Member Listing
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Hawaii Orchid Growers Association
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Category: Search terms:
About HOGA
HOGA is an alliance of professional orchid growers in the state of Hawaii. Its goals are to promote
the development of this industry by supporting marketing, research and educational projects. A nonprofit service organization, HOGA is dedicated to being an active, ethical member of the Hawaii
business community.
Home
About HOGA
HOGA Member Listing
Contact HOGA
HOGA was formed in 1995 to serve as the vehicle for coordinated efforts among breeders,
propagators, and growers of orchids in Hawaii. Its membership represents a $20,000,000.00
Hawaii orchid industry that is rapidly growing and expanding.
HOGA embraces members of the Big Island Dendrobium Growers Association (BIDGA) and
Dendrobium Orchid Growers Association of Hawaii (DOGAH) as Adjunct HOGA members, and
extends privileges of special rates and prices to their members.
HOGA has recently joined the Hawaii Tropical Flower Council (HTFC) and anticipates supporting
and participating fully in this organization.
Working together, the orchid and tropical flower growers of Hawaii are best positioned to address
the needs of our clients.
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Hawaii Orchid Growers Association
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Contact HOGA
For questions about membership or communications from HOGA, contact Ruth Iwata, phone/fax
961-2043 or email [email protected]
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Showing 1 - 15 of 130 total
Phone
Email
Bergstrom Orchid Nursery
Bergstrom Orchids is world famous and has been in business for over
twenty five years specializing in species orchids from all over the globe.
Best known for Species Cattleyas, Phragmipediums, Brassias,
Catasetinae, and now Bulbophyllums. Now also offering many Brassia
hybrids. Many of these are pictured in the over one thousand
photographs on the bergstromorchid.com website, one of the most
comprehensive sites of this type. Visitors welcome with previous
notification to nursery located at the end of 19th street off
808-982-6047
Email
G H Trading Company
808-961-6468
Email
Sadorra Hawaiian Flowers & Leis
808-987-5105
N/A
Hilo Orchid Farm Hawaii, Inc.
We are a wholesale nursery specializing in Oncidium alliance and
Paphiopedilums as potted plants. From our three-acre greenhouse, we
are able to supply small sizes or pre-finished plants in quantity all year
round. We especially welcome wholesale growers and wholesale
brokers.
808-968-8801
Email
Orchids of Olinda Inc.
808-572-0839
Email
Walter Uohara Orchids
808-959-5939
N/A
Ernie Nelson
671-472-7873
Email
Orchid Alley
808-822-0486
Email
Akatsuka Orchid Gardens
808-967-8234
Email
Rainbow Country Orchids
N/A
N/A
Carmela Orchids, Inc.
808-963-6189
Email
Swann Orchids of Hawaii
808-965-9100
Email
Newman's Nursery, Inc.
Newman’s Nursery has 300,000 sq. ft. of greenhouse with close to two
million plants currently growing. Our facility is located 15 minutes south
of Hilo in the Puna district of the Big Island of Hawaii. We grow
Dendrobium, Oncidium, Cattleya, Paphiopedilum, Intergeneric varieties
and Vanda. We are a certified wholesale nursery and ship to the U.S.
mainland and other foreign destinations.
808-966-4545
Email
Ilima Flowers
808-982-9852
N/A
Nursery Things, Inc.
808-959-9135
N/A
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Showing 16 - 30 of 130 total
Phone
Email
Hawaiian Paradise Flowers, LLC
808-828-0022
Email
Maluhia Orchids
Aloha, We are located 5 minutes away from beautiful Kealakekua Bay,
under the warm sunny skies of Kona. We grow a wide variety of
Cattleyas, Vandas, Phalaenopsis and Dendrobiums. Yes, for the
Species admirer, we do have a small corner to help satisfy the hobbyist
in all of us. We are a family run, certified nursery ready to help with your
orchid needs.
808-328-2673
Email
Orchid Center
We are a wholesale orchid nursery located on the island of Oahu,
specializing in Cattleyas and Phalaenopsis. We are certified to ship
anywhere in the United States and to foreign countries.
808-696-2974
N/A
Kolekole Farm
808-963-6808
Email
Gubler Orchids
800-482-5377
Email
808-965-8444 x2
Email
Miyasato Orchids
808-638-5358
Email
Cloud Forest Orchids
Please write or call 808-987-4492 for current list.
808-987-4492
N/A
Cyanotech Corp.
808-334-9425
Email
Kamuela Greenhouse/Spec. Orchids
The emphasis at KG/SO is on the making of new hybrids along odont.
intergeneric lines. We are aiming for vivid color, diverse flower shapes,
and high performance. This 30,000 s.f. nursery was recently established
by experienced orchid growers near historic Parker Ranch, on the Big
Island. The area’s temperate climate is well-suited to production of our
other primary crops: paphs (complex and vini), miltoniopsis, and selected
intergeneric clonal material. Within a year cymbidiums will also be
available. KG/SO sells mainly to independent, small to mid-size
wholesalers and retailers.
808-887-6505
Email
H & S Farms
808-968-6364
Email
Hawaiian Greenhouse Inc.
808-965-8351
Email
Hualalai Estate
808-326-7775
Email
Gines Orchids
Gines Orchids is a small nursery specializing in the production of
different genera of pre-finished orchid pot plants from plug trays to
spiking plants. A selection of orchid species is available. We also offer a
contract growing service.
808-966-4550
Email
Rainbow Specialties
808-968-6351
N/A
The Tropical Connection LLC
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Showing 31 - 45 of 130 total
Phone
Email
Starr Farms
We are a holistic/organic practice farm established in 1979. Located on
the windward side of the big island of Hawaii, we ship wholesale to retail
in tropical cut flowers and foliages. We are bench certified for the
shipment of potted plants. We grow a wide variety of species and hybrids
in Orchid and Anthurium, along with many varieties in Zingiberales and
Cordyline.
808-966-8884
Email
Volcano Orchid Farms
808-968-8505
Email
USDA - ARS
808-959-4343
Email
W.H. Shipman, Ltd.
808-966-9325
Email
Floribunda Palms & Exotics
808-966-8003
Email
Schors' Dream Farm
Primarily Birds of Paradise, Red Ginger, Ti Leaves, Torch Ginger and
Heliconias make up our inventory. We are a growing business shipping
in the continental U.S., Hawaii and Alaska.
808-981-1334
Email
Bob's Tropicals
808-822-0117
Email
G. Tasaka Orchids
808-623-0473
Email
Sunset Tropicals MK Ent. Inc.
808-878-1211
Email
Kalapana Tropicals
Kalapana Tropicals is a family owned & operated orchid farm located
south east of Hilo on the Big Island of Hawaii. We have 75,000 sq ft of
covered greenhouse that is divided between two locations. The
Kalapana farm at 400’ grows mainly dendrobium, vandas, ascocendas,
brassia and brassidium. The Kurtistown location at 900’ is not only our
home, but growing area for intergeneric oncidinae, miltoniopsis, encyclia,
oncidium, brassia, zygopetalum, paphiopedilum and phragmipedium. We
pride ourselves on extremely well grown, established plants and fantastic
customer service. Plants are shipped primarily in spike to mature bud.
808-966-6842
Email
Olomana Orchids, Inc.
Olomana Orchids is a family owned and operated orchid nursery that
has been in business more than thirty years. We breed and grow
Dendrobiums for use by florists and interiorscapers. We produce a wide
variety of different hybrids in sizes appropriate for use as centerpieces
up to large blooming plants for use in containers.
808-239-8111
Email
Alan Yamaguchi
808-959-6356
Email
Christel Orchids
808-966-9541
Email
Marty's Orchids
808-259-8000
Email
University of Hawaii at Hilo
808-974-7393
Email
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Showing 46 - 60 of 130 total
Phone
Email
Big Island Flower Company
Makuu in Hawaiian Paradise Park, Keaau.
808-939-9043
Email
KKFFCC, LLC
808-572-2269
Email
Mera Pharmaceuticals Inc.
808-327-4060
N/A
H & R Nurseries, Inc.
We feature an extensive assortment of hobby and pot plant orchids. We
have a world-wide reputation for new, innovative and rare orchids as well
as familiar items. Our Retail and Wholesale Color Catalogs are issued
three times a year. We have budded plants available for wholesale. We
are located half an hour east of Honolulu and Waikiki. We are certified
for U.S. Mainland shipping and have CITES for foreign shipments (no
budded). We do no European shipments.
808-259-9626
N/A
Papaya Penthouse Orchids
In 1944, on the island of Saipan, Air Force men of the 73 Bomb Wing
received flight orders announced from a bombed-out Japanese bunker,
which they named The “Papaya Penthouse”. Our farm is named to honor
those men and my Dad, Left Wing Gunner Sgt. Haygood, of the B29
Slick Dick. We are a new business, in the first year of raising warm
microclimate orchids: Cattleyas, Phalaenopsis, Oncidiums, “Fire and
Foxtail” Orchids on the Big Island of Hawaii. We will offer retail and mail
order sales when the plants mature.
808-982-6335
Email
Golden Gate Orchids
N/A
N/A
Tropical Flowers Express
808-822-3894
Email
Richway International, Inc.
808-589-2800
Email
Hawaiian Acres of Orchids
We are a small certified nursery with two locations on the Big Island.
This enables us to offer a wide variety of both potted and cut orchids.
Our primary production for potted orchids is Intergenerics with some
availability of Dendrobium and Ascocenda. We also offer approximately
eight varieties of Cut Orchids. Our product is sold farm direct to the retail
outlet and shipped via FedEx.
866-667-2443
Email
Kaleialoha Orchid Farm
We are a retailer/wholesaler of potted orchids and tropical flowers. We
specialize in Dendrobium and Oncidium Intergenerics plants,
Dendrobium and Oncidium cut flowers, orchid leis, tropical floral gift
boxes and orchid plant gift boxes. Our plants are grown in 4-in. pots and
can be purchased in bud, in bloom or non-blooming, for finishing at your
nursery. Although we do not sell plants in 6-in. pots, many of our plants
can be repotted immediately into 5 or 6 inch pots for re-sale. Contact us
for wholesale prices and availability; check our website for our retail
selection.
808-982-5204
Email
Hawaii Blooms, Inc.
Hawaii Blooms specializes in custom orders. We offer all varieties of
tropical cut flowers, orchid plants and Hawaiian leis. We have no
minimum order. Hawaii Blooms excels in the quality of flowers and
service to our customers. All orders are carefully packed and shipped
directly from Hawaii to your door. Call our toll free number 1-888-9827744.
808-982-7744
Email
Mountain View Orchids, Inc.
808-968-8029
Email
N/A
Email
Green Point Nurseries, Inc.
808-959-3535
Email
Lichty's Quality Plants
Lichty’s is a wholesale grower of Anthuriums and Orchids. We grow
Oncidiums, intergenerics and Dendrobiums for the potted market,
Anthuriums as cut flower, and potted flowering plants for the cut flower
grower.
808-982-6779
Email
Sandra Pechter Schutte
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Showing 61 - 75 of 130 total
Company Name
Phone
Email
808-981-2265
Email
808-964-5832/52
Email
Kona Coffee Connection
808-322-2864
Email
Orchids in the Mist, Inc.
808-985-8789
N/A
Gervais Orchids
Gervais Orchids is a 2.5 acre orchid nursery located near Hilo, just off
the Volcano Highway. We sell assorted genera of orchids for the pot
plant trade. Cut Oncidiums are also available. We have a plant inventory
of 500,000 plus plants.
808-959-0825
Email
Pacific Island Nursery
808-966-9225
Email
Alohilani Nursery
Alohilani Nursery is a family operated business; we have been at this
location since 1991. Our farm is located on the east side of the Big
Island of Hawaii. We’re surrounded with tropical fruits and flowers. Our
operation is on 21 acres where we grow tropical fruits and flowers, but
we specialize in Oncidium Dendrobium and Intergeneric Orchids. Only
the finest cut stems and first quality potted plants are offered.
808-965-6216
Email
Pacific Paradise Orchids
808-965-9299
Email
Maebo's
Jingle Flower Nursery
UpRiver Orchids
UpRiver Orchids is a family run farm a few minutes north of Hilo on the
Big Island of Hawaii. We have 10,000 sq ft of production and are in the
midst of expansion.
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808-959-8763
N/A
Maile Orchids
808-966-7124
Email
The OrchidWorks
We sell Oncidiinae and Miltonia plugs for pot plant production. We offer
over 80 varieties a year and we produce over one million plugs annually.
Our web site offers realtime inventory, photos of the flowers, and cultural
information for specific varieties as well as for the group in general.
808-963-6233
Email
Pualani Orchids
808-329-5584
Email
Hawaii Hybrids LLC
808-981-5500
Email
Blue Pacific Orchids
808-962-9747
Email
Peles' Island Plants
We are a small, family run nursery located on the slopes of Mauna Loa
on the Island of Hawaii. Our higher elevation allows us to grow a wide
variety of warm to intermediate genera, including Oncidiums, Miltonias,
Cattleyas, Vandas, New Guinea Dendrobiums and some of the more
unusual varieties. Being a smaller operation enables us to pay closer
attention to our plants. We offer quality potted plants in spike and gift
boxes for special occasions.
808-939-9282
Email
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Showing 76 - 90 of 130 total
Phone
Email
C & L Orchids
808-259-6344
N/A
Okika Ltd.
Okika Limited is a small orchid breeding company. We offer new
varieties of Miltonia, Oncidiinae intergenerics and Masdevallia. Visitors
are always welcome. Please call for appointment.
808-937-1606
Email
N/A
Email
Ohana Orchids, Inc.
Ohana Orchids is known for providing premium orchid plants to both
businesses and enthusiasts. We are a group of small flower farmers with
a mutual passion for growing beautiful, healthy orchids in the Puna
region of the Big Island of Hawaii. Because we collect the highest quality
plants from a variety of growers, we are able to offer a fantastic selection
of orchids at unmatched prices. Our flowers are raised with care and
devotion in America’s finest natural habitat and delivered fresh, without
the expense of buying through middlemen. We provide service with
Aloha!
808-938-5616
Email
Asia Pacific Flowers, Inc.
808-965-9570
Email
Kogachi Orchids
808-696-2040
Email
Kihalani Tropicals
808-962-6352
Email
Walter Scheeren Orchids
Specializing in Disa.
808-775-1185
Email
Hawaiian Tropicals Direct
Our nursery is located in sunny Kapoho, south of Hilo. We have
approximately 88,000 sq ft of covered greenhouses and produce a large
variety of orchid plants. We specialize in dendrobiums and oncidiums,
and also grow oncidinae, intergenerics, cattleyas, vandas, phalaenopsis
& paphiopedilums. We produce flask material in our tissue culture lab. In
addition we retail/wholesale tropical flowers & foliage and assorted giftbox items and leis. We ship anywhere in the continental States and
Alaska.
808-965-0704
Email
Linda's Place
808-968-6903
Email
Orchid Plantation,Inc.
Our main site is located 25 miles south of Hilo on the island of Hawaii.
We specialize in potted orchid plants, cut and lei flower heads. We have
mostly Dendrobium and some Oncidium, Cattleya, Ascocenda.
Established in 1987, we are a certified nursery with a very extensive
selection of potted plants, shipping 20-100 plants of any one genera
each week.
808-965-2695
Email
Rolfe Horticulture
808-968-6863
Email
N/A
N/A
Tomono Orchids Hawaii
Established in 1972, we are a certified nursery with a very extensive
selection of potted orchids under 10+ acres of shade at four different
sites in the Kona area. Our main site is located about 15 miles south of
Kailua-Kona in the Kealakekua Bay area. We specialize in potted orchid
plants, cut and lei flower heads. We have mostly Dendrobium but we
also have some Oncidium, Cattleya, Mokara, Vanda, Ascocenda and
Phalaenopsis. We ship anywhere in the continental United States,
Puerto Rico, Guam and Saipan. Open by appointment only.
808-328-8065
Email
Orchids of Waianae, Inc.
Retailer/wholesaler of Orchid potted plants, we specialize in Cattleya and
Dendrobiums. We ship assorted spiked Dendrobiums & budded
Cattleyas. Blooming size plants, compots and flasks are also available.
808-696-6923
N/A
Eugene Tao
Phil Holman
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Showing 91 - 105 of 130 total
Phone
Email
Mien Yap Imports
808-878-2021
Email
Fire Mountain Farm
808-985-7167
N/A
Hawaiian Floral Express
Wholesale—to the trade only. We are growers of a large variety of
quality orchids and tropical flowers and foliage. As a certified nursery for
potted plants and tropical flowers, we ship throughout the continental
United States. We are located in Hawaiian Paradise Park in the District
of Puna. We invite you to visit us and enjoy the beautiful Island of
Hawaii. Aloha!
808-982-9298
Email
Chief Master Sergeants of Hawaii
808-449-0690
Email
Red Road Tropicals
808-965-6181
Email
The Uniques
808-982-6495
Email
Puna Orchids, Inc.
808-965-6200
Email
Lehua Orchids
The nursery is located in Mountain View, 14 miles south of Hilo on the
road to Volcano. Specializing in intermediate temperature and warm
tolerant orchid plants, we sell blooming size and in-spike/bud plants. The
typical order size is 50 to 200 plants per shipment.
808-968-8898
Email
LaJolla Orchids
858-452-0976
Email
Hawaii Orchids
808-966-7712
Email
Novelty Greens
808-981-0882
Email
Tropical Gardens of Maui, Inc.
808-244-3085
Email
Seven Rocks Orchids
808-968-8196
Email
South Seas Orchids, Ltd.
679-662-206
N/A
Jerry Robert Bonelli
808-965-2613
N/A
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Company Name
Phone
Email
Island Sun Orchids
808-965-7042
Email
Puanani Orchids
808-259-5494
N/A
Quintal Farm, Inc.
Our nursery is located approximately 10 miles south of Hilo on the island
of Hawaii. We specialize in potted Intergeneric Oncidiniae,
Paphiopedilum and Phragmipedium orchid plants for the wholesale and
retail markets. We also offer cut Anthuriums. We currently ship
approximately 1800 cut Anthuriums and 600 potted plants per week. Our
inventory continues to increase as we bring in new and unusual orchid
plants.
808-966-7370
Email
Lokelani Enterprises, LLC
We are a family owned nursery located on the Big Island of Hawaii. Our
particular environment supports both warm weather and water thirsty
Dendrobium and Oncidinae orchids. We as owners are involved in the
daily operations of the nursery and we personally handle every order to
insure complete satisfaction for our customers. If you have a big or small
order our service is unsurpassed and we pride ourselves in solving your
individual plant needs.
808-982-6503
Email
Mitchell Gacula
808-966-7222
Email
Yamamoto Dendrobiums HI
We specialize in growing Nobile type of Dendrobium pot plants,
wholesale only. We sell plugs and small sizes year round, but during the
blooming season in spring, we sell In Bud plants. We are located
approximately 20 minutes from Hilo Airport, about 13 miles south on
Highway 11 on the Big Island of Hawaii.
808-968-6955
Email
Hawaiian Mamaki Tea Plantation, Inc.
808-959-8185
Email
Little hawaiian Store
808-528-4244
Email
Hawaiian Flowers
Hawaiian Flowers is a family farm located one mile down South Point
Road on the southern tip of the Big Island. Our main products are a wide
variety of potted blooming orchid plants and cut flower Protea. We
specialize in smaller orders and accounts, and custom orders. A
personal customer service relationship with each of our customers is an
advantage of our smaller operation. We do unique individually designed
cut flower Orchid and Protea arrangements delivered locally. Visitors are
Welcome on our farm.
808-929-9737
Email
Winning Orchids, LLC
Our greenhouse is located about 13 miles south of Hilo on the Big Island
of Hawaii. We specialize in potted orchid plants. We are a certified
nursery with a very extensive selection of Phalaenopsis. All wholesalers
and retailers are welcome. We sell young plants as well as plants in bud,
or blooming plants. We can provide more than 2000 plants a week.
808-968-0717
Email
Tropical Breeze
808-329-6770
N/A
Morgado Nursery
808-982-7317
Email
Hale Kalopa Orchids
808-775-0008
N/A
Waimea Orchids
808-885-7236
Email
Orchid Isle Dendrobiums
808-966-7610
Email
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Phone
Email
Orchids of Hawaii, Hilo Branch
808-959-3581
Email
Mauna Kea Orchids
We are a breeding facility and propagation company. We sift through
thousands of hybrids looking for those very special plants that will be the
exceptional production plants of tomorrow. We sell excess hybrid flasks
and seedlings of flowering size. We have what you won’t find elsewhere.
808-963-6233
Email
AlphaGenesis
808-964-2247
Email
Flowers in Bloom
808-965-7134
N/A
Hawaiian Floral Nursery
We are breeders, developers, and growers of new Dendrobium, Cattleya
alliance and Oncidium alliance orchids since 1984. We offer 98-cell and
58-cell orchid seedling flats for pot-plant and cut-flower production; and
blooming-size orchids and flowering orchids in 4” pots. We are a certified
nursery shipping worldwide.
808-259-8311
Email
UH-Manoa Dept. of TPSS
808-956-5312
Email
Nakaji Orchids
808-964-5039
Email
Charlene Adams
808-965-7266
N/A
Hawaiian Orchid House
503-819-9803
Email
Volcano Island Honey Company
808-775-0806
Email
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USDA - ARS
Contact:
Marisa Wall
P.O. Box 4459
Hilo, HI 96720
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808-959-4343
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>Hawaii Agricultural Statistics Service: Hawaii Flowers & Nursery Products
Go to:
HASS Homepage
Publications List
Hawaii Agricultural Statistics Service
Fact finding for agriculture
HAWAII DEPARTMENT OF AGRICULTURE
U.S. DEPARTMENT OF AGRICULTURE
P.O. BOX 22159
HONOLULU, HI 96823-2159
(808) 973-9588
FAX: (808) 973-2909
Hawaii Flowers & Nursery Products
Annual Summary
Released: May 22, 2002
Table of Contents: (Click on one of the underlined to go directly to that section)
●
●
●
●
Summary
Selected Cut Flowers
Foliage
Orchids
●
●
●
●
Lei Flowers & Individual Blooms
Potted Flowering
Bedding/Garden Plants
Other Nursery Products
●
●
●
●
County Summaries
Farm Numbers & Area Summary
Out-of-State Sales
Dendrobium Orchids
2001 FLORICULTURE AND NURSERY SALES TOP $87 MILLION
Grower sales of Hawaii's flower and nursery products totaled a record $88.0 million in 2001. According
to the Hawaii Agricultural Statistics Service, the 2001 wholesale value was 6 percent higher than the
$82.7 million value for 2000. Orchids, foliage, and potted flowering plant categories registered increases
in 2001.
Cut flower value of sales declined 5 percent in 2001 to $15.5 million. Anthuriums remained the leading
cut flower with value of sales pegged at $6.9 million.
Value of orchid sales increased 10 percent from 2000 with "Other potted orchids" and "Potted
dendrobiums" leading the way. Potted dendrobium value of sales, which includes the community pots
and in bud/bloom pots, increased 1 percent.
Foliage growers reported $20.2 million in sales. Sales of potted foliage for indoor or patio use were a
record $19.2 million, beating last years record of $17.1 million.
The lei flower category, with wholesale sales pegged at $3.5 million, dropped 5 percent from a year ago.
http://www.nass.usda.gov/hi/flower/flower.htm (1 of 3)6/23/2003 7:52:43 AM
>Hawaii Agricultural Statistics Service: Hawaii Flowers & Nursery Products
Sales of potted flowering plants were valued at $5.1 million, nearly unchanged from 2000.
County Rankings:
Hawaii county, with $51.3 million in sales, ranked number one in 2001. Honolulu farmers registered
sales of $24.9 million, 4 percent higher than 2000. Maui county sales totaled $9.9 million, 1 percent
lower than last year. Kauai sales, pegged at $1.9 million, were 51 percent higher than 2000.
FLORICULTURE AND NURSERY PRODUCTS: Wholesale value, State of Hawaii, 1997-2001
Commodity
1997
1998
1999
2000
2001
1,000 dollars
Cut flowers 1
13,969
15,176
16,517
16,297
15,500
Orchids
15,479
15,790
17,166
18,106
19,989
3,813
3,485
4,051
3,615
3,450
16,989
3 15,403
16,055
18,295
20,239
3,751
3,892
4,421
5,044
5,060
11,250
17,982
15,978
19,850
22,267
1,404
1,479
1,537
1,477
1,471
66,655
73,207
75,725
82,684
87,976
Lei flowers
Foliage 2
Potted flowering plants
All other nursery products 4
Unspecified sales 5
Total
1 Cut
orchids included in "Orchids" category.
2 Includes potted, cut, and unfinished. Beginning 1998, Landscape foliage included with "All other
nursery products".
3 Unfinished foliage, 1998 included with "All other nursery products".
4 Includes bedding plants, plant rentals, and any other nursery products not elsewhere classified.
5 Includes sales of growers greater than $999 but less than $10,000 which were not categorized.
FLORICULTURE & NURSERY PRODUCTS: Top ten crops, State of Hawaii, 2000-2001
Crop
Rank
2000
Value of production
2001
Number
2000
2001
1,000 dollars
Dracaena (potted for indoor or patio use)
3
1
6,648
8,443
Palms (potted for indoor or patio use)
1
2
8,434
8,280
Anthuriums, cut
2
3
7,357
6,904
Dendrobiums, potted 1
4
4
6,528
6,608
http://www.nass.usda.gov/hi/flower/flower.htm (2 of 3)6/23/2003 7:52:43 AM
>Hawaii Agricultural Statistics Service: Hawaii Flowers & Nursery Products
Dendrobiums, sprays
5
5
2,335
2,990
Roses, cut
6
6
2,057
1,942
Gingers, cut
7
7
1,508
1,416
Poinsettia, potted
9
8
1,292
1,272
Protea
8
9
1,392
1,122
Phalaenopsis, potted
10
10
1,030
926
1 Includes
in bud/bloom and community pots.
Go to:
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HASS Homepage
http://www.nass.usda.gov/hi/flower/flower.htm (3 of 3)6/23/2003 7:52:43 AM
Publications List
>Hawaii Agricultural Statistics Service: Hawaii Flowers & Nursery Products
Go to:
HASS Homepage
Publications List
Hawaii Agricultural Statistics Service
Fact finding for agriculture
HAWAII DEPARTMENT OF AGRICULTURE
U.S. DEPARTMENT OF AGRICULTURE
P.O. BOX 22159
HONOLULU, HI 96823-2159
(808) 973-9588
FAX: (808) 973-2909
Hawaii Flowers & Nursery Products
Released: May 22, 2002
ORCHIDS: State of Hawaii, 1996-2000 1
Crop
Farms
having
sales 2
Production
area
Quantity
sold
Value
of
sales
Number
1,000 square feet
1,000
1,000 dollars
Cymbidiums, cut - flowers
1997
8
275
348
137
1998
12
315
418
216
1999
12
335
537
337
2000
10
NA
509
315
2001
9
NA
372
232
1997
56
3,505
368
2,549
1998
59
2,970
419
2,864
1999
49
2,610
378
2,608
2000
49
NA
340
2,335
2001
49
NA
415
2,990
1997
28
305
34
356
1998
32
485
58
580
Dendrobiums, sprays - dozens
Oncidiums, sprays - dozens
http://www.nass.usda.gov/hi/flower/orchid01.htm (1 of 3)6/23/2003 7:53:21 AM
>Hawaii Agricultural Statistics Service: Hawaii Flowers & Nursery Products
1999
31
355
47
463
2000
37
NA
56
536
2001
35
NA
83
813
1997
5
NA
NA
25
1998
4
NA
NA
52
1999
6
NA
NA
28
2000
10
NA
NA
119
2001
9
NA
NA
28
1997
63
1,295
1,409
6,392
1998
63
NA
1,107
6,069
1999
72
NA
942
5,640
2000
74
NA
1,065
6,528
2001
76
NA
1,176
6,608
1998
20
NA
221
1,178
1999
21
NA
205
1,169
2000
24
NA
143
1,030
2001
24
NA
154
926
1997
56
1,235
1,295
6,020
1998
57
NA
951
4,831
1999
61
NA
1,551
6,921
2000
75
NA
1,561
7,243
2001
78
NA
2,256
8,392
Other orchids, sprays 9- dozens
Dendrobiums, potted 10 - pots
Phalaenopsis, potted 11 - pots
1997
Other orchids, potted - pots
Click here for footnotes.
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Hawaii Agricultural Statistics Service
Fact finding for agriculture
HAWAII DEPARTMENT OF AGRICULTURE
U.S. DEPARTMENT OF AGRICULTURE
P.O. BOX 22159
HONOLULU, HI 96823-2159
(808) 973-9588
FAX: (808) 973-2909
Hawaii Flowers & Nursery Products
Released: May 22, 2002
OUT-OF-STATE SALES PEGGED AT $54.9 MILLION
The value of out-of-State sales of flowers and nursery products (including wholesale and retail sales)
during 2001 was estimated at $54.9 million. Values in this table are not comparable to values shown in
the majority of other tables throughout this release. The value of out-of-State sales represents the dollar
received at the point the commodity leaves the State. Thus, the product contains retail and wholesale
sales and may include multiple transactions by the time it leaves the State.
Potted foliage, valued at $16.2 million, was the number one floriculture and nursery product exported.
Anthurium exports were valued at $11.0 million, 4 percent higher than the revised 2000 estimate. Other
potted orchids followed with $7.2 million in value. Potted dendrobium orchids ranked fourth in out-ofState sales with $4.9 million.
FLORICULTURE AND NURSERY PRODUCTS: Out-of-State sales, State of Hawaii, 1997-20011
Commodity
1997
1998
1999
2000
2001
1,000 dollars
Anthuriums, cut
10,945
9,795
10,685
10,600
11,000
720
945
710
980
860
80
130
110
100
110
3,545
3,820
2,875
3,395
3,500
270
545
660
Birds of Paradise
Cymbidiums
Dendrobiums, sprays
Oncidium
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>Hawaii Agricultural Statistics Service: Hawaii Flowers & Nursery Products
Foliage, cut:
Ti leaves
670
475
400
670
710
Other cut greens
885
1,070
845
1,060
1,480
10,320
12,220
12,785
13,525
16,200
Ginger, red
765
810
875
1,010
560
Gingers, other
450
800
890
830
460
Heliconias
820
955
970
1,400
1,270
3,510
4,360
4,120
3,850
4,930
285
655
640
Foliage, potted
Potted orchids:
Dendrobiums
Phalaenopsis
Other orchids
5,410
6,485
5,395
6,285
7,180
Proteas
2,025
2,405
2,130
1,930
1,480
70
400
355
270
270
Unfinished potted foliage stock
Mixed assortment of cut flowers
All other flowers and nursery
products
Total
1,260
1,185
2,510
2,245
2,345
2,300
41,400
47,180
45,945
49,450
54,870
1Based
on F.O.B. island value. Includes both wholesale and retail sales. Does not include sales of cut
flowers, leis, etc., purchased within the State and hand carried out.
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Fact finding for agriculture
HAWAII DEPARTMENT OF AGRICULTURE
U.S. DEPARTMENT OF AGRICULTURE
P.O. BOX 22159
HONOLULU, HI 96823-2159
(808) 973-9588
FAX: (808) 973-2909
Hawaii Flowers & Nursery Products
Released: May 22, 2002
BIG ISLAND VALUE TOPS $51 MILLION
Hawaii county growers of flowers and nursery products accounted for 58 percent of the state's total
wholesale value of flowers and nursery products in 2001. Big Island's 360 growers rang up sales of
$51.3 million, up 8 percent from the $47.5 million in 2000. Declines in cut and lei flower sales were
offset by increases in other categories. Honolulu's 220 producers accounted for 28 percent of the state's
total wholesale value of flowers and nursery products. Honolulu farmers reported sales of $24.9 million,
4 percent higher than 2000. Maui county's 150 producers generated $9.9 million in wholesale sales, 1
percent lower than a year ago. Kauai's 60 producers registered $1.9 million in wholesale sales, 51
percent more than 2000.
Hawaii County's Top Five Floriculture and Nursery Products/Categories, 2001
* Dracaena (potted for indoor or patio use)
* Palms (potted for indoor or patio use)
* Anthuriums, cut
* Other potted orchids
* Dendrobiums, potted
Honolulu County's Top Five Floriculture and Nursery Products/Categories, 2001
* Landscape plant material
* Other potted orchids
* Dendrobiums, potted
* Plant rentals
* Other bedding & garden plants
Kauai County's Top Five Floriculture and Nursery Products/Categories, 2001
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>Hawaii Agricultural Statistics Service: Hawaii Flowers & Nursery Products
*
*
*
*
*
Landscape plant material
Other potted orchids
Dendrobiums, potted
Plant rentals
Dendrobium, individual blossoms
Maui County's Top Five Floriculture and Nursery Products, 2001
* Landscape plant material
* Protea
* Other potted orchids
* Cut flowers not separately specified
* Other bedding and garden plants
FLORICULTURE AND NURSERY PRODUCTS: Value of grower sales, by county, 1997-2001
Lei
Potted flowering
Cut
Foliage3
Orchids2
Year
1
flowers
plants
flowers
All other
nursery
products4
Unspecified
Total
sales5
1,000 dollars
State
1997
13,969
15,479
3,813
1998
15,176
15,790
3,485
1999
16,517
17,166
2000
16,297
2001
16,989
3,751
11,250
1,404 66,655
15,403
3,892
17,982
1,479 73,207
4,051
16,055
4,421
15,978
1,537 75,725
18,106
3,615
18,295
5,044
19,850
1,477 82,684
15,500
19,989
3,450
20,239
5,060
22,267
1,471 87,976
1997
10,939
8,063
1,226
11,124
882
1,726
541 34,501
1998
11,410
9,114
1,022
11,612
1,676
3,715
604 39,153
1999
12,588
10,015
1,697
12,754
2,011
2,718
679 42,462
2000
12,592
10,319
1,140
15,757
2,120
4,859
712 47,499
2001
11,958
12,525
1,068
17,736
2,333
4,932
731 51,283
1997
848
6,136
1,332
4,957
1,917
6,562
379 22,131
1998
774
5,839
1,258
6 3,331
1,387
10,745
409 23,743
6
Hawaii
6
Honolulu
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>Hawaii Agricultural Statistics Service: Hawaii Flowers & Nursery Products
1999
745
5,741
1,210
2,601
1,063
10,119
386 21,865
2000
680
6,515
1,098
1,940
1,609
11,832
327 24,001
2001
531
6,205
1,136
2,121
1,440
13,146
337 24,916
Kauai
1997
76
7
7
7
7
1,555
173
1,804
1998
138
7
7
7
7
1,090
132
1,360
1999
133
411
7
72
118
696
117
1,547
2000
99
245
7
55
194
560
113
1,266
2001
353
281
7
7
140
1,039
98
1,911
Maui
1997
2,106
7
7
7
7
5,802
311
8,219
1998
2,854
7
7
7
7
5,763
334
8,951
1999
3,051
999
7
628
1,229
3,589
355
9,851
2000
2,926
1,027
7
543
1,121
3,976
325
9,918
2001
2,658
978
7
7
1,147
4,778
305
9,866
1Cut
orchids included in "Orchids" category. 2Excludes orchids used for lei flowers. 3Includes potted,
cut, and unfinished. Beginning 1998, Landscape foliage included with "All other nursery products".
4Includes bedding plants, plant rentals, sod, trees, and any other nursery products not elsewhere
classified. Sum of counties may not add to total. 5Includes grower sales greater than $999 but less than
$10,000 which were not categorized. 6Unfinished foliage, 1998 included with "All other nursery
products". 7Data not shown separately to avoid disclosure of individual operations but combined and
included in the State total.
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46403
Proposed Rules
Federal Register
Vol. 63, No. 169
Tuesday, September 1, 1998
Animal and Plant Health Inspection
Service
inspect comments are requested to call
ahead on (202) 690–2817 to facilitate
entry into the comment reading room.
FOR FURTHER INFORMATION CONTACT: Mr.
Peter M. Grosser, Senior Import
Specialist, Phytosanitary Issues
Management Team, PPQ, APHIS, 4700
River Road Unit 140, Riverdale, MD
20737–1236; (301) 734–6799; fax (301)
734–5786; e-mail:
[email protected].
SUPPLEMENTARY INFORMATION:
7 CFR Part 319
Background
[Docket No. 98–035–1]
The regulations in 7 CFR part 319
prohibit or restrict the importation into
the United States of certain plants and
plant products to prevent the
introduction of plant pests. The
regulations contained in ‘‘Subpart—
Nursery Stock, Plants, Roots, Bulbs,
Seeds, and Other Plant Products,’’
§§ 319.37 through 319.37–14 (referred to
below as the regulations) restrict, among
other things, the importation of living
plants, plant parts, and seeds for
propagation.
Paragraph § 319.37–8(a) of the
regulations requires, with certain
exceptions, that plants offered for
importation into the United States be
free of sand, soil, earth, and other
growing media. This requirement is
intended to help prevent the
introduction of plant pests that might be
present in the growing media; the
exceptions to the requirement take into
account factors that mitigate that plant
pest risk. Those exceptions, which are
found in paragraphs (b) through (e) of
§ 319.37–8, consider either the origin of
the plants and growing media
(paragraph (b)), the nature of the
growing media (paragraphs (c) and (d)),
or the use of a combination of growing
conditions, approved media,
inspections, and other requirements
(paragraph (e)).
That combination approach found in
§ 319.37–8(e) provides conditions under
which plants from nine listed genera
may be imported into the United States
established in an approved growing
medium. In addition to specifying the
types of plants that may be imported,
§ 319.37–8(e) also:
• Specifies the types of growing
media that may be used;
• Requires plants to be grown in
accordance with written agreements
between the Animal and Plant Health
Inspection Service (APHIS) and the
This section of the FEDERAL REGISTER
contains notices to the public of the proposed
issuance of rules and regulations. The
purpose of these notices is to give interested
persons an opportunity to participate in the
rule making prior to the adoption of the final
rules.
DEPARTMENT OF AGRICULTURE
Importation of Orchids in Growing
Media
AGENCY: Animal and Plant Health
Inspection Service, USDA.
ACTION: Proposed rule.
We are proposing to amend
our regulations governing the
importation of plants and plant
products to add orchids of the genus
Phalaenopsis to the list of plants that
may be imported in an approved
growing medium subject to specified
growing, inspection, and certification
requirements. We have assessed the pest
risks associated with the importation of
Phalaenopsis spp. orchids established
in growing media and have determined
that the degree of pest risk is no greater
than the pest risk associated with the
importation of bare-rooted Phalaenopsis
spp. orchids, which may already be
imported under the regulations. This
proposed rule would allow
Phalaenopsis spp. orchids established
in growing media to be imported into
the United States under certain
conditions.
DATES: Consideration will be given only
to comments received on or before
November 2, 1998.
ADDRESSES: Please send an original and
three copies of your comments to
Docket No. 98–035–1, Regulatory
Analysis and Development, PPD,
APHIS, suite 3C03, 4700 River Road
Unit 118, Riverdale, MD 20737–1238.
Please state that your comments refer to
Docket No. 98–035–1. Comments
received may be inspected at USDA,
room 1141, South Building, 14th Street
and Independence Avenue SW.,
Washington, DC, between 8 a.m. and
4:30 p.m., Monday through Friday,
except holidays. Persons wishing to
SUMMARY:
plant protection service of the country
where the plants are grown and between
the foreign plant protection service and
the grower;
• Requires the plants to be rooted and
grown in a greenhouse that meets
certain requirements for pest exclusion
and that is used only for plants being
grown in compliance with § 319.37–
8(e);
• Restricts the source of the seeds or
parent plants used to produce the
plants, and requires grow-out or
treatment of parent plants imported into
the exporting country from another
country;
• Specifies the sources of water that
may be used on the plants, the height of
the benches on which the plants must
be grown, and the conditions under
which the plants must be stored and
packaged; and
• Requires that the plants be
inspected in the greenhouse and found
free of evidence of plant pests no more
than 30 days prior to the exportation of
the plants.
A phytosanitary certificate issued by
the plant protection service of the
country in which the plants were grown
that declares that the above conditions
have been met must accompany the
plants at the time of importation. These
conditions have been used successfully
to mitigate the risk of pest introduction
associated with the importation into the
United States of approved plants
established in growing media.
In 1997, the Government of Taiwan
requested that APHIS consider
amending the regulations to allow
orchids of the genus Phalaenopsis—
commonly known as moth orchids—to
be imported into the United States
under the provisions of § 319.37–8(e).
Taiwan is the largest exporter of
Phalaenopsis spp. orchids to the United
States, exporting most of them as barerooted plants under the provisions of
§ 319.37–8(a). Several other countries,
notably Thailand and The Netherlands,
also export orchids, including
Phalaenopsis spp. orchids, to the United
States. In its request, the Taiwanese
Government specifically requested that
we allow Phalaenopsis spp. orchids to
be imported into the United States
established in sphagnum moss, which is
one of the approved growing media
listed in § 319.37–8(e)(1).
The regulations in § 319.37–8(g)
provide that a request such as that made
46404
Federal Register / Vol. 63, No. 169 / Tuesday, September 1, 1998 / Proposed Rules
by Taiwan to allow the importation of
additional taxa of plants established in
growing media will be evaluated by
APHIS using specific pest risk
evaluation standards. That analysis is
conducted to determine the plant pest
risks associated with each requested
plant article and to determine whether
or not APHIS will propose to allow the
requested plant article established in
growing media to be imported into the
United States. The pest risk evaluation,
the standards for which are set forth in
§ 319.37–8 (g)(1) through (g)(4), involves
collecting commodity information,
cataloging quarantine pests, conducting
individual pest risk assessments, and
determining an overall estimation of
risk based on a compilation of the
component estimates.
After receiving Taiwan’s request to
allow the importation of Phalaenopsis
spp. orchids established in growing
media, APHIS conducted the required
pest risk analysis in accordance with the
standards described above. (The
analysis is described in a qualitative,
pathway-initiated pest risk assessment
titled ‘‘Importation of Moth Orchid
(Phalaenopsis spp.) Seedlings from
Taiwan in Growing Media into the
United States,’’ copies of which are
available through the person listed
under FOR FURTHER INFORMATION
CONTACT.) The pest risk assessment
identified several arthropod pests
(Planococcus minor, Spodoptera litura,
and Spodoptera sp.), mollusks (Acusta
(Bradybaena) tourranensis and
Bradybaena sp.), and fungi
(Colletotrichum phalaenopsidis,
Cylindrosporium phalaenopsidis,
Phomopsis orchidophila, and
Sphaerulina phalaenopsidis) as the
plant pests most likely to travel with the
plant and having the greatest potential
for economic damage. However, the pest
risk assessment acknowledged that the
risk presented by these plant pests is
consistent with any propagative
epiphytic orchid materials and pest
associations. Further, it is important to
note that those plant pest risks were
identified in the absence of the
mitigative effects of the requirements of
§ 319.37–8(e), which are designed to
establish and maintain a pest-free
production environment and ensure the
use of pest-free seeds or parent plants.
Given that, the pest risk assessment
concluded that it is likely that the risk
of Phalaenopsis spp. orchids, or any
other epiphytic orchid, grown in
sphagnum moss (an approved growing
medium) under modern conditions (i.e.,
the conditions required by § 319.37–
8(e)) is no greater than that posed by
epiphytic orchid material currently
allowed entry as bare-rooted plants or
on other approved epiphytic growing
media (tree fern slabs, coconut husks, or
coconut fiber).
Based on the conclusions of the pest
risk assessment, we have determined
that the importation of Phalaenopsis
spp. orchids from any country—not just
Taiwan—under the conditions required
by § 319.37–8(e) would pose no greater
plant pest risk than is posed by the
importation of epiphytic orchid material
currently allowed entry from any
country as bare-rooted plants under
§ 319.37–8(a) or established on other
approved epiphytic growing media (tree
fern slabs, coconut husks, or coconut
fiber) under § 319.37–8(d). On the basis
of that determination, we are proposing
to amend the regulations in § 319.37–
8(e) by adding the genus Phalaenopsis
to the list of genera that may be
imported established in approved
growing media. This proposed change
would allow Phalaenopsis spp. orchids
to be imported into the United States
established in approved growing media
from any country provided the orchids
were produced, handled, and imported
in accordance with the requirements of
§ 319.37–8(e) and are accompanied at
the time of importation by a
phytosanitary certificate issued by the
plant protection service of the country
in which the plants were grown that
declares that those requirements have
been met.
and kind of small entities that may
incur benefits or costs from the
implementation of this proposed rule.
Under the Federal Plant Pest Act (7
U.S.C. 150aa–150jj) and the Plant
Quarantine Act (7 U.S.C. 151–165 and
167), the Secretary of Agriculture is
authorized to regulate the importation of
plants and plant products to prevent the
introduction of injurious plant pests.
This proposed rule would amend the
regulations to add orchids of the genus
Phalaenopsis to the list of plants that
may be imported in an approved
growing medium subject to specified
growing, inspection, and certification
criteria. This proposal follows the
completion of our analysis of the pest
risks associated with the importation of
Phalaenopsis spp. orchids established
in growing media and our determination
that the degree of pest risk is no greater
than the pest risk associated with the
importation of bare-rooted Phalaenopsis
spp. orchids. This proposed rule would
allow Phalaenopsis spp. orchids
established in approved growing media
to be imported into the United States
under certain conditions.
Economic data on potted orchid
plants in general is scarce, and specific
data on potted Phalaenopsis spp.
orchids in particular is virtually
nonexistent. Nevertheless, certain
conclusions and inferences regarding
the potential economic impact of the
proposed rule are possible.
Miscellaneous
As part of this proposed rule, we are
also proposing to renumber an incorrect
footnote reference in § 319.37–8.
Domestic Production
The National Agricultural Statistics
Service (NASS) of the U.S. Department
of Agriculture (USDA) publishes data on
the value and production of potted
orchid plants in the United States.
However, that data is of limited
usefulness for this analysis because it:
(1) Shows only aggregate data for all
types of orchid plants, and does not
offer specific data for Phalaenopsis spp.
orchids as a separate orchid type; (2) is
available only for the year 1996; (3)
includes only the larger producers, i.e.,
those with annual gross sales of
$100,000 or more; and (4) includes only
producers in 36 States.
The NASS data shows that there were
169 growers of potted orchid plants in
the United States in 1996. These 169
growers sold a combined 8.2 million
potted orchids that year, with an
equivalent wholesale value of $42.7
million, for an average of $252,781 per
grower. Of the 8.2 million potted
orchids sold, 5.1 million (62 percent)
were less than 5 inches in diameter. The
average wholesale price of pots less than
5 inches in diameter was $3.90; the
average wholesale price for pots 5
inches or more in diameter was $7.30.
Executive Order 12866 and Regulatory
Flexibility Act
This proposed rule has been reviewed
under Executive Order 12866. The rule
has been determined to be not
significant for the purposes of Executive
Order 12866 and, therefore, has not
been reviewed by the Office of
Management and Budget.
In accordance with 5 U.S.C. 603, we
have performed an Initial Regulatory
Flexibility Analysis, which is set out
below, regarding the impact of this
proposed rule on small entities. Based
on the information we have, there is no
basis to conclude that adoption of this
proposed rule would result in any
significant economic impact on a
substantial number of small entities.
However, we do not currently have all
of the data necessary for a
comprehensive analysis of the effects of
this proposed rule on small entities.
Therefore, we are inviting comments on
potential effects. In particular, we are
interested in determining the number
Federal Register / Vol. 63, No. 169 / Tuesday, September 1, 1998 / Proposed Rules
The 8.2 million pots were produced in
a 6.3 million sq. ft. area, an average of
36,982 sq. ft. for each of the 169
growers. Three States—California,
Florida, and Hawaii—accounted for 55
percent of the growers and 92 percent of
the pots sold in 1996. Florida alone
accounted for about 25 percent of the
growers and about 50 percent of the pots
sold (USDA, NASS, ‘‘Floriculture Crops,
1996 Summary’’). The American Orchid
Society (AOS) does not collect statistical
data on the production of potted
Phalaenopsis spp. orchids in the United
States, but it estimates that about half of
all potted orchid plants produced in the
United States fall within that genus.
Imports and Exports
The USDA’s Foreign Agriculture
Service (FAS) collects and publishes
data on U.S. imports and exports of
orchid plants. The FAS data is also of
limited usefulness for the purposes of
this analysis because it, too, shows only
aggregate data for all types of orchid
plants without separating out figures for
separate orchid types such as
Phalaenopsis.
As noted in the background section of
this proposed rule, most of the
Phalaenopsis spp. orchids currently
imported into the United States arrive as
bare-rooted plants. We expect that
complying with the growing, inspection,
and treatment requirements of § 319.37–
8(e) would increase costs for orchid
producers in exporting countries. In
addition, the cost of shipping orchids in
growing media would be higher than the
cost of shipping bare-rooted plants.
Therefore, it is reasonable to expect that
Phalaenopsis spp. orchids would be
exported to the United States
established in growing media only if the
higher production and shipping costs
were offset by the savings that would
accompany the elimination of the costs
associated with shipping the plants
bare-rooted and then preparing them for
sale after their arrival (i.e., de-potting
the plants in the country of origin for
importation purposes, then re-potting
the plants in the United States for sale
purposes).
The FAS data shows that the United
States is a net importer of orchid plants.
In 1996, the United States imported 223
metric tons of orchid plants worth $4.3
million; Taiwan, Thailand, and The
Netherlands together accounted for 93
percent of those imports. In 1997, 289
metric tons of orchid plants worth $6.6
million were imported into the United
States, with almost 90 percent of those
imports originating in either Taiwan
(171 metric tons), Thailand (49 metric
tons), or The Netherlands (33 metric
tons). In comparison, the United States
exported 52 metric tons of orchid plants
in 1996 and 112 metric tons of orchid
plants in 1997. The value of the 1997
U.S. exports was $235,330.
Effects on Small Entities
The Regulatory Flexibility Act
requires that agencies consider the
economic impact of rule changes on
small businesses, organizations, and
governmental jurisdictions. Those
entities potentially affected by this
proposed rule are growers, retailers, and
importers of Phalaenopsis spp. orchids.
Domestic orchid growers sell their
plants primarily at wholesale to general
merchandise retailers (e.g., hardware or
home improvement stores) and to
specialty retailers such as specialty
florists and landscapers. Domestic
producers would be adversely affected if
they lose plant sales to cheaper foreign
imports. Currently, Phalaenopsis spp.
orchids grown in Taiwan are sold in the
United States at or below the price of
domestically produced Phalaenopsis
spp. orchids, according to the AOS. This
proposed rule would likely enhance the
competitive positions of the countries
currently exporting orchids to the
United States if, as discussed above, it
serves to reduce the costs that are
incurred in preparing imported, barerooted Phalaenopsis spp. orchids for
sale in the United States.
Domestic growers are already
competing with imports of bare-rooted
Phalaenopsis spp. orchids, so the
magnitude of any adverse economic
impact would depend on the extent to
which they rely on potted Phalaenopsis
spp. orchids as a source of their overall
revenue, the extent to which their sales
of potted Phalaenopsis spp. orchids are
displaced by imports, and the amount of
any increase in the overall level of
orchid plant imports. Most orchid
producers grow only orchids, and many
of those—especially the larger
producers—grow only one type of
orchid. The number of producers who
grow potted Phalaenopsis spp. orchids
exclusively, i.e., those who could be
affected most by the rule change, is
unknown. However, many producers
appear to be in that category, since the
AOS estimates that about half of all
potted orchid plants produced by U.S.
growers are of the genus Phalaenopsis.
The amount of lost sales would
depend, in turn, on the price differential
between domestic and foreign plants
and on the volume of plant imports,
both of which are unknown at this time.
If the price differential in favor of
imports was not significant, it is
conceivable that some retailers would
continue to purchase their plants from
domestic growers, especially if those
46405
growers provided superior service or
other non-price advantages. The volume
of imports is significant because it could
be too small to satisfy the demand of all
retailers, leaving some with no other
option but to purchase plants from
domestic growers.
The availability of cheaper foreign
imports would likely benefit plant
retailers and importers. Retailers would
benefit because they could pass the
savings from lower wholesale prices on
to their customers, creating an
environment that would lead to
increased sales volume and revenue.
Importers would benefit from the
income that the increased business
activity would produce.
The number of commercial growers of
potted Phalaenopsis spp. orchids in the
United States is unknown, but there are
at least 300 to 400 producers who grow
one or more of the various types of
potted orchid plants, since that is the
number of growers who advertise their
products through the AOS. The number
of retailers who sell potted Phalaenopsis
spp. orchids is also unknown, as is the
number of importers. Nevertheless, it is
reasonable to assume that most of the
entities potentially affected by this
proposed rule are small, at least by U.S.
Small Business Administration’s (SBA)
standards. This assumption is based on
composite data for providers of the same
and similar services in the United
States. In 1992, the per-farm average
gross receipts for all 38,569 U.S. farms
in Standard Industrial Classification
(SIC) 0181 (‘‘Ornamental Floriculture
and Nursery Products,’’ which includes
potted orchid producers) was $174,431,
well below the SBA’s small entity
threshold of $0.5 million for those
farms. Similarly, the 1993 per-firm
average gross receipts for all 9,867 U.S.
firms in SIC 5261 (‘‘Retail Nurseries,
Lawn and Garden Supply Stores,’’
which includes plant retailers) was
$688,898, well below the SBA’s small
entity threshold of $5 million. In 1993,
there were 3,877 U.S. firms in SIC 5193
(‘‘Flowers, Nursery Stock, and Florists’
Supplies,’’ which includes plant
importers), and 98 percent of those
firms had fewer than 100 employees, the
SBA’s small entity threshold.
Alternatives Considered
Two alternatives to this proposed rule
were considered: (1) To make no
changes in the regulations and (2) to
limit the scope of the proposed rule to
Phalaenopsis spp. orchids from Taiwan.
We rejected the first alternative—
making no change in the regulations—
after determining that the degree of pest
risk associated with the importation of
Phalaenopsis spp. orchids in growing
46406
Federal Register / Vol. 63, No. 169 / Tuesday, September 1, 1998 / Proposed Rules
media under the conditions set forth in
§ 319.37–8(e) is no greater than the pest
risk associated with the importation of
bare-rooted Phalaenopsis spp. orchids.
Because there is no greater risk
involved, we have no plant pest-based
rationale for rejecting the Taiwanese
request that we consider allowing the
importation of Phalaenopsis spp.
orchids in growing media. Similarly, we
rejected the second alternative of
limiting the scope of the proposal to
Phalaenopsis spp. orchids from Taiwan
because our pest risk assessment
indicated that Phalaenopsis spp.
orchids produced in accordance with
the growing, inspection, and
certification requirements of the
regulations could be safely imported
from any country, regardless of specific
pest associations.
Executive Order 12988
This proposed rule would allow the
importation of Phalaenopsis orchids
established in growing media under
certain conditions. If this proposed rule
is adopted, State and local laws and
regulations regarding Phalaenopsis
orchids imported under this rule would
be preempted while the plants are in
foreign commerce. Some nursery stock
articles are imported for immediate
distribution and sale to the consuming
public, and would remain in foreign
commerce until sold to the ultimate
consumer. The question of when foreign
commerce ceases in other cases must be
addressed on a case-by-case basis. If this
proposed rule is adopted, no retroactive
effect would be given to this rule, and
this rule would not require
administrative proceedings before
parties may file suit in court challenging
this rule.
Paperwork Reduction Act
This proposed rule contains no new
information collection or recordkeeping
requirements under the Paperwork
Reduction Act of 1995 (44 U.S.C. 3501
et seq.).
List of Subjects in 7 CFR Part 319
Bees, Coffee, Cotton, Fruits, Honey,
Imports, Incorporation by reference,
Nursery stock, Plant diseases and pests,
Quarantine, Reporting and
recordkeeping requirements, Rice,
Vegetables.
Accordingly, we are proposing to
amend 7 CFR part 319 as follows:
PART 319—FOREIGN QUARANTINE
NOTICES
1. The authority citation for part 319
would continue to read as follows:
Authority: 7 U.S.C. 150dd, 150ee, 150ff,
151–167, 450, 2803, and 2809; 21 U.S.C. 136
and 136a; 7 CFR 2.22, 2.80, and 371.2(c).
§ 319.37–8
[Amended]
2. In § 319.37–8, paragraph (e), the
introductory text of the paragraph
would be amended by removing the
footnote reference 11 immediately after
the word ‘‘Nidularium,’’ and adding the
footnote reference 10 in its place, and by
adding the word ‘‘Phalaenopsis,’’
immediately after the word
‘‘Peperomia,’’.
Done in Washington, DC, this 25th day of
August 1998.
Alfred S. Elder,
Acting Administrator, Animal and Plant
Health Inspection Service.
[FR Doc. 98–23406 Filed 8–31–98; 8:45 am]
BILLING CODE 3410–34–P
SBA: Office of Advocacy - United States Department of Agriculture, Animal, Plant and Inspection Service - 12/2/98
Office of Advocacy
December 2, 1998
Regulatory Analysis and Development
Policy and Program Development Division
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
Suite 3C03
4700 River Road Unit 118
Riverdale, MD 20737-1238
Re: Proposed Rule for Importation of Orchids in Growing Media; 63
Fed. Reg. 46,403 (September 1, 1998); Docket No. 98-035-1.
Dear Docket Manager:
On September 1, 1998, the Animal and Plan Health Inspection Service (APHIS) published a
proposed rule to add orchids of the genus Phalaenopsis to the list of plants that may be imported
in an approved growing medium under certain conditions. The government of Taiwan, already
the largest exporter of this type of orchid to the United States in bare root form, requested
permission to export the orchids established in sphagnum moss (--an approved growing medium).
APHIS is permitted to prohibit or restrict the importation of certain plants and plant products into
the United States in order to prevent the introduction of plant pests. With certain exceptions,
plants offered for importation into the United States must be free of sand, soil, earth and other
growing media—a requirement intended to help prevent the introduction of plant pests present in
such growing media. The exceptions take into account requirements that mitigate the plant pest
risk (i.e., the plants were rooted and grown in certain greenhouse conditions, approved types of
growing media were used, etc.).
Pursuant to the requirements in 7 C.F.R. part 319, APHIS conducted a pest risk analysis in
accordance with its regulatory standards. Based on the conclusions of the pest risk analysis,
APHIS determined that the importation of the designated orchids from Taiwan or any other
country under the conditions required by section 319.37-8(e) would pose no greater pest risk than
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currently posed by the importation of the plant in bare root form. The effect of this regulatory
amendment will be to allow, without any quantity restriction, importation of the designated genus
of orchid from all foreign countries.
Effect of Proposal on Small Entities
The Office of the Chief Counsel for Advocacy of the U.S. Small Business Administration (SBA)
was created in 1976 to represent the views and interests of small businesses in federal policy
making activities.(1) The Chief Counsel participates in rulemakings when he deems it necessary
to ensure proper representation of small business interests. In addition to these responsibilities the
Chief Counsel monitors compliance with the Regulatory Flexibility Act (RFA), and works with
federal agencies to ensure that their rulemakings analyze and substantiate the impact that their
decisions will have on small businesses.
The Office of Advocacy does not have sufficient expertise to question or challenge APHIS’s pest
risk analysis. However, this office does wish to comment on the potential impact of this proposed
amendment on small orchid growers and the agency’s failure to prepare an adequate initial
regulatory flexibility analysis (IRFA).
APHIS Did Not Comply with the Requirements of the RFA
Section 603 of the RFA requires agencies to prepare an IRFA whenever the agency determines
that there will be a significant economic impact on a substantial number of small entities. The
analysis must describe the impact of the proposed rule on small entities and must contain, among
other things, a description of the compliance requirements (i.e., the costs).
APHIS supplies information on approximate annual receipts, number of pots produced, and the
number of growers for all types of orchids based on National Agricultural Statistics Service data
in the proposed rule. The agency also provides information from USDA’s Foreign Agricultural
Service regarding U.S. imports of all bare root orchid plants. Finally, the agency correctly
concludes that most of the entities potentially affected by the proposed rule are small by U.S.
Small Business Administration standards.
However, the agency’s analysis does not go beyond a very general discussion of the price
differential between domestic and foreign plants and on the volume of plant imports—both of
which are unknown to the agency. The agency does not address other potential impacts of the
regulation. For instance, there is a niche industry that establishes Phalaenopsis imported bare root
orchids in pots and then sells the potted orchids wholesale. In addition, there are factors that
contribute to the likelihood that the U.S. market will be flooded and dominated by Taiwanese
businesses. Some of those factors include the overwhelming size of the Taiwan orchid industry in
comparison to that of the U.S., the low production costs in Taiwan (i.e., low employee wages),
and government subsidies enjoyed by Taiwanese companies.
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The orchid industry also has data regarding the number of domestic orchid growers, domestic
production and sales, and the characteristics of orchid grower businesses (e.g., average cost to
grow orchid plants, etc.). More importantly, the industry has historical data documenting the
impact of foreign dumping on domestic flower growing generally.
According to a recent report titled The Changing Floriculture Industry: A Statistical Overview by
the Society of American Florists (January 1997), production of carnations, roses and
chrysanthemums fell sharply after foreign imports were allowed to flood the market. To wit:
"In 1971, U.S. domestic growers produced over 589 million carnations and supplied almost 95%
of the domestic market. Imports accounted for about half of the carnations sold in the U.S. in
1980, and in 1991, the over 1 billion standard carnations imported accounted for almost 85% of
the carnations sold in the U.S. In 1991, Columbia alone was the source of over 96% of imported
carnations, with Ecuador and Mexico the next largest suppliers. The latest data, for 1995, shows
domestic production falling to 113,8 million blooms representing only 12 percent of the supply.
Imports now account for the remaining 88 percent."(2)
APHIS appears to be ambivalent about the impact of the proposal on small orchid producers.
Initially, APHIS states that there is no basis to conclude that adoption of the proposed rule would
result in any significant economic impact on a substantial number of small entities. Such a
statement seems to contradict APHIS’s subsequent statement that the current imports from
Taiwan are sold in the US below the price of domestic orchids. If the foreign orchids are sold at a
lower price, it is reasonable to assume that the rule will allow expanded importation of foreign
less expensive orchids, and therefore would have a negative impact on domestic growers.
Furthermore, given the findings in the report on the impact of the importation of roses,
carnations, and chrysanthemums, it is reasonable to assume that the importation will be in mass
amounts that could lead to the crippling or closure of U.S. businesses.
Later, APHIS acknowledged that the proposed rule would likely impact domestic growers,(3) but
the agency expressed uncertainty with regard to the degree of impact. The International Trade
Commission furnishes studies, reports, and recommendations involving international trade to the
President, Congress, and government agencies. Did APHIS contact the ITC to garner information
about the potential economic impact of the importation of orchids on domestic producers?
Finally, APHIS concludes that retailers, importers and consumers may benefit from the proposed
rule—at least in the near term—by allowing unrestricted dumping of foreign orchids. Whether or
not benefits confer to consumers and retailers is entirely dependent on whether importers pass
along savings. In any event, growers would surely be impacted severely.
APHIS Failed to Consider Significant Alternatives to the Proposed Rule
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Section 603(c) of the RFA states that each IRFA shall contain a description of any significant
alternatives to the proposed rule which accomplishes the stated objectives of applicable statutes
and which minimize any significant economic that the proposed rule will have on small entities.
Although the agency considered two alternatives to the proposal, they were not analyzed from the
standpoint of obtaining alternatives that minimized economic impact. The alternatives considered
were 1) no regulatory action, and 2) allowing importation from Taiwan only. Both alternatives
were rejected solely on the basis of the pest risk analysis, not economics. In other words, cost/
economic impact did not appear to have been a consideration in weighing less burdensome
alternatives.
While APHIS may have lacked certain economic data that would enable the agency to select the
alternatives with the least impact on small businesses, it is fairly clear that APHIS has selected
the alternative with the greatest potential for harm. If the agency’s objective is to respond to a
request for importation of orchids made by Taiwan, the alternative that accomplishes that goal is
to allow importation from Taiwan only. To allow unrestricted importation from Taiwan and all
other countries goes beyond the stated objective of the proposal and exacerbates the economic
impact on small entities, thus usurping the purpose of the RFA.
Furthermore, other alternatives may have been available that accomplish the objective of
allowing the importation of orchids while minimizing the economic impact. For instance, the
International Trade Administration at the Department of Commerce imposes quotas on foreign
imports of non-agricultural products to prevent dumping and to preserve domestic markets.
Would the imposition of a quota for imports minimize the impact of the importation of orchids on
small orchid growers?
Conclusion
In promulgating the RFA, Congress intended to create an analytical process through which
agencies would consider the impact of their actions on small entities and assure that small entities
were not being harmed economically by unduly burdensome regulations. Requiring agencies to
perform an IRFA is intended to provide the public with sufficient information on an agency’s
analysis to elicit informed public comment of an agency’s findings and alternatives. Public
comments on an agency’s analysis help the agency achieve rational rulemaking. By failing to
provide a thorough analysis and viable alternatives, APHIS has failed to meet its duty to comply
with the requirements of the RFA and is depriving itself of an opportunity to elicit information
that would help it craft a different regulatory solution.
If you have any questions, please do not hesitate to contact my office at (202) 205-6533.
Sincerely,
Jere W. Glover
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Chief Counsel
Jennifer A. Smith
Asst. Chief Counsel
Economic Regulation & International Trade
Shawne Carter McGibbon
Asst. Chief Counsel
Food, Drug & Health Policy
ENDNOTES
1. Regulatory Flexibility Act, 5 U.S.C. § 601, as amended by the Small Business Regulatory Flexibility
Act, Pub. L. No. 104-121, 110 Stat. 866 (1996).
2. The Changing Floriculture Industry at 9.
3. See 63 Fed. Reg. at 46,405.
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Guidelines for Pathway-Initiated Pest Risk Assessments
U.S. Department of Agriculture
Animal and Plant Health Inspection Service
Plant Protection and Quarantine
Permits and Risk Assessment
Commodity Risk Analysis Branch
4700 River Road, Unit 133
Riverdale, MD 20737-1236
— Version 5.02 —
October 17, 2000
Introduction
This document presents guidelines for pathway-initiated, qualitative pest risk assessments
conducted by Plant Protection and Quarantine (PPQ) within the Animal and Plant Health
Inspection Service (APHIS) of the U.S. Department of Agriculture. The goal is to harmonize PPQ
risk assessment procedures with guidelines provided by the Food and Agriculture Organization
(FAO) and the North American Plant Protection Organization (NAPPO). The use of biological
and phytosanitary terms conforms with the FAO Glossary of Phytosanitary Terms (FAO, 1999)
(included as Appendix 1 of this document), the Definitions and Abbreviations (Introduction
Section) in International Standards for Phytosanitary Measures, Section 1—Import Regulations:
Guidelines for Pest Risk Analysis (FAO 1996) and the NAPPO Compendium of Phytosanitary
Terms (NAPPO 1996).
Pest risk assessment is one of three stages of an overall pest risk analysis (FAO, 1996):
Stage 1: Initiating the process for analyzing pest risk (identifying pests or pathways for which the
pest risk analysis is needed)
Stage 2: Assessing pest risk (determining which pests are quarantine pests, characterized in terms
of likelihood of entry, establishment, spread, and economic importance)
Stage 3: Managing pest risk (developing, evaluating, comparing and selecting options for dealing
with the risk)
This document provides a template for conducting FAO Stages 1 and 2. The FAO process (1996)
also describes two general categories of initiating events for pest risk analyses. A pest risk
analysis can be either “pest initiated” (a quarantine pest is discovered in a new area, a pest is
intercepted at a port of entry, etc.) or “pathway initiated” (international trade is initiated in a new
commodity, etc.). This document describes procedures used by PPQ for pathway-initiated pest
risk assessments.
PPQ conducts pathway-initiated pest risk assessments at both qualitative and quantitative levels.
This document outlines the process for qualitative pest risk assessments. Both types of
assessments are similar in most respects, however, in quantitative assessments quarantine pests
are examined in greater detail and provide a quantitative assessment of the likelihood of
introduction (see Step 6). PPQ completes six basic steps in pathway-initiated pest risk
assessments:
Stage 1 (FAO): Initiating Pest Risk Analysis Process
Step 1. Document the initiating event(s) for the PRA.
Stage 2 (FAO): Assessing Pest Risk
Step 2. Assess Weediness Potential (of the species to be imported).
Step 3. Identify Previous Risk Assessments, Current Status of Importations, and Pertinent
Pest Interceptions.
1
Step 4a. Pest Categorization. Produce a list of pests of the commodity parent species and then
determine their quarantine status.
Step 4b. Identify Potential Quarantine Pests. Identify pests of potential quarantine significance
reported to be associated with the host species in the exporting country/region.
Step 4c. Identify Quarantine Pests Likely to Follow the Pathway. Determine which
quarantine pests may reasonably be expected to follow the pathway.
Step 5. Assess Consequences of Introduction. For each quarantine pest expected to follow the
pathway, estimate the consequences of introduction. Issues to consider include “...the
establishment, spread and economic importance potential in the PRA area” (FAO, 1996).
Environmental impacts are also addressed.
Step 6. Assess Introduction Potential. For each quarantine pest expected to follow the
pathway, estimate the likelihood of introduction via the pathway.
Step 7. Conclusion / Phytosanitary Measures: Pest Risk Potential of Quarantine Pests.
Produce a single rating which represents an overall estimate of the risk posed by
each quarantine pest. Comment briefly on the meaning of the Pest Risk Potentials for
each quarantine pest. Although this document focuses on risk assessment, the risk
assessment (FAO Stages 1 and 2) and risk management (FAO Stage 3) stages are
interrelated. Accordingly, the risk assessor may occasionally make brief comments
regarding risk management options associated with the requested commodity
importations.
Methods: Pest Risk Assessment Guidelines
FAO Stage 1: Initiating Pest Risk Analysis (PRA) Process
Step 1. Document the Initiating Event(s) for the PRA
Document the reason(s) for initiating the pathway-initiated PRA, e.g., importation of a new
commodity or new importation from a new area provides a potential pathway for the introduction
of plant pests.
Stage 2 (FAO): Assessing Pest Risk
Step 2. Assess Weediness Potential (Table 1)
Assess the weediness potential of the imported species. This step is important to the initiation
process because if the assessment finds that the species being considered for import poses a risk
as a weed pest, then a “pest-initiated” pest risk assessment may be initiated. If the species to be
imported passes the weediness screening, the pathway-initiated pest risk assessment continues.
Table 1 shows how weediness potential is assessed and can be used to present findings and
conclusions.
2
Table 1. Process for Determining Weediness Potential of Commodity
Commodity: (Scientific and common names of commodity)
Phase 1: Consider whether the species is new to or not widely prevalent in the United States
(exclude plants grown under USDA permit in approved containment facilities)?
Phase 2: Answer Yes or No to the following questions:
Is the genus, species, or subspecies listed in:
Geographical Atlas of World Weeds (Holm et al., 1979)
World's Worst Weeds (Holm et al., 1977)
World Weeds: Natural Histories and Distribution (Holm et al., 1997)
Report of the Technical Committee to Evaluate Noxious Weeds; Exotic
Weeds for Federal Noxious Weed Act (Gunn and Ritchie, 1982)
Economically Important Foreign Weeds (Reed, 1977)
Weed Science Society of America list (WSSA, 1989)
Is there other literature reference indicating weediness (e.g., AGRICOLA, CAB,
Biological Abstracts, AGRIS; search on "species name" combined with
"weed").
Phase 3: Conclusion:
IF: 1. The species is widely prevalent in the United States and the answers to all of the
questions are no...
Proceed with the pest risk assessment.
2. The species is widely prevalent in the United States and the answer to one or
more of the questions is yes...
Proceed with the pest risk assessment, provide comments on findings in
text, and incorporate findings regarding weediness into the Risk Elements
described below.
3. The species is new to or not widely prevalent in the United States and the
answers to all of the questions are no...
Proceed with the pest risk assessment.
4. The species is new to or not widely prevalent in the United States and the
answer to one or more of the questions is yes...
Consult authority under the Federal Noxious Weed Act for listing plant
species as a noxious weed and consider the advisability of performing a
pest-initiated pest risk assessment on the plant species. Provide
explanations of findings in text.
3
Step 3. Identify and Cite Previous Risk Assessments
Identify previous pest risk assessments from the same country/region and the same, or related
commodity. If there is an existing risk assessment that adequately assesses the risks in question,
the risk assessment stops. Describe appropriate current importations, e.g., same commodity from
other countries, other commodities from the country in question. Report pertinent pest
interceptions at United States ports of entry.
Step 4a. Pest Categorization (Table 2)
PPQ adheres to accepted international definitions of quarantine pest: a pest of potential economic
importance to the area endangered thereby and not yet present there, or present but not widely
distributed and being officially controlled (FAO, 1996; NAPPO, 1996 ). The first step in
identifying quarantine pests is to present a comprehensive pest list of potential quarantine pests
known to occur in the country or region from which the commodity is to be exported (Table 2).
The list includes all pests in the exporting country known to be associated with the parent species
of the proposed export commodity. Because all pests on the list are associated with the plant
species they are considered to be “of potential economic importance” (FAO, 1996). The listed
pests may or may not also occur in the United States.
There are two primary components to the definition of quarantine pest (FAO, 1996; NAPPO,
1996). First, a pest must be “of potential economic importance.” To be included on the
comprehensive list of potential quarantine pests, an organism is considered to be of potential
economic importance because scientific evidence, as indicated in the literature, demonstrates that
an organism has an association with the plant species being assessed. Thus, all of the listed
organisms are potential quarantine pests. Second, to be considered a quarantine pest, an organism
must satisfy geographic and regulatory criteria, specifically, the pest must be “not yet present there,
or present but not widely distributed and being officially controlled” (FAO, 1996; NAPPO, 1996).
Information should be collected and provided in the risk assessment which documents how each
organism satisfies these criteria. Pertinent geographic and regulatory information, i.e., with
respect to the exporting country and the United States, should be provided on the comprehensive
pest list. If none of the potential quarantine pests satisfy the geographic and regulatory criteria as a
quarantine pest, the PRA stops. For each pest on the list, include:
¯ scientific name (when available)
¯ selected references
¯ limited pertinent information regarding:
¯ the regulatory status of a pest, as determined by APHIS or other Federal
Agencies
¯ pest biology, e.g., pest-parent species or pest-commodity association, pathway
association, life history, climatic tolerance
¯ geographic distribution with respect to the exporting country and the U.S.
¯ regulatory history, e.g., interception records at U.S. ports.
The list of information sources, at a minimum, should include:
¯ Literature reviews using electronic databases, e.g., AGRICOLA, CAB database,
University of California computer information system, MELVYL
4
¯ Previous risk assessments covering importation of the commodity
¯ The PPQ catalogue of intercepted pests and interception records
¯ CIE and CMI. Distribution Maps/Descriptions of Plant Pests (Arthropods, Fungi,
Bacteria)
¯ Various texts and indices of plant diseases and pathogens
¯ PPQ files on Pests Not Known To Occur in the U. S. (PNKTOs) and Insects Not
Known To Occur (INKTOs)
¯ International databases, e.g. EPPO, FAO, CABI/CPC
Step 4b. Identify Quarantine Pests Likely to Follow the Pathway
Quarantine pests identified as likely to be associated with the potential export commodity are
subjected to steps 5-7. The biology and pest potential for these pests is documented as completely
as possible. It must be reasonable to assume these quarantine pest will:
¯ be present in the exporting country
¯ be associated with the commodity at the time of harvest
¯ remain with the commodity in viable form during harvesting, packing and shipping
procedures
Because pests associated with the parent species are listed, there will be quarantine pests not
expected to follow the pathway. For example:
¯ a pest may be associated only with plant parts other than the commodity
¯ a pest may not reasonably be expected to remain with the commodity during harvest and
packing
Pests not expected to follow the pathway are not considered further. Supporting information must
be documented on the pest list or in the text. The decision not to further analyze a particular pest
applies only to the current PRA; a pest may pose a different level of risk for the same commodity
from a different country or from a different commodity from the same host plant species.
However, should any of the pests be intercepted in shipments of the commodity, quarantine action
may be taken at the port of entry and additional risk analyses may be conducted.
IF NO POTENTIAL QUARANTINE PESTS ARE IDENTIFIED , THE PRA STOPS AT THIS POINT.
5
Table 2. Pests Associated With Commodity in Country
Pest
Geographic
Distribution1
Plant Part
Affected2
Quarantine
Pest3
Follow
Pathway3
References
Arthropods
Pest species Author
(Order: Family)
Viruses
name
(Family)
Bacteria
Pest species Author
(Order)
Fungi
Pest species Author
(Class or
Superclass: Order)
Nematodes
Pest species Author
(Family)
Mollusks
Pest species Author
(Family)
1
Use two letter abbreviations to represent countries and states
2
Use abbreviations, e.g., L (leaf), F (fruit), to indicate affected plant parts
3
Use “Yes” or “No”
*Additional explanatory notes for Table entries may be placed here
IF NO QUARANTINE PESTS ARE EXPECTED TO FOLLOW THE PATHWAY, THE PRA STOPS.
Step 5. Assess Consequences of Introduction (Table 3)
The undesirable outcomes being considered are the negative impacts resulting from the
introduction of quarantine pests. After identifying those quarantine pests that could reasonably be
expected to follow the pathway, the assessment of risk continues by considering the consequences
of introduction (Table 3). For each of these quarantine pests, the potential consequences of
introduction are rated using five Risk Elements. These elements reflect the biologies, host ranges
6
and climatic/geographic distributions of the pests. For each Risk Element, pests are assigned a
rating of or or Low (L, 1 point), Medium (M, 2 points) or High (H, 3 points). A Cumulative Risk
Rating is then calculated by summing all Risk Element values.
Risk Element #1: Climate—Host Interaction
When introduced to new areas, pests can be expected to behave as they do in their native
areas if host plants and climates are similar. Ecological zonation and the interactions of
the pests and their biotic and abiotic environments are considered in the element.
Estimates are based on availability of both host material and suitable climate conditions.
To rate this Risk Element, the U.S. "Plant Hardiness Zones" U.S. Department of
Agriculture (USDA, 1990) is used (Figure 1). Due to the availability of both suitable host
plants and suitable climate, the pest has potential to establish a breeding colony:
Low (1): In a single plant hardiness zone.
Medium (2): In two or three plant hardiness zones.
High (3): In four or more plant hardiness zones.
IF NONE OF THE QUARANTINE PESTS ARE CAPABLE OF BECOMING ESTABLISHED IN THE PRA
AREA BECAUSE OF THE ABSENCE OF SUITABLE CLIMATES OR HOSTS , THE PRA STOPS.
Risk Element #2: Host Range
The risk posed by a plant pest depends on both its ability to establish a viable, reproductive
population and its potential for causing plant damage. For arthropods, risk is
assumed to be correlated positively with host range. For pathogens, risk is more
complex and is assumed to depend on host range, aggressiveness, virulence and
pathogenicity; for simplicity, risk is rated as a function of host range.
Low (1): Pest attacks a single species or multiple species within a single genus.
Medium (2): Pest attacks multiple species within a single plant family.
High (3): Pest attacks multiple species among multiple plant families.
Risk Element #3: Dispersal Potential
A pest may disperse after introduction to a new area. The following items are considered:
¯ reproductive patterns of the pest (e.g., voltinism, biotic potential)
¯ inherent powers of movement
¯ factors facilitating dispersal (wind, water, presence of vectors, human, etc.)
Low (1): Pest has neither high reproductive potential nor rapid dispersal
capability.
Medium (2): Pest has either high reproductive potential OR the species is capable
of rapid dispersal.
High (3): Pest has high biotic potential, e.g., many generations per year, many
offspring per reproduction (“r-selected” species), AND evidence exists that
the pest is capable of rapid dispersal , e.g., over 10 km/year under its own
power; via natural forces, wind, water, vectors, etc., or human-assistance.
7
Risk Element #4: Economic Impact
Introduced pests are capable of causing a variety of direct and indirect economic impacts.
These are divided into three primary categories (other types of impacts may occur):
¯ Lower yield of the host crop, e.g., by causing plant mortality, or by acting as a
disease vector.
¯ Lower value of the commodity, e.g., by increasing costs of production, lowering
market price, or a combination.
¯ Loss of foreign or domestic markets due to presence of new quarantine pest.
Low (1): Pest causes any one or none of the above impacts.
Medium (2): Pest causes any two of the above impacts.
High (3): Pest causes all three of the above impacts.
Risk Element #5: Environmental Impact (Table 4)
The assessment of the potential of each pest to cause environmental damage (Table 4)
(FAO, 1995) proceeds by considering the following factors:
¯ Introduction of the pest is expected to cause significant, direct environmental
impacts, e.g., ecological disruptions, reduced biodiversity. When used within
the context of the National Environmental Policy Act (NEPA) (7CFR §372),
significance is qualitative and encompasses both the likelihood and severity of an
environmental impact.
¯ Pest is expected to have direct impacts on species listed by Federal Agencies as
endangered or threatened (50CFR §17.11 and §17.12), by infesting/infecting a
listed plant. If the pest attacks other species within the genus or other genera
within the family, and preference/no preference tests have not been conducted
with the listed plant and the pest, then the plant is assumed to be a host.
¯ Pest is expected to have indirect impacts on species listed by Federal Agencies
as endangered or threatened by disrupting sensitive, critical habitat.
¯ Introduction of the pest would stimulate chemical or biological control
programs.
Low (1): None of the above would occur; it is assumed that introduction of a
nonindigenous pest will have some environmental impact (by definition,
introduction of a nonindigenous species affects biodiversity).
Medium (2): One of the above would occur.
High (3): Two or more of the above would occur.
For each pest, sum the five Risk Elements to produce a Cumulative Risk Rating. This Cumulative
Risk Rating is considered to be a biological indicator of the potential of the pest to establish,
spread, and cause economic and environmental impacts. The Cumulative Risk Rating should be
interpreted as follows:
Low: 5 - 8 points
Medium: 9 - 12 points
High: 13 - 15 points
8
Table 3. Risk Rating for Consequences of Introduction: (Risk Elements #1-5)
Risk
Element 1
Risk
Element 2
Risk
Element 3
Risk
Element 4
Risk
Element 5
Climate/Host
Interaction
Host
Range
Dispersal
Potential
Economic
Impact
Environmental
Impact
L, M, H
(1, 2, 3)
L, M, H
(1, 2, 3)
L, M, H
(1, 2, 3)
L, M, H
(1, 2, 3)
L, M, H
(1, 2, 3)
Pest
Pest species
(Order: Family)
Cumulative
Risk Rating
L, M, H
(5 - 15)
Step 6. Assess Introduction Potential (Table 4)
Use Risk Element 6 to rate the potential likelihood of introduction for quarantine pests likely to
follow the pathway. The cumulative score for the Likelihood of Introduction Risk Elements is
referred to as the Likelihood of Introduction Risk Score.
Risk Element #6: Pest Opportunity (Survival and Access to Suitable Habitat and Hosts)
For each pest, consider six sub-elements:
1. Quantity of commodity imported annually: The likelihood that an exotic pest will
be introduced depends on the amount of the potentially-infested commodity that is
imported. For qualitative pest risk assessments, the amount of commodity imported is
estimated in units of standard 40 foot long shipping containers. In those cases where
the quantity of a commodity imported is provided in terms of kilograms, pounds,
number of items, etc., convert the units into terms of 40 foot shipping containers.
Score as follows:
Low (1 point): < 10 containers/year
Medium (2 points): 10 - 100 containers/year
High (3points): > 100 containers/year
2. Survive postharvest treatment: For this sub-element, postharvest treatment refers to
any manipulation, handling or specific phytosanitary treatment to which the commodity
is subjected. Examples of postharvest treatments include culling, washing, chemical
treatment, cold storage, etc. If there is no postharvest treatment, estimate the
likelihood of this sub-element as High.
3. Survive shipment: Estimate survival during shipment; assume standard shipping
conditions.
4. Not be detected at the port of entry: Unless specific protocols are in place for
special inspection of the commodity in question, assume standard inspection protocols
for like commodities. If no inspection is planned, estimate this sub-element as high.
9
5. Imported or moved subsequently to an area with an environment suitable for
survival: Consider the geographic location of likely markets and the proportion of the
commodity that is likely to move to locations suitable for pest survival. Even if infested
commodities enter the country, not all final destinations will have suitable climatic
conditions for pest survival.
6. Come into contact with host material suitable for reproduction: Even if the final
destination of infested commodities are suitable for pest survival, suitable hosts must be
available in order for the pest to survive. Consider the complete host range of the pest
species.
Rate sub-elements 2-6 as follows:
Low (1 point): < 0.1% (less than one in one thousand)
Medium (2 points): Between 0.1% - 10% (between one in one thousand to one in
ten)
High (3 points): > 10% (greater than one in ten)
The events described in sub-elements 2 - 6 should be considered as a series of independent events
that must all take place before a pest outbreak can occur, i.e., the estimates for one element should
not affect estimates for other elements.
For each pest, sum the six sub-elements to produce a Cumulative Risk Rating for the Likelihood of
Introduction (Table 4). This Cumulative Risk Rating is considered to be an indicator of the
likelihood that a particular pest would be introduced. Interpret the Cumulative Risk Rating for the
Likelihood of Introduction as follows:
Low: 6 - 9 points
Medium: 10 - 14 points
High: 15 - 18 points
Table 4. Risk Rating for Likelihood of Introduction: (Risk Element #6)
Pest
Pest
species
Subelement 1
Subelement 2
Subelement 3
Quantity
imported
annually
Survive
postharvest
treatment
Survive
shipment
L, M, H
(1, 2, 3)
L, M, H
(1, 2, 3)
Subelement 4
Subelement 5
Subelement 6
Not
detected at
port of
entry
Moved to
suitable
habitat
Contact
with host
material
L, M, H
(1, 2, 3)
L, M, H
(1, 2, 3)
L, M, H
(1, 2, 3)
10
L, M, H
(1, 2, 3)
Cumulative
Risk Rating
L, M, H
(6 - 18)
Step 7. Conclusion/Pest Risk Potential: Pests Requiring Phytosanitary Measures (Table 5)
To estimate the Pest Risk Potential for each pest, sum the Cumulative Risk Rating for the
Consequences of Introduction and the Cumulative Risk Rating for the Likelihood of Introduction
(Table 5). Rate the Pest Risk Potential as follows:
Low: 11 - 18 points
Medium: 19 - 26 points
High: 27 - 33 points
Table 5. Pest Risk Potential
Pest
Pest species
Consequences of Introduction
Cumulative Risk Rating
Likelihood of Introduction
L, M, H
(5 - 15)
L, M, H
(6 - 18)
Pest Risk Potential
Cumulative Risk Rating
L, M, H
(11 - 33)
Following assignment of the Pest Risk Potential for each pest, the risk assessor may comment
briefly on risk management options associated with the requested commodity importations. The
following guidelines are offered as an interpretation of the Low, Medium and High Pest Risk
Potential ratings:
Low: Pest will typically not require specific mitigations measures; the port-of-entry inspection to
which all imported commodities are subjected can be expected to provide sufficient
phytosanitary security.
Medium: Specific phytosanitary measure may be necessary.
High: Specific phytosanitary measures are strongly recommended. Port-of-entry inspection is
not considered sufficient to provide phytosanitary security.
Identification and selection of appropriate sanitary and phytosanitary measures to mitigate risk for
pests with particular Pest Risk Potential ratings is undertaken as part of the risk management phase
and is not discussed in this document. The appropriate risk management strategy for a particular
pest depends on the risk posed by that pest. APHIS risk management programs are risk based and
dependent on the availability of appropriate mitigation methods and are Details of APHIS risk
management programs are published, primarily, in the Federal Register as quarantine notices.
11
Literature Cited
FAO. 1996. International Standards for Phytosanitary Measures, Part 1—Import Regulations:
Guidelines for Pest Risk Analysis. Secretariat of the International Plant Protection Convention,
Food and Agriculture Organization (FAO) of the United Nations, Rome.
FAO. 1999. International Standards for Phytosanitary Measures. Glossary of Phytosanitary
Terms, Publication No. 5. Secretariat of the International Plant Protection Convention, Food and
Agriculture Organization (FAO) of the United Nations, Rome.
Gunn, C. R. and C. Ritchie. 1982. 1982 Report of the Technical Committee to Evaluate Noxious
Weeds; Exotic Weeds for Federal Noxious Weed Act. (unpublished).
Holm, L. G., Plucknett, D. L., Pancho, J. V. and J.P. Herberger. 1977. The World's Worst Weeds.
University of Hawaii Press, Honolulu.
Holm, L.G., Pancho, J. V., Herberger, J. P. and D.L. Plucknett. 1979. A Geographical Atlas of
World Weeds. John Wiley and Sons, New York.
Holm, L., Doll, J., Holm, E., Pancho, J. and J. Herberger. 1997. World Weeds: Natural Histories
and Distribution. John Wiley and Sons, New York.
NAPPO. 1996. NAPPO Compendium of Phytosanitary Terms, (B.E. Hopper, NAPPO
Secretariat, ed.). North American Plant Protection Organization (NAPPO), Nepean, Ontario,
Canada.
Reed, C. F. 1977. Economically Important Foreign Weeds. Agriculture Handbook No. 498
U.S. Department of Agriculture (USDA). 1990. USDA plant hardiness zone map. USDAAgricultural Research Service (ARS). Miscellaneous Publication Number 1475. USDA-ARS,
Washington, DC 20002
WSSA, 1989. Composite List of Weeds. Weed Science Society of America.
Acknowledgments
The prototype for this process was developed by Gary Cave, Ph.D., Entomologist, USDA, APHIS,
PPQ Risk Assessment Staff. It has been revised and enhanced by the USDA, APHIS, PPQ Risk
Assessment staff : Mike Firko, Ph.D., Entomologist; Edwin Imai, Branch Chief; Polly Lehtonen,
Botanist; John Lightfield, Plant Pathologist; Edward Podleckis, Ph.D., Plant Virologist; Scott
Redlin, Ph.D., Plant Pathologist; Laura Redmond, Plant Pathologist; Russell Stewart,
Entomologist. In addition, constructive comments on earlier drafts was received from Robert
Griffin, Plant Pathologist; Charles Miller, Entomologist; and Richard Orr, Entomologist of the
Planning and Policy Development, Planning and Risk Analysis Systems Staff and William C.
Kauffman, Ph.D., Entomologist, of the APHIS, PPQ Biological Control Laboratory, Niles, MI.
12
APPENDIX 1
GLOSSARY OF PHYTOSANITARY TERMS AND DEFINITIONS
Note: This version of the Glossary is still under consultation/comment by the various National
Plant Protection Organizations and Regional Plant Protection Organizations.
Additional declaration
A statement that is required by an importing country
to be entered on a phytosanitary certificate and
which provides specific additional information
pertinent to the phytosanitary condition of a
consignment [FAO, 1990]
Antagonist*
An organism (usually pathogen) which does no
significant damage to the host but its colonization of
the host protects the host from significant subsequent
damage by a pest [ISPM Pub. No. 3, 19961
Area
An officially defined country, part of a country or all
or parts of several countries [FAO, 1990; revised
FAO, 1995; CEPM, 1999; based on the World Trade
Organization Agreement on the Application of
Sanitary and Phytosanitary Measures]
Area endangered
See Endangered area
Area of low pest prevalence*
An area, whether all of a country, part of a country,
or all or parts of several countries, as identified by
the competent authorities, in which a specific pest
occurs at low levels and which is subject to effective
surveillance, control or eradication measures [IPPC,
1997]
Authority*
The National Plant Protection Organization, or other
entity or person officially designated by the
government to deal with matters arising from the
responsibilities set forth in the Code [ISPM Pub. No.
3, 1996]
Biological control agent*
A natural enemy, antagonist or competitor, and other
self-replicating biotic entity used for pest control
[ISPM Pub. No. 3, 1996]
*Indicates terms with specific use
13
Biological control (Biocontrol)*
Pest control strategy making use of living natural
enemies, antagonists or competitors and other selfreplicating biotic entities [ISPM Pub. No.3, 1996]
Biological pesticide*
(Biopesticide)
A generic term, not specifically definable, but
generally applied to a biological control agent,
usually a pathogen, formulated and applied in a
manner similar to a chemical pesticide, and normally
used for the rapid reduction of a pest population for
short-term pest control [ISPM Pub. No. 3, 1996]
Buffer zone*
An area in which a specific pest does not occur or
occurs at a low level and is officially controlled, that
either encloses or is adjacent to an infested area, an
infested place of production, a pest free area, a pest
free place of production or a pest free production
site, and in which phytosanitary measures are taken
to prevent spread of the pest [ISPM Pub. No. 10,
1999]
Bulbs and tubers
Dormant underground organs of plants intended for
planting [FAO, 1990]
Certificate
An official document which attests to the
phytosanitary status of any consignment affected by
phytosanitary regulations [FAO, 1990]
Classical biological control*
The intentional introduction and permanent
establishment of an exotic biological agent for longterm pest control [ISPM Pub. No.3, 1996]
Clearance (of a consignment)
Verification of compliance with phytosanitary
regulations [FAO, 1995]
Commission*
The Commission on Phytosanitary Measures
established under Article XI, [IPPC, 1997]
Commodity
A type of plant, plant product or other regulated
article being moved for trade or other purpose
[FAO, 1990]
Commodity class
A category of similar commodities that can be
considered together in phytosanitary regulations
[FAO, 1990]
14
Commodity pest list
A list of pests occurring in an area which may be
associated with a specific commodity [CEPM, 1996]
Competitor*
An organism which competes with pests for essential
elements (e.g. food, shelter) in the environment
[ISPM Pub. No. 3, l996]
Compliance procedure
(for a consignment)
Official procedure used to verify that a
consignment complies with stated phytosanitary
requirements [CEPM, 1999]
Consignment
A quantity of plants, plant products and/or other
regulated articles being moved from one country to
another and covered by a single phytosanitary
certificate (a consignment may be composed of one
or more lots) [FAO, 1990]
Consignment in transit
Consignment which passes through a country without
being imported, and without being exposed in that
country to contamination or infestation by pests. The
consignment may not be split up, combined with
other consignments or have its packaging changed
[FAO, 1990; revised CEPM, 1996; CEPM 1999;
formerly country of transit]
Containment
Application of phytosanitary measures in and around
an infested area to prevent spread of a pest [FAO,
1995]
Contaminating pest
A pest that is carried by a commodity and, in the
case of plants and plant products, does not infest
those plants or plant products [CEPM, 1996; revised
CEPM, 1999]
Contamination
Presence in a commodity, storage place, conveyance
or container, of pests or other regulated articles, not
constituting an infestation (See Infestation) [CEPM,
1997; revised CEPM, 1999]
Control (of a pest)
Suppression, containment or eradication of a pest
population [FAO, 1995]
Controlled area
A regulated area which an NPPO has determined to
be the minimum area necessary to prevent spread of
a pest from a quarantine area [CEPM, 1996]
15
Country of origin (of a consignment
plant products)
Country where the plants from which the plant
products are derived were grown [FAO, 1990;
revised CEPM, 1996; CEPM, 1999]
Country of origin (of a consignment
of plants)
Country where the plants were grown [FAO, 1990;
revised CEPM, 1996; CEPM, 1999]
Country of origin (of regulated articles
other than plants and plant products)
Country where the regulated articles were first
exposed to contamination by pests [FAO, 1990;
revised CEPM, 1996; CEPM, 1999]
Country of re-export*
Country into which a consignment of plants, plant
products, or other regulated articles has been
imported and was stored, split up, had its packaging
changed or was otherwise exposed to contamination
by pests, prior to export to a third country [ISPM
Pub. No. 7, l998]
Cut flowers and branches
Fresh parts of plants intended for decorative use and
not for planting [FAO, 1990]
Debarking
Removal of bark from round wood (debarking does
not necessarily make the wood bark-free) [FAO,
1990]
Delimiting survey
Survey conducted to establish the boundaries of an
area considered to be infested by or free from a pest
[FAO, 1990]
Detection survey
Survey conducted in an area to determine if pests are
present [FAO, 1990, revised FAO, 1995]
Detention
Keeping a consignment in official custody or
confinement for phytosanitary reasons (See
Quarantine) [FAO, 1990; revised FAO, 1995;
CEPM, 1999]
Dunnage
Wood used to wedge or support cargo [FAO, 1990]
Ecoarea*
An area with similar fauna, flora an climate and
hence similar concerns about the introduction of
biological control agents [ISPM Pub. No. 3, 1996]
16
Ecosystem*
A complex of organisms and their environment,
interacting as a defined ecological unit (natural or
modified by human activity, e.g. agroecosystem),
irrespective of political boundaries [ISPM Pub. No.
3, 1996]
Endangered area
An area where ecological factors favor the
establishment of a pest whose presence in the area
will result in economically important loss [FAO,
1995]
Entry (of a consignment)
Movement through a point of entry into an area
[FAO, 1995]
Entry (of a pest)
Movement of a pest into an area where it is not yet
present, or present but not widely distributed and
being officially controlled [FAO, 1995]
Equivalence
The situation of phytosanitary measures which are
not identical but have the same effect [FAO, 1995;
revised CEPM, 1999; based on the World Trade
Organization Agreement on the Application of
Sanitary and Phytosanitary Measures]
Eradication
Application of phytosanitary measures to eliminate a
pest from as area [FAO, 1990; revised FAO, 1995;
formerly Eradicate]
Establishment
Perpetuation, for the foreseeable future, of a pest
within an area after entry [FAO, 1990; revised FAO,
1995; IPPC, 1997; formerly Established]
Establishment (of a biological control
agent)*
The perpetuation, for the foreseeable future, of a
biological control agent within an area after entry
[ISPM Pub. No. 3, 1996]
Exotic*
Not native to a particular country, ecosystem or
ecoarea (applied to organisms intentionally or
accidently introduced as a result of human
activities). As this Code is directed at the
introduction of biological control agents from one
country to another, the term “exotic” is used for
organisms not native to a country [ISPM Pub. No. 3,
1996]
17
Field
A plot of land with defined boundaries within a
place of production which a commodity is grown
[FAO, 1990]
Find free
To inspect a consignment, field or place of
production and consider it to be free from a specific
pest [FAO, 1990]
Free from (of a consignment, field or
place of production)
Without pests (or a specific pest) in numbers or
quantities that can be detected by the application of
phytosanitary procedures [FAO, 1990; revised FAO,
1995; CEPM, 1999]
Fresh
Living; not dried, deep-frozen or otherwise
conserved [FAO, 1990]
Fruits and vegetables
Fresh parts of plants intended for consumption or
processing [FAO, 1990]
Fumigation
Treatment with a chemical agent that reaches the
commodity wholly or primarily in a gaseous state
[FAO, 1990; revised FAO, 1995]
Germplasm
Plants intended for use in breeding or conservation
programs [FAO, 1990]
Grain
Seeds intended for processing or consumption and
not for planting (See Seeds) [FAO, 1990]
Growing medium
Any material in which plans roofs are growing or
intended for that purpose [FAO, 1990]
Growing season
Period of the year when plants will actively grow in
an area [FAO, 1990]
Harmonization
The establishment, recognition and application by
different countries of phytosanitary measures based
on common standards [FAO, 1995; revised CEPM,
1999; based on the World Trade Organization
Agreement on the Application of Sanitary and
Phytosanitary Measures]
Harmonized phytosanitary measures*
Phytosanitary measures established by contracting
parties to the IPPC, based on international standards
[IPPC, 1997]
18
Hitch-hiker pest
See Contaminating pest
Host pest list
A list of pests that infest a plant species, globally or
in an area [CEPM, 1996; revised CEPM, 1999]
Host range
Species of plants capable, under natural conditions,
of sustaining a specific pest [FAO, 1990]
Import permit
Official document authorizing importation of a
commodity in accordance with specified
phytosanitary requirements [FAO, 1990; revised
FAO, 1995]+
Import permit (of a biological control
agent)*
An official document authorizing importation (of a
biological control agent) in accordance with
specified requirements [ISPM Pub. No. 3, 1996]
Infestation (of a commodity)
Presence in a commodity of a living pest of the plant
or plant product concerned. Infestation includes
infection [CEPM, 1997; revised CEPM, 1999]
Inspection
Official visual examination of plants, plant products
or other regulated articles to determine if pests are
present and/or to determine compliance with
phytosanitary regulations [FAO, 1990; revised FAO,
1995; formerly Inspect]
Inspector
Person authorized by a National Plant Protection
Organization to discharge its functions [FAO, 1990]
Interception (of a consignment)
The refusal or controlled entry of an imported
consignment due to failure to comply with
phytosanitary regulations [FAO, 1990; revised FAO,
1995]
Interception (of a pest)
The detection of a pest during inspection or testing of
an imported consignment [FAO, 1990; revised
CEPM, 1996]
Intermediate quarantine
Quarantine in a country other then the country of
origin or destination [CEPM, 1996]
International Plant Protection Convention
International Plant Protection Convention as
deposited with FAO in Rome in 1951 and as
subsequently amended [FAO, 1990]
19
International Standard for Phytosanitary
Measures
An international standard adopted by the Conference
of FAO, the Interim Commission on Phytosanitary
Measures or the Commission on Phytosanitary
Measures, established under the IPPC [CEPM,
1996; revised CEPM, 1999]
International standards*
International standards established in accordance
with Article X paragraph 1 and 2 of the IPPC [IPPC,
1997]
Introduction
The entry of a pest resulting in its establishment
[FAO, 1990; revised FAO, 1995; IPC, 1997]
Introduction (of a biological control
agent)*
The release of a biological control agent into an
ecosystem where it did not exist previously (see also
“establishment”) [ISPM Pub. No. 3, 1996]
Inundative release*
The release of overwhelming numbers of a massproduced, invertebrate biological control agent in the
expectation of achieving a rapid reduction of a pest
population without necessarily achieving continuing
impact [ISPM Pub. No. 3, 1996]
IPPC
Acronym for the International Plant Protection
Convention, as deposited in 1951 with FAO in Rome
and as subsequently amended [FAO, 1990]
ISPM
Acronym for International Standard for Phytosanitary
Measures [CEPM, 1996]
Legislation*
Any act, law, regulation, guideline or other
administrative order promulgated by a government
[ISPM Pub. No. 3, 1996]
Lot
A number of units of a single commodity, identifiable
by its homogeneity of composition, origin etc.,
forming part of a consignment [FAO, 1990]
Micro-organism*
A protozoan, fungus, bacterium, virus or other
microscopic self-replicating biotic entity [ISPM Pub.
No. 3, 1996]
Monitoring
An official ongoing process to verify phytosanitary
situations [CEPM,1996]
20
Monitoring survey
Ongoing survey to verify the characteristics of a pest
population [FAO, 1995
National Plant Protection
Organization
Official service established by a government to
discharge the functions specified by the IPPC [FAO,
1990; formerly Plant Protection Organization
(National)
Natural enemy*
An organism which lives at the expense of another
organism and which may help to limit the population
of its host. This includes parasitoids, parasites,
predators and pathogens [ISPM Pub. No. 3, 1996]
Naturally occurring*
A component of an ecosystem or a selection from a
wild population, not altered by artificial means
[ISPM Pub. No. 3, 1996]
Non-quarantine pest
Pest that is not a quarantine pest for an area [FAO,
1995]
NPPO
Acronym for National Plant Protection Organization
[FAO, 1990]
Occurrence
The presence in an area of a pest officially reported
to be indigenous or introduced and/or not officially
reported to have been eradicated [FAO, 1990;
revised FAO, 1995; formerly Occur]
Official
Established, authorized or performed by a National
Plant Protection Organization [FAO, 1990]
Organism*
Biotic entity capable of reproduction or replication,
vertebrate or invertebrate animals, plants and microorganisms [ISPM Pub. No. 3, 1996]
Outbreak
An isolated pest population, recently detected and
expected to survive for the immediate future [FAO,
1995]
Parasite *
An organism which lives on or in a larger organism,
feeding upon it [ISPM Pub. No. 3, 1996]
Parasitoid*
An insect parasitic only in its immature stages,
killing its host in the process of its development, and
free living as an adult [ISPM Pub. No. 3, 1996]
21
Pathogen*
Micro-organism causing disease [ISPM Pub. No. 3,
1996]
Pathway
Any means that allows the entry or spread of a pest
[FAO, 1990; revised FAO 1995]
Pest
Any species, strain or biotype of plant, animal or
pathogenic agent injurious to plants or plant products
[FAO, 1990; revised FAO, 1995; IPPC, 1997]
Pest free area
An area in which a specific pest does not occur as
demonstrated by scientific evidence and in which,
where appropriate, this condition is being officially
maintained [FAO, 1995]
Pest free place of production*
Place of production in which a specific pest does not
occur as demonstrated by scientific evidence and in
which where appropriate, this condition is being
officially maintained for a defined period [ISPM
Pub. No. 10, 1999]
Pest free production site*
A defined portion of a place of production in which
a specific pest does not occur as demonstrated by
scientific evidence and in which, where appropriate,
this condition is being maintained for a defined
period and that is managed as a separate unit in the
same way as a pest free place of production [ISPM
Pub. No. 10, 1999]
Pest record
A document providing information concerning the
presence or absence of a specific pest at a particular
location at a certain time, within an area (usually a
country) under described circumstances [CEPM,
1997]
Pest risk analysis
The process of evaluating biological or other
scientific and economic evidence to determine
whether a pest should be regulated and the strength
of any phytosanitary measures to be taken against it
[FAO, 1995; revised IPPC, 1997]
Pest risk assessment
Determination of whether a pest is a quarantine pest
and evaluation of its introduction potential [FAO,
1995]
22
Pest risk management
The decision-making process of reducing the risk of
introduction of a quarantine pest [FAO,1995]
Pest status (in an area)
Presence or absence, at the present time, of a pest in
an area, including where appropriate it distribution,
as officially determined using expert judgement on
the basis of current and historical pest records and
other information [CEPM, 1997; revised ISPM,
1998]
PFA
Acronym for pest-free area [FAO, 1995]
Phytosanitary certificate
Certificate patterned after the model certificates of
the IPPC [FAO, 1990]
Phytosanitary certification
Use of phytosanitary procedures leading to the issue
of a phytosanitary certificate [FAO, 1990]
Phytosanitary legislation
Basic laws granting legal authority to a National
Plant Protection Organization from which
phytosanitary regulations may be drafted [FAO,
1990; revised FAO, 1995]
Phytosanitary measure
Any legislation, regulation or official procedure
having the purpose to prevent the introduction and/or
spread of pests [FAO, 1995; revised IPPC, 1997]
Phytosanitary procedure
Any officially prescribed method for performing
inspections, tests, surveys or treatments in
connection with regulated pests [FAO, 1990; revised
FAO, 1995; CEPM, 1999]
Phytosanitary regulation
Official rule to prevent the introduction and/or
spread of pests, by regulating the production,
movement or existence of commodities or other
articles, or the normal activity of persons, and by
establishing procedures for phytosanitary
certification [FAO, 1990; revised FAO, 1995;
CEPM, 1999]
Place of production
Any premises or collection of fields operated as a
single production or farming unit. This may include
production sites which are separately managed for
phytosanitary purposes [FAO, 1990; revised CEPM,
1999]
23
Plating (including replanting)
Any operation for the placing of plants in a growing
medium, or by grafting or similar operations, to
ensure their subsequent growth, reproduction or
propagation [FAO, 1990; revised CEPM, 1999]
Plant pest
See Pest
Plant products
Unmanufactured material of plant origin (including
grain) and those manufactured products that, by their
nature or that of their processing, may create a risk
for the introduction and spread of pests [FAO, 1990;
revised IPPC, 1997; formerly Plant product]
Plant protection organization (national)
See National Plant Protection Organization
Plant quarantine
All activities designed to prevent the introduction
and/or spread of quarantine pests or to ensure their
official control [FAO, 1990; revised FAO, 1995]
Plants
Living plants and parts thereof, including seeds and
germplasm [FAO, 1990; revised IPPC, 1997]
Plants for planting
Plants intended to remain planted, to be planted or
replanted [FAO, 1990]
Plants in tissue culture
Plants in an aseptic medium in a closed container
[FAO, 1990; revised CEPM, 1999]
Point of entry
Airport, seaport or land border officially designated
for the importation of consignments, and/or entrance
of passengers [FAO, 1995]
Post-entry quarantine
Quarantine applied to a consignment after entry
[FAO, 1995]
PRA
Acronym for pest risk analysis [FAO, 1995]
PRA area
Area in relation to which a pest risk analysis is
conducted [FAO, 1995]
Practically free
Of a consignment, field, or place of production,
without pests (or a specific pest) in numbers or
quantities in excess of those that can be expected to
result from, an be consistent with good cultural and
handling practices employed in the production and
24
marketing of the commodity [FAO, 1990; revised
FAO, 1995]
Preclearance
Phytosanitary certification and/or clearance in the
country of origin, performed by or under the regular
supervision of the National Plant Protection
Organization of the country of destination [FAO,
1990; revised FAO, 1995]
Predator*
A natural enemy that preys and feeds on other animal
organisms, more than one of which are killed during
its lifetime [ISPM Pub. No. 3, 1996]
Prohibition
A phytosanitary regulation forbidding the
importation or movement of specified pests or
commodities [FAO, 1990; revised FAO, 1995]
Protected area
A regulated area which an NPPO has determined to
be the minimum area necessary for the effective
protection of an endangered area [FAO, 1990;
omitted from FAO, 1995; new concept from CEPM,
1996]
Quarantine
Official confinement of regulated articles for
observation and research of for further inspection,
testing and/or treatment [FAO, 1990; revised FAO,
1995; CEPM, 1999]
Quarantine area
An area within which a quarantine pest is present
and is being officially controlled [FAO, 1990;
revised FAO, 1995]
Quarantine (of a biological control
agent)*
Official confinement of biological control agents
subject to phytosanitary regulations for observation
and research, or for further inspection and/or testing
[ISPM Pub. No. 3, 1996]
Quarantine pest
A pest of potential economic importance to the area
endangered thereby and not yet present there, or
present but not widely distributed and being
officially controlled [FAO, 1990; revised FAO,
1995; IPPC, 1997]
Quarantine station
Official station for holding plants or plant products
in quarantine [FAO, 1990; revised FAO, 1995;
25
formerly Quarantine station or facility]
Re-exported consignment
Consignment which has been imported into a country
from which it is then exported without being exposed
to infestation or contamination by pests. The
consignment may be stored, split up, combined with
other consignments or have its packaging changed
[FAO, 1990; revised CEPM, 1996; CEPM, 1999]
Refusal
Forbidding entry of a consignment or other regulated
article when it fails to comply with phytosanitary
regulations [FAO, 1990; revised FAO, 1995]
Region
The combined territories of the member countries of
a Regional Plant Protection Organization [FAO,
1990]
Regional Plant Protection Organization
An intergovernmental organization with the functions
laid down by Article IX of the IPPC [FAO, 1990;
revised FAO, 1995; CEPM, 1999; formerly Plant
Protection Organization (Regional)]
Regional standards
Standards established by a regional plant protection
organization for the guidance of the members of that
organization [IPPC, 1997]
Regulated area
An area into which, within which and/or from which
plants, plant products and other regulated articles are
subjected to phytosanitary measures in order to
prevent the introduction and/or spread of regulated
pests (See Controlled area and Protected area)
[CEPM, 1996; revised CEPM, 1999]
Regulated article
Any plant, plant product, storage place, packaging,
conveyance, container, soil and any other organism,
object or material capable of harboring or spreading
pests, deemed to requite phytosanitary measures,
particularly where international transportation is
involved [FAO, 1990; revised FAO, 1995; lPPC,
1997]
Regulated non-quarantine pest
A non-quarantine pest whose presence in plants for
planting affects the intended use of those plants with
an economically unacceptable impact and which is
therefore regulated within the territory of the
26
importing contracting party [IPPC, 1997]
Regulated pest
A quarantine pest or a regulated non-quarantine pest
[IPPC, 1997]
Release (Into the environment)*
Intentional liberation of an organism into the
environment (see also “introduction” and
“establishment”) [ISPM Pub. No. 3, 1996]
Release (of a consignment)
Authorization for entry after clearance [FAO, 1995]
Replanting
See Planting
Restriction
A phytosanitary regulation allowing the importation
or movement of specified commodities subject to
specific requirements [CEPM, 1996, revised CEPM,
1999]
Round wood
Wood not sawn longitudinally, carrying its natural
rounded surface, with or without bark [FAO, 1990]
RPPO
Acronym for Regional Plant Protection Organization
[FAO, 1990]
Sawn wood
Wood sawn longitudinally, with or without its
natural rounded surface with or without bark [FAO,
1990]
Secretary*
Secretary of the Commission appointed pursuant to
Article X11 [IPPC, 1997]
Seeds
Seeds for planting not for consumption or processing
(see Grain) [FAO, 1990]
A measure of the host range of a biological control
agent on a scale ranging from an extreme specialist
only able to complete development on a single
species or strain of its host (monophagous) to a
generalist with many hosts ranging over several
groups of organisms (polyphagous) [ISPM Pub. No.
3, 1996]
Specificity*
Spread
Expansion of the geographical distribution of a pest
within an area [FAO, 1995]
Standard
Document established by consensus and approved by
27
a recognized body, that provides, for common and
repeated use, rules, guidelines or characteristics for
activities or their results, aimed at the achievement
of the optimum degree of order in a given context
[FAO, 1995; ISO/IEC GUIDE 2:1991 definition]
Stored product
Unmanufactured plant product intended for
consumption or processing, stored in a dried form
(this includes in particular grain and dried fruits and
vegetables) [FAO, 1990]
Suppression
The application of phytosanitary measures in an
infested area to reduce pest populations [FAO, 1995;
revised CEPM, 1999]
Surveillance
An official process which collects and records data
on pest occurrence or absence by survey, monitoring
or other procedures [CEPM, 1996]
Survey
An official procedure conducted over a defined
period of time to determine the characteristics of a
pest population or to determine which species occur
in an area [FAO, 1990; revised CEPM, 1996]
Technically justified
Justified on the basis of conclusions reached by
using an appropriate pest risk analysis or, where
applicable, another comparable examination and
evaluation of available scientific information [IPPC,
1997]
Test
Official examination, other than visual, to determine
if pests are present or to identify pests [FAO, 1990]
Tissue culture
See Plants in tissue culture
Transience*
Presence of a pest that is not expected to lead to
establishment [ISPM Pub. No. 8, 1998]
Transit
See Consignment in transit
Transparency
The principle of making available, at the
international level, phytosanitary measures and their
rationale [FAO, 1995; revised CEPM, 1999; based
on the World Trade Organization Agreement on the
28
Application of Sanitary and Phytosanitary Measures]
Treatment
Officially authorized procedure for the killing,
removal or rendering infertile of pests [FAO, 1990,
revised FAO, 1995]
Wood
Round wood, sawn wood, wood chips or dunnage,
with or without bark [FAO, 1990]
29
Figure 1: Climatic Zones Map (USDA, 1990).
30
Risk Analysis of the Importation of Moth Orchid,
Phalaenopsis spp., Plants in Approved Growing Media
From Taiwan into the United States
Agency Contacts:
Gary L. Cave, Ph.D. (Risk Assessment)
United States Department of Agriculture
Animal and Plant Health Inspection Service
Plant Protection and Quarantine
Center for Plant Health Science and Technology
Plant Epidemiology and Risk Analysis Laboratory
1017 Main Campus Drive, Suite 1550
Raleigh, NC 27606-5202
William E. Thomas (Risk Management)
United States Department of Agriculture
Animal and Plant Health Inspection Service
Plant Protection and Quarantine
Phytosanitary Issues Management Team
4700 River Road, Unit 140
Riverdale, MD 20737-1236
May 6, 2003
Executive Summary
This pathway-initiated commodity risk assessment examines the risks associated with the proposed
importation of moth orchid, Phalaenopsis spp., plants (including those with inflorescences and
buds) in approved growing media from Taiwan into the United States. The quarantine pests that
are likely to follow the pathway are analyzed using the methodology described in the USDA,
APHIS, PPQ Guidelines 5.02 which examines pest biology in the context of the Consequences of
Introduction and the Likelihood of Introduction and estimates the Baseline Pest Risk Potential.
The quarantine pests likely to follow this importation pathway are: Acusta (Bradybaena)
tourranensis (Souleyet) (Mollusca: Bradybaenidae), Planococcus minor (Maskell) (Homoptera:
Pseudococcidae), Cylindrosporium phalaenopsidis Saw. (Fungi Imperfecti, Coelomycetes),
Phomopsis orchidophila Cash & A. M. Watson (Fungi Imperfecti, Coelomycetes), Sphaerulina
phalaenopsidis Saw. (Loculoascomycetes, Dothideales), and Spodoptera litura (F.) (Lepidoptera:
Noctuidae). The Baseline Pest Risk Potential for Spodoptera litura is High, and all the other pests
have Baseline Pest Risk Potential ratings of Medium. Port of entry inspections, as the sole
mitigation measure, for certain propagative materials, may be insufficient to safeguard U.S.
agriculture from these pests, and additional phytosanitary measures are considered necessary to
mitigate risks.
The fungus, Colletotrichum phalaenopsidis was synonymized to Colletotrichum gloeosporioides
(Redlin, 2002) after the publication of the original risk assessment in 1996. Colletotrichum
gloeosporioides is widely distributed in the United States (Farr et al. 1989), and therefore this
organism is no longer of quarantine concern.
The pest risk management section of this document considers the manner in which regulations for
the importation of plants in APHIS-approved growing media (7 CFR § 319.37-8) will reduce the
risks associated with this importation. The application of additional safeguards will reduce the risk
posed by the importation of Moth Orchid, Phalaenopsis spp. plants in growing media from Taiwan.
The safeguards will effectively remove the pests of concern from the pathway and reduce the risk
to a low level, that will be the same level or below that posed by currently permitted bare root
importations.
Table of Contents
I.
Introduction..........................................................................................................................1
II.
Risk Assessment ..................................................................................................................1
A. Initiating Event: Proposed Action...................................................................................1
B. Assessment of Weediness Potential of the Commodity..................................................1
C. Current Status and Pest Interceptions ..............................................................................2
D. Pest Categorization..........................................................................................................2
E. Analysis of Quarantine Pests ...........................................................................................8
F. Conclusion: Pest Risk Potential.....................................................................................17
III.
Risk Management ..............................................................................................................18
IV.
References ..........................................................................................................................27
V.
Authors and Reviewers/Contributors.................................................................................34
I. Introduction
This risk analysis was prepared by the Plant Epidemiology and Risk Analysis Laboratory of the
United States Department of Agriculture, Animal and Plant Health Inspection Service, Plant
Protection and Quarantine, Center for Plant Health Science and Technology (USDA, APHIS, PPQ,
CPHST, PERAL) to examine the plant pest risks associated with the importation of moth orchid
plants, in approved growing media, from Taiwan into the United States. Risk is characterized as
high, medium or low, following version 5.02 of the PPQ Guidelines (USDA, 2000) and is linked to
the supporting scientific evidence in order to provide clarity.
Regional and international plant protection organizations, such as the North American Plant
Protection Organization (NAPPO) and the International Plant Protection Convention (IPPC)
administered by the Food and Agriculture Organization (FAO) of the United Nations, provide both
guidance for conducting pest risk assessments (FAO, 1995, 1996, 2001) and the use of biological
and phytosanitary terms (FAO, 1999). The terms and the methods used to initiate, conduct and
report this assessment are consistent with these international guidelines. This document satisfies
the requirements of the three stages of the FAO guidelines (Initiation, Risk Assessment and Risk
Management), and is consistent with applicable U.S. regulations, e.g. 7 CFR § 319.40-11 and
7 CFR § 319.37-8(g).
II. Risk Assessment
A. Initiating Event: Proposed Action
This commodity-based, pathway- initiated pest risk assessment examines the phytosanitary risks
associated with the potential importation, from Taiwan into the United States, of moth orchid plants
rooted in APHIS-approved growing media. The importation of propagative material into the
United States is regulated under “Subpart-Nursery Stock,” 7 CFR § 319.37 through 319-37-14, and
a risk analysis was conducted by APHIS in furtherance of its mission under the Plant Protection
Act of 2000 (7 U.S.C. §§ 7701-7772).
B. Assessment of the Weediness Potential of Moth Orchid
If the species considered for import poses a risk as a weed pest, then a “pest initiated” risk
assessment is conducted. The results of the screening for weed potential for moth orchid (Table 1)
did not prompt a pest initiated risk assessment because plants already present in the United States
are not reported as weeds.
1
Table 1:
Process for Determining Weediness Potential of Moth Orchid.
Commodity: Phalaenopsis Blume (Orchidaceae). A genus of 40-50 cultivated ornamental epiphytes or
chasmophytes native to tropical Asia, Philippines, and Mala ysia, yielding hothouse orchids.
Phase 1:
Consider whether the genus is new to or not widely prevalent in the United States (exclude plants
grown under USDA permit in approved containment facilities)
Phalaenopsis is widely cultivated in greenhouses in Florida and other places in the United States. Florida
has over 51 growers and shipped over 3 million potted orchids in 2001 (USDA, 2002).
Phase 2:
Answer Yes or No to the following questions:
Is the genus listed in:
NO
NO
NO
Geographical Atlas of World Weeds (Holm et al., 1979)
World's Worst Weeds (Holm et al., 1977)
Report of the Technical Committee to Evaluate Noxious Weeds; Exotic Weeds for Federal
Noxious Weed Act (Gunn and Ritchie, 1982)
NO
Economically Important Foreign Weeds (Reed, 1977)
NO
Weed Science Society of America list (WSSA, 2002)
NO
Is there any literature reference indicating weed potential, e.g., AGRICOLA, CAB, Biological
Abstracts, AGRIS; search on "Phalaenopsis" combined with "weed").
Phase 3:
Conclusion: The species is prevalent in the United States and the answer to all of the questions is
no, therefore, the commodity does not have weediness potential.
C. Current Status and Pest Interceptions
There are no previous requests from Taiwan for Phalaenopsis rooted in APHIS-approved
growing media. Bare-root Phalaenopsis plants and plants rooted in coconut fiber, fern trunk,
and other approved media are allowed entry from Taiwan into the United States (7 CFR §
319.37). Pests intercepted by APHIS between 1985-2003 at U.S. ports of entry are reported in
Table 2 (PPQ, 1998; PPQ, 2003), and discussed in Section E. In 2001, there was one
interception of a leaf beetle, Medythis suturalis (Coleoptera: Chrysomelidae), but this quarantine
pest was likely present as an accidental hitchhiker and is not further analyzed because it is not
reported in the scientific literature as a pest of Phalaenopsis orchids and operational procedures,
such as prohibiting packing at night under lights, can be immediately implemented in order to
eliminate its occurrence.
D. Pest Categorization
Pests associated with moth orchids in Taiwan are listed in Table 2. This list identifies: (1) the
presence or absence of these pests in the United States, (2) hosts, (3) the generally affected plant
part or parts, (4) the quarantine status of the pest with respect to the United States, (5) the
likelihood of introduction of the pest into the United States on commercially imported moth
orchids, and (6) pertinent citations for the distribution or the biology of the pest. Because of
specific characteristics of biology and distribution, many organisms are eliminated from further
2
consideration as sources of phytosanitary risk on moth orchids because they do not satisfy the
FAO definition of a quarantine pest.
Table 2. Pests of Phalaenopsis spp. orchids in Taiwan.
Pest
Distribution1
Hosts
Plant Part
Affected
Quarantine Follow
Pest
Pathway
References
ARTHROPODA
ACARI
Acari sp.
TW
Brassica, Dracaena,
Paeonia, Rutaceae,
Various
Leaf, Stem
Yes
Yes
PPQ, 2003
TW
Capsicum, Clemantis,
Cymbidium, Dracaena,
Leaf, Stem
Odontoglossum
Oncidium, Phalaenopsis,
Thuja occidentalis,
Yes
Yes
PPQ, 2003
TW
Actinidia, Chamaedorea,
Orchidaceae, Rutaceae, Leaf, Stem
Vitis, Polypahagous
Yes
Yes
PPQ, 2003
Tarsonemidae
Xenotarsonemus sp.
Tenuipalpidae
Brevipalpus sp.
Tenuipalpus pacificus
Baker
TW,US
Orchidaceae,
Phalaenopsis
Leaf, Stem
No
Yes
Jeppson et al.,
1975; Taiwan,
1996
TW
Various
Flower,
Leaf, Soil,
Stem
Yes
Yes
PPQ, 2003
TW
Cymbidium,
Orchidaceae,
Polyphagous
Leaf, Stem
Yes
Yes
PPQ, 1998
TW
Brassica, Citrus,
Dracaena, Paeonia,
Various
Leaf, Stem
Yes
Yes
PPQ, 2003
TW
Various
Leaf, Soil,
Stem
Yes
Yes
PPQ, 2003
TW
Brassica, Dracaena,
Paeonia, Punica,
Rutaceae, Various
Leaf, Stem
Yes
Yes
PPQ, 2003
TW
Dendrobium
Orchidaceae,
Polyphagous,
Leaf, Stem
Yes
Yes
PPQ, 1998
INSECTA
Insecta sp.
COLEOPTERA
Curculionidae
Curculionidae sp.
COLLEMBOLA
Sminthuridae
Sminthuridae sp.
DIPTERA
Diptera sp.
Agromyzidae
Agromyzidae sp.
HOMOPTERA
Aphididae
Aphididae sp.
3
Distribution1
Hosts
Plant Part
Affected
Cerataphis sp.
Cicadellidae
Cicadellidae sp.
Coccidae
TW
Orchidaceae
Leaf, Stem
Yes
Yes
PPQ, 1998
TW
Brassica, Polyphagous
Leaf, Stem
Yes
Yes
PPQ, 1998
Coccidae sp.
TW
Cymbidium,
Polyphagous
Leaf, Stem
Yes
Yes
PPQ, 1998
Pest
Saissetia coffeae
(Signoret)
Diaspididae
Diaspididae sp.
TW,US
TW
Lepidosaphes chinensis
Chamberlin
TW
Parlatoria sp.
TW
Parlatoria proteus
(Curtis)
Miridae
Miridae sp.
Pseudococcidae
References
Leaf, Stem
No
Yes
Hamon and
Williams,
1984; Taiwan,
1996
Polyphagous
Leaf, Stem
Areca catechu,
Cymbidium, Cocos
nucifera, Combrelum
lakka, Dracena, Licuala,
Leaf, Stem
Litsea cubeba,
Loranthus, Maxillaria,
Michelia pandanas,
Rhaphis excelsa,
Schomburgki
Dendrobium,
Leaf, Stem
Polyphagous
Yes
Yes
PPQ, 1998
Yes
Yes
Nakahara,
1982; PPQ,
1998
Yes
Yes
PPQ, 1998
Phalaenopsis
TW,US
Arecaceae, Orchidaceae,
Leaf, Stem
Polyphagous
No
Yes
Nakahara,
1982; Taiwan,
1996
TW
Oncidium, Polyphagous Leaf, Stem
Yes
Yes
PPQ, 1998
Yes
Yes
Cox, 1989;
PPQ, 1998;
Tu et al.,
1988; Tandon
and Verghese,
1987;
Williams,
1982;
Williams and
Granara de
Willink, 1992
Yes
Yes
PPQ, 1998
Yes
Yes
PPQ, 2003
Yes
McKenzie,
1967; Taiwan,
1996
Planococcus minor
(Maskell)
TW
Pseudococcidae sp.
TW
Pseudococcus sp.
TW
Pseudococcus
longispinus (Targioni
Tozzetti)
HYMENOPTERA
Formicidae
Quarantine Follow
Pest
Pathway
TW,US
Phalaenopsis,
Polyphagous
Flower,
Leaf, Stem
Phalaenopsis,
Leaf, Stem
Polyphagous
Orchidaceae, Rosaceae,
Leaf, Stem
Rutaceae, Polyphagous
Phalaenopsis,
Polyphagous
Leaf, Stem
No
4
Pest
Crematogaster sp.
Distribution1
TW
Hosts
Plant Part
Affected
Eucalyptus, Hemileuca
Flower,
oliviae, Mangifera
indica, Pinus, Quercus Leaf, Stem
suber, Various
Quarantine Follow
Pest
Pathway
References
Yes
Yes
PPQ, 2003
Yes
Yes
PPQ, 1998
Yes
Yes
PPQ, 1998
Yes
Yes
PPQ, 1998
LEPIDOPTERA
Lymantriidae
Lymantriidae sp.
TW
Dendrobium,
Polyphagous
Leaf, Stem
Noctuidae
Noctuidae sp.
TW
Spodoptera sp.
TW
Oncidium, Orchidaceae, Leaf, Soil,
Polyphagous
Stem
Leaf, Soil,
Brassia, Polyphagous
Stem
Spodoptera litura (F.)
TW
Phalaenopsis,
Polyphagous
Leaf, Soil,
Stem
Yes
Yes
Anon, 1982;
Taiwan, 1996;
Smith et al.,
1992;
Matsuura and
Naito, 1992a,
b
Plutellidae
Plutellidae sp.
Tortricidae
TW
Orchidaceae
Leaf, Stem
Yes
Yes
PPQ, 1998
Tortricidae sp.
TW
Orchidaceae,
Polyphagous
Leaf, Stem
Yes
Yes
PPQ, 1998
TW
Orchidaceae,
Phalaenopsis
Leaf, Stem
Yes
Yes
PPQ, 1998
TW
Orchidaceae
Flower,
Leaf, Stem
Yes
Yes
PPQ, 1998
TW
Polyphagous
Flower,
Leaf, Stem
Yes
Yes
PPQ, 1998
ORTHOPTERA
Tettigoniidae
Tettigoniidae sp.
THYSANOPTERA
Phlaeothripidae
Phlaeothripidae sp.
Thripidae
Dichromothrips sp.
Frankliniella intonsa
(Trybom)
TW
Frankliniella schultzei
(Trybom)
TW
Thripidae, sp.
TW
Abelmoschus,
Asparagus, Avena,
Flower,
Glycine, Lycopersicon,
Medicago, Phaseolus, Leaf, Stem
Prunus, Orchidaceae,
Trifolium
Dendrobium,
Polyphagous
Dendrobium,
Orchidaceae,
Polyphagous
Chang, 1987;
Chen and
Chan, 1987;
Chieu et al.,
1991; PPQ,
1998;
Tang, 1976
Yes
Yes
Flower,
Leaf, Stem
Yes
Yes
PPQ, 1998;
Wang, 1987
Flower,
Leaf, Stem
Yes
Yes
PPQ, 1998
5
Pest
Thrips hawaiiensis
(Morgan)
Thrips palmi Karny
Distribution1
TW,US
TW, US
(FL, HI)
Hosts
Phalaenopsis,
Polyphagous
Cymbidium,
Dendrobium,
Orchidaceae,
Polyphagous
Plant Part
Affected
Flower,
Leaf, Stem
Flower,
Leaf, Stem
Quarantine Follow
Pest
Pathway
No
Yes
Yes
Yes
References
Taiwan, 1996
Smith et al.,
1992; PPQ,
1998
MOLLUSCA
Bradybaenidae
Acusta (Bradybaena)
tourannensis (Souleyet)
TW
Acacia confusa,
Adenanthera
microsperma, Albizzia
lebbeck,
Chrysalidocarpus
lutescens, Cocos
nucifera, Morus alba,
Phalaenopsis
Bradybaena sp.
TW
Phalaenopsis,
Polyphagous
Flower,
Leaf, Soil,
Stem
Yes
Yes
PPQ, 1998
TW
Aglaonema, Aranda,
Aster, Codiaeum,
Cordyline, Dracena,
Eryngium, Heliconia,
Musa, Orchidaceae,
Schefflera, Vanda
Leaf, Soil,
Stem
Yes
Yes
PPQ, 2003
TW,US
Phalaenopsis
Flower,
Leaf, Soil,
Stem
No
Yes
Taiwan, 1996
Yes
Bradbury,
1986; Taiwan,
1996;
Willems et al.,
1992
Yes
Anon., 1979;
Bradbury,
1986; Pirone,
1978
Succinea sp.
Vaginulus alte
Ferrussae
BACTERIA
Acidovorax cattleya
(Pavarino) Willems et
al. (=Pseudomonas
cattleyae (Pavarino)
Savulescu)
(Pseudomonadaceae)
Erwinia caroto vora
subsp. carotovora
(Jones) Bergey et al.
(Enterobacteriaceae)
Erwinia chrysanthemi
pv. zeae (Sabat)
Victoria, Arboleda &
Munoz
(Enterobacteriaceae)
Erwinia cyperpedii
(Hori) Bergey et al.
(Enterobacteriaceae)
FUNGI
TW, US
TW, US
Phalaenopsis,
Orchidaceae
Phalaenopsis, Various
Flower,
Leaf, Soil,
Stem
Yes
Yes
Leaf, Stem
Leaf, Stem
No
No
Lai, 1984;
Taiwan, 1996;
Wu, 1982
TW, US
Phalaenopsis, Various
Leaf, Stem
No
Yes
Bradbury,
1986; Taiwan,
1996
TW, US
(CA, FL)
Carica, Phalaenopsis,
Orchidaceae
Leaf, Stem
No
Yes
Bradbury,
1986
6
Pest
Botrytis cinerea
Pers.:Fr.
(Fungi Imperfecti,
Hyphomycetes)
Capnodium sp.
(Loculoascomycetes,
Dothideales)
Cercospora sp.
(Fungi Imperfecti,
Hyphomycetes)
Colletotrichum
phalaenopsidis Saw.
(=Colletotrichum
gloeosporioides (Penz.)
Penz. & Sacc. in Penz.)
(Fungi Imperfecti,
Coelomycetes)
Cylindrosporium
phalaenopsidis Saw.
(Fungi Imperfecti,
Coelomycetes)
Distribution1
Hosts
Plant Part
Affected
TW, US
Phalaenopsis, Various
Leaf, Stem
No
Yes
Farr et al.,
1989; Taiwan,
1996
TW
Phalaenopsis, Various
Leaf, Stem
Yes
Yes
Taiwan, 1996
TW
Phalaenopsis, Various
Leaf, Stem
Yes
Yes
PPQ, 1998
References
TW, US
Phalaenopsis, Various
Leaf, Stem
No
Yes
Anon., 1979;
Farr et al.,
1987; Redlin,
2002; Taiwan,
1996
TW
Phalaenopsis
Leaf, Stem
Yes
Yes
Anon., 1979
Yes
Yes
PPQ, 2003
Yes
Yes
PPQ, 2003
Yes
Yes
PPQ, 2003
Fusarium sp.
(Fungi Imperfecti,
Hyphomycetes)
TW
Fusicoccum sp.
(Fungi Imperfecti,
Coelomycetes)
TW
Phaeosphaeria sp.
(Loculoascomycetes,
Dothideales)
TW
Phomopsis orchidophila
Cash & A.M. Watson
(Fungi Imperfecti,
Coelomycetes)
Phytophthora
nicotianae Breda de
Haan var. parasitica
(Dastur) G. M.
Waterhouse
(=Phytophthora
parasitica Dastur)
(Oomycetes,
Peronosporales)
Pythium sp.
(Oomycetes,
Peronosporales)
Quarantine Follow
Pest
Pathway
Capsicum, Musa,
Orchidaceae, Rosaceae,
Leaf, Stem
Rutaceae, Sola naceae,
Various
Leucacendron,
Orchidaceae,
Leaf, Stem
Pittosporium, Protea,
Rutaceae, Various
Chamaedorea, Dracena,
Heliconia, Orchidaceae,
Leaf
Oryza, Viburnum,
Various
TW
Phalaenopsis
Orchidaceae
Leaf
Yes
Yes
Cash and
Watson, 1955;
PPQ 1998,
2003
TW, US
Phalaenopsis, Various
Leaf, Stem
No
Yes
Farr et al.,
1989; Taiwan,
1996
TW
Phalaenopsis, Various
Leaf, Stem
Yes
Yes
Taiwan, 1996
7
Pest
Sclerotium rolfsii Sacc.
(Fungi Imperfecti,
Agonomycetes)
Sphaerulina
phalaenopsidis Saw.
(Loculoascomycetes,
Dothideales)
VIRUSES
Distribution1
Hosts
Plant Part
Affected
Quarantine Follow
Pest
Pathway
TW, US
Phalaenopsis, Various
Leaf, Stem
No
Yes
Farr et al.,
1989; Taiwan,
1996
TW
Phalaenopsis
Leaf, Stem
Yes
Yes
Anon., 1979;
Sawada, 1959
Cymbidium mosaic
potex virus
TW, US
Phalaenopsis
Leaf, Stem
No
Yes
Cucumber mosaic virus
TW, US
Phalaenopsis
Leaf, Stem
No
Yes
Odontoglossum ringspot
TW, US
Phalaenopsis
Leaf, Stem
No
Yes
virus
1
Distribution: TW= Taiwan, US= United States, CA=California, FL= Florida, HI= Hawaii
References
Brunt et al.,
1990; Pirone,
1978; Smith et
al., 1988
Zettler et al.,
1990
Brunt et al.,
1990
E. Analysis of Quarantine Pests
The undesirable consequences that may occur from the introduction of quarantine pests are
assessed in this section. For each quarantine pest, the potential consequences of introduction are
rated using five Risk Elements (REs). These REs (Climate-Host Interaction, Host Range, Dispersal
Potential, Economic Impact and Environmental Impact) reflect the biology, host range and
climatic/geographic distribution of each pest and are supported by published biological
information. For each RE, pests are assigned a rating of Low (1 point), Medium (2 points) or High
(3 points). Cumulative risk values are then calculated by a summation of the ratings. The
following scale is used to interpret this total: Low (5-8 points) Medium (9-12 points) and High (1315 points) and are summarized in Table 4. The ratings were determined using the criteria in the
risk assessment Guidelines, Version 5.02 (USDA, 2000).
Sources of uncertainty in this analysis stem from the quality of the biological information which
includes increased uncertainty whenever biological information is lacking on the regional flora
and fauna (Gallegos and Bonano, 1993), and the inherent biological variation within a population
of organisms (Morgan and Henrion, 1990). In order to address this uncertainly, only the
quarantine pests that can reasonably be expected to follow the pathway, i.e., be included in
commercial shipments of Phalaenopsis plants are further analyzed. Most of the pests in Table 2
identified only to the order, family or generic level are associated with Phalaenopsis only
through interceptions of these pests by PPQ officers from cargo, passenger baggage or mail.
They could not be identified to species because the intercepted life stage can not be identified to
species (e.g., scale insects other than adult females). If identified, these pests may or may not
belong to quarantine pest species. These intercepted pests might also represent single instances
of hitchhiker pests. The intercepted pests identified only to higher taxa may actually belong to a
nonquarantine species already addressed in the document under a species epithet (e.g.,
Pseudococcus sp.= Pseudococcus longispinus). The biological hazards of organisms identified
only to the order, family or generic levels are not assessed, but if pests identified only to higher
taxa are intercepted in the future, reevaluations of their risk may occur at that time. In this risk
8
assessment, this applies to the following taxa: Acari, Agromyzidae, Aphididae, Brevipalpus sp.,
Cerataphis sp., Cicadellidae, Coccidae, Crematogaster sp., Curculionidae, Diaspididae,
Dichromothrips sp., Diptera, Lymantriidae, Miridae, Noctuidae, Parlatoria sp., Phlaeothripidae,
Plutellidae, Pseudococcidae, Pseudococcus sp., Smithuridae, Spodoptera sp., Tettigoniidae,
Thripidae, Tortricidae, Xenotarsonemus sp., Succinea sp., Capnodium sp., Cercospora sp.,
Fusarium sp., Fusicoccum sp., Phaeosphaeria sp., and Pythium sp. Because of this uncertainty
about species identifications, quarantine action will be required if any of these organisms are
intercepted during port of entry inspections by PPQ Officers.
Generally, only the biological hazards of organisms identified to the species level are assessed
because often there are many species within a genus, and it is reasonable to assume that the
biology of congenerics are similar. Lack of species identification may indicate the limits of the
current taxonomic knowledge or the life stage or the quality of the specimen submitted for
identification. In cases where only genus- level identification is available but other evidence
indicates that pest species in that genus occur in the immediate vicinity and in association with
the commodity, it may be assumed (based on the scientific evidence) that such pest species may
be present. By necessity, pest risk assessments focus on the organisms for which biological
information is available. Development of detailed assessments for known pests that inhabit a
variety of ecological niches, such as the surfaces or interiors of fruit, stems or roots, allow
effective mitigation measures to eliminate the known organisms as well as similar but
incompletely identified organisms that inhabit the same niche. In addition, qua rantine species
may be present in those groups identified only to the genus level. Should these incompletely
identified species be intercepted by PPQ Officers during port of entry inspection, quarantine
action will be required.
Other plant pests listed in Table 2 may be potentially detrimental to the agricultural systems of the
United States; however, the y were not subjected to further analysis for a variety of reasons. First,
the pest’s primary association may be with plant parts other than the commodity. Secondly, the
pests may not be associated with the commodity during transport or processing because of their
inherent mobility and/or instinct to avoid light, or human activity. Thirdly, sterile insect stages can
be transported in a shipment but are unable to establish viable populations upon entry. Lastly,
packing procedures at the country of origin may cause contamination by organisms not normally
associated with Phalaenopsis orchids. Should any of these biological contaminants be intercepted
during inspection by PPQ Officers, quarantine action will be required (PPQ, 2003) and the packing
procedures will be modified in order to eliminate the presence of these organisms. In addition,
there are instances in Table 2, e.g., Dichromothrips sp., Frankliniella intonsa (Trybom) and
Lepidosaphes chinensis Chamberlin, where quarantine pests are listed as either pests of specific
genera of orchids other than Phalaenopsis or non-specifically, as pests of Orchidaceae. In those
cases, the likelihood and consequences of introduction into the United States were not analyzed
because no specific host linkages to Phalaenopsis could be found in the scientific literature.
The fungus, Colletotrichum phalaenopsidis was synonymized with C. gloeosporioides (Penz.)
(Penz. & Sacc. in Penz.) (Redlin, 2002) after the publication of the original risk assessment in
1996. Colletotrichum gloeosporioides is widely distributed in the United States (Farr et al.
1989), and therefore is no longer of phytosanitary concern.
9
Table 3: Quarantine Pests Likely to Follow Pathway
Arthropods
Planococcus minor
Spodoptera litura
Mollusks
Acusta (= Bradybaena) tourranensis and Bradybaena sp.1
Fungi
Cylindrosporium phalaenopsidis Saw. [Fungi Imperfecti, Coelomycetes]
Phomopsis orchidophila Cash & A.M. Watson [Fungi Imperfecti, Coelomycetes]
Sphaerulina phalaenopsidis Saw. [Loculoascomycetes, Dothideales]
1
For purposes of this analysis, Acusta (= Bradybaena) tourranensis and Bradybaena sp. will be analyzed together.
1. Consequences of Introduction
Risk Element 1: Climate-Host Interaction
The subtropical and tropical orchid-growing areas of Taiwan correspond to USDA Plant Hardiness
Zone 11 (average annual minimum temperature, 40EF (ARS, 1960). Zone 11 is limited to the
southern part of Florida (National Climatic Data Center, 2000). It is unlikely that pests associated
with plants grown, either indoors or in a greenhouse, in Plant Hardiness Zones other than Zone 11,
will be affected by the outdoor weather in that area. This risk assessment assumes that those pests
will be unable to establish or spread in the out-of-doors environment.
The mollusk, A. tourranensis has a tropical Asian distribution (La i, 1984) that corresponds to no
more than three climatic zones in the United States (ARS, 1960). The mealybug, Planococcus
minor, occurs in the Neotropical, Oriental, Austro-oriental, and Malagasian regions represented by
no more than three subtropical plant hardiness zones in the Unites States (Cox, 1989). The risk
rating for the Climate-Host Interaction for these pests is Medium (2).
In contrast, Spodoptera litura occurs over a wide range of climates including Australasia and Asia
(CIE, 1993; Pogue, 2002). It is likely to establish in four or more Plant Hardiness Zones in the
United States (ARS, 1960); therefore a risk rating of High (3) is warranted.
The geographical distribution of Phomopsis orchidophila includes Taiwan, South America, Mexico,
Guatemala, Puerto Rico, India, Australia and the Pacific Islands (Uecker, 1988). The climatic
ranges for the other pathogens are assumed to be similar. While orchids may be grown outdoors in
the southern tier of the United States, generally, they are grown indoors and/or in temperature
controlled production facilities (Hartmann and Kester, 1959). The risk rating for the Climate-Host
Interaction for these pests is Low (1).
Risk Element 2: Host Range
More than 10 families of plants are listed as hosts for the mollusk, A. tourranensis, including
herbaceous and tree species (Lai, 1984). The host range of the mealybug, P. minor, includes more
10
than 30 species of plants in over ten families (Cox, 1989). The host range for S. litura includes
plants in the families Cruciferae, Rutaceae, and Fabaceae (Zhang, 1994). The risk rating for the
Host Range for each of these pests is High (3).
In the original risk assessment, the host range for the pathogens Cylindrosporium phalaenopsidis
and Sphaerulina phalaenopsidis was assumed to be only Phalaenopsis, and there is no evidence to
the contrary as of this date (USDA, 1997). The host range for P. orchidophila includes only
species of Catasetum, Cattleya, Coelogyne, Cymbidium and Phalaenopsis (Uecker, 1988). There
are approximately 109 species of Phomopsis present in the United States, and only three of them
are reported to infect more than four different plant host genera (Farr et al., 1989). Assuming that
P. orchidophila is a valid species, it is unlikely that this is a new generalist because reports of it
infecting more plants would be seen in the literature. For all of these pathogens, the risk rating for
the Host Range is Low (1).
Risk Element 3: Dispersal Potential
Mollusca, a class of animals that includes snails and slugs, live in the soil and under debris.
Although the adults may be large and easily detected, the eggs are small. Snails and slugs may
chew irregular holes with smooth edges in succulent foliage or fruit, and some can clip succulent
plant parts (Ohlendorf, 1999). These pests feed on foliage, flowers and fruit from various plant
species, especially in greenhouses (Godan, 1983). The adults of the mollusk, A. tourranensis, are
large and likely to be dislodged from plants before transport (Godan, 1993; Ohlendorf, 1999).
Adults and juveniles move slowly from one site to another, and the reproductive cycle is long and
few eggs are produced (Lai, 1984). This pest is reported only in southern Taiwan, and has not
spread to other areas of Asia, indicating limited dispersal capabilities (Wu, 1982). The Dispersal
Potential for this pest is rated Low (1).
The generalized life history of mealybugs (Pseudococcidae) indicates that crawlers readily spread
among closely placed plants (Cox, 1989; McKenzie, 1967; Williams and Granara de Willink,
1992). Ovipositing females are sedentary, and can lay up to 500 eggs per event ; there can be as
many as 10 generations per year on a host (Cox, 1989; McKenzie, 1967; Williams and Granara de
Willink, 1992). The primary mode of long distance dispersal is through commercial movement of
plants (CABI, 1999). Although distributed in the U.S. Virgin Islands (ScaleNet, 2002), there are
no interceptions of P. minor on Phalaenopsis species (PPQ, 2003). For these reasons, the risk
rating for the Dispersal Potential of this mealybug is Medium (2).
Female S. litura oviposit in clusters of several hundred eggs, fecundity ranges from 2,000-2,600
eggs per female, there may be up to 12 generations per year, moths can fly up to 1.5 km per night
and eggs and larvae may be spread long distances through commerce (Anon., 1982; CABI, 1999;
CIE, 1993; Matsuura and Naito, 1992a; 1992b; Pogue, 2002). For these reasons, the risk rating for
the Dispersal Potential of S. litura is High (3).
The fungal pathogens, Cylindrosporium phalaenopsidis and Phomopsis orchidophila, are in genera
that produce spores that are splashed by irrigation or rain onto nearby hosts (Agrios, 1997; Pirone,
1978). These spores also may be carried by insects, animals, and humans moving among plants
(Agrios, 1997; Pirone, 1978). Sphaerulina phalaenopsidis is in a genus that produces air dispersed
spores that are not likely to be widely dispersed over long distances (Agrios, 1997). For these
reasons, the risk rating for the Dispersal Potential for all the pathogens is Medium (2).
11
Risk Element 4: Economic Impact
Mollusk feeding reduces the visual quality of the plant, the available photosynthetic surface area,
and some clip succulent plant parts (Godan, 1983; Ohlendorf, 1999). The introduction of the
mollusk Bradybaena similaris (Ferrussac) into Louisiana and other states from tropical China
necessitated control treatments for this occasional citrus and garden pest (Aguirre and Poss,
2000). It is anticipated that if A. tourranensis is introduced into a new area, there will be a need
for similar control measures. The mealybug, Planococcus minor, may vector a virus (Cox,
1989). Additionally, large populations can rapidly develop on a host, and decrease plant quality
through the accumulation of unsightly sooty molds and plant wilting (Cox, 1989; McKenzie,
1967; Williams and Granara de Willink, 1992). For these reasons, the Economic Impact rating
for these pests is Medium (2).
Spodoptera litura causes major damage to tobacco, cotton, chilies, cabbage, and other crops
(Anon., 1982; CABI, 1999; CIE, 1993; Matsuura and Naito, 1992a; 1992b; Pogue, 2002).
Where it is present, it is responsible for heavy quality and yield loss and qualifies as a key pest
(Smith, et al., 1997). A density of 1.5 larvae per plant reduced yield of greenhouse peppers by
10% (CABI, 1999). In tomatoes, larvae bore into fruit and reduce quality significantly (CABI,
1999; Smith, et al., 1997). For these reasons, the Economic Impact rating for this pest is High
(3).
The fungal pathogens, Cylindrosporium phalaenopsidis, Phomopsis orchidophila and Sphaerulina
phalaenopsidis, are in genera that infect leaves (Agrios, 1997; Pirone, 1978). Most leaf-spot
causing pathogens reduce visual quality and decrease the value of ornamental crops in addition to
reducing the available photosynthetic area and reducing plant vigor (Agrios, 1997; Pirone, 1978).
These losses reduce the market value of the plants (Agrios, 1997). The risk rating for the
Economic Impact for these pathogens is Medium (2).
Risk Element 5: Environmental Impact
There is no evidence that any Endangered, Threatened or Candidate species are hosts of quarantine
pests. The two insect pests, Planococcus minor and Spodoptera litura, however, have hosts that
are congeneric with USFWS listed species (Table 4) (USFWS, 2001). This should not be
interpreted to mean that any listed species can be hosts for these pests. Rather, this Table should be
interpreted as an extrapolation from scientifically demonstrated host ranges and represents a
possible, not a probable potential for harm to the environmental resources in the United States.
These possible impacts in combination with the direct and indirect effects of these pests on hosts
warrant a risk rating for Environmental Impact of Medium (2) for Planococcus minor and
Spodoptera litura.
12
Table 4. Listed species that potential pests may adversely impact. (Each listed plant is congeneric
with a host of a quarantine pest likely to follow the pathway in an unmitigated importation of
plants.
Listed species
Status 1
Range
Pest with a host in the same
genus as the listed species
Amaranthus brownii
E
HI
A. pumilus
T
DE, MA, MD, NC, NJ,
NY, RI, SC
Cucurbita okeechobeensis
E
FL
ssp. Okeechobeensis
Cyperus trachysanthos
E
HI
Euphorbia haeleeleana
E
HI
E. telephioides
T
FL
Helianthus eggertii
T
AL, KY, TN
H. paradoxus
T
NM, TX
H. schweinitzii
E
NC, SC
Planococcus minor
H. verticillatus
C
AL, GA, TN
Justicia cooleyi
E
FL
Manihot walkerae
E
TX, MX
Rhus michauxii
E
GA, NC, SC, VA
Solanum drymophilum
E
PR
S. incompletum
E
HI
S. nelsonii
C
HI
S. sandwicense
E
HI
Verbena californica
T
CA
Vigna o-wahuensis
HI
E
Ziziphus celata
E
FL
Apios priceana
T
AL, IL, KY, MS, TN
Allium munzii
E
CA
Linum arenicola
C
FL
L. carteri carteri
C
FL
Manihot walkerae
E
TX, MX
Spodoptera litura
Trifolium ameonum
E
CA
T. stoloniferum
E
AR, IL, IN, KS, KY,
MO, OH, WV
T. trichocalyx
E
CA
Vigna o-wahuensis
E
HI
1
E = Endangered species; T = Threatened species ; C = Candidate species
The following host genera for Planococcus minor did not correspond to any genera listed as
threatened, endangered, proposed or candidate: Abutilon, Acacia, Acalypha, Adenanthera,
Aglaonema, Aleurites, Alocasia, Alphitonia, Alpinia, Anacardium, Ananas, Annona, Antidesma,
Aphelandra, Apium, Arachis, Aralia, Araujia, Areca, Artocarpus, Asparagus, Balaka,
Barringtonia, Bauhinia, Bidens, Bischofia, Boehmeria, Borreria, Brassica, Broussonetia,
Brunfelsia, Caesia, Cajanus, Calliandra, Calophyllum, Camellia, Cananga, Capsicum, Cassia,
Castilla, Casuarina, Centrosema, Chrysalidocarpus, Cichorium, Citrullus, Clerodendrum, Cocos,
Codiaeum, Coffea, Coleus, Commelina, Cordia, Corynocarpus, Crinum, Croton, Cryptosperma,
13
Dahlia, Datura, Dendrobium, Dieffenbachia, Dioscorea, Elettaria, Emilia, Epimeredi,
Epipremnum, Erythrina, Eucalyptus, Eugenia, Evodia, Excoecaria, Fagraea, Ficus, Flemingia,
Gardenia, Gladiolus, Gliricidia, Glochidion, Glycine, Gossypium, Graptophyllum, Guettarda,
Harrisia, Hedychium, Heliconia, Hibiscus, Howeia, Hoya, Hyptis, Impatiens, Inocarpus, Ipomoea,
Ixora, Jatropha, Kleinhovia, Lagerstroemia, Leucaena, Leucosyke, Ludwigia, Lumnitzera,
Lycopersicon, Macadamia, Macaranga, Mallotus, Mangifera, Manilkara, Maranta, Merremia,
Michelia, Mikania, Mimosa, Morinda, Morus, Mucuna, Musa, Myristica, Nicolaia, Ocimum,
Odontonema, Pachystachys, Pandanus, Passiflora, Pavonia, Pemphis, Persea, Phaseolus,
Philodendron, Phyllanthus, Piper, Pipturus, Pistia, Pluchea, Plumeria, Polyscias, Pometia,
Premna, Procris, Psidium, Pyrus, Randia, Raphanus, Rhaphidophora, Ricinus, Rosa, Russelia,
Saccharum, Schefflera, Sechium, Spondias, Stachytarpheta, Synedrella, Tagetes, Tectona,
Terminalia, Theobroma, Tithonia, Tournefortia, Tradescantia, Triumfetta, Vitex, Vitis, Wedelia,
Wisteria, Xanthosoma, Zea, Zingiber, Zinnia.
The following host genera for Spodoptera sp. did not correspond to any genera listed as threatened,
endangered, proposed or candidate: Abelmoshus, Alternanthera, Ananas, Apium, Arachis,
Asparagus, Bacop, Beta, Brachiaria, Brassica, Camellia, Capsicum, Castilla, Chrysanthemum,
Cicer, Citrus, Coccinia, Colocasia, Corchorus, Cyamopsis, Cynara, Cynodon, Derris, Digitaria,
Echinochloa, Eichornia, Eleusine, Elymus, Eremochloa, Erythxylym, Fimbristylis, Fragaria,
Gladiolus, Glycine, Gossypium, Hordeum, Ipomoea, Isachne, Kumara, Lablab, Leptochloa,
Leucaena, Lilium, Luffa, Medicago, Morus, Musa, Nicotiana, Oryza, Paspalum, Pennisetum,
Phaseolus, Ricinus, Rosa, Saccharum, Sesbania, Sorghum, Spinacia, Stenotaphrum, Theobroma,
Triticum, Ulmus, Vitis, Zea, Zoysia. Because of its wide host and climate range and high capacities
for dispersal, we estimate introduction of Spodoptera litura would lead to significant ecological
impact and trigger chemical or biological control programs. This element is rated as high for
Spodoptera litura.
There are no populations of the mollusk, Acusta tourannensis, established from the importations of
bare-root Phalaenopsis plants into the United States to date, and it is rarely intercepted on these
plants (PPQ, 2003). Nevertheless, snails are spread in commerce, and due to their
hermaphroditism, one snail can start a population (Godan, 1983). If this pest established, it would
be likely to disrupt unmanaged ecosystems in the subtropical areas of Hawaii, Florida, and other
climatically similar areas. The Environmental Impact risk rating for this mollusk is Medium (2).
In the earlier version of this risk assessment document (USDA, 1997), the host range for the
pathogens Cylindrosporium phalaenopsidis and Sphaerulina phalaenopsidis was assumed to be
only Phalaenopsis, and there is no evidence to the contrary as of this date. It is not reasonable to
assume that these fungi have unlimited host ranges, based on Flor’s Gene for Gene Theory which
says that host specificity is the norm based on the evolutionary genetic interactions between hosts
and pathogens (Agrios, 1997). It is unreasonable to assume that they will infect host plants ad
infinitum. For these reasons, the Environmental Impact rating for these pathogens is Low (1).
14
Table 5: Summary of the Risk Ratings and the Value of the Consequences of Introduction
Pest
Acusta tourranensis
Planococcus minor
Spodoptera litura
Cylindrosporium
phalaenopsidis
Phomopsis orchidophila
Sphaerulina
phalaenopsidis
Climate/Host
Interaction
Host
Range
Dispersal
Potential
Economic
Impact
Environmental
Impact
Consequences
of Introduction
Value
Medium
(2)
Medium
(2)
High
(3)
Low
(1)
Low
(1)
Low
(1)
High
(3)
High
(3)
High
(3)
Low
(1)
Low
(1)
Low
(1)
Low
(1)
Medium
(2)
High
(3)
Medium
(2)
Medium
(2)
Medium
(2)
Medium
(2)
Medium
(2)
High
(3)
Medium
(2)
Medium
(2)
Medium
(2)
Medium
(2)
Medium
(2)
High
(3)
Low
(1)
Low
(1)
Low
(1)
Medium
(10)
Medium
(11)
High
(15)
Low
(7)
Low
(7)
Low
(7)
2. Likelihood of Introduction
The likelihood of introduction for a pest is rated relative to six factors which includes the quantity
to be imported (USDA, 1995). As per the Guidelines v.5.02, the value for the Likelihood of
Introduction is the sum of the ratings for the Quantity Imported Annually and the Summary of the
Risk Ratings for the Likelihood of Introduction (Table 6). The following scale is used to interpret
this total: Low is 6-9 points, Medium is 10-14 points and High is 15-18 points.
Risk Element 6, subelement 1: Quantity of commodity imported annually
The rating for the Quantity Imported Annually is based on the amount reported by the country of
proposed export converted into standard units of 40- foot long shipping containers. Permission to
import into the United States is likely to be linked with an increase in production in the future and
subsequent increases in the volumes of imports. No more than 10 containers per year ha ve ever
been exported or are expected to be exported from Taiwan into the United States.
The assessment next considers ratings in five additional areas. These ratings are based on the
biological features exhibited by the pest’s interaction with the commodity, and represent a series of
independent events that must all take place before a pest outbreak can occur. The five areas
consider the availability of postharvest treatments, whether the pest can survive through the interval
of normal shipping procedures, whether the pest can be detected during a port of entry inspection,
the likelihood that the pest will be imported or subsequently moved into a suitable environment,
and the likelihood that the pest will come into contact with suitable hosts.
Risk Element 6, subelement 2: Availability of Post- harvest Treatments
There are no specific postharvest treatments proposed to control, reduce or eliminate any of the
pest species, so this element is rated High (3) for all the pests.
15
Risk Element 6, subelement 3: Survive Shipment
The plants are expected to be shipped at moderate temperatures and humidity which is unlikely to
adversely affect any of the quarantine pest populations that are present during shipment. Larval
stages of Spodoptera sp. routinely sur vive shipment, and Planococcus minor is often intercepted
(PPQ, 2003). The conditions required for plant survival during shipment will not inhibit the
growth of any fungi that are likely to follow the pathway. For these reasons, this element is rated
High (3) for all the pests.
Risk Eleme nt 6, subelement 4: Not Detected at the Port of Entry
Standard inspection techniques are highly likely to detect larger mature and juvenile forms of the
mollusk, A. tourranensis, present on plants (Robinson, 2002). Although small eggs in soil are
highly likely to escape detection, plants produced in APHIS-approved growing media under pestexclusionary conditions are expected to be free of mollusk eggs. This element is rated Low (1) for
this pest.
Standard visual inspection techniques are not likely to detect microscopic crawler stages of the
mealybug, Planococcus minor (CABI, 1999). In contrast, the adults, associated sooty mold, and
wilting are readily detected (CABI, 1999; Cox, 1989; McKenzie, 1967; Williams and Granara de
Willink, 1992). This element is rated Medium (2) for this pest.
The larvae of Spodoptera litura can be up to 45 mm in length and are on plant surfaces where they
are readily detected (Anon., 1982; CABI, 1999; CIE, 1993; Matsuura and Naito, 1992a; b; Pogue,
2002; Smith, et al., 1997). Eggs hidden between leaves, in media, or within flowers are more
difficult to detect (Pogue, 2002). This element is rated Medium (2) for this pest.
The pathogens, C. phalaenopsidis, P. orchidophila and S. phalaenopsidis, infect leaves causing
leafspots (Agrios, 1997; Pirone, 1978) that are easily detected by trained inspectors. Latent
infections are unlikely to be detected (Agrios, 1997; Pirone, 1978). For these reasons, this element
is rated Medium (2) for these pests.
Risk Element 6, subelement 5: Moved to a Suitable Habitat
Mollusks and mealybugs shipped to temperate United States ports in winter, spring, or fall are not
likely to find suitable outdoor habitats, but if quickly transported into warm, indoor sites (such as
greenhouses or shops) the pests may proliferate (CABI, 1999; Cox, 1989; Godan, 1993; Lai, 1984;
McKenzie, 1967; Ohlendorf, 1999; Williams and Granara de Willink, 1992). Mollusks and
mealybugs shipped to subtropical ports are more likely to be moved into a suitable habitat. The
wide range of suitable climates for S. litura (CABI, 1999) means that it is highly likely to be moved
to suitable climates.
The spores of the fungal pathogens are readily disseminated by a variety of mechanisms (Agrios,
1997; Pirone, 1978). Spores often require high relative humidity and moderate temperatures for
limited periods of time to infect (Agrios, 1997). These conditions can be met during regular orchid
culture conditions (Hartmann and Kester, 1959), so it is reasonable to expect that spores will find
suitable habitats for infection. In China, C. phalaenopsidis caused an epidemic in orchids when
environmental conditions of “cloudy and drizzly weather” occurred in the otherwise windless, hot
16
and sunny climate (Lu et al., 1994). Removal of diseased leaves along with application of
pesticides from December to March provided control of the disease (Lu et al., 1994). For all these
reasons, this element is rated High (3) for all of the pests.
Risk Element 6, subelement 6: Contact with Host Material
All of the pests are highly likely to come into contact with host material if they enter the United
States because the infested orchids are likely to be grown near other orchids indoors or in
greenhouses. Additionally, the mollusk, mealybug, and S. litura have wide host ranges (CABI,
1999; Cox, 1989; Lai, 1984; Zhang, 1994), so native potential host plants are likely to be located
near the locations where orchids are grown. Fungal spores are likely to be disseminated in indoor
environments to other orchid plants by a variety of mechanisms (Agrios, 1997; Pirone, 1978). For
all these reasons, this element is rated High (3) for all of the pests.
Table 6: Summary of the Risk Ratings for the Likelihood of Introduction
Quantity
imported
annually
Pest
Acusta
tourranensis
Planococcus
minor
Spodoptera litura
Cylindrosporium
phalaenopsidis
Phomopsis
orchidophila
Sphaerulina
phalaenopsidis
Survive postharvest
treatment
Low
(1)
Low
(1)
Low
(1)
Low
(1)
Low
(1)
Low
(1)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
Survive
shipment
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
Not detected at Moved to a Find
suitable
port of entry suitable
habitat
hosts
Low
(1)
Medium
(2)
Medium
(2)
Medium
(2)
Medium
(2)
Medium
(2)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
High
(3)
Risk
Rating
High
(14)
High
(15)
High
(15)
High
(15)
High
(15)
High
(15)
F. Conclusion: Pest Risk Potential
The summation of the values for the Consequences of Introduction and the Likelihood of
Introduction gives the values for the Pest Risk Potential (Table 7). The following scale is used to
interpret this total: Low (11-18 points), Medium (19-26 points) and High (27-33 points). This is
a baseline estimate of the risks associated with this importation, and reduction of risk occurs
through the use of mitigation measures.
Table 7: Pest Risk Potential, Quarantine Pests of Phalaenopsis spp. From Taiwan.
Pest
Acusta tourannensis
Planococcus minor
Spodoptera litura
Cylindrosporium phalaenopsidis
Phomopsis orchidophila
Sphaerulina phalaenopsidis
Consequences of
Introduction
Medium (10)
Medium (11)
High (15)
Low (7)
Low (7)
Low (7)
Likelihood of
Introduction
High (14)
High (15)
High (15)
High (15)
High (15)
High (15)
Baseline Pest Risk
Potential
Medium (24)
Medium (26)
High (30)
Medium (22)
Medium (22)
Medium (22)
17
Pests with a Baseline Pest Risk Potential value of Low may not require mitigation measures other
than port of entry inspection, while values within the Medium or High range indicate that specific
phytosanitary measures (in addition to port of entry inspection) are necessary to ensure
phytosanitary security.
III. Risk Management
A. Introduction
The pest risks identified in the risk assessment (Table 4) represent a baseline risk associated with
the unmitigated importation of Phalaenopsis orchids from Taiwan in APHIS-approved growing
media. The proposed importation of Phalaenopsis orchids from Taiwan in APHIS-approved
growing media, if approved, would be regulated by existing plants in growing media regulations [7
CFR § 319.37-8 (e)]. The mitigations described in 7 CFR § 319.37-8, comprise a “Systems
Approach” designed to establish and maintain a pest-free production environment and ensure the
use of pest- free parent plants. These mitigations, when applied to this importation, effectively
remove the pests from the pathway, thus precluding them from establishment in the United States.
The Plant Protection Act of 2000 (SEC. 401. 7 U.S.C. 7701) defines “Systems Approach” as “…a
defined set of phytosanitary procedures, at least two of which have an independent effect in
mitigating pest risk associated with the movement of commodities.” The FAO Draft Standard for
Integrated Measures for Pest Risk Management proposed a definition of a Systems Approach as,
“The integration of different pest risk management measures, at least two of which act
independently, and which cumulatively achieve the desired level of phytosanitary protection.”
(FAO, 2001). Pest risk management is the decision- making process of reducing the risk of
introduction of a quarantine pest (FAO, 1996). Systems Approaches are employed by an importing
country as an alternative to the use of single measures that achieve an appropriate level of
phytosanitary protection when a single phytosanitary measure is nonexistent, infeasible or
undesirable. The combinations of specific mitigation measures that provide overlapping or
sequential safeguards are distinctly different from single mitigation methodologies such as
fumigation or inspection. Systems Approaches vary in complexity, however, they all require the
integration of different measures, at least two of which act independently, with a cumulative effect
and are often tailored to specific commodity-pest-origin combinations. Options for specific
measures may be selected from a range of pre- harvest and post-harvest measures (e.g., surveys,
inspections, sanitation, chemical treatments, etc, and include mitigation measures to compensate
for uncertainty. PPQ uses systems approaches for the importation of many commodities including
Unshu oranges from Japan (7 CFR § 319.28), tomatoes from Spain, France, Morocco, and Western
Sahara (7 CFR § 319.56-2dd), and peppers from Israel (7 CFR § 319.56-2u). These programs have
performed successfully for many years.
The three main categories of mitigation measures specifically required by 7 CFR § 319.37-8 (e) for
Phalaenopsis from Taiwan are: use of pest-free propagative material, pest-exclusionary
greenhouses and inspection. Ensuring pest-free propagative material requires monitoring and
testing of mother stock and descendant plants (Agrios, 1997; Jarvis, 1992). Pest-exclusionary
greenhouses employ treatments, good sanitation, e.g., surface disinfestation of tools and plant
materials, etc. (Agrios, 1997; Jarvis, 1992; Hartman et al., 2002; Kahn and Mathur, 1999), clean
water sources (Jarvis, 1992; Kahn and Mathur, 1999; Van der Plank, 1963), and use of approved
18
growing media. Studies on APHIS-approved growing media found that pathogens are not present
(Palm, 1994; Santacroce, 1991).
While not specifically required under 7 CFR§319.37-8(e), standard industry practices help to
further ensure that the pests of concern do not follow the pathway. These include sanitation and
chemical treatments designed to reduce or eliminate mealybugs (Cory and Highland, 1959), viruses
(Gara et al., 1997; Inouye and Gara, 1996; Wey et al., 2001) and fungi (McCain et al., 1973); in
vitro or aseptic vegetative propagation (Hsieh, 2001; Pearson, et al., 1991). Other cultural practices
enhance plant vigor so that pests are less able to establish infestations (Smith and Neal, 1998).
These practices include proper lighting (Konow and Wang, 2001; Wang, 1995), temperature (Wey,
2002), aeration and watering (Frank, 1988; Miller, 1990), sanitation (Smith and Neal, 1998) and
nutrition (Wang, 1998; Wang and Gregg, 1994). There are attempts to identify pest resistant
varieties of Phalaenopsis (Chen and Hsieh, 1978).
B. General Program Requirements for Plants in Growing Media
Risk mitigation measures for Phalaenopsis plants from Taiwan are drawn from the general risk
mitigation program requirements outlined in the APHIS regulation for certain plants in growing
media are outlined in 7 CFR§ 319.37-8(e). That regulation states:
(1) Plants must be established in approved unused growing media.
(2) Articles must be grown in compliance with a written agreement for enforcement of this
section signed by the plant protection service of the country of the country of origin and
Plant protection and quarantine APHIS. The plants must be developed from mother stock
which has been inspected no more than sixty days before establishment of the plants. The
inspection will be performed by an APHIS inspector or an inspector of the plant
protection service of the country of origin.
(3) The plants must be grown in compliance with a written agreement between the grower
and the plant protection service of the country of origin. The grower must allow access to
his facility to make sure he is complying with the regulations.
(4) Grown solely in a greenhouse in which sanitary procedures are employed to exclude plant
pests and diseases. This includes cleaning and dis infection of tools and facilities and
adequate measures to protect against plant pests and disease. The greenhouse must be free
of soil and sand. It must have screens on all vents and opening of not more than 0.6mm.
All entryways must be equipped with automatic closing doors.
(5) Rooted and grown in an active foliar state for at least four consecutive months before
export. The greenhouse must be used solely for exports to the United States.
(6) Grown from seeds germinated in the greenhouse or descended from a mothe r plant that
was grown for at least nine months in the exporting country. If the mother plant was
imported into the exporting country then it must be grown for at least twelve months prior
to establishment of the descendent plants or treated at the time of importation into the
exporting country with a treatment for pests of the plant prescribed by the plant protection
service of the exporting country and then grown for nine months prior to establishment of
descendent plants.
(7) Watered only with rainwater that has been boiled or pasteurised, with clean well water or
with potable water.
19
(8)
Rooted and grown in approved growing media on benches supported by legs and raised at
least 46cm off the floor.
(9) Stored and packed only in areas free of soil earth and plant pest.
(10) Inspected in the greenhouse and found free of evidence of plant pests and diseases by an
APHIS inspector or an inspector of the plant protection service of the country of origin.
C. Program Safeguards to Ensure Compliance
As outlined above in B. General Program Requirements for Plants in Growing Media, the
plants in growing media regulation 7 CFR§319.37-8(e) mandates certain procedures by APHIS and
the plant protection service of the country of origin to ensure compliance with the regulation. A
written agreement between the plant protection service of the country of origin and APHIS outlines
the respective responsibilities and obligations for the enforcement of the various requirements of 7
CFR§319.37-8(e). This agreement is called the “Operational Work Plan”. A current operational
work plan for plants in growing media from the Netherlands is in place (APHIS, 2003). Before
plants can be imported from Taiwan, a similar work plan will be developed and signed. The
Netherlands operational work plan states how the program will be monitored and supervised to
ensure compliance. The requirements, outlined in the Netherlands plants in growing media
operational work plan, include:
§
§
§
§
§
§
Officials from APHIS and the plant protection service of the Netherlands inspect each of the
greenhouses as part of the approval process for admittance into the export program;
APHIS monitors each of the approved greenhouses about four times a year but not more than
once a month;
The plant protection service of the Netherlands conducts monthly inspections of the approved
facilities and provides APHIS with a monthly accounting of the growing stocks for each
approved facility;
The plant protection service of the Netherlands has a written compliance agreement with each
approved grower;
The plant protection service of the Netherlands conducts phytosanitary inspections (in the
Netherlands), and issues and signs a Phytosanitary Certificate for each shipment;
APHIS inspectors verify documentation and inspect the plants at a PPQ plant inspection station
at a port of entry. Plant inspection stations are PPQ facilities located at certain ports of entry
specifically designed and staffed to inspect imported propagative plant material. Propagative
material is inspected carefully. The inspection is conducted in a clean, well- lit inspection room
with hand lenses, large magnification lenses, and wide- field scopes available to the inspectors.
The inspectional sample is large. It is generally larger then the sample for cut flowers and
fruits, as large as 100 percent. The inspection process normally includes removing the plants
from the medium and examining the roots.
D. Historical Performance of Existing Plants in Growing Media Import Programs
Current quarantine regulations 7 CFR§319.37-8(e) allow for plants of Alstroemeria, Ananas,
Anthurium, Begonia, Gloxinia, Peperomia, certain ferns, rhododenrons from Europe and
Saintpaulia to be imported into the United States in accordance with the measures described in
Section B. The same measures that will apply to Phalaenopsis plants from Taiwan. In evaluating
20
these risk management measures as they apply to Phalaenopsis plants from Taiwan, APHIS has
reviewed (Miller, 2003) the performance record of the current program.
Summary of results of regular APHIS inspections of the greenhouses participating in the plants in
growing media import program from 1990 to April 2003.
§
§
In the Netherlands, two to four greenhouses (companies) have participated in the program.
Both ferns and Anthurium have been grown and exported to the United States. Currently,
three greenhouses are in the program. APHIS plant health specialists have inspected the
greenhouses four to twelve times a year. They inspect for both noncompliance and plant
pests. No plant pests were found on any of these visits.
In Israel, one greenhouse growing ferns and African violets participated in the program
between 1990 and 1994. This facility was inspected by APHIS plant health specialists from
three to five times a year. Again, no plant pests were found.
All totaled, APHIS plant health specialists made approximately 200 inspectional site visits to
participating greenhouses. No plant pest detections were made during any of these visits (Miller,
2003).
Additional greenhouse inspections.
In addition to the regular program inspections, on at least two different occasions participating
greenhouses were visited by plant health specialists from the United States as part of general
reviews of APHIS import programs.
In February 1984, two entomologis ts and a plant pathologist from PPQ inspected a program
greenhouse in the Netherlands. No plant pests were found.
In March 1990, the Officer- in-Charge of the Plant Inspection Station at John F. Kennedy
International Airport, NY, also carefully inspected a program greenhouse in the Netherlands and
found no plant pests (Miller, 2003).
Port of Entry Inspections
Only one port of entry inspectional detection has been reported from program export plants. In
1990, a Lepidoptera larva was found in a single shipment. A very careful inspection of the
originating greenhouse in the Netherlands failed to detect any pests and the interception was
questioned (Miller, 2003). In comparison, there have been numerous interceptions during port of
entry inspections of bare-rooted plants that are not required to enter under the proposed for plants
in growing media (PPQ, 2003).
E. Evidence for the Effective Removal of Pests of Concern from the Pathway
Based on their characteristics, e.g., respective biologies, methods of dispersal and ability to be
detected, APHIS believes that the safeguards of 7 CFR§319.37-8(e) (see B. General Program
Requirements for Plants in Growing Media) outlined above will result in the effective removal
21
of the six pests of concern identified by the risk assessment from the Phalaenopsis plants from
Taiwan pathway. The FAO (1999) defines pathway as “Any means that allows the entry or spread
of a pest.” The following paragraphs present the evidence APHIS used to determine that the
measures required by 7 CFR§319.37-8(e) would effectively remove pests of concern from the
Phalaenopsis plants from Taiwan pathway.
Acusta tourannensis
Acusta tourannensis has a tropical Asian distribution (Lai, 1984) and a host range that includes
more than 10 families of plants (Lai, 1984). The adults of A. tourrannensis are large and likely to
be dislodged from plants before transport (Godan, 1993; Ohlendorf, 1999). This snail feeds on
Phalaenopsis spp. as well as other plants. It is known to be a tropical species. Snails and slugs are
detectable by slime trails, chewed leaves and excrement (Hollingworth and Sewake, 2002).
Standard inspection techniques are highly likely to detect larger mature and juvenile forms of the
mollusk, A. tourrannensis, present on plants (Robinson, 2002). Although small eggs in soil are
highly likely to escape detection, plants produced in APHIS-approved growing media under pestexclusionary conditions (e.g., sterile growing media) are expected to be free of mollusk eggs. The
rule governing importation of plants in approved growing media [7 CFR§319.37-8(e)] reduces the
risk of plants being contaminated by this species. Specific requirements (see B. General Program
Requirements for Plants in Growing Media) that mitigate the risk of A. tourrannensis include:
Measure 1
Evidence
1
Sterile growing media is not a good pathway
for snail movement.
2, 5, 10 All mother stock must be examined no more
than sixty days before establishment and
plants must be actively growing stage for four
months. In addition, the orchids must be
inspected in the greenhouse and found free of
evidence of A. tourrannensis by an APHIS
inspector or an inspector of the plant
protection service of the country of origin.
Snails are detectable by slime trails, chewed
leaves and excrement. Since standard
inspection techniques are highly likely to
detect larger mature and juvenile forms of A.
tourrannensis, this would allow snails to be
found either before they move into the
greenhouse or during required inspections.
4, 7, 8, 9 Plants will be grown solely in greenhouses
with sanitary procedures adequate to exclude
mollusks and other plant pests, e.g., there are
no irrigation ditches or other openings in
which the snails could gain access. The
greenhouse must be free of soil and sand to
prevent another potential pathway for entry of
snails. In addition orchids must be stored and
packaged in areas free of soil, sand, earth and
Reference
(Hollingworth and Sewake,
2002)
(Robinson, 2002;
Santacroce, 1991; CABI,
2002)
(Bessin, et al., 1997;
Hamon, 1995; Hollingworth
and Sewake, 2002; van
Rooyen, 2003)
22
Measure 1
Evidence
Reference
plant pests, whic h would further aid in
eliminating snails from the pathway The
requirement for a water source from clean
well water, boiled rain water or drinking
quality water will further reduce the likelihood
of introducing mollusks. Growing the plants
on raised benches is an additional physical
barrier to snails that might inhabit the cool
damp floor of the greenhouse.
1
see B. General Program Requirements for Plants in Growing Media for corresponding
measure
Planococcus minor
The generalized life history of mealybugs (Pseudococcidae) indicates that the mobile young insects
(crawlers) readily spread among closely placed plants (Cox, 1989; McKenzie, 1967; Williams and
Granara de Willink, 1992). Ovipositing females are sedentary (Cox, 1989; McKenzie, 1967;
Williams and Granara de Willink, 1992). The primary mode of long distance dispersal is through
movement of live plants (CABI, 1999). Planococcus minor the mealybug of concern has only
been intercepted once on Phalaenopsis and 3245 times on other hosts since 1985 (PPQ, 2003). This
would indicate that Phalaenopsis is not a preferred host for P. minor and Phalaenopsis plants are a
poor pathway for the introduction of P. minor into the United States.
Measure 1
Evidence
2, 5, 10 All mother stock must be examined no more
than sixty days before propagation of the
export plants. Plants must be actively grown
for four months. In addition, the orchids must
be inspected in the greenhouse and found free
of evidence of P. minor by an APHIS
inspector or an inspector of the plant
protection service of the country of origin.
The white-bodied adults are about 2.0 mm
long and are usually associated with black
sooty mold. These physical features facilitate
detection of P. minor on the green background
of plants, as the numerous of port of entry
interceptions attests. While young crawlers are
so minute as to be difficult to detect, the fourmonth period of observation in the originating
greenhouse will allow immatures to develop.
Regular inspections are recognized as an
important part of a balanced pest management
program for orchids. The use of pest free
propagating material is a primary measure to
prevent the introduction of mealybugs into
Reference
(McKenzie, 1967; Cox,
1989; PPQ, 2003; Roosjen,
et al., 1999)
23
Measure 1
Evidence
Reference
greenhouse crops.
4, 7
Plants will be grown solely in a greenhouse in (Roosjen, et al., 1999; van
which sanitary procedures are adequate to
Rooyen, 2003)
exclude plant pests. The greenhouse
enclosure provides a physical barrier to plants’
exposure to mealybugs from outside. Good
greenhouse sanitation, e.g., removal of plant
debris, cleaning and disinfection of tools and
facilities, etc. are essential safeguards
commonly recommended to prevent mealybug
infestations
1
see B. General Program Requirements for Plants in Growing Media for corresponding
measure
Spodoptera litura
Spodoptera litura causes major damage to tobacco, cotton, chilies, cabbage, and other crops
(Anon., 1982; CABI, 1999; CIE, 1993; Matsuura and Naito, 1992a; 1992b; Pogue, 2002).
Spodoptera infestation usually occurs when adults fly into the production area to lay eggs (CABI,
2002).
Measure 1
Evidence
2, 5, 10 All mother stock must be examined no more
than sixty days before establishment and
plants must be kept in an active growing stage
for four months. In addition, the orchids must
be inspected in the greenhouse and found free
of evidence of S. litura by an APHIS inspector
or an inspector of the plant protection service
of the country of origin. The larvae of S. litura
are from 2.3 mm to 32 mm in length and are
on plant surfaces where they are readily
detected. Newly emerged larvae can be easily
detected by the “scratch marks” they make on
the leaf sur face. These physical features
facilitate detection of S. litura as numerous
port of entry interceptions attest. Eggs clusters
which may be on cuttings are also readily
detectable because they are laid in clusters of
several hundred on the surface of the leaves.
Eggs are 0.6 mm and the egg mass is 4 to
7mm in diameter. Generation time is
approximately one month which would
facilitate finding the insect during the fourmonth growing period. Regular inspections
are recognized as part of a balanced pest
Reference
(Anon., 1982; CABI, 1999;
CABI, 2002; CIE, 1993;
Matsuura and Naito, 1992a;
b; Pogue, 2002; Smith, et
al., 1997; Roosjen, et al.,
1999; van Rooyen, 2003)
24
Measure 1
Evidence
Reference
manage ment program for orchids. The use of
pest free propagating material is an effective
measure to prevent the introduction of insects
into greenhouse crops.
4, 7
Plants will be grown solely in a greenhouse in (CABI, 2002; Roosjen, et
which sanitary procedures are adequate to
al., 1999; van Rooyen, A.,
exclude plant pests. The greenhouse
2003)
enclosure with its automatic double doors and
screened vents provides a physical barrier to
plants’ exposure to insects from outside.
Adult moths, which are 15mm to 20mm in
length, are easily excluded by the required 0.6
mm mesh screening. Good greenhouse
sanitation, e.g., removal of plant debris,
cleaning and disinfection of tools and
facilities, etc. are essential safeguards
commonly recommended to prevent insect
infestations
1
see B. General Program Requirements for Plants in Growing Media for corresponding
measure
Cylindrosporium phalaenopsidis
Phomopsis orchidophila
Sphaerulina phalaenopsidis
The fungal pathogens, Cylindrosporium phalaenopsidis and Phomopsis orchidophila, are in genera
that produce spores that are splashed by irrigation or rain onto nearby hosts (Agrios, 1997; Pirone,
1978). These spores also may be carried by insects, animals, and humans moving among plants
(Agrios, 1997; Pirone, 1978). Sphaerulina phalaenopsidis is in a genus that produces air dispersed
spores that are not likely to be widely dispersed over long distances (Agrios, 1997). The pathogens,
C. phalaenopsidis, P. orchidophila and S. phalaenopsidis, infect leaves causing leafspots (Agrios,
1997; Pirone, 1978; Rossman, et al., 1987) that are easily detected by trained inspectors. PPQ
interception records indicate that P. orchidophila was intercepted at ports of entry 53 times since
1985, with the majority of those interceptions made on orchid species, including two interceptions
on Phalaenopsis sp. imported under the current bare root requirement (port of entry inspection
only; PPQ, 2003). Fungi in the genera Cylindrosporium (five interceptions since 1985) and
Sphaerulina (16 interceptions since 1985) have also been intercepted on various hosts (PPQ, 2003).
The rules governing importation of plants in approved growing media reduce the risk of plants
being contaminated by these species. Specific requirements of 7 CFR§319.37-8(e) (see B. General
Program Requirements for Plants in Growing Media) that mitigate the risk of C.
phalaenopsidis, P. orchidophila and S. phalaenopsidis include:
Measure 1
Evidence
1
Fungal pathogens are generally introduced
into the greenhouse via infested plant material
or soil particles. The use of sterilized or
Reference
(Barry, 1996; Daughtrey, et
al., 1995; McQuilken and
Hopkins, 2001)
25
Measure 1
Evidence
Reference
pasteurized growing media will prevent the
introduction and / or spread of many fungal
pathogens and is required.
2, 5, 10 All mother stock must be examined no more
(Agrios, 1997; Pirone,
than sixty days before establishment and
1978; PPQ, 2003; Barry,
plants must be kept in an active growing stage 1996; Roosjen, et al., 1999;
for four months. In addition, the orchids must
Simone and Burnett, 1995;
be inspected in the greenhouse and found free Daughtrey, et al., 1995)
of evidence of C. phalaenopsidis, P.
orchidophila and S. phalaenopsidis by an
APHIS inspector or an inspector of the plant
protection service of the country of origin.
The pathogens, C. phalaenopsidis, P.
orchidophila and S. phalaenopsidis, infect
leaves causing leafspots that are easily
detected by trained inspectors. Regular
inspections are recognized as part of a
balanced disease management program for
orchids. Fungal pathogens are generally
introduced into the greenhouse via infested
plant material or soil particles. The use of
disease- free propagating material, as
established by the required inspections of
mother plants, is a primary measure to prevent
the introduction of fungal pathogens into
greenhouse crops.
4, 7
Plants will be grown solely in a greenhouse in (Agrios, 1997; Pirone,
which sanitary procedures are adequate to
1978; Barry, 1996; Roosjen,
exclude plant pests. The greenhouse
et al., 1999; Simone and
enclosure provides a physical barrier to plants’ Burnett, 1995)
exposure to fungal propagules from outside as
the spores are rain splashed (C.
phalaenopsidis and P. orchidophila) or
windborne (S. phalaenopsidis). Good
greenhouse sanitation, e.g., removal of plant
debris, cleaning and disinfection of tools and
facilities, etc. are essential safeguards
commonly recognized to prevent fungal
infections and are required by the proposed
program. The requirement for a water source
from clean well water, boiled rain water or
drinking quality water will further reduce the
likelihood of introducing pathogens.
1
see B. General Program Requirements for Plants in Growing Media for corresponding
measure
26
F. Conclusion
The mitigations described in 7 CFR § 319.37-8 (e) are designed to establish and maintain a pestfree production environment and ensure the use of pest- free parent plants. These mitigations, when
applied to the importation of Phalaenopsis plants from Taiwan, effectively remove the pests of
concern identified in the risk assessment from the pathway, thus precluding their introduction into
the United States.
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33
V. Authors
Risk Assessment
Gary L. Cave, Ph.D., Entomologist, USDA, APHIS, PPQ, CPHST, PERAL
Scott C. Redlin, Ph. D., Plant Pathologist, USDA, APHIS, PPQ, CPHST, PERAL
Russell Stewart, Entomologist, USDA, APHIS, PPQ
Risk Management
William E. Thomas, Import Specialist, USDA, APHIS, PPQ, PIM
Charles E. Miller, Senior Entomologist, USDA, APHIS, PPD, RAS
Edward V. Podleckis, Ph.D., Lead Risk Mitigation Specialist, USDA, APHIS, PPQ, PHP
Shaharra J. Usnick, Ph.D., Risk Mitigation Specialist, USDA, APHIS, PPQ, PHP
Reviewers/Contributors
Ron A. Sequeira, USDA, APHIS, PPQ, CPHST
Michael K. Hennessey, Ph.D., Entomologist, USDA, APHIS, PPQ, CPHST, PERAL
Hossien M. El-Nashaar, Ph. D., Plant Pathologist, USDA, APHIS, PPQ, CPHST, PERAL
Stacy Scott, Botanist, USDA, APHIS, PPQ, CPHST, PERAL
Eileen Sutker, Ph. D., Ecologist, USDA, APHIS, PPQ, CPHST, PERAL
Wayne Burnett, Team Leader, USDA, APHIS, PPQ, PIM, IIS
34
United States
Department of
Agriculture
Marketing and
Regulatory
Programs
Animal and
Plant Health
Inspection
Service
Proposed Rule for
the Importation of
Moth Orchids
(Phalaenopsis spp.)
in Approved Growing
Media From Taiwan
Environmental Assessment,
May 2003
Proposed Rule for the
Importation of Moth Orchids
(Phalaenopsis spp.)
in Approved Growing Media
From Taiwan
Environmental Assessment,
May 2003
Agency Contact:
William Thomas, Import Specialist
Import and Interstate Services
Phytosanitary Issues Management
Plant Protection and Quarantine
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
4700 River Road, Unit 140
Riverdale, MD 20737–1237
Telephone: 301–734–6799
The U.S. Department of Agriculture (USDA) prohibits discrimination in all
its programs and activities on the basis of race, color, national origin, sex,
religion, age, disability, political beliefs, sexual orientation, or marital or
family status. (Not all prohibited bases apply to all programs.) Persons with
disabilities who require alternative means for communication of program
information (Braille, large print, audiotape, etc.) should contact the USDA’s
TARGET Center at 202–720–2600 (voice and TDD).
To file a complaint of discrimination, write USDA, Director of Civil Rights,
Room 326–W, Whitten Building, 14 th and Independence Avenue, SW,
Washington, DC 20250–9410 or call 202–720–5964 (voice and TDD).
USDA is an equal employment opportunity employer.
Mention of companies or commercial products in this report does not imply
recommendation or endorsement by the U.S. Department of Agriculture
over others not mentioned. USDA neither guarantees nor warrants the
standard of any product mentioned. Product names are mentioned solely
to report factually on available data and to provide specific information.
This publication reports research involving pesticides. All uses of pesticides
must be registered by appropriate State and/or Federal agencies before they
can be recommended.
CAUTION: Pesticides can be injurious to humans, domestic animals,
desirable plants, and fish or other wildlife—if they are not handled or applied
properly. Use all pesticides selectively and carefully. Follow recommended
practices for the disposal of surplus pesticides and pesticide containers.
Table of Contents
I.
Purpose and Need for Proposed Action . . . . . . . . . . . . . . . . . . . 1
II. Alternatives, Including the Proposed Action . . . . . . . . . . . . . . . 2
III. Affected Environment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
IV. Potential Environmental Impacts of the Proposed
Action and Alternatives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
V. Listing of Agencies and Persons Consulted . . . . . . . . . . . . . . 21
VI. Literature Cited . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
I. Purpose and Need for Proposed Action
The United States Department of Agriculture (USDA), Animal and Plant
Health Inspection Service (APHIS), Plant Protection and Quarantine (PPQ) is
proposing to amend the regulations for the importation of plants and plant
products (7 Code of Federal Regulations (CFR) part 319) to add orchids of
the genus Phalaenopsis, known as moth orchids, from Taiwan, to the list of
plants that may be imported in approved growing media, subject to specified
growing, inspection, and certification requirements.
Currently, Phalaenopsis and other orchids are imported from Taiwan into the
United States as bare rooted plants or growing on tree fern slabs or in coconut
husk or fiber. In 1997, the Government of Taiwan requested that PPQ
consider amending the regulations to allow Phalaenopsis spp. orchids to be
imported into the United States in approved growing media under the
provisions of 7 CFR § 319.37–8(e).
Background
Currently in the United States, moth orchids are grown in pots primarily
for the interior design market. It is not uncommon for the plants to be
mass-produced and sold at wholesale to general merchandise retailers and
specialty outlets where they are purchased by consumers. Phalaenopsis spp.
and other orchids are imported into the United States as bare rooted plants, or
growing on tree fern or in coconut husk or fiber (7 CFR § 319.37–8(d)) and
are enterable subject to inspection findings at USDA plant inspection stations
at certain U.S. ports of entry. Many U.S. potted orchid growers start out with
imported plants; they purchase the bare rooted imports, grow them, then pot
them for sale. (In Hawaii, for example, it has been estimated that growers
import about half the orchid plants they use to establish potted orchids.) In
the United States all orchid plants sold to general merchandise and specialty
outlets are potted, and all are sold by U.S. growers (K. Dolan, pers. comm.).
According to USDA, Foreign Agricultural Service trade statistics, Taiwan’s
orchid exports to the United States were valued at $9.4 million in 2001 (K.
Dolan, pers. comm.). Taiwan is the largest exporter of Phalaenopsis spp.
orchids to the United States. Taiwan has requested to export to the United
States moth orchids potted in sphagnum moss or other approved growing
media. This will improve the viability of imported plants because currently
there is high mortality of bare rooted plants (Su et al., 2001). In addition,
with this rule change, Taiwan can provide potted, finished plants directly to
U.S. retailers (K. Dolan, pers. comm.).
1
In this document, PPQ analyzes the environmental effects of implementation
of the proposed rule changes to 7 CFR part 319. This environmental
assessment (EA) was prepared to comply with the National Environmental
Policy Act (42 United States Code § 4321 et seq.) as prescribed in
implementing regulations adopted by the Council on Environmental Quality
(40 CFR §§1500–1508), by USDA (7 CFR part 1b), and by APHIS (7 CFR
part 372), and to satisfy Executive Order 12114, “Environmental Effects
Abroad of Major Federal Actions.”
II. Alternatives, Including the Proposed
Action
This EA analyzes potential environmental consequences of the
implementation of a proposal to amend the regulations governing importation
of plants and plant products into the United States (7 CFR part 319). Two
possible alternatives are considered in this EA: regulation under the
proposed rule (preferred alternative) and maintaining the current regulation
for the importation of orchids of the genus Phalaenopsis into the
United States (no action alternative).
A. No Action
The no action alternative would be to leave 7 CFR part 319 unchanged.
Section 319.37–8(a) of the regulations requires, with certain exceptions,
that plants offered for importation into the United States be free of sand,
soil, earth, and other growing media. This requirement is intended to help
prevent the introduction of plant pests that might be present in unapproved
growing media; the exceptions to the requirement take into account factors
that mitigate that risk. Those exceptions, which are found in paragraphs
(b) through (e) of 7 CFR § 319.37–8, consider either the origin of the plants
and growing media, the nature of the growing media, and/or the use of a
combination of growing conditions, approved media, inspections, and other
requirements.
Currently, Phalaenopsis and other orchids are imported as bare rooted plants
established solely on tree fern slabs, coconut husks, or coconut fiber (7 CFR
§ 319.37–8(d)). All forms are enterable subject to inspection findings at
designated ports of entry to the United States, i.e., ports associated with
facilities where propagative material can be examined (plant inspection
stations). All orchid consignments must be accompanied by a USDA permit
and a phytosanitary certificate issued by the plant protection service of the
2
exporting country. This document certifies that the orchids have been
inspected and found free of quarantine pests.
The following taxa established in approved growing media are currently
allowed entry to the United States: Alstroemeria, Ananas, Anthurium,
Begonia, Gloxinia (=Sinningia), Nidularium, Peperomia, Polypodiophyta
(=Filicales), Rhododendron from Europe, and Saintpaulia (7 CFR
§ 319.37–8(e)). Under the no action alternative, Phalaenopsis spp. orchids
from Taiwan would not be added to the list of taxa allowed entry into the
United States established in approved growing media, but would continue to
enter the United States under current requirements (7 CFR § 319.37–8(d)).
B.
Amend Regulations According to the Proposed
Rule
This alternative would change 7 CFR part 319, according to the proposed
rule, and allow importation of moth orchids of the genus Phalaenopsis from
Taiwan rooted in approved growing media, provided the orchids are
produced, handled, and imported in accordance with the requirements of
7 CFR § 319.37–8(e) and are accompanied at the time of importation by a
phytosanitary certificate issued by Taiwan’s Bureau of Animal and Plant
Health Inspection and Quarantine (BAPHIQ) declaring that those
requirements have been met.
The proposed action of propagation, rearing, shipping, and importation of
Phalaenopsis in approved growing media into the United States from Taiwan
must meet the following requirements in 7 CFR § 319.37–8(e):
(e) Phalaenopsis spp. orchids may be imported from Taiwan established in
an approved growing medium, if the article meets the conditions of this
paragraph, and is accompanied by a phytosanitary certificate issued by
BAPHIQ that declares that the article meets the conditions of this paragraph:
(1) Approved growing media includes baked expanded clay pellets,
organic and inorganic fibers, peat, sphagnum moss, vermiculite, and other
media (see 7 CFR § 319.37–8(e)(1) for a complete list), and must not have
been previously used.
(2) Articles imported under this paragraph must be grown in compliance
with a written agreement for enforcement of this section signed by BAPHIQ
and PPQ, must be developed from mother stock that was inspected and
found free from evidence of disease and pests by a PPQ or BAPHIQ
inspector no more than 60 days prior to the time the article is established in
the greenhouse (except for articles developed from seeds germinated in the
greenhouse), and must be:
3
(i) Grown in compliance with a written agreement between the grower
and BAPHIQ, in which the grower agrees to comply with the provisions of
this section and to allow inspectors and representatives of BAPHIQ access to
the growing facility as necessary to monitor compliance with the provisions
of this section;
(ii) Grown solely in a greenhouse in which sanitary procedures adequate
to exclude plant pests and diseases are always employed, including cleaning
and disinfection of floors, benches, and tools, and the application of measures
to protect against any injurious plant diseases, injurious insect pests, and
other plant pests. The greenhouse must be free from sand and soil and must
have screening with openings of not more than 0.6 mm on all vents and
openings except entryways. All entryways must be equipped with automatic
closing doors;
(iii) Rooted and grown in an active state of foliar growth for at least
4 consecutive months immediately prior to importation into the
United States, in a greenhouse unit that is used solely for articles grown in
compliance with this paragraph;
(iv) Grown from seeds germinated in the greenhouse unit; or descended
from a mother plant that was grown for at least 9 months in Taiwan prior to
importation of the descendent plants into the United States, provided that if
the mother plant was imported into Taiwan from another country, it must be:
A. Grown for at least 12 months in Taiwan prior to importation of the
descendent plants into the United States, or
B. Treated at the time of importation into Taiwan with a treatment
prescribed for pests of that plant by BAPHIQ and then grown for at least
9 months in Taiwan prior to importation of the descendent plants into the
United States;
(v) Watered only with rainwater that has been boiled or pasteurized,
with clean well water, or with potable water;
(vi) Rooted and grown in approved growing media listed in 7 CFR
§ 319.37–8(e)(1) on benches supported by legs and raised at least
46 cm above the floor;
(vii) Stored and packaged only in areas free of sand, soil, earth, and
plant pests;
(viii) Inspected in the greenhouse and found free from evidence of plant
pests and diseases by a PPQ inspector or an inspector of BAPHIQ, no more
than 30 days prior to the date of export to the United States.
The packaging commonly used in the orchid industry is cardboard boxes, but
other alternatives, such as plastic, are possible. These cardboard boxes are
similar to other PPQ-approved packaging that excludes pests during the
packing process and prevents hitchhikers from entering the packaged plants.
The term “hitchhikers” is commonly used within PPQ to mean biological
contaminants, including insects, that generally are not specific to orchids.
4
PPQ-approved packing material includes paper, rock wool, sawdust, and
other media specified in 7 CFR § 319.37–9. The pots containing the plants
are most likely those that are commonly used in the orchid industry such as
plastic, clay, or other composite materials.
Preshipment treatment measures (i.e., fumigation) are not included as a
condition of entry of Phalaenopsis spp. orchids from Taiwan because the pest
risk assessment (USDA, APHIS, 2003a) did not identify any quarantine pests
which required these treatments in order to ensure quarantine security beyond
the mitigations listed in 7 CFR § 319.37–8(e).
III. Affected Environment
The area available for both the current importation of bare rooted
Phalaenopsis orchids and the proposed importation of Phalaenopsis spp.
orchids from Taiwan in approved growing media is the United States,
including its possessions and trust territories. However, no orchid plants will
be shipped directly to a location prior to passing through a PPQ plant
inspection station where plants can be inspected at the port of entry. Once
consignments are cleared through a plant inspection station, orchids could be
distributed to any location in the United States, including its possessions and
trust territories.
After receiving Taiwan’s request to allow importation of Phalaenopsis spp.
orchids established in approved growing media into the United States,
APHIS conducted a pest risk assessment (USDA, APHIS, 1997) to examine
the potential plant pest risk associated with unmitigated importations of moth
orchids in growing media. This risk assessment was revised in 2003 (USDA,
APHIS, 2003a) to provide new information and to employ current accepted
guidelines for risk assessment preparation. The revised risk assessment
prepared by APHIS to examine the plant pest risk associated with the
importation of moth orchids from Taiwan followed version 5.02 of the PPQ
Guidelines (USDA, APHIS, 2000) and characterizes risk in terms such as
high, medium, or low, based on supporting evidence. In addition, the
methods used to initiate, conduct, and report the risk assessment are
consistent with guidelines provided by the North American Plant Protection
Organization and the International Plant Protection Convention administered
by the Food and Agriculture Organization of the United Nations.
In the revised risk assessment (USDA, APHIS, 2003a), only the quarantine
pests that can reasonably be expected to follow the pathway (i.e., be included
in commercial shipments of Phalaenopsis plants) were further analyzed. A
quarantine pest is defined as “a pest of potential economic importance to the
5
area endangered thereby and not yet present there, or present but not widely
distributed and being officially controlled” (FAO, 2002). The biological
hazard of organisms identified only to the order, family, or generic levels
(except for Bradybaena spp. mollusks) is not assessed, but if pests identified
only to higher taxa are intercepted at the port of entry in the future, then
reevaluations of their risk may occur. Although thrips are known to be pests
of Phalaenopsis spp. orchids in Taiwan (Yang, 1997), they were not analyzed
further in the risk assessment because there was no linkage of specific thrips
species to Phalaenopsis in the scientific literature. The pests that were
determined to have potential to be included in commercial shipments of
Phalaenopsis (both bare rooted or in growing media) are listed in table 1.
The plant pathogenic fungus Colletotrichum phalaenopsidis Saw. was
identified in the 1997 risk assessment as a quarantine pest likely to follow the
pathway. However, since the original risk assessment was completed,
Colletotrichum phalaenopsidis was synonymized to Colletotrichum
gloeosporioides (Penz.) Penz. & Sacc. in Penz. (Redlin, 2002).
Colletotrichum gloeosporioides is widely distributed in the United States
(Farr et al., 1989) and therefore, is no longer of phytosanitary concern.
Table 1. Quarantine pests that may follow the pathway on Phalaenopsis spp.
from Taiwan into the United States in an unmitigated importation as
identified in the risk assessment document (USDA, APHIS, 2003a).
Arthropods
Planococcus minor (Maskell) (Homoptera: Pseudococcidae)
Spodoptera litura (F.) (Lepidoptera: Noctuidae)
Mollusks
Acusta (=Bradybaena) tourranensis (Souleyet) and Bradybaena spp.
(Mollusca: Bradybaenidae)*
Fungi
Cylindrosporium phalaenopsidis Saw. (Fungi Imperfecti,
Coelomycetes)
Phomopsis orchidophila Cash & Watson (Fungi Imperfecti,
Coelomycetes)
Sphaerulina phalaenopsidis Saw. (Loculoascomycetes,
Dothideales)
*
For purposes of this EA, Acusta (=Bradybaena) tourranensis and Bradybaena spp. will be analyzed
together.
Host Range of Quarantine Pests: More than 10 families of plants are
listed as hosts for the mollusk Acusta tourranensis, including both
herbaceous and tree species (Lai, 1984). The host range of the mealybug,
Planococcus minor, includes more than 30 species of plants in over
10 families (Cox, 1989). The host range for Spodoptera litura includes
plants in the families Cruciferae, Rutaceae, and Fabaceae (Zhang, 1994). The
host range for Cylindrosporium phalaenopsidis and Sphaerulina
phalaenopsidis is assumed to be only Phalaenopsis (USDA, APHIS, 2003a).
The host range for Phomopsis orchidophila includes only species of
6
Catasetum, Cattleya, Coelogyne, Cymbidium, and Phalaenopsis (Uecker,
1988).
Climate–Host Interaction: The mollusk, A. tourranensis, has a tropical
distribution (Lai, 1984) that corresponds to no more than three climatic zones
(USDA, APHIS, 2003a). The mealybug P. minor occurs in regions
represented by no more than three subtropical plant hardiness zones in the
United States (USDA, APHIS, 2003a). The moth S. litura occurs over a
wide range of climates and may establish in four or more plant hardiness
zones. The geographical distribution of P. orchidophila includes Taiwan,
South America, Mexico, Guatemala, Puerto Rico, India, Australia, and the
Pacific Islands (Uecker, 1988). The climatic ranges for C. phalaenopsidis
and S. phalaenopsidis are assumed to be similar (USDA, APHIS, 2003a).
Threatened and Endangered Species: There is no direct evidence that
any endangered, threatened, proposed, or candidate species are hosts of the
quarantine pests identified as likely to be included in the unmitigated
importation of Phalaenopsis spp. orchids from Taiwan. The two insect pests,
P. minor and S. litura, have hosts that are congeneric (occur within the same
genus) with federally listed endangered, threatened, and candidate species
(table 2). No hosts of the pathogens identified in the risk assessment are
congeneric with any federally listed endangered, threatened, proposed, or
candidate species. It should be noted that there is a level of uncertainty in the
congeneric approach; simply because a listed plant occurs within the same
genus as known hosts of the identified quarantine pests represents a possible,
not a probable potential harm to these species.
Orchid species native to the United States that may be affected (as a result of
habitat invasion) by the importation of moth orchids from Taiwan include
Cranichis ricartii and Lepanthes eltoroensis (endangered, PR), Platanthera
holochila (endangered, HI), Spiranthes delitescens (endangered, AZ), Piperia
yadonii (proposed endangered, CA), Isotria medeoloides (threatened, CT,
DC, DE, GA, IL, MA, MD, ME, MN, MS, NC, NH, NJ, NY, PA, RI, SC,
TN, VA, and VT), Spiranthes diluvialis (threatened, ID, CO, MT, NV, and
UT), and Anoectochilus sandvicensis and Liparis hawaiiensis (species of
concern, HI).
7
Table 2. Listed and candidate species that may be adversely affected by pests
imported with moth orchids from Taiwan.*
Listed species
Status
Range
Amaranthus brownii
A. pumilus
E
T
HI
DE, MA, MD, NC,
NJ, NY, RI, SC
Cucurbita okeechobeensis
ssp. okeechobeensis
E
FL
Cyperus trachysanthos
E
HI
Euphorbia haeleeleana
E. telephioides
E
T
HI
FL
Helianthus eggertii
H. paradoxus
H. schweinitzii
H. verticillatus
T
T
E
C
AL, KY, TN
NM, TX
NC, SC
AL, GA, TN
Justicia cooleyi
E
FL
Manihot walkerae
E
TX, MX
Rhus michauxii
E
GA, NC, SC, VA
Solanum drymophilum
S. incompletum
S. nelsonii
S. sandwicense
E
E
C
E
PR
HI
HI
HI
Verbena californica
T
CA
Vigna o-wahuensis
E
HI
Ziziphus celata
E
FL
Apios priceana
T
AL, IL, KY, MS, TN
Allium munzii
E
CA
Linum arenicola
L. carteri carteri
C
C
FL
FL
Manihot walkerae
E
TX, MX
Trifolium ameonum
T. stoloniferum
E
E
CA
AR, IL, IN, KS, KY,
MO, OH, WV
CA
T. trichocalyx
E
Vigna o-wahuensis
E
Pest with a host in
the same genus as
the listed species
Planococcus minor
Spodoptera litura
HI
* Each listed plant is congeneric with a host of a quarantine pest (identified in the risk assessment as
likely to follow the pathway in an unmitigated importation of Phalaenopsis). There are no proposed
species identified because there are none that correspond to genera of pest hosts (USDA, APHIS,
2002b).
8
IV. Potential Environmental Impacts of the
Proposed Action and Alternatives
A.
Potential Environmental Impacts Common to Both
Alternatives
The following environmental impacts would apply for either alternative
should the pests identified in table 1 be imported with either bare rooted
Phalaenopsis orchids (no action alternative) or with Phalaenopsis orchids in
growing media (proposed rule) and establish in the United States.
Potential Invasiveness of Imported Phalaenopsis: No reports of
invasiveness of Phalaenopsis spp. have been observed in key references
recognized as standards (WSSA, 2002; Gunn and Ritchie, 1982; Holm et al.,
1979; Holm et al., 1977; and Reed, 1977). In addition, there are no reports of
invasiveness of Phalaenopsis orchids in the United States (including Hawaii
and Florida) since bare rooted importations have been allowed to enter the
country. The importation of orchids into the United States has occurred for
decades, and they are shipped to all known habitats. The PLANTS database
(<http://plants.usda.gov>) and other weed reporting services do not include
reports of imported moth orchids as invasive or having weed potential.
Reports of orchids as weeds include Monadenia bracteata in Australia,
which grows well in disturbed sites and flowers more abundantly after fire
(Bates, 2002). An orchid recently identified as Eulophia graminea also is
reported as an invasive species in Australia (Macrae, 2002). The introduced
Epipactis helliborine is an orchid with few growth requirements (high
environmental plasticity) that grows as a weed across much of the eastern
United States (Anonymous, 1997). These characteristics differ from the
basic biology of Phalaenopsis; therefore, the moth orchids are not expected
to become invasive.
In Australia and the Hawaiian islands, the orchid Epidendrum o’brienianum
is reported as invasive, and in pine and spruce plantations in Europe the
boreal orchids Goodyera repens and Listera cordata are spreading
(Adamowski, 1999). There is also a report that the African species
Oeceoclades maculata is invasive in Southern and Central America
(Adamowski, 1999). These invasive orchids share the following
characteristics: quick development, self-pollination (autogamy), asexual
reproduction through seeds (apomixis), wide ecological amplitudes, and
broad natural distribution (Adamowski, 1999). The genus Phalaenopsis is
9
broadly distributed in Asia (Bailey and Bailey, 1976) but does not share any
of the other characteristics.
The climate that favors Phalaenopsis is replicated in greenhouses and indoor
environments (not less than 65 °F and either a humid atmosphere or unfailing
moisture at the roots (Bailey and Bailey, 1976)) within most of the
continental United States, which creates environmental and spatial barriers to
plant introduction into native ecosystems. Moth orchids are native to Asia,
the Malay archipelago, and Oceania (Bailey and Bailey, 1976). Although
plants may be discarded, there is no evidence that these discards have the
capacity to over-season out-of-doors outside of tropical and semi-tropical
areas.
Moth orchids are epiphytes or rock-dwelling herbs (Bailey and Bailey, 1976).
The physical environments that favor root growth are found in osmundia
fiber or sphagnum moss (Wey et al., 2001, and Bailey and Bailey, 1976) in
pots (Griesbach, 2000). Moth orchids have light intensity requirements
(Konow and Wang, 2001, and Wang, 1995) in addition to nutrition (Wang,
1998; Duan and Yazawa, 1995; and Wang and Gregg, 1994) and mycorrhizal
requirements (Clements, 1988). This means that a favorable combination of
many factors is needed for moth orchids to grow. This contrasts with the
habits of plants that tend to become problematic as invasive species (Mooney
and Hobbs, 2000; Cox, 1999; Zimdahl, 1999; Devine, 1998; and Radosevich
et al., 1997). For these reasons, it is unlikely that Phalaenopsis species will
become invasive in the future.
Potential negative effects to listed members of the Orchidaceae are not
expected because the host ranges for the quarantine pests do not overlap or
are not within the same genus (congeneric) as Phalaenopsis. The listed
species Isotria medeoloides occurs in many places within the continental
United States and is primarily threatened by loss of habitat (NatureServe,
2002). This contrasts with Phalaenopsis which requires temperatures greater
than 65 °F and either a humid atmosphere or unfailing moisture at the roots
(Bailey and Bailey, 1976). Similarly, the listed species Platanthera
leucophaea occurs in colder climates such as Iowa, Illinois, Indiana,
Missouri, New York, Ohio, Pennsylvania, Oklahoma, Virginia, and
Wisconsin (NatureServe, 2002). The taxonomically related P. praeclara also
occurs in areas likely to be too cold for moth orchids such as Iowa, Kansas,
Minnesota, Missouri, Nebraska, North Dakota, and Oklahoma (NatureServe,
2002).
The listed species Spiranthes diluvialis, which was originally known from
only Colorado, Utah, and Nevada, is now reported to also occur in Wyoming,
Montana, Nebraska, and Idaho where the temperatures are unlikely to support
10
Phalaenopsis, even though S. diluvialis grows in lower-elevation wet
meadow habitats (NatureServe, 2002). In contrast, the listed species
Spiranthes delitescens occurs in Arizona (NatureServe, 2002), where the
climate is likely to be too dry for moth orchids to survive out-of-doors
(Bailey and Bailey, 1976). Spiranthes parksii is reported as variable and
robust, exhibiting hybrid vigor because it is believed to be either a polyploid
member of the S. cernua complex or it is a nonpersisting hybrid of S. lacera
var. gracilis and S. cernua (NatureServe, 2002). It occurs in open, grassy
woodland sites in Texas that are likely to be exposed to heavy cattle grazing
(NatureServe, 2002). The soil types that support grassy woodlands are
unlikely to be able to provide the physical and nutritional requirements of
moth orchids which are either epiphytes or (less commonly) rock-dwelling
herbs (Bailey and Bailey, 1976).
The two endangered species found in Puerto Rico, Cranichis ricartii and
Lepanthes eltoroensis, along with the Hawaiian Platanthera holochila occur
in climates similar to those preferred by moth orchids with respect to
temperature and moisture (NatureServe, 2002). While the risk of
Phalaenopsis becoming established out-of-doors in those areas is increased,
the ability of this genus to grow at high altitudes has not been reported. It is
unlikely that seed from moth orchids will be dispersed into the remote high
altitude habitats of the two Puerto Rican orchids (FWS, 1992). There is no
evidence that Phalaenopsis species can grow in raised hummocks of fine
organic mold in large bogs (montane bog) which is the habitat for the
Hawaiian Platanthera holochila (NatureServe, 2002, and Anonymous, 2003).
Lack of habitat does not appear to limit P. holochila (NatureServe, 2002), so
it is unlikely that moth orchids would compete with this plant for habitat.
Consequences of Pest Introduction: Several arthropod pests (P.
minor and S. litura), mollusks (A. tourranensis and other Bradybaena spp.),
and fungi (C. phalaenopsidis, P. orchidophila, and S. phalaenopsidis) were
identified as quarantine pests likely to be imported with unmitigated
shipments of Phalaenopsis spp. moth orchids, possibly requiring
phytosanitary measures to mitigate risk.
Insects: Although distributed in the U.S. Virgin Islands (ScaleNet,
2002, (<http://www.sel.barc.usda.gov/scalenet/scalenet.htm>), there has been
only one interception of the mealybug, P. minor, on Phalaenopsis spp.
(USDA, APHIS, 2003b). Mealybug crawlers readily move from plant to
plant among closely placed plants. The host range of P. minor includes more
than 30 species in over 10 families (Cox 1989). S. litura causes major
damage to tobacco, cotton, chilies, cabbage, and other crops and has a host
range of at least 120 species (CPC, 2002). Most damage by S. litura is
caused by larval foliar feeding, but larvae may also injure cotton bolls and
11
corn stalks and ears. This insect has high dispersal capability and potential
for a high level of economic impact if it were to become established in the
United States.
Mollusks: The mollusks Bradybaena spp. and A. tourannensis are
snails that chew holes in foliage, flowers, and fruit, especially in greenhouses.
There are no reports of populations of A. tourannensis established from
the importation of bare rooted Phalaenopsis plants into the continental
United States to date, and it is rarely intercepted on these plants. However,
snails are spread in commerce, and due to their hermaphroditism (both sexes
within one individual), one snail can start a population (Godan, 1983). More
than 10 families of plants are listed as hosts for A. tourannensis, including
both herbaceous and tree species (Lai, 1984). If this pest established, it
would be likely to disrupt unmanaged ecosystems in the subtropical areas of
Hawaii, Florida, and other climatically similar areas (USDA, APHIS, 2003a).
Bradybaena similaris (Ferussac), a tropical species from China, already
exists in Hawaii and Louisiana (Burch, 1962). A. tourannensis, present in
southern Taiwan, has not spread to other areas of Asia, indicating low natural
dispersal capabilities may exist (Wu, 1982).
Pathogens: In the 1997 risk assessment document, the host range
for the pathogens C. phalaenopsidis and S. phalaenopsidis was assumed to be
only Phalaenopsis, and there is no evidence to the contrary as of this date.
Spores may be splashed by irrigation or rain onto nearby hosts or carried by
insects, animals, and humans moving among plants. P. orchidophila is
reported on the stems and leaves of species of Catasetum, Cattleya,
Coelogyne, Cymbidium, and Phalaenopsis (Uecker, 1988). Fungi in this
genus produce air-dispersed spores that are not likely to be dispersed over
long distances (USDA, APHIS, 2003a). Typically, leaf-spot causing
pathogens, such as C. phalaenopsidis, P. orchidophila, and S.
phalaenopsidis, reduce visual quality and decrease the value of ornamental
crops and reduce available photosynthetic area and plant vigor. It is not
reasonable to assume that these fungi will infect host plants ad infinitum
USDA, APHIS, 2003a).
B. Risk Management
Although the affected environment and the environmental consequences
under both the no action alternative and the proposed action alternative are
the same, the risk management to prevent the introduction of pests differs
between the two alternatives. The following section discusses the
phytosanitary measures imposed under the current importation scheme of
bare rooted Phalaenopsis spp. orchids (no action alternative) and the
12
proposed phytosanitary measures for imports of these plants in growing
media (preferred alternative).
Phytosanitary Measures of Alternative A: No Action
This section describes the phytosanitary measures of the no action alternative
that would leave 7 CFR part 319 unchanged. Currently, Phalaenopsis and
other orchids are imported as bare rooted plants or growing on tree fern slabs
or in coconut husk or fiber (7 CFR § 319.37–8(d)). All forms are enterable
subject to inspection findings at designated ports of entry, i.e., ports
associated with facilities where propagative material can be examined (plant
inspection stations). All orchid consignments must be accompanied by a
USDA permit and a phytosanitary certificate issued by BAPHIQ. This
document certifies that the orchids have been inspected and found free of
quarantine pests before shipment to the United States. No special growing
conditions are required for these plants. Phalaenopsis spp. plants imported
bare rooted generally do not have buds or flowers and roots are not hidden
from view within growing media, and thus, visual inspection of these plants
at the port of entry is effective.
Inspection of bare rooted orchid consignments are conducted by PPQ at a
plant inspection station at the first port of entry in the United States. These
stations are staffed with PPQ pest identification specialists as well as PPQ
officers who carefully examine orchid consignments. Inspection and
examination may be limited to a verification of the contents and a review of
the documentation or may consist of a standard inspection, including an
inspection of up to 2 percent of the plants in the shipment. If quarantine pests
are discovered on bare rooted orchid consignments, appropriate phytosanitary
measures are conducted (e.g., treatment, destruction, return of consignments
to exporting country).
Phytosanitary Measures of Alternative B: Amend Regulations
According to the Proposed Rule
This section describes the phytosanitary measures required if Phalaenopsis
spp. plants in approved growing media are imported into the United States
from Taiwan. Amending 7 CFR part 319 according to the proposed rule
would allow importation of Phalaenopsis spp. moth orchids from Taiwan
rooted in approved growing media, provided the orchids were produced,
handled, and imported in accordance with the requirements of 7 CFR
§ 319.37-8(e) and are accompanied at the time of importation by a
phytosanitary certificate issued by BAPHIQ declaring that those requirements
have been met.
13
Systems Approach: To effectively prevent the introduction of plant pests
associated with plants grown in approved media, a series of important
safeguards, conditions, or phytosanitary measures must be in place. The risk
management program used for plants in media is the systems approach, a
defined set of phytosanitary procedures, at least two of which have an
independent effect in mitigating pest risk associated with the movement of
commodities. This approach relies on a series of phytosanitary measures that
individually and cumulatively reduce the pest risk posed by pests that may be
associated with plants. All phases associated with plants established in
growing media—before planting, during the growing period, post harvest,
during transport, and importation—are considered. The APHIS regulation on
plants in media requires multiple phytosanitary measures designed to reduce
the pest risk. The overall systems approach operates like a fail-safe system in
that tiered safeguards are built into the process. That is, if one mitigating
measure fails, other safeguards exist to ensure that the risk is progressively
reduced and managed. The systems approach is designed to apply all the
measures to obtain the maximum risk reduction and to apply additional
safeguards as required. The steps or measures may be overlapping or
redundant to assure an adequate reduction in pest risk and that the reduction
is maintained during the entire process. These measures would be applied to
the importation of Phalaenopsis spp. orchids from Taiwan in approved
growing media.
Approved Plant Sources: The orchids imported into the United States
will be greenhouse- or laboratory-propagated plants or may be propagated
in the laboratory from aseptic tissue culture. Wild or collected specimens
or nondomesticated plants are not approved for importation into the
United States. The plants must come from pest-free mother stock, as
determined by a PPQ or BAPHIQ inspector, no more than 60 days prior to
the time the plants are established in the greenhouse.
Approved Growing Media: Plants offered for importation into the
United States must be free of sand, soil, earth, and other unapproved growing
media. This requirement helps prevent the introduction of plant pests that
might be present in and around the roots and also eliminates many soil and
root associated saprophytic organisms. Exceptions to the growing media
requirement reflect additional factors that mitigate plant pest risk. Those
exceptions consider either the origin of the plants and the growing media
(7 CFR § 319.37–8(b)), the nature of the growing media (§§ 319.37–8(c),
(d)), or the use of a combination of growing conditions, approved media,
inspections, and other requirements (§ 319.37–8(e)). Soil-less and new,
unused growing media eliminates an initial source for pests, including A.
tourranensis. The relatively low pH of sphagnum is associated with
14
conditions that do not favor bacterial and some types of fungal growth.
Studies on APHIS-approved growing media found that pathogens are not
present (Palm, 1994 and Santacroce, 1991).
Agreements: The orchids must be grown in accordance with written
enforcement agreements among APHIS, BAPHIQ, and Taiwanese growers.
This will include the preparation of an operational workplan that outlines
specific detection and eradication protocols to detect problem pests and
eliminate them before the orchids are exported to the United States. The
workplan also outlines how the program will be monitored and supervised to
ensure compliance. Taiwanese orchid growers who plan to export moth
orchids in growing media must be registered with BAPHIQ; any grower not
complying with the workplan requirements will be eliminated from the
program.
Exclusionary Greenhouse: The orchids for shipment must be grown in
a pest exclusionary greenhouse using the following phytosanitary measures:
“Grown solely in a greenhouse in which sanitary procedures are adequate to
exclude plant pests and diseases are always employed, including cleaning and
disinfection of floors, benches, and tools, and the application of measures to
protect against any injurious plant diseases, and injurious insect pests, and
other plant pests” (7 CFR § 319.37–8(e)(2)(ii)). These measures may include
trapping, surveying, and scouting to determine if pests are present, and
pesticide applications or other control measures to eliminate pests that are
discovered.
Raised Benches: The height of the benches on which the orchids are
grown must be at least 46 cm above the floor. Raised benches reduce the
chance of water being splashed onto benches from the floors that might be
contaminated with nematodes, pathogens, and weed seeds. Also, because
snails and slugs have the capability to climb up sidings and posts, higher
benches make it difficult for snails and slugs to climb and decrease the
chances that such pests will invade the plants and media.
Floors: Greenhouse floors must be completely void of soil and composed
of permanent material that can be cleaned and sanitized to destroy pathogens
and nematodes and prevent establishment of weeds.
Automatic Doors: Automatic closing doors are required to exclude flying
insects from entering the growing area. They are also used to a limited extent
to keep windborne pests from being blown into the growing area.
15
Screens: Greenhouses have vents or openings principally for the exchange
of outside air and for temperature control. The addition of screens to these
openings lowers the risk of certain pests entering the greenhouse. Screens
must have openings no larger than 0.6 mm. Screens with 0.6 mm openings
do not exclude all pests; however, they will act as a deterrent or barrier to
many pests including S. litura.
Sanitation: Sanitary procedures must be used to maintain the greenhouse
relatively free of pests. A suitable disinfectant should be employed to
sanitize the greenhouse interior prior to plantings to reduce pathogens,
nematodes, and other pests. These procedures should also include keeping
tools, hoses, benches, floors, work areas, and floor benches clean and
properly sanitized. The grower should maintain a record of the times
disinfection takes place.
Detention Periods: Plant materials are commonly detained to allow time
for certain pests to develop and become visible and detectable. Mother stock
orchids must be grown in Taiwan for at least 9 months prior to export of
descendant orchids to the United States. Mother plants imported into Taiwan
from another country must be grown at least 12 months in Taiwan prior to the
export of descendant orchids to the United States. The growing period can be
reduced to 9 months as above, provided there is a prescribed treatment of the
mother stock upon importation of that plant into Taiwan. Descendant plants
in media must be rooted and grown in an active state of foliar growth for at
least 4 consecutive months prior to export. Detention periods are necessary
to allow ample time for the expression of disease, symptoms, and other signs
of pests.
Clean Water Sources: The water source must be either rainwater that has
been boiled or pasteurized, clean well water, or potable (municipal) water.
Water is considered one of the principal means for the dispersal of plant
pests, including pathogens and mollusks, and water from clean sources must
be used throughout the entire system.
Phytosanitary Certificate: A phytosanitary certificate must be issued by
BAPHIQ. This document, that must accompany the plants during
importation, certifies that the required growing conditions were met.
Inspection: Inspections are an integral phytosanitary measure to reduce
pest risk. In growing areas in Taiwan, inspection of Phalaenopsis spp.
orchids in growing media is primarily the responsibility of BAPHIQ.
Whenever pests of quarantine significance are found during inspection,
16
appropriate action must be taken promptly as outlined in the operational
workplan.
Mother stock must be inspected by a PPQ or BAPHIQ inspector no more
than 60 days prior to the time the orchids are established in the greenhouse
and found free of evidence of diseases and insect pests. The rationale is to
inspect the mother stock in advance to ensure a pest-free source of plant
material used for descendant plants. Inspection may take place at any time
within the 60-day period. Inspection of mother stock is a primary measure to
prevent the introduction of pests such as mollusks, insects, and pathogens
into greenhouse crops.
For descendant plants, an inspection must be performed no more than
30 days prior to the date of export and must be done on the premises or site
where the orchids are grown to prevent contaminants and hitchhikers from
entering the shipment. Because the roots cannot be visually examined while
they are in growing media, a small number of plants will be removed from
the media to examine the roots and inside of the media ball.
APHIS inspectors will visit Taiwan periodically to ensure that the program
is working adequately, including review of treatment and control records
generated by registered Taiwanese growers.
At the port of entry in the United States, inspection of orchid consignments
will be conducted by PPQ at plant inspection stations. These stations are
staffed with PPQ pest identification specialists as well as PPQ officers who
will carefully examine orchid consignments. Generally, initial consignments
from a newly approved importation program (such as would be orchids in
approved growing media) are subjected to extremely rigorous inspections that
include removal of plants from pots to examine roots and growing media.
Later, the inspection and examination may be limited to a verification of the
contents and a review of the documentation or may consist of a standard
inspection of at least 2 percent of the plants in the consignment, including
roots and growing media. Standard inspection techniques are highly likely to
detect larger mature and juvenile forms of the mollusk, A. tourranensis,
present on plants (Robinson, 2002). Small eggs in soil are highly likely to
escape detection; however, plants produced in APHIS-approved growing
media under pest-exclusionary conditions are expected to be free of mollusk
eggs. Standard visual inspection techniques are not likely to detect
microscopic crawler stages of the mealybug P. minor although adults are
easily detected. The larvae of S. litura can be up to 45 mm in length and are
on plant surfaces where they are readily detected, although eggs hidden
between leaves, in media, or within flowers are more difficult to detect. The
pathogens C. phalaenopsidis, P. orchidophila, and S. phalaenopsidis infect
17
leaves causing leaf spots that are easy for trained inspectors to detect. Latent
infections are more difficult to detect. However, plants produced in
APHIS-approved growing media under pest-exclusionary conditions are
expected to be free of these pests.
If interceptions of quarantine pests are made on a large portion of orchid
consignments or if a single quarantine pest is detected often, PPQ will require
more specific mitigation against the pest(s) of concern. Registered
greenhouses in Taiwan will allow specific problem greenhouses or growers
to be easily identified. In addition, if quarantine pests are discovered on moth
orchid consignments at the port of entry, appropriate phytosanitary measures
will be conducted (e.g., treatment, destruction, or return of consignment to
exporting country).
Packing and Storing: Plants for export must be packed and stored in
areas free of sand, soil, earth, and plant pests. Packages should be such to
prevent contamination and the introduction of hitchhikers. Phalaenopsis
plants shall not be packed in the same container as prohibited articles.
Conclusions
The program has determined that quarantine pests are effectively removed
from the pathway and effectively precluded from establishment in the
United States by the mitigation measures already present in the applicable
regulations. The importation of moth orchids (Phalaenopsis spp.) from
Taiwan under the conditions required by 7 CFR § 319.37–8(e) poses no
greater pest risks than the risks presented by other epiphytic orchid material
currently allowed entry as bare rooted plants. The application of additional
safeguards will reduce the risk posed by the importation of Phalaenopsis spp.
moth orchids to a low level, that will be the same level or below that posed
by currently permitted bare rooted importations (USDA, APHIS, 2002b).
If quarantine pests accompanying Phalaenopsis shipments were to become
established in the United States, an eradication program would likely be
initiated. Although eradication of any nonindigenous pest would require
the use of pesticides, APHIS would prepare the necessary environmental
documentation under the National Environmental Policy Act (NEPA) and
the Endangered Species Act (ESA) in advance of any eradication activities.
18
Other Environmental Statutes and Executive Orders
Endangered Species Act
Section 7 of the ESA and the ESA’s implementing regulations require
Federal agencies to consult with the U.S. Fish and Wildlife Service (FWS)
and/or the National Marine Fisheries Service to ensure that their actions are
not likely to jeopardize the continued existence of endangered or threatened
species or result in the destruction or adverse modification of critical habitat.
APHIS submitted a biological evaluation (BE) (USDA, APHIS, 2002b) to
FWS, Arlington, VA, in compliance with Section 7 of the ESA. Based on
the information provided in the BE and additional supporting documentation,
FWS concurred with the APHIS’ determination that the importation of
Phalaenopsis spp. orchids from Taiwan will not adversely affect federally
listed or proposed endangered or threatened species or their habitats.
Executive Orders
Executive Order (EO) 12898, "Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income Populations," focuses
Federal attention on the environmental and human health conditions of
minority and low-income communities and promotes community access to
public information and public participation in matters relating to human
health or the environment. The executive order requires Federal agencies to
conduct their programs, policies, and activities that substantially affect
human health or the environment in a manner so as not to exclude persons
and populations from participation in or benefitting from such programs. It
also enforces existing statutes to prevent minority and low-income
communities from being subjected to disproportionately high and adverse
human health or environmental effects. Neither alternative poses
disproportionately high or adverse human health or environmental effects
to any specific minority or low-income group.
EO 13045, “Protection of Children from Environmental Health Risks and
Safety Risks,” acknowledges that children may suffer disproportionately
from environmental health and safety risks because of their developmental
stage, greater metabolic activity levels, and behavior patterns, as compared
to adults. The EO (to the extent permitted by law and appropriate, and
consistent with the agency’s mission) requires each Federal agency to
consider environmental health risks and safety risks that may
disproportionately affect children. Neither alternative is expected to have
19
disproportionately high or adverse human health or environmental effects to
children.
20
V. Listing of Agencies and Persons
Consulted
Environmental Services
Policy and Program Development
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
4700 River Road, Unit 149
Riverdale, MD 20737–1238
Phytosanitary Issues Management
Plant Protection and Quarantine
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
4700 River Road, Unit 140
Riverdale, MD 20737–1228
Regulatory Coordination
Plant Protection and Quarantine
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
4700 River Road, Unit 141
Riverdale, MD 20737–1228
21
VI. Literature Cited
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26
§ 319.37–8
7 CFR Ch. III (1–1–03 Edition)
7734, or other applicable Federal statutes.
(g) State. As used in this section,
‘‘State’’ means each of the 50 States of
the United States, the District of Columbia, Guam, Northern Mariana Islands, Puerto Rico, the Virgin Islands
of the United States, and all other territories and possessions of the United
States.
(Approved by the Office of Management and
Budget under control number 0579–0049)
[45 FR 31585, May 13, 1980; 45 FR 35305, May
27, 1980, as amended at 45 FR 81531, Dec. 11,
1980; 48 FR 57466, Dec. 30, 1983; 57 FR 43148,
43150, Sept. 18, 1992; 58 FR 38267, July 16, 1993;
58 FR 41124, Aug. 2, 1993; 59 FR 67610, Dec. 30,
1994; 61 FR 51210, Oct. 1, 1996; 66 FR 21056,
Apr. 27, 2001]
§ 319.37–8 Growing media.
(a) Any restricted article at the time
of importation or offer for importation
into the United States shall be free of
sand, soil, earth, and other growing
media, except as provided in paragraph
(b), (c), (d) or (e) of this section.
(b) A restricted article from Canada,
other than from Newfoundland or from
that portion of the Municipality of
Central Saanich in the Province of
British Columbia east of the West
Saanich Road, may be imported in any
growing medium.
(c) A restricted article growing solely
in agar or in other transparent or
translucent tissue culture medium may
be imported established in such growing media.
(d) Epiphytic plants (including orchid
plants) established solely on tree fern
slabs, coconut husks, or coconut fiber
may be imported on such growing
media.
(e) A restricted article of any of the
following groups of plants may be imported established in an approved
growing medium listed in this paragraph, if the article meets the conditions of this paragraph, and is accompanied by a phytosanitary certificate
issued by the plant protection service
of the country in which the article was
grown that declares that the article
10 These articles are bromeliads, and if imported into Hawaii, bromeliads are subject to
postentry quarantine in accordance with
§ 319.37–7.
meet the conditions of this paragraph:
Alstroemeria, Ananas,10 Anthurium, Begonia,
Gloxinia
(=
Sinningia),
Nidularium,11
Peperomia,
Polypodiophyta (= Filicales) (ferns),
Rhododendron
from
Europe,
and
Saintpaulia.
(1) Approved growing media are
baked expanded clay pellets, cork,
glass wool, organic and inorganic fibers, peat, perlite, polymer stabilized
starch, plastic particles, phenol formaldehyde, polyethylene, polystyrene,
polyurethane, rock wool, sphagnum
moss, ureaformaldehyde, vermiculite,
or volcanic rock, or any combination of
these media. Growing media must not
have been previously used.
(2) Articles imported under this paragraph must be grown in compliance
with a written agreement for enforcement of this section signed by the
plant protection service of the country
where grown and Plant Protection and
Quarantine, must be developed from
mother stock that was inspected and
found free from evidence of disease and
pests by an APHIS inspector or foreign
plant protection service inspector no
more than 60 days prior to the time the
article is established in the greenhouse
(except for articles developed from
seeds germinated in the greenhouse),
and must be:
(i) Grown in compliance with a written agreement between the grower and
the plant protection service of the
country where the article is grown, in
which the grower agrees to comply
with the provisions of this section and
to allow inspectors, and representatives of the plant protection service of
the country where the article is grown,
access to the growing facility as necessary to monitor compliance with the
provisions of this section;
(ii) Grown solely in a greenhouse in
which sanitary procedures adequate to
exclude plant pests and diseases are always employed, including cleaning and
disinfection of floors, benches and
tools, and the application of measures
to protect against any injurious plant
diseases, injurious insect pests, and
other plant pests. The greenhouse must
be free from sand and soil and must
have screening with openings of not
more than 0.6 mm (0.2 mm for greenhouses growing Rhododendron spp.) on
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Animal and Plant Health Inspection Service, USDA
all
vents
and
openings
except
entryways. All entryways must be
equipped with automatic closing doors;
(iii) Rooted and grown in an active
state of foliar growth for at least four
consecutive months immediately prior
to importation into the United States,
in a greenhouse unit that is used solely
for articles grown in compliance with
this paragraph;
(iv) Grown from seeds germinated in
the greenhouse unit; or descended from
a mother plant that was grown for at
least 9 months in the exporting country prior to importation into the
United States of the descendent plants,
provided that if the mother plant was
imported into the exporting country
from another country, it must be:
(A) Grown for at least 12 months in
the exporting country prior to importation of the descendent plants into
the United States, or
(B) Treated at the time of importation into the exporting country with a
treatment prescribed for pests of that
plant by the plant protection service of
the exporting country and then grown
for at least 9 months in the exporting
country prior to importation of the descendent plants into the United States;
(v) Watered only with rainwater that
has been boiled or pasteurized, with
clean well water, or with potable
water;
(vi) Rooted and grown in approved
growing media listed in § 319.37–8(e)(1)
on benches supported by legs and
raised at least 46 cm above the floor;
(vii) Stored and packaged only in
areas free of sand, soil, earth, and plant
pests;
(viii) Inspected in the greenhouse and
found free from evidence of plant pests
and diseases by an APHIS inspector or
an inspector of the plant protection
service of the exporting country, no
more than 30 days prior to the date of
export to the United States;
(ix) For Rhododendron species only,
the plants must be propagated from
mother plants that have been visually
inspected by an APHIS inspector or an
inspector of the plant protection service of the exporting country and found
free of evidence of diseases caused by
the following pathogens: Chrysomyxa
ledi
var.
rhododendri,
Erysiphe
cruciferarum,
Erysiphe
rhododendri,
§ 319.37–8
Exobasidium vaccinnum and vaccinum
var. japonicum, and Phomopsis theae;
and
(x) For Rhododendron species only,
the plants must be grown solely in a
greenhouse equipped with automatic
closing double doors of an airlock type,
so that whenever one of the doors in an
entryway is open the other is closed,
and the plants must be introduced into
the greenhouse as tissue cultures or as
rootless stem cuttings from mother
plants that:
(A) Have received a pesticide dip prescribed by the plant protection service
of the exporting country for mites,
scale insects, and whitefly; and
(B) Have been grown for at least the
previous 6 months in a greenhouse that
meets the requirements of § 319.37–
8(e)(2)(ii).
(f) A restricted article of Hyacinthus
spp. (hyacinth) may be imported established in unused peat, sphagnum moss,
or vermiculite growing media, or in
synthetic growing media or synthetic
horticultural foams, i.e., plastic particles, glass wool, organic and inorganic
fibers,
polyurethane,
polystyrene, polyethylene, phenol formaldehyde, or ureaformaldehyde:
(1) If there is a written agreement between Plant Protection and Quarantine
and the plant protection service of the
country where the article is grown in
which the plant protection service of
the country where the article is grown
agrees to implement a program in compliance with the provisions of this section;
(2) If there is a written agreement between the grower of the article and the
plant protection service of the country
in which the article is grown wherein
the grower agrees to comply with the
provisions of this section, wherein the
grower agrees to allow an inspector access to the growing facility as necessary to monitor compliance with the
provisions of this section, and wherein
the grower agrees to allow representatives of the plant protection service of
the country in which the article is
grown access to the growing facility as
necessary to make determinations concerning compliance with the provisions
of this section;
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§ 319.37–8
7 CFR Ch. III (1–1–03 Edition)
(3) If: (i) Inspected immediately prior
to the growing period by the plant protection service of the country in which
the article is to be grown and found to
be free of injurious plant diseases, injurious insect pests, and other plant
pests;
(ii) Grown throughout its growing period only in a coldroom (with temperatures not exceeding 9 °C. (48 °F.)) within an enclosed building;
(iii) Grown only in a coldroom unit
solely used for articles grown under all
the criteria specified in this paragraph
(f);
(iv) Grown only in unused peat,
sphagnum moss, or vermiculite growing media; or grown only in synthetic
growing media or synthetic horticultural foams, i.e., plastic particles,
glass wool, organic and inorganic fibers, polyurethane, polystyrene, polyethylene,
phenol
formaldehyde,
ureaformaldehyde;
(v) Watered only with clean rainwater that has been pasteurized, with
clean well water, or with potable
water;
(vi) Grown in a coldroom free of sand,
soil, or earth;
(vii) Grown only in a coldroom where
strict sanitary procedures are always
practiced, i.e., cleaning and disinfection of floors and tools and the application of measures to protect against any
injurious plant diseases, injurious insect pests, and other plant pests; and
(viii) Stored only in areas found free
of sand, soil, earth, injurious plant diseases, injurious insect pests, and other
plant pests;
(4) If appropriate measures have been
taken to assure that the article is to be
stored, packaged, and shipped free of
injurious plant diseases, injurious insect pests, and other plant pests;
(5)
If
accompanied
by
a
phytosanitary certificate of inspection
containing an accurate additional declaration from the plant protection
service of the country in which grown
that the article meets conditions of
growing, storing, and shipping in compliance with 7 CFR 319.37–8(f); and
(6)
If
the
accompanying
phytosanitary certificate of inspection
is endorsed by a Plant Protection and
Quarantine inspector in the country of
origin or at the time of offer for impor-
tation, representing a finding based on
monitoring inspections that the conditions listed above are being met.
(g) Pest risk evaluation standards for
plants established in growing media.
When evaluating a request to allow importation of additional taxa of plants
established in growing media, the Animal and Plant Health Inspection Service will conduct the following analysis
in determining the pest risks associated with each requested plant article
and in determining whether or not to
propose allowing importation into the
United States of the requested plant
article.
(1) Collect commodity information. (i)
Determine the kind of growing medium, origin and taxon of the regulated
article.
(ii) Collect information on the method of preparing the regulated article
for importation.
(iii) Evaluate history of past plant
pest interceptions or introductions (including data from plant protection
services of foreign countries) associated with each regulated article.
(2) Catalog quarantine pests. For the
regulated article specified in an application, determine what plant pests or
potential plant pests are associated
with the type of plant from which the
regulated article was derived, in the
country and locality of origin. A plant
pest that meets one of the following
criteria is a quarantine pest and will be
further evaluated in accordance with
paragraph (g)(3) of this section:
(i) Non-indigenous plant pest not
present in the United States;
(ii)
Non-indigenous
plant
pest,
present in the United States and capable of further dissemination in the
United States;
(iii) Non-indigenous plant pest that is
present in the United States and has
reached probable limits of its ecological range, but differs genetically from
the plant pest in the United States in a
way that demonstrates a potential for
greater damage potential in the United
States;
(iv) Native species of the United
States that has reached probable limits
of its ecological range, but differs genetically from the plant pest in the
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Animal and Plant Health Inspection Service, USDA
United States in a way that demonstrates a potential for greater damage potential in the United States; or
(v) Non-indigenous or native plant
pest that may be able to vector another plant pest that meets one of the
criteria in (g)(2)(i) through (iv) of this
section.
(3) Conduct individual pest risk assessments. Each of the quarantine pests
identified by application of the criteria
in paragraph (g)(2) of this section will
be evaluated based on the following estimates:
(i) Estimate the probability the quarantine pest will be on, with, or in the
regulated article at the time of importation;
(ii) Estimate the probability the
quarantine pest will survive in transit
on the regulated article and enter the
United States undetected;
(iii) Estimate the probability of the
quarantine pest colonizing once entered into the United States;
(iv) Estimate the probability of the
quarantine pest spreading beyond the
colonized area; and
(v) Estimate the actual and perceived
economic, environmental and social
damage that would occur if the quarantine pest is introduced, colonizes,
and spreads.
(4) Determine overall estimation of risk
based on compilation of component estimates. This step will evaluate whether
the pest risk of importing a regulated
article established in growing media,
as developed through the estimates of
paragraph (g)(3) of this section, is
greater than the pest risk of importing
the regulated article with bare roots as
allowed by § 319.37–8(a).
(i) If the pest risk is determined to be
the same or less, the regulated article
established in growing media will be
allowed importation under the same
conditions as the same regulated article with bare roots.
(ii) If the pest risk is determined to
be greater for the regulated article established in growing media, APHIS will
evaluate available mitigation measures
to determine whether they would allow
safe importation of the regulated article. Mitigation measures currently in
use as requirements of this subsection,
and any other mitigation methods relevant to the regulated article and
§ 319.37–9
plant pests involved, will be compared
with the individual pest risk assessments in order to determine whether
requiring particular mitigation measures in connection with importation of
the regulated article would reduce the
pest risk to a level equal to or less
than the risk associated with importing the regulated article with bare
roots as allowed by § 319.37–8(a). If
APHIS determines that use of particular mitigation measures could reduce the pest risk to this level, and determines that sufficient APHIS resources are available to implement or
ensure implementation of the appropriate mitigation measures, APHIS
will propose to allow importation into
the United States of the requested regulated article if the appropriate mitigation measures are employed.
[45 FR 31585, May 13, 1980, and 47 FR 3087,
Jan. 22, 1982, as amended at 57 FR 43151, Sept.
18, 1992; 60 FR 3077, Jan. 13, 1995; 61 FR 51210,
Oct. 1, 1996; 64 FR 66716, Nov. 30, 1999]
§ 319.37–9
Approved packing material.
Any restricted article at the time of
importation or offer for importation
into the United States shall not be
packed in a packing material unless
the plants were packed in the packing
material immediately prior to shipment; such packing material is free
from sand, soil, or earth (except for
sand designated below); has not been
used previously as packing material or
otherwise; and is listed below:
Baked or expanded clay pellets.
Buckwheat hulls.
Coral sand from Bermuda, if the article
packed in such sand is accompanied by a
phytosanitary certificate of inspection
containing an accurate additional declaration from the plant protection service of
Bermuda that such sand was free from soil.
Excelsior.
Exfoliated vermiculite.
Ground cork.
Ground peat.
Ground rubber.
Paper.
Perlite.
Polymer stabilized cellulose.
Quarry gravel.
Rock wool.
Sawdust.
Shavings—wood or cork.
Sphagnum moss.
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Growing dendrobium orchids in Hawaii
Pests and pest management
O
rchid growers in Hawaii wage continual battle with an increasing number of
alien pests of orchids. “Alien” pests are species that arrive in Hawaii with the
help (usually inadvertent) of humans; these immigrant organisms are also referred to as
nonnative, exotic, nonindigenous, or introduced. They can arrive in many ways, including through the violation of plant importation regulations by people who bring plants to
Hawaii without the proper approvals and inspections. Despite the best efforts of the regulatory agencies that try to protect Hawaii’s environment from alien introductions, new
pests keep coming. In each recent year, for example, the state of Hawaii has suffered the
arrival of from 10 to 28 new insects. Because of the threat to Hawaii’s environment posed
by alien organisms, imports and exports of dendrobiums are subject to various regulations requiring permits, inspections, and in some cases quarantine, as briefly described in
the chapter on the dendrobium orchid business (p. 69).
Dendrobiums and other orchids are themselves alien introductions. They might not
have found any serious pests among the organisms that were present in Hawaii before the
arrival of man, and dendrobium crops likely would be relatively pest-free, were it not for
other alien species. The alien species that qualify as pests of dendrobium orchids include
certain insects, mites, snails, birds, mammals, weeds, and disease pathogens.
Many of these aliens have become serious pests of dendrobium orchids. Most alien
pests leave their natural enemies back in their native homeland, and without these natural
enemies, the organisms often spread freely and develop large populations in Hawaii. The
Hawaii Department of Agriculture has historically attempted “classical” biological controls against serious pests, involving the deliberate introduction of specific natural enemies. It is often difficult, however, to locate effective and specific natural enemies in the
native home of the pest and to be sure that these natural enemies do not have undesirable
effects on Hawaii’s native flora.
Although most of the major alien pests of orchids have natural enemies that occur in
Hawaii, the normally monocultural orchid production environment in shadehouses and
greenhouses may encourage alien pests and discourage their natural enemies. The use of
broad-spectrum chemical insecticides especially discourages natural enemies.
In this chapter on dendrobium pests and their management, the recommendations are
intended to maximize the use of biological, cultural, and physical control measures and
minimize the use of broad-spectrum chemical pesticides. Also, an integrated pest management program should emphasize the use of “biorational” pesticides—pesticides that
are effective against insect pests but not toxic to natural enemies of the pests, not harmful
to humans, and do not cause pollution of the environment.
The alien species
that qualify as
pests of dendrobium include
insects, mites,
snails, birds,
mammals, weeds,
and disease
pathogens
Insects, mites, and other pests
Some of the pests that infest dendrobiums are illustrated in the drawing on the next page.
These and other dendrobium pests are described in detail in the following sections.
29
Growing dendrobium orchids in Hawaii
Some of the places to look for orchid pests*
Plant bugs
Thrips
Looper
Weevils
Mealybugs
Aphids
Snails
Thrips
Looper
Aphids
Plant bugs
Mites
Slugs
Mites
Weevils
Ants
Snails
Slugs
Mealybugs
30
*Pests not drawn to scale.
Insects, mites, and other pests
Growing dendrobium orchids in Hawaii
Aphids (Order: Homoptera, Family: Aphididae)
Cotton aphid, Myzus persicae (Sulzer)
Fringed orchid aphid, Cerataphis orchidearum (Westwood)
Green peach aphid, Aphis gossypii Glover
Orchid aphid, Macrosiphum luteum (Buckton)
Aphids colonize dendrobium leaves (Fig 3.1) and flowers
(Fig. 3.2). They have sucking mouthparts and feed on plant
juices causing reduced plant vigor, stunting, leaf and flower
deformities, and bud drop. Aphids are about 1⁄16 inch in size,
can be either winged or wingless, and have a pair of hornlike structures (cornicles) on the posterior end of the abdomen. Aphids excrete a sugary substance known as honeydew, which is a perfect medium for the growth of sooty mold.
In severe aphid infestations, flowers and leaves often become
covered with black sooty mold. Honeydew also serves as
food for ants and results in a symbiotic relationship that is
beneficial to both the ants and the aphids. Ants will drive off
or kill aphid parasitoids (parasites that kill their host, the 3.1. Aphids on dendrobium leaves.
aphid), and this defense results in larger aphid populations.
In Hawaii, all aphids are females that give birth to live young, which allows their population to increase rapidly. No male aphids have been observed in Hawaii due to our mild
climate.
Pest management. Beneficial insects, including ladybird beetles, lacewings, syrphid
flies, and parasitic wasps, can significantly reduce aphid populations. Parasitic wasps
cause mummified aphids (Fig. 3.3), from which adult wasps emerge. Controlling ants
that tend aphids will reduce aphid populations. Because aphids are delicate, soft bodied,
and slow moving, insecticidal soaps and ultrafine oils are effective controls. However,
soaps and oils may injure flowers and leaves of orchids (Fig. 3.4). If chemical insecticides are applied, at least two weekly applications are needed for effective control.
3.2. Aphids on a
dendrobium flower.
3.3. Mummified aphids from which parastitic wasps
emerge.
3.4. Injury to flower caused by
insecticidal soap.
31
Growing dendrobium orchids in Hawaii
Ambrosia beetles (Order: Coleoptera, Family: Scolytidae)
Black twig borer, Xylosandrus compactus (Eichoff)
The most important management
practice is removal of infested
plants or plant
parts from the
premises.
32
The black twig borer bores into the canes
of dendrobium and also attacks over 100
other species of plants in 44 families,
including cattleya, epidendrum, vanda,
anthurium, avocado, citrus, cacao, coffee, hibiscus, lychee, macadamia,
pikake, and floral ginger. Small pinholes
in the cane indicate the presence of this
pest. The area surrounding the pinhole
is usually discolored. Besides the mechanical damage caused by the beetle
boring, the associated ambrosia fungus
(Fusarium solani) is pathogenic to plant
tissue and causes discoloration and death
of the cane. Entire plant death has been
reported in severe infestations.
The black twig borer completes its
life cycle from egg to adult within the
cane. Life cycle stages include egg,
larva, pupa, and adult. Eggs are oval,
white, and laid on the ambrosia fungus
(Fig. 3.5) cultivated by the female beetle.
Larvae are white, legless grubs with distinct head capsules (Fig. 3.6) and feed
entirely on the ambrosia fungus. The
newly formed pupa is white and changes
to light brown with black wings as it
approaches maturity (Fig. 3.7). Female
beetles are shiny black and about 1⁄16 inch
long (Fig. 3.8)). The female adults
emerge from galleries and disperse by
flight in search of a suitable host to construct a new gallery. Male beetles are
brown, smaller than the female, and
flightless (Fig 3.8).
Pest management. The most important management practice is removal of
infested plants or plant parts from the
premises. Infested plants contain live
beetles. Place all infested materials in a
trash bag or a sealed container and dispose of them. This beetle is known to
attack plants that are suffering from
water, nutritional, or other stresses.
Maintain plants in good health to minimize attacks by the black twig borer.
3.5. Eggs of the black twig borer laid on ambrosia
fungus in the cane.
3.6. White, legless grubs in a gallery of the black
twig borer.
3.7. Pupae in the gallery of the black twig borer.
3.8. Adult male (left) and female (right) of the
black twig borer.
Growing dendrobium orchids in Hawaii
Caterpillars (Order: Lepidoptera, Family: Noctuidae)
Green garden looper, Chrysodeixis eriosoma (Doubleday)
(Family: Tortricidae)
Mexican leafroller, Amorbia emigratella Busck
The terms “looper” and
“leafroller” refer to the immature larval or caterpillar
stage (Fig. 3.9) of certain
moths. Moths are nocturnal
and active during the evening hours. The characteristics of their feeding damage
on plants depend upon the
caterpillar age and species.
Younger loopers feed on one
side of the leaf, leaving a
window-like appearance on 3.9. Caterpillar on ti leaf.
the other side, while older
larvae eat holes completely through the leaf or flower. In Hawaii, their life cycle lasts 33–
35 days. The mature larvae spin a thin, white, silken cocoon and pupate within the cocoon. Cocoons are most commonly attached to the underside of leaves or within folded
leaf edges of leaves. Adult females can deposit up to 280 eggs during their lifespan.
The Mexican leafroller attacks many kinds of plants including shrubs and fruit trees.
The leafroller or caterpillar stage rolls the edges of leaves or flowers (especially young
growth) or webs together leaves or flowers. The leafroller feeds for 28–35 days and then
pupates within the folded leaf or flower. The adult emerges in about 10 days.
Pest management. Naturally occurring wasp and fly parasitoids are usually very effective against caterpillars, and therefore caterpillars seldom become a problem pest on
ornamentals. Products utilizing the bacterial organism Bacillus thuringiensis (“Bt”), are
effective against most caterpillars and have the added benefit of being non-toxic to natural predators and parasites. Caterpillars that feed on Bt do not die instantly, but they stop
feeding and eventually die of starvation.
Moths are
nocturnal and
active during
the evening
hours.
33
Growing dendrobium orchids in Hawaii
False spider mites (Order: Acariformes, Family: Tenuipalpidae)
Red and black flat mite, Brevipalpus phoenicis (Geijskes), Tenupalpus pacificus Baker
3.10. False spider mite
feeding injury on a
dendrobium leaf.
False spider mites are a major pest of dendrobium. Unlike spider mites, false spider mites
do not spin a silken web. Plant injury is characterized by stippling, a silver-ish or bleached
appearance (Fig. 3.10) resulting from mites sucking on plant sap and chlorophyll with
their needle-like mouthparts. As the injured plant tissue oxidizes, the mite injury turns to
brown and black (Fig. 3.11). False spider mites can be found on upper and lower leaf
surfaces, stems, petioles, and flowers (Fig. 3.12). Life stages include egg, larva, nymph,
and adult. The eggs are oval, bright red, and usually found on both leaf surfaces (Fig.
3.13). The larvae are about 1/200 inch long, are bright red, and have six legs. Nymphs
have eight legs and are larger than the larvae. Adult mites are red and about 1⁄100 inch long
(Fig. 3.14). The development time from egg to adult is about 29 days. Each female lays
about 50 eggs in her lifespan of 34 days. False spider mites have a wide host range and
also feed on allamanda, azalea, chrysanthemum, coffee, citrus, daisy, guava, hibiscus,
mango, papaya, passionfruit, and other orchids.
Pest management. Early detection of the false spider mite is critical for effective
control. Look for any tiny red specks associated with silvering of leaves, and confirm the
presence of mites with a 10–15X hand lens. Fast moving, predatory mites, thrips, and
ladybird beetles may control large populations of false spider mites. If miticides are used,
apply two to three applications of a registered miticide at 2-week intervals. Sprays should
be directed to the underside of leaves and flowers.
3.12. False spider mite feeding injury on flower spike.
3.11. False spider mite
feeding injury after plant
tissue oxidizes.
3.13. False spider mite
eggs are oval, bright
red, and usually found
on both leaf surfaces
3.14. False spider mite
adult (1⁄100 inch long)
34
Growing dendrobium orchids in Hawaii
Mealybugs (Order: Homoptera, Family: Pseudococcidae)
Longtailed mealybug, Pseudococcus longispinus (Targioni-Tozzetti)
Obscure mealybug, Pseudococcus affinis (Maskell)
Dendrobium mealybug, Pseudococcus dendrobiorum Williams
Jack Beardsley mealybug, Pseudococcus jackbeardsleyi Gimpel & Miller
Mealybugs are difficult to control because they are protected by white, waxy secretions
and aggregate in cryptic habitats such as leaf axials and roots. Mealybugs have piercingsucking mouthparts, feed on sap, and secrete honeydew. Feeding damage on dendrobium
results in deformed flower spikes (Fig. 3.15). Mealybugs are also found on roots and are
a major cause of quarantine rejections for exported potted orchids. Adult mealybugs can
either lay eggs or give birth to live young,
referred to as crawlers. If eggs are laid, they
usually hatch in less than 24 hours. Crawlers are highly mobile and are the dispersal
stage of this pest. Once the crawlers find a
suitable site they settle down and begin to
feed. The entire life cycle ranges from 2 to
4 months and adults live from 27 to 57
days, depending on the species.
Pest management. Early detection is
the key to successful pest management. Observe leaves and spikes for signs of mealybugs and remove plants from pots to inspect roots for mealybugs. Slow-growing
plants or pots that are root-bound are more
likely to become root-infested). Remove
and dispose of flower spikes that are infested and deformed (unmarketable). If
plants are heavily infested with foliar or
root-infesting mealybugs, place them in
3.15. Jack Beardsley mealybug infestation
trash bags and remove them from the farm.
causing deformed flower spike.
For foliar mealybugs, apply weekly applications of an insecticide approved for the use until the mealybugs are brought under
control. Thorough spray coverage is essential to bring this pest under control. Insecticide
drenches are somewhat effective for root-infesting mealybugs, but every effort should be
made to prevent infestations. The following practices are recommended to prevent mealybug establishment and spread:
1) Inspect roots of all orchid plants, including newly purchased plants, by removing the
plant from the pot.
2) Avoid root-bound plants by re-potting as needed; root-bound plants encourage mealybugs.
3) Use clean pots and media; if infested, wash with a detergent.
4) Treat or remove alternate hosts from your premises.
5) Do not allow water from infested areas to drain into clean areas; crawlers are transported by water movement.
Integrated pest
management
(IPM) is a systems
approach to
reducing pest
damage to crops.
35
Growing dendrobium orchids in Hawaii
Midge (Order: Diptera, Family: Cecidomyiidae)
Blossom midge, Contarinia maculipennis (Westwood)
The maggot stage
of the blossom
midge feeds
inside unopened
flower buds,
causing deformity
and aborted bud
development.
The blossom midge has been in Hawaii since the early 1900s. The maggot stage of the
blossom midge feeds inside unopened flower buds, causing deformity and aborted bud
development (Fig. 3.16). Severely infested dendrobium buds rot and/or drop off the plant.
As many as 30 maggots may be found infesting a dendrobium bud. Eggs are deposited
inside the bud by the female. Maggots crawl and feed in the bud, bathed in fluids from the
damaged tissue (Fig. 3.17). Maggots are able to leave the buds by “jumping” and burrowing into soil to pupate. Late stage pupae are active, burrowing up to the soil surface in
preparation for adult emergence. Adult emergence
from pupae usually occurs
in the early evening hours.
Adult blossom midges are
very tiny, somewhat mosquito-like (Fig. 3.18). The
life cycle from egg to adult
is about 21 days, with 14
days spent in the soil. The
blossom midge has an unusually wide host range
spanning at least six plant
families including orchids
(Orchidaceae), hibiscus
3.16. Buds deformed by blossom midge.
(Malvaceae), tomato, eggplant, pepper, potato, Paraguay nightshade (Solanum rantonnetii) (Solanaceae), pak-choi
(white mustard cabbage) (Cruciferae), bitter melon (Momordica charantia) (Cucurbitaceae), and pikake (Oleaceae).
Pest management. Except for the adult stage, all stages of the blossom midge are
secluded either within buds or in the soil. Removing and destroying infested buds is the
most important management practice for the blossom midge. Only the adult stage is vulnerable to contact foliar insecticides, and systemic insecticides are not translocated to
orchid buds to affect the maggots. Insecticides applied as a drench can target the pupal
stage of the blossom midge. To date, no parasitoids have been specifically introduced by
Hawaii Department of Agriculture to control the blossom midge. Adults are vulnerable to
general predators, such as web-spinning spiders.
3.17. Blossom midge maggots inside a bud.
36
3.18. Blossom midge adult (1⁄25 inch long).
Growing dendrobium orchids in Hawaii
Orchid weevils (Order: Coleoptera, Family: Curculionidae)
Orchid weevil, Orchidophilus aterrimus (Waterhouse)
Lesser orchid weevil, Orchidophilus perigrinator (Buchanan)
Orchid weevil larvae and adults have chewing mouthparts (Fig. 3.19) and feed on orchid
flowers, stems, leaves, and exposed roots (Fig. 3.20). The adult female chews a hole in
the canes or leaf and deposits an egg. After hatching, the grub continues feeding within
the cane for about 4 months. The grub then creates a frass and fiber chamber within the
cane for pupation. About 2 weeks after pupation, the adult chews a hole about 1⁄16 inch in
diameter (Fig. 3.21) and crawls out of the pupation site. Total development time from egg
to adult is about 5 months. Adults live for about 9 months to a year. Orchidophilus aterrimus
is the largest of the orchid weevils in Hawaii, which range from 1⁄8 to 1⁄4 inch long. The
lesser orchid weevil, Orchidophilus perigrinator, is at the lower end of the orchid weevil
size range.
3.19. Adult orchid weevil
and grub in orchid stem.
The adult female
chews a hole in
the canes or leaf
and deposits
an egg.
3.21. Emergence hole of the
adult orchid weevil.
3.20. Orchid weevil feeding
injury on leaves and stem.
Pest management. There are no reported specific parasitoids or predators of the orchid weevil. General predators, including spiders, toads, and birds, can be expected to
feed on orchid weevils. Because of the orchid weevil’s long life cycle of 5 months, sanitation is the most important management measure. Plants or plant parts with feeding damage and adult emergence holes should be placed in trash bags and taken from the premises. If sanitation is done soon enough, the spread of weevil infestations will be prevented. Contact insecticides are only effective against the adult stage, and systemic insecticides are not effective against the grub stage. Therefore, insecticide applications must be
repeated to effectively control orchid weevils in infested plants. Spray applications must
be repeated every 2 to 3 weeks for four applications to effectively control orchid weevils
in severely infested plants. Organophosphate and synthetic pyrethroid insecticides are
effective against adult orchid weevils. Certain synthetic pyrethroids have a longer residual activity and greater repellency against the orchid weevil for more effective control
than organophosphates.
A postharvest pyrethroid dip will help eliminate adults harbored in leaf axils and
flowers but will not affect eggs, larvae, or pupae inside stems or leaves. Potted plants with
feeding damage and other symptoms of orchid weevil infestation should not be marketed.
37
Growing dendrobium orchids in Hawaii
Plant bug, seed bug, and stink bug
(Order: Hemiptera, Family: Miridae)
Plant bug, Taylorilygus pallidulus (Blanchard)
(Family: Lygaeidae)
Seed bug, Nysius spp.
(Family: Pentatomidae)
Southern green stink bug, Nezara viridula (Linnaeus)
Plant bugs, seed
bugs, and stink
bugs develop
from eggs into
nymphs and then
adults.
38
Plant bugs, seed bugs, and stink
bugs (Fig. 3.22) have been associated with bud drop on dendrobium. Although there are other
causes for bud drop, including
physiological, nutritional, and
environmental causes, these insects possess piercing-sucking
mouthparts to feed on developing flower buds and cause bud
drop or abortion. At night, growers have observed plant bugs
feeding on developing buds followed by bud drop a few days 3.22. The southern green stink bug, Nezara viridula.
later. Usually, these sucking bugs
do not breed on orchids, but they breed on wild host plants located in areas adjacent to the
orchid production. Plant bugs, seed bugs, and stink bugs develop from eggs into nymphs
and then adults. The nymph appears slightly different from the adult because nymph
wings are undeveloped, exposing their abdomen. The life cycle (egg to adult) of these
sucking bugs is completed in about 30–45 days.
Pest management. The most important management measure is to locate the breeding host plants adjacent to the orchid production area. If practical, remove host plants or
minimize their occurrence. Repeated insecticide applications to orchids will be necessary
to control these bugs when they are breeding on adjacent host plants but feeding on the
orchids.
Growing dendrobium orchids in Hawaii
Scales (Order: Homoptera, Family: Diaspididae—armored scales)
Boiduval scale, Diaspis boisduvalii Signoret
Florida red scale, Chrysomphalus aonidum (Linnaeus)
Proteus scale, Parlatoria proteus (Curtis)
Furcaspis biformis
(Family: Coccidae—soft scales)
Brown soft scale, Coccus hesperidum L.
Stellate scale, Vinsonia stellifera (Westwood)
The two types of scale insect are armored scales and soft scales. The armored scale makes
a separate protective covering (armor) under which the insect lives, feeds, and lays eggs.
The armored covering is nonliving and composed of secreted waxes that cement cast
skins together to form the covering. The armor may be circular, semi-circular, oblong, or
pear-shaped and varies in color from white to red to dark brown (Fig. 3.23). The adult
female is always wingless and legless, while the adult male has functional wings and
looks very much like a small gnat. Armored scales feed on plant juices and cause loss of
vigor, deformation of infested plant parts, yellowish spots on leaves, loss of leaves, and
even death of the plant. Most species of armored scale have similar life histories. The
female deposits from 30 to 150 eggs under the armor. These hatch in 1–2 weeks. The
hatched crawler is very mobile and moves about in search of an ideal place to feed. The
crawler inserts its needle-like mouthpart into the plant and remains there as it develops
into an adult. The adult stage is reached in 5–7 weeks. Armored scales do not excrete
honeydew and are not tended by ants.
The soft scale does not have a separate armor, and its body is exposed. Soft scales
retain their legs and antennae throughout adult life. Young females are primarily sedentary but may move about for a brief time after feeding begins. Their life cycle is very
similar to armored scales, although soft scales do excrete honydew and are tended by ants.
Pest management. Scale insects are very difficult to control with insecticides, especially in severe infestations. The best control method is to destroy all severely infested
plants or plant parts. Because armored scales are spread chiefly through movement of nursery stock, only propagation material that is free of scales should be planted. Ladybird beetles
(ladybugs) and parasitic wasps have been introduced and have become established in Hawaii to control armored scales. Scale covers that look chewed and have no insect underneath are signs that predators have been feeding on the scales. A tiny circular hole on the
covering indicates that a parasitic wasp developed and emerged from the scale insect. Scraping
and scrubbing to remove scales from plants are effective mechanical control tactics.
Most modern insecticides act on contact, and therefore only the crawler stage of the
armored scale is susceptible to insecticides; the other stages are protected from contact
insecticides because of the armor covering. Pruning and adequate plant spacing are important cultural practices that will allow maximum coverage when using contact insecticides. Systemic insecticides that are taken up by the roots and translocated to leaves may
be effective against the nymph and adult stages of armored scales. However, systemic
activity of insecticides varies among plants, and translocation of systemic insecticides in
dendrobium orchids has not been demonstrated.
Soft scales are easier to control. Eliminating ants foraging for honeydew will lower
soft scale populations, and most contact insecticides are effective against soft scales. Horticultural oils have been shown to be effective against exposed eggs and crawlers of the
armored scale and various stages of the soft scales. Early detection of incipient infestations is a key to successful scale insect control, because established scale insect infestations are very difficult to manage.
3.23. Furcaspis biformis,
an armored scale.
Armored scales
feed on plant
juices and cause
loss of vigor,
deformation of
infested plant
parts, yellowish
spots on leaves,
loss of leaves,
and even death
of the plant.
39
Growing dendrobium orchids in Hawaii
Thrips (Order: Thysanoptera, Family: Thripidae)
Banded greenhouse thrips, Hercinothrips femoralis
Dendrobium thrips, Dichromothrips dendrobii Sakimura
Greenhouse thrips, Heliothrips haemorrhoidalis (Bouche)
Hawaiian flower thrips, Thrips hawaiiensis
Melon thrips, Thrips palmi (Karny)
Onion thrips, Thrips tabaci
Vanda thrips, Dichromothrips corbetti
Western flower thrips, Frankliniella occidentalis (Pergande)
Yellow flower thrips, Frankliniella shultzei
(Family: Phlaeotrhipidae)
Black flower thrips, Haplothrips gowdeyi (Franklin)
Small populations
of thrips on open
blossoms often
go unnoticed
because of the
insect’s small
size.
40
Many species of thrips attack the leaves and flowers of dendrobium orchids, causing
feeding damage with their rasping-piercing-sucking mouthparts. Greenhouse thrips and
banded greenhouse thrips cause silvering of leaves (Fig. 3.24), which turn brown with
time. Dendrobium thrips and vanda thrips attack flower buds and spikes, causing deformity and death (Fig. 3.25); these thrips also attack the young terminal leaves, causing
dieback (Fig. 3.25).
A complex of thrips
species infests open
blossoms, the most
prevalent being the
western flower thrips,
Frankliniella
occidentalis, yellow
thrips, F. schultzei,
and melon thrips,
Thrips palmi. Large
populations of thrips
on open blossoms are
usually recognized by
feeding damage char- 3.24. Greenhouse thrips feeding injury.
acterized by white
streaks on petals occurring as narrow, irregular white lines and
blotches (Fig. 3.27). Small populations of thrips on open blossoms
often go unnoticed because of the
insect’s small size.
Melon thrips (Fig. 3.28) is a
quarantine action pest of the U.S.
Department of Agriculture, Animal
and Plant Health Inspection Service
(APHIS), with a zero tolerance into
continental U.S. Because immature 3.25. Dendrobium thrips injury to flower spike.
thrips are almost impossible to distinguish among species, quarantine inspectors will reject dendrobium blossoms infested
with immature thrips that appear similar to melon thrips. Western flower thrips and yellow flower thrips have immature stages that appear similar to melon thrips. Thrips life
stages include egg, two immature larval instars, prepupa, pupa, and adult. Eggs are ovi-
Growing dendrobium orchids in Hawaii
posited into plant tissue. Immature larval stages and adults are the feeding stages. With
most thrips species, immature thrips migrate off the plant and pupate in the media, plant
debris, or other protected places. Melon thrips and western flower thrips can complete
their entire life cycle in as little as 11 and 13 days, respectively.
Pest management. Chemical control of thrips is very difficult because almost all
stages are found inside flowers, and thrips are resistant to or tolerant of many insecticides.
Therefore, non-chemical control of thrips should be emphasized. The first step in effectively managing thrips is early detection by monitoring. All dendrobium growers should
construct or purchase a modified Berlese funnel to monitor thrips. A simple apparatus, the
Berlese funnel, separates thrips from orchid blossoms. Briefly, a brooder lamp is placed
on a galvanized funnel containing blossoms, and the heat from the lamp drives the thrips
down the funnel into a jar containing alcohol (see Appendix A for construction details).
With the Berlese funnel, low population levels of thrips can be detected, and this is the
stage when control measures must be implemented. All infested flowers and plants should
be removed and placed into trash bags. Insecticide application should be applied both to
leaves and the ground. Foliar application targets immature and adult thrips, and ground
application targets the pupal stage of
thrips. Due to the difficulty in controlling
thrips with insecticides, growers may want
to take advantage of natural enemies of
thrips. In Hawaii, pirate bugs (Orius spp.)
have been observed in dendrobium blossoms heavily infested with western flower
thrips. Under high humidity conditions,
entomopathogenic fungi such as Beauvaria bassiana and Paecilomyces fumosoroseus may control thrips.
An educational video was produced
by CTAHR to help growers identify and
3.26. Dendrobium thrips cause die-back of
control thrips problems. It can be borterminal leaves.
rowed from Cooperative Extension Service county offices.
3.27. Damage to flowers caused by melon thrips.
The first step
in effectively
managing thrips
is early detection
by monitoring.
3.28. Melon thrips on a dendrobium
flower.
41
Growing dendrobium orchids in Hawaii
Whitefly (Order: Homoptera, Family: Aleyrodidae)
Silverleaf whitefly, Bemisia argentifolia Bellows & Perring
Sprialing whitefly, Aleurodicus dispersus Russell
Silverleaf whiteflies have been
found infesting
orchid flowers,
causing aesthetic
and quarantine
problems.
42
Silverleaf whitefly has been distinguished as one
of the most economically destructive pests of agriculture. Although silverleaf whitefly is the most
serious pest of poinsettia, dendrobium orchids do
not escape infestations. Silverleaf and spiraling
whiteflies have been found infesting orchid flowers, causing aesthetic (Fig. 3.29) and quarantine
problems. They cause damage directly by removing plant sap during feeding and indirectly when
they excrete honeydew that becomes a medium for 3.29. Spiraling whitefly egg track.
the growth of sooty mold fungus.
Whiteflies progress from egg to
crawler (the first nymphal stage)
through two nymphal stages to pupa
and adult. Only the crawler and the
winged adult stages are mobile.
Silverleaf whitefly resembles the
sprialing whitefly (Fig. 3.30) and is
so similar to the greenhouse whitefly, Trialeurodes vaporariorum
(Westwood), that it can be distinguished only by microscopic examination of the pupal stage. The entire 3.30. This spiraling whitefly closely resembles the
life cycle from egg to adult may silverleaf whitefly.
range from 15 to 70 days, depending on temperature and the plant host.
Pest management. Whiteflies were very difficult to control chemically until the registration of imidacloprid (Marathon®, Merit®). However, overuse of imidacloprid will
render it ineffective against the silverleaf whitefly. In recent years, lower populations of
the silverleaf whitefly in Hawaii have been associated with higher occurrence of parasitic
wasps specific to whiteflies. Therefore, whitefly control on dendrobium should not be
problematic if proper pest management measures are followed. Most important is early
detection of whiteflies and implementing control measures when the population is low to
moderate. Whiteflies are tolerant of or resistant to many insecticides, and therefore effective insecticides in different classes (e.g., oils, soaps, pyrethroids, organophosphates,
chloronicotinyl) must be rotated to prevent the development of resistance. Oils and soaps
are effective against whiteflies, although depending on their concentration, the formulations may be phytotoxic to dendrobium orchids.
Growing dendrobium orchids in Hawaii
Birds
Red vented bulbul, Pycnonotus cafer; red whiskered bulbul, P. jacosus
Common sparrow, Passer domesticus
Rice bird, Munia nisoria
White-eye or mejiro, Zosterops palpebrosus japonica
Kentucky cardinal, Richmondena cardinalis
Birds are a severe problem in
orchids, especially in September through December in Hawaii. During this period, crop
losses can exceed 80% in certain growing areas. Bird damage is usually confined to
spikes, buds, and open flowers. Flower buds are usually
pecked off the spike (Fig.
3.31), or spikes are sheared in
half. In open flowers, birds remove the cap covering the
pollinia (pollen masses) to get
to the pollen. Once the pollen 3.31. Flower buds damaged by birds.
is removed, the flower begins
to die.
Pest management. Birds develop feeding habits and learned behaviors. Therefore,
fields should be frequently monitored for birds so early action can be taken. Total enclosure by screening the crop area is the most effective method to reduce damage. The odor
of certain insecticides and fungicides is also known to repel birds, but repellence is short
lived. Several noise and visual scare devices are on the market including noise cannons,
sticky traps for roosting birds, “look alive” predators, scare crows, flashing tape, and
electronic bird repellers. Many of these methods work for a while, but birds eventually
learn that these devices are not harmful. Electronic bird repellers, which broadcast bird
distress calls, are species-specific. For optimum control, a combination of devices should
be used, and the devices should be removed as soon as the birds are not a problem.
Birds are a
severe problem
in orchids
in Hawaii,
especially in
September
through
December.
43
Growing dendrobium orchids in Hawaii
Mice
House mouse, Mus musculus
Mice outbreaks
and damage to
crops usually
occur during a
drought period
when wild food
and water
sources dwindle.
44
Mice can become a problem in dendrobium production at any time of the year due to their
fast reproductive capability and their ability to adapt to various foods and environmental
conditions. Mice outbreaks and damage to crops usually occur during a drought period
when wild food and water sources dwindle. During such times, dendrobium growers have
experienced widespread damage to flower spikes. Mice usually feed on the newly emerged
immature spikes. Damage by mice can easily be mistaken for bird injury. However, unlike bird injury, mice usually leave no remnants of the spike, and the severed end appears
serrated and not sheared off. The best way to distinguish mouse damage from bird damage is to monitor the field at night for mouse activity.
Mice can vary in color from tan to gray and are 6–7 inches from nose to tail. The tail
is as long or longer than the head and body combined. A mouse has a slender body, large
ears, small eyes, and a pointed nose. Nests are built just about anywhere, including under
rocks, boards, and vegetation, and each female can produce as many as 50 young per year.
Pest management. Mice, like other rodents, are mainly nocturnal but occasionally
feed during the day. There are many types of effective non-chemical mouse traps on the
market including sticky traps, snap traps, and cage traps. Rodenticides contain a food bait
and a chemical toxicant, and because rodents are mammals, these rodenticides are also
highly toxic to humans and domestic animals. Rodenticides are divided into either singledose or multiple-dose rodenticides.
As the name implies, multiple-dose rodenticides require repeated feedings before death
occurs. Multiple-dose rodenticides are safer to non-target mammals than single-dose rodenticides. The majority of multiple-dose rodenticides are anti-coagulants, which causes
death by internal bleeding. Single-dose rodenticides are used for quick knock-down of
mouse populations. When using single-dose rodenticides, bait shyness may cause ineffectiveness, and rotation with multiple-dose rodenticides is recommended.
Growing dendrobium orchids in Hawaii
Slugs and snails
(Family: Limacidae) Marsh slug, Deroceras laeve (Muller)
(Family: Veronicellidae) Brown slug, Vaginulus plebeius Fischer,
Two-striped slug, Veronicella cubensis (Pfeiffer)
(Family: Bradybaenidae) Small garden snail, Bradybaena similaris (Rang)
(Family: Achatinellidae—cone spiral shell) Tornatellides sp.
(Family: Helicarionidae) Liardetia doliolum (Pfeiffer)
(Family: Zontidae—flat spiral shell) Zonitoides arboreus (Say)
Slugs and snails are among the major pests of dendrobium, causing feeding damage to
leaves, roots, and flowers and quarantine rejections in export shipments. These pests also
move pathogens between pots or within the field. Their feeding activity causes wounds,
which aid pathogen entry.
During the day, snails and slugs are found hidden in plants and plant debris or under
rocks or pots. However, following rain, they are seen foraging in daylight. The most
pestiferous slugs are the brown slug, Vaginulus plebeius (Fig. 3.32), and the two-striped
slug, Veronicella cubensis (Fig. 3.33), first reported in Hawaii in 1978 and 1985, respectively. Since then, high population levels of these slugs have resulted in severe damage to
many ornamental, vegetable, and landscape plants in Hawaii.
The brown slug and the two-striped slug range in color from beige to dark brown. The
two-striped slug is easily recognized by the two longitudinal stripes on its back. These
veronicellid slugs are hermaphroditic, with a single slug having both male and female
reproductive organs. However, mating is usually required between two individual slugs
and both may lay eggs. Depending on the species, 10–200 eggs are laid, which hatch in 14–
30 days. Juveniles reach sexual maturity in 3–5 months and may live for as long as 2 years.
In recent years a native snail (Tornatellides sp., Fig. 3.34), and the introduced snails
Liardetia doliolum and Zonitoides arboreus (Fig. 3.35) have become of quarantine significance on ornamentals, including dendrobium. These snails occur primarily on roots in
the media and on leaves and are tiny (1⁄8–1⁄2 inch) and therefore may go unnoticed. Z.
arboreus has been in Hawaii since at least 1928, and its presence has been confirmed on
Oahu, Maui, and Hawaii.
Pest management. The control of snails and slugs must first include sanitation, that
is, the destruction of hiding places and removal of plant debris. An effective physical
control is the use of barriers in the form of copper flashing, copper screen, or copper
hydroxide. Copper is highly repellent to snails and slugs, and continuous contact with
copper will cause their death. Copper flashing can be affixed to bench legs to inhibit
snails and slugs from reaching bench tops from the ground.
Most molluscicides contain metaldehyde and a bait to attract snails and slugs.
Metaldehyde acts as a contact and stomach poison. After absorption or ingestion,
metaldehyde disrupts the lining of the gut and causes excessive mucus secretion. For best
results, molluscicides should be applied after rainfall when slugs are actively foraging.
Although pelleted and granule formulations provide high initial mortality immediately
after application, effectiveness rapidly declines with rainfall. On the other hand, liquid
paste formulations increase in effectiveness with rainfall for 4 –6 days after application
before decreasing in effectiveness. For controlling tiny snails on plants, a liquid spray-on
metaldehyde molluscicide could be used.
These mollusc pests are among a group that is spreading around the world. For example, at least 34 alien snail and slug species are currently on the island of Hawaii, and
many were likely introduced on horticultural products. Strict observance of quarantine
inspection requirements will minimize the accidental import and export of mollusc pests.
3.32. Brown slug.
3.33. Two-striped slug.
3.34. Tornatellides sp., a
native snail.
3.35. Zonitoides arboreus,
an introduced shail.
45
Reprinted from: Trends in new crops and new uses. 2002. J. Janick
and A. Whipkey (eds.). ASHS Press, Alexandria, VA.
Development of Phalaenopsis Orchids for the Mass-Market
R.J. Griesbach
INTRODUCTION
It is widely recognized that potted Phalaenopsis production has increased tremendously in last few years.
The specific statistics for Phalaenopsis are not available, for the US Department of Agriculture only keep
records on total orchid production and sales. However, over 75% of all orchids sold are Phalaenopsis (American
Orchid Society, pers. commun.). In 2000, wholesale orchid sales were approximately $100,000,000 (Fig. 1).
The only crop with a higher value was poinsettia. During the last five years orchids sales has been increasing,
unlike all the other ornamental crops (Fig. 2).
Large scale, potted Phalaenopsis production is occurring in the Netherlands, Germany, China, Taiwan,
United States, and Japan. In one cooperative venture, cultivar development is taking place in the Unites States;
selected clones are being placed into tissue culture in Japan; mass proliferation of the tissue cultures is occurring in China; and the tissue cultured plants are being grown to maturity in the Netherlands. In 1957, James
Shoemaker stated that “orchid growing has not fully achieved the transition from a hobby to an industry.”
Today, orchid growing is more than just an industry, it is an international business.
VICTORIAN BEGINNINGS
The development of hybrids reflects the preference of the consumer. As consumers’ taste change, so
does the type of hybrids produced and grown. During the Victorian period from 1830 to 1900, many homes
had “parlor plants” (Martin 1988). During this period, the design of homes changed from a large single room
to several smaller multiple-function rooms. Plants were grown in either the front or back rooms or parlors.
The front parlor usually lacked heat and was extremely cold during the winter; while, the back parlor was
typically overheated during the day and not heated at night. Many of the modern potted plants which we
consider “new” were common house plants at this time. Several orchid species in the Cattleya Ldl. and
Dendrobium Ldl. alliances were also common parlor plants.
The conditions in the Victorian home were not well suited to growing Phalaenopsis Bl. These orchids
were considered a challenge to grow. James Veitch in his Manual of Orchidaceous Plants (1894) stated that
“the introduction of species of Phalaenopsis … has been one of the most difficult cultural problems horticulturists have been called upon to solve.” Because of the environmental conditions within the home, Phalaenopsis
were predominantly grown in a conservatory or greenhouse.
Fig. 1. Wholesale value of flowering potted plants
within the United States for 2000 (USDA Agricultural
Statistics).
Fig. 2. Wholesale value of orchids within the
United States for the last five years (USDA Agricultural Statistics).
458
Ornamentals
Many homes in Europe at this time had greenhouses. In 1870, 50% of the middle and better class homes
in London had attached greenhouses (Martin 1988). However in the United States, greenhouses were extremely expensive and rarely found. Because of this difference, Phalaenopsis were not as widely grown in
the United States during the Victorian period.
The popularity of Phalaenopsis naturally led to the creation of many artificial hybrids. The first hybrid
(P. Intermedia) was created in 1875 when John Seden at Veitch and Son’s Nursery in England crossed P.
amabilis (L.) Bl. with P. equestris Rchb. (Veitch 1886). The seed was sown at the base of the mother plant
and only a single seedling survived which flowered a decade later in 1886. By 1900, an additional 13 primary
hybrids were created and flowered. John Seden was responsible for creating all but one of these hybrids. The
emphasis in hybridization at this time was to create exotic parlor plants.
The potential of artificial hybridization for creating new types was widely recognized, but the technical
expertise required to germinate the seed and to raise the seedlings to maturity precluded its wide spread application. Only a few individuals were successful until 1909 (White 1942). In 1909, Hans Burgeff from Germany and Noel Bernard from France independently reported that orchid seeds germinated only in the presence
of a symbiotic fungus. This discovery was used by Joseph Charlesworth and James Ramsbottom at the
Charlesworth Company in England to develop a practical procedure to “symbiotically” germinate orchid seeds.
In this procedure, a peat and sand mixture was sterilizing and then inoculated with the symbiotic fungus.
After the fungus has penetrated the compost, the seed was sown on top. This symbiotic germination technology made it easier to produce hybrids, but large scale, commercial production of hybrids was still not possible. Many of the seeds in a capsule germinated, but few survived the process due to excessive fungal infection.
ORCHID TECHNOLOGY
Non-symbiotic Germination
Symbiotic germination methods were only used for a short time before being replaced by non-symbiotic
germination procedures. In 1922, Lewis Knudson at Cornell University reported that the fungus was not required for germination if the seed was sown on agar containing appropriate salts and sugars. His Knudson C
medium is still being used to germinate the seed of some species. With non-symbiotic germination technology, thousands of seedlings could be raised to maturity from a single seed capsule.
Besides the obvious potential in breeding, this technology was also extremely important for vegetative
propagation. Unlike Cattleya, Phalaenopsis plants were difficult to import because they lacked water storage
pseudobulbs. Many of the plants died in transit. Those plants which did survive were difficult to vegetatively
propagate. The most desirable species (i.e. P. amabilis) produced a single stem that would produce only a
few ‘off-sets’. Non-symbiotic germination technology made it possible to produce very large quantities of
plants.
By the time these new seed germination procedures were developed, the parlor plant craze had ended.
Consumer preference shifted from potted plants to cut-flowers. Therefore, the emphasis in breeding focused
on developing hybrids for this new market. Improved germplasm collected by Regnier in the Philippine Islands served as the genetic foundation for the cut-flower hybrids. Two improved forms of P. amabilis were
collected. The grandiflora form of P. amabilis produced flowers that had fuller, rounder form with wider
petals than the typical species. The rimestandiana form produced flowers that had the typical form and size
but had tremendous substance. The rimestandiana forms that were used in breeding were later found to be
tetraploid (Maurice Lecoufle pers. commun.). These two forms were originally recognized as distinct species.
Breeding Advances
The first major advance in breeding was made in 1920 by Dr. Jean Gratiot from France when he registered P. Gilles Gratiot. This hybrid, the result of a cross between the typical form of P. amabilis and the
rimestandiana form, had extremely heavy substance. The second major advance in breeding came in 1927
when Henri Lecoufle at Vacherot and Lecoufle Company in France registered the hybrid between the
rimestandiana and grandiflora forms of P. amabilis. This hybrid, P. Elisabethae, had the heavy substance of
the rimestandiana from and the improved flower shape of the grandiflora form.
459
Trends in New Crops and New Uses
Through extensive in-breeding and out-crossing to P. aphrodite Rchb. superior hybrids were created, the
most important of which was P. Doris. This hybrid was registered in 1940 by Duke Farms in New Jersey. P.
Doris produced long, arching inflorescences on plants that were large and vigorous. The flowers were pure
white, huge, and flat. Their heavy substance made them ideal for cut-flower production.
Production Protocols
Once cut-flower hybrids were developed, research began on developing commercial production protocols. The first experiments were preformed in the 1930s by H.O. Eversole in California (White 1942). He
determined that Phalaenopsis grew the fastest and produced the most flowers in a sand-peat medium. Prior to
this time, nearly all orchids were grown in living moss. Because of the difficulty in obtaining high quality
peat, osmunda fiber became the medium of choice during the 1940s. Repotting orchids in osmunda fiber was
both difficult and labor intensive. During the 1950s, independent research by O. Wesley Davidson at Rutgers
University working with George Off at the Off Orchid Company and by Rod McLellan at the Rod McLellan
Company resulted in the development of bark-based media. With these media, repotting was fast and easy.
Today, the Rutger #3/Off mix is the most popular bark medium used.
Coupled with the development of improved potting media was the formulation of better fertilizers. Research on nutrition by Ratsek (1932), Evers and Laurie at Ohio State University (1940), Withner at Brooklyn
College (1942), Fairborn at the Missouri Botanical (1944), Beaumont and Bowers at the University of Hawaii
(1954), Davidson at Rutgers University (1957), and Sheehan at the University of Florida (1960) resulted in
improved fertilizers. Before 1960, few growers fertilized their orchids. These studies showed that fertilization was critical for commercial production.
Another important research discovery was made by Gavino Rotor at Cornell University. In 1952, he
reported that short days induced flowering in P. amabilis hybrids and that high temperatures inhibited flowering. All of this data was used to develop improved production protocols which increased the rate of plant
growth and the yield of cut-flowers.
MARKET DEVELOPMENT
Between 1930 and 1950, the predominant cut-flower market was for white flowered hybrids. One of the
reasons for the predominance of white flowers was the lack of quality hybrids in other colors. Pink cut-flower
hybrids were developed during the 1950s. Interestingly, the genetic background of these pink hybrids was not
significantly different than that of the white hybrids. The pink species (P. schilleriana Rchb. and P. sanderiana
Rchb.) were not suitable for cut-flower production because of their thin substance. In addition, these species
quickly wilted if the pollen was accidentally removed or disturbed during harvest. Many of the cut-flower
pink hybrids that were developed actually arose from P. amabilis. Phalenopsis amabilis is not completely
white, but has a pink flush on the back of it’s sepals and petals. Through inbreeding and intense selection,
hybrids were eventually developed that were solid pink in color. These pink forms of P. amabilis (i.e. P.
Doris) were then used in breeding with P. schilleriana and P. sanderiana to create quality hybrids.
By 1960, only a handful of closely related species (P. aphrodite, amabilis, schilleriana, and sanderiana)
were in the background of nearly every hybrid created. The other species or “novelty” species were rarely
used in breeding. Oscar Kirsch (1960) in Hawaii stated of novelty hybrids that “many of these new creations
would not be of value as commercial flower producers.” There were many reasons why they were of little
value. First, the commercial market demanded cut-flower plants that produced long inflorescences with lots
of large flowers. Novelty hybrids usually produced short inflorescences with a few small flowers. Second,
the growers needed uniformity in both the product and production of the product. Populations of novelty
hybrids generally contained plants that flowered at different times, had different growth habits and had different flower colors. Third, the cut-flower market wanted flowers that were uniform in color and not patterned.
Many novelty hybrids produced flowers that had unusual colors.
In order to develop cut-flowers in an expanded range of pure colors without markings, the novelty species had to be used. Although the breeding protocol to create the “colored” cut-flower hybrids was obvious—
cross the novelty species with the white, cut-flower hybrids and then backcross to the white parent—the problems
associated with this approach were not. First, there were few novelty species in cultivation. Second, there
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Ornamentals
was no experience on the genetic influence of the novelty species in breeding. Third, the modern primary
hybrids were not very fertile due to chromosomal problems. The original primary hybrids made prior to 1900
used diploid forms of P. amabilis; while the modern recreation of these hybrids used tetraploid forms of P.
amabilis (i.e. P. Doris).
The first novelty species to be used extensively in hybridization was P. equestris. This species was used
to create a unique flower that had white petals and sepals with a red lip. The first P. equestris × P. amabilis
hybrid was made by Seden in 1875 and had diploid parents. Its flowers were pale pink with a solid, dark red,
lip. They were not flat and had poor substance and open shape. When a tetraploid, white, cut-flower hybrid
was crossed with a diploid P. equestris, the results were quite different. These hybrids produced flowers that
were nearly white with a pale red, stained lip. The flowers were reasonably large with heavy substance, but
had poor shape. The most important of these hybrids was P. Sally Lowrey (P. equestris × P. Pua Kea). This
hybrid was registered in 1954 by Oscar Kirsch in Hawaii. Through intensively backing-crossing of P. Sally
Lowrey to white hybrids followed by sib-mating, improved forms were created that were pure white with dark
red lips. In addition, these flowers had the improved form, size, and substance of the cut-flower hybrids.
During the 1960s, consumer preference shifted from cut-flowers back to potted plants. The parlor plant
craze was reborn. Unlike Victorian homes, modern homes were ideally suited to growing Phalaenopsis. Novelty
species were now used to create their own unique hybrids and not just for introducing color into cut-flowers.
All of the species were re-introduced into cultivation and many were improved through intraspecific hybridization. In several instances, polyploid forms of the novelty species were created. These improved species
were used to create primary hybrids that were far superior to those created at the turn-of-the-century.
Experimental crosses determine the genetic influence of the various species. For example, it was discovered that the brown spotting found on P. amboinensis J.J.Sm. flowers was not expressed in its hybrids with
P. amabilis; while the spotting in P. mannii Rchb. was expressed. Additional studies showed that certain
species combinations produced new characteristics. For example, when the solid colored P. pulchra Rchb.
was crossed to hybrids with fine spotting, the progeny had large blotches of colors. All of this information
and experience was used to create a wide range of unique hybrids.
PHALAENOPSIS DEVELOPMENT
Phalaenopsis grew in popularity and in the 1980s displaced Cattleya as the most popular orchid. At this
time in Europe, a new, floral, marketing strategy was being developed. This strategy was aimed at the massmarket consumer and not at the conventional gardening hobbyist. In the Netherlands, a large-scale cooperative was created for growing and marketing all plants, including orchids. Individual growers specialized in a
single crop, or even a single cultivar. The growers then jointly sold their product at an auction. In this manner, it was possible to supply wholesalers with a wide range of uniform, quality products throughout the year.
Jan Post (1985) stated that in order to be commercially successful “a pot plant market needs a lot of plants
which no grower is able to handle and fulfill alone. Only with a large quantities from several growers will
you create a orchid market for the consumer.”
The first orchid to be commercial marketed in this manner was Vuylstekeara Cambria ‘Plush’. In 1975,
Klass Schoone from the Netherlands began to propagate this clone for the mass-market. Since conventional
methods for vegetative propagation were inadequate, Schoone turned to tissue culture. Orchids were the first
plants to be commercially propagated through tissue culture. By 1985, over 100,000 tissue culture propagated
plants of V. Cambria ‘Plush’ were being sold per year!
Tissue Culture Protocols
The first experiments in orchid tissue culture were carried out in Knudson’s laboratory at Cornell University. In 1949, Gavino Rotor at Cornell University demonstrated that inflorescence nodes from Phalaenopsis
could be induced to form a plantlet if aseptically placed on seed germination media. More than a decade later,
Georges Morel (1960) at the Central Station for Plant Physiology in France reported that excised Cymbidium
Sw. shoot tips could be induced to form multiple plantlets when cultured on seed germination media supplemented with phytohormones. Shortly after this report, Donald Wimber (1963) at Brookhaven National Laboratory developed a successful method of using tissue culture to commercial propagate Cymbidium.
461
Trends in New Crops and New Uses
Tissue culture techniques that were commercially successful for many orchids could not be used with
Phalaenopsis. In Phalaenopsis, tissue culture propagation produced too much genetic variation. In some
instances, over 50% of the propagated plants produced flowers that were significantly different than the mother
plant. Therefore, mass-market Phalaenopsis were seed, and not vegetatively, propagated. Recently, tissue
culture protocols specific for Phalaenopsis have been developed by Tse and others (1971) at the University of
California, Intuwong and Sagawa (1974) at the University of Hawaii, Reisinger and others (1976) at the University of California, Zimmer and Pieper (1977) at the Technical University in Germany, Haas-von Schmude
(1983) in Germany, Griesbach (1983) at the US Department of Agriculture, Homma and Asahira (1985) at
Kyoto University in Japan, Tanaka (1987) at Kagawa University in Japan, Hinnen and others (1989) at the
Agricultural University in the Netherlands, Tokuhara and Mii (1993) at Chiba University in Japan, Ernst (1994)
at the University of California and Zhou (1995) at Sapporo Breweries in Japan, and Park and others (1996) at
Shizuoka University in Japan. These methods, while generally successful, still can not be used to propagate
all cultivars. In certain cultivars, these methods still produce too much variation. Due to the tremendous
increase in uniformity with vegetatively propagated plants, the future mass-market Phalaenopsis will most
like be tissue culture propagated and not seed propagated.
Breeding
Breeding for the mass-market was very different than breeding for the hobbyist or cut-flower markets.
In the hobbyist and cut-flower markets, emphasis was placed exclusively on floral traits; while in the massmarket, vegetative characteristics were of nearly equal importance with floral traits.
The first Phalaenopsis that were sold in mass-market were cut-flower hybrids that were selected for
more compact growth and flowering. The development of hybrids specifically for this market is in its infancy.
Currently, Phalaenopsis equestris is being heavily used as parent. Unlike in breeding for cut-flowers, this
species is not being used to introduce a single trait (i.e. red lip) into the white hybrids. Instead, the white
hybrids are being used to introduce a single trait (i.e. better shape) into the species.
The first important hybrid in this line of breeding was P. Cassandra (P. equestris × P. stuartiana) which
was made by Seden and registered by Veitch in 1899. P. Cassandra was remade many times, but the break
through came in 1978 when Herb Hager at Herb Hager Orchids in California used P. Cassandra to make P. Be
Glad. The other parent of P. Be Glad, P. Swiss Miss, was hybrid a between P. equestris and a white with a red
lip, cut-flower hybrid. P. Be Glad produced flowers with greatly improved shape and size. The plants, however, were less floriferous and much larger in size.
The next step logical step in this line of breeding was obvious—backcross P. Be Glad to P. equestris.
This hybrid, P. Be Tris, was registered in 1989 by Frank Smith at Krull-Smith Orchids in Florida. A triploid
form of P. Be Tris was recently created by Amado and George Vasquez at Zuma Canyon Orchids in California. The tetraploid form of P. equestris which was used to create the triploid hybrid was produced through
chemical treatment. During the 1970’s, Robert J. Griesbach (1981) in cooperation with Arnold Klehm at
Klehm Growers in Illinois developed procedures for using colchicine to double the chromosome number of
Phalaenopsis seedlings. A colchicine-induced tetraploid form of P. equestris was seed propagated and distributed by Klehm Growers, the US Department of Agriculture and the American Orchid Society. Of the seed
propagated tetraploids, P. equestris ‘Riverbend’ was the most widely distributed clone. The triploid forms of
P. Be Tris are far superior to P. equestris, with more distinct coloration, better shape and heavier substance.
Production Protocols
Production protocols that were developed for cut-flowers were not the best for potted plant production.
Extensive research in plant physiology by Sheehan (1960) at the University of Florida, Poole and Seeley (1978)
at Cornell University, Krizek and Lawson (1979) at the US Department of Agriculture, Sakanishi and others
(1979) at Oska University in Japan, Tanaka and others (1988) at Miyazaki University in Japan, Endo and
Ikusiuma (1989) at Chiba University in Japan, Ota and others (1991) at Nagoya University in Japan, Doi and
others (1992) at Kubota University in Japan, Kubota and Yoneda (1993) at Nihon University in Japan, Porat
and others (1994) at the Hebrew University in Israel, and Wang (1995) at Texas A&M University helped to
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Ornamentals
Fig. 3. Phalenopsis production. A) dwarf cultivar P. Hummingbird; B) Tissue culture propagation laboratory
in Taiwan; and C) Production greenhouse in the Unites States.
define the precise factors essential for maximum plant growth and development. The practical results of this
research was the development of large-scale, production protocols (Fig. 3).
FUTURE POTENTIAL
Phalaenopsis production is now international in scope. For example, in one operation breeding occurs
in the United States. Selected clones are sent to Japan where tissue culture progation is initiated. Successful
cultures are then sent to China for mass proliferation. In vitro grown plantlets are next sent to the Netherlands
for greenhouse production. Finally, flowering plants are returned to the United States for sales. Very few
Phalaenopsis are bred, propagated, flowered, and sold in the same country.
At this time, production does not meet the demand. It is widely expected that sales will increase as
production increases. Demand for Phalaenopsis should continue well into the future as new types are developed. Based upon today’s breeding efforts, the cultivars of the future will have a compact growth habit, variegated foliage, fragrance, and be ever flowering.
REFERENCES
Beaumont, J.H. and F.A. Bowers. 1954. Interrelationships of fertilization, potting media and shading on
growth of seedling vanda orchids. Hawaii Ag. Expt. Sta. Tech. Paper 334:1–6.
Doi, M., H. Oda, N. Ogasawara, and T. Asahira. 1992. Effects of CO2 enrichment on the growth and development of in vitro cultured plantlets. J. Japan. Soc. Hort. Sci. 60:963–970.
Davidson, O.W. 1957. New potting medium lowers costs of production. Am. Orchid Soc. Bul. 26:409–411.
Endo, M. and I. Ikusiuma. 1989. Diurnal rhythm and characteristics of photosynthesis and respiration in the
leaf and root of a Phalaenopsis plant. Plant Cell Physiol. 30:43–47.
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Trends in New Crops and New Uses
Ernst, R. 1994. Effects of thidiazuron on in vitro propagation of Phalaenopsis and Doritaenopsis. Plant Cell
Tissue Organ Culture 39:273–275.
Evers, O.R. and A. Laurie. 1940. Nutritional studies with orchids. Ohio State Agr. Expt. Sta. Bul. 207:166–
173.
Fairborn, D.C. 1944. Gravel culture for orchids. Missouri Bot. Gard. Bul. 32:1–16.
Griesbach, R.J. 1981. Colchicine–induced polyploidy in Phalaenopsis orchids. Plant Cell Tissue Organ
Culture 1:103–107.
Griesbach, R.J. 1983. The use of indoleacetylamino acids on the in vitro propagation of Phalaenopsis orchids. Scientia Hort. 19:363–366.
Haas-von Schmude, N.F. 1983. Klonale Massenvehrung von Phalaenopsis. Die Orchidee 34:242–248.
Hinnen, M.G.J., R.L.M. Pierik, and F.B.F. Bronsema. 1989. The influence of macronutients and some other
factors on growth of Phalaenopsis hybrid seedlings in vitro. Scientia Hort. 41:105–116.
Homma, Y. and T. Asahira. 1985. New means of Phalaenopsis propagation with internodal sections of flower
stalks. J. Japan. Soc. Hort. Sci. 54:379–387.
Intuwong, O. and Y. Sagawa. 1974. Clonal propagation of Phalaenopsis by shoot-tip culture. Am. Orchid
Soc. Bul. 43:893–895.
Kirsch, O.M. 1960. Breeding of Phalaenopsis hybrids. Third World Orchid Conf. Proc., London, England.
Knudson, L. 1922. Non-symbiotic germination of orchid seeds. Bot. Gaz. 73:1–25.
Krizek, D.T. and R.H. Lawson. 1974. Accelerated growth of Cattleya and Phalaenopsis under controlledenvironmental conditions. Am. Orchid Soc. Bul. 43:503–510.
Kubota, S. and K. Yoneda. 1993. Effects of light intensity on development and nutritional status of
Phalaenopsis. J. Japan. Soc. Hort. Sci. 62:173–179.
Martin, T. 1988. Once upon a windowsill. Timber Press, Portland, OR.
Morel, G. 1960. Producing virus-free cumbidiums. Am. Orchid Soc. Bul. 29:495–497.
Ota, K., K. Morioka, and Y. Yamamoto. 1991. Effects of leaf age, inflorescence, temperature, light intensity
and moisture conditions on CAM photosynthesis in Phalaenopsis. J. Japan. Soc. Hort. Sci. 60:125–
132.
Park, Y.S., S. Kakuta, A. Kano, and M. Okabe. 1996. Efficient propagation of protocorm-like bodies of
Phalaenopsis in liquid medium. Plant Cell Tissue Organ Culture 45:79–85.
Poole, H.A. and J.G. Seeley. 1978. Nitrogen, potassium and magnesium nutrition of three orchid genera. J.
Am. Soc. Hort. Sci. 3:485–488.
Porat, R., A. Borochov, A. Halevy, and S. O’Neill. 1994. Pollination–induced senescence of Phalaenopsis
petals. Plant Growth Regul. 15:129–136.
Post, J.H. 1985. Production and marketing of orchids. RHS International Centenary Orchid Conf. Proc.,
London, England.
Reisinger, D.M., E.A. Ball, and J. Arditti. 1976. Clonal propagation of Phalaenopsis by means of flowerstalk node cultures. Orchid Rev. 84:45–52.
Ratsek, J.C. 1932. Preliminary experiments on nutrients and the pH of water and nutrients as they affect
growth of orchid seedlings. Am. Soc. Hort. Sci. Proc. 29:558–561.
Rotor, G.B. 1949. A method of vegetative propagation of Phalaenopsis stem cuttings. Am. Orchid Soc. Bul.
18:738–739.
Rotor, G.B. 1952. Daylength and temperature in relation to growth and flowering of orchids. Cornell Expt.
Sta. Bul. 885:1–47.
Sagawa, Y. 1961. Vegetative propagation of Phalaenopsis stem cuttings. Am. Orchid Soc. Bul. 30:808–809.
Sakanishi, Y., H. Imanishi, and G. Ishida. 1980. Effect of temperature on growth and flowering of Phalaenopsis
amabilis. Bul. Univ. Osaka Pref. 32:1–9.
Sheehan, T. 1960. Effects of nutrition and potting media on growth and flowering of certain epiphytic orchids. Third World Orchid Conf. Proc., London, England.
Shoemaker, J. 1957. An economist view of the orchid industry. Second World Orchid Conf. Proc., Honolulu,
Hawaii.
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Tanaka, M. 1987. Studies on the clonal propagation of Phalaenopsis through in vitro culture. Bul. Fac. Agr.
Kagawa Univ. 49:1–85.
Tanaka, T., T. Matsuno, M. Masuda, and K. Gomi. 1988. Effects of concentration of nutrient solution and
potting media on growth and chemical composition of a Phalaenopsis hybrid. J. Japan. Soc. Hort. Sci.
57:78–84.
Tokuhara, K. and M. Mii. 1993. Micro propagation of Phalaenopsis and Doritaenopsis by culturing shoot
tips of flower stalk buds. Plant Cell Rpt. 13:7–11.
Tse, A.T., R.J. Smith, and W.P. Hackett. 1971. Adventitious shoot formation on Phalaenopsis nodes. Am.
Orchid Soc. Bul. 40:807–810.
Veitch, H.J. 1886. The hybridization of orchids. J. Royal Hort. Soc. 7:22–49.
Wang, Y. 1995. Phalaenopsis orchid light requirements during the induction of spiking. HortScience 30:59–
61.
White, E.A. 1942. American orchid culture. A.T. De LaMare, Co., New York.
Wimber, D. 1963.
Withner, C.L. 1942. Nutrition experiments with orchid seedlings. Am. Orchid Soc. Bul. 11:112–115.
Zhou, T. 1995. In vitro culture of Doritaenopsis: comparison between formation of the hyperhydric protocormlike bodies (PLB) and the normal PLB. Plant Cell Rpt. 15:181–185.
Zimmer, K. and W. Pieper. 1977. Zur vegetativen Vermehrung von Phalaenopsis in vitro. Die Orchidee
28:118–122.
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Introduction
he world economy is shaped by
technological advances, domestic
market maturation, and strategic
international alliances. Borders are
becoming irrelevant in the context of
international travel and trade. The
challenge to the United States
Department of Agriculture, Animal
and Health Plant Inspection Service,
Plant Protection and Quarantine
(USDA-APHIS-PPQ) is to define the
AgencyÕs role in this global economy.
Future relevance, indeed survival, of
the Agency in this operating environment is contingent upon its ability to
effectively discharge three important
duties. First, and foremost, is the
safeguarding of AmericaÕs abundant
plant resources from invasive plant
pests. Second, is the expeditious and
secure admission of an increasing volume of goods and passengers into the
United States. Third, is the facilitation
of agricultural trade in compliance
with international obligations and
standards. Recent breaches of the
APHIS-PPQ safeguarding system that
allowed entry of dangerous invasive
plant pests into the U.S. have raised
concerns that current organizational
policies and procedures are inadequate to execute these functions.
T
Recognizing the need to enhance the
effectiveness of current safeguarding
procedures, the Agency sought input
from stakeholders through a formal
review process. Under a cooperative
agreement with APHIS-PPQ, the
National Plant Board (NPB) assembled
a panel of external stakeholders composed of representatives from academia, government, industry, and
REPORT
non-governmental organizations. The
Review Panel included two
Chairpersons and five Committee
Chairs, as well as the Project Advisor
(a former APHIS-PPQ Deputy
Administrator), and a Project
Specialist. The Review Panel was assisted by thirty-three external stakeholders assigned to four committees
by subject matter expertise. Guidance
and oversight was provided by the
APHIS-PPQ Steering Committee.
Committee charges included, but were
not limited to, addressing the following points. The Pest Exclusion
Committee examined the effectiveness
of the current system for protecting
U.S. borders from unauthorized entry
of invasive plant pests and how offshore activities can be employed to
maximize the efficacy of this system.
The Pest Detection and Response
Committee investigated the adequacy
of mechanisms employed for early detection of, and response to, invasive
plant pests that penetrate border defenses. The International Pest
Information Committee examined
methods for gathering and disseminating information to maximize the efficacy of the safeguarding system,
including the availability of worldwide
databases for identifying and determining the potential impact of global
threats to American plant resources.
The Permits Committee studied the
adequacy of current permit procedures by which regulated products
and organisms are allowed to enter
the U.S.
Safeguarding American Plant Resources
1
Review Committees, working over a
three month period, acquired comprehensive background information
through a broad-based approach. Site
visits were made to maritime ports,
airports, land border crossings, and
other PPQ field and staff locations.
Formal interviews conducted with
plant health regulatory officials from
five foreign countries and cooperating
Federal agencies were supplemented
by conversations with APHIS employees and representatives from academia, industry, scientific societies, the
traveling public, port authorities, importers, environmental groups, and
animal health groups, as well as a
written survey of officials from state
departments of agriculture and state
forestry units. Literature searches and
studies of statutes, authorities, and
prior review reports provided additional documentation. Initial findings
and recommendations derived from
these sources were submitted to 65
external stakeholders whose comments were considered for incorporation into the final document.
Resulting recommendations extend
beyond narrow agendas of individual
stakeholders to the overall mission of
the safeguarding system. The Review
Panel has broadly prioritized its recommendations (Summary of Issues,
Findings and Recommendations) and
will be available to APHIS-PPQ to clarify and support implementation of
these recommendations (see
Implementation and Accountability).
Budgetary concerns and unaddressed
issues, both of which are outside the
scope of this Review, will be considered during the implementation
phase.
The Role of Safeguarding
The American safeguarding system is
composed of a complex network of
programs, decisions, and actions focused on preventing the entry and establishment of invasive plant pests in
2
REPORT
the form of arthropods, pathogens,
and noxious weeds. For the purposes
of this discussion, plant resources are
defined as agricultural food and fiber
crops; horticultural crops such as
fruits, vegetables, nursery and floral
plants; forestry resources; and natural resources including native
species and ecosystems. Historically,
agriculture has been viewed as the
primary beneficiary of the safeguarding system, however, the economic
benefits of protecting plant resources
accrue broadly. Freedom from invasive plant pests minimizes agricultural production costs while
enhancing product quality and marketability. The result is an abundant
and affordable supply of food, fiber,
plants, and plant products for domestic and export markets. Compliance
with phytosanitary standards provides
a comparative advantage in many
agricultural products and has secured
U.S. exporters a top share in the
global marketplace with exports totaling $60.4 billion in 1996. The value
of agricultural trade in the U.S. economy is illustrated by a 1996 agricultural surplus of $26.8 billion during a
period when the non-agricultural
trade account was in deficit by $235.1
billion (U.S. Agriculture and World
Trade, 1998). Agricultural industries
further impact the economy through
employment of approximately 17% of
the U.S. workforce.
The societal benefits of safeguarding
reach far beyond agricultural contributions to the economy, they ensure a
healthy environment and an extensive
natural resource base. North
American plant resources are highly
vulnerable to the impacts of invasive
plant pests, resulting in dramatic economic and environmental effects.
Introduced invasive plant pests result
in an estimated $41 billion annually
in lost production and in prevention
and control expenses (GAO Report,
1997). These are costs paid either directly or indirectly by the American
Safeguarding American Plant Resources
taxpayer. In addition to the direct economic damage, invasive plant pests
also reduce the general quality of life
by stripping towns and forests of important plant species such as the
stately American elm and the chestnut. Other foreign imports in the form
of pesky weeds such as kudzu, crabgrass, and the ubiquitous dandelion
plague the daily life in this country.
APHIS-PPQ is the primary Federal
agency charged with designing, implementing, and evaluating the safeguarding system. Responsibility for
preventing entry of invasive plant
pests into the United States was delegated to the Agency by the United
States Congress through statutory
law contained in eleven separate acts
passed since 1912. Administrative law
contained in the Code of Federal
Regulations includes quarantine and
inspection requirements that provide
the framework for orderly movement
of agricultural products, other commodities, and passengers across U.S.
borders. International obligations require that scientifically-based risk assessment support these regulatory
requirements without being overly restrictive to trade. Domestic programs,
administered jointly with the States,
function within a similar framework
to prevent or slow the spread of invasive plant pests of Federal interest
within the U.S.
Although the legal mandate for safeguarding activities rests with APHISPPQ, the system relies on
collaboration with other USDA units,
as well as several Federal agencies,
state and local departments of agriculture, academia, environmental organizations, and industry. The
safeguarding framework extends beyond U.S. borders through Agency
participation in setting plant health
standards with the North American
Plant Protection Organization (NAPPO)
and the International Plant Protection
Convention Secretariat of the United
REPORT
NationsÕ Food and Agriculture
Organization and through trade negotiations with partners worldwide. The
challenge faced by APHIS-PPQ is to
build upon domestic and international partnerships to assume an authoritative role in phytosanitary
negotiations that ensures continued
market access, while simultaneously
protecting both agricultural and environmental sectors of society.
Processing and disseminating scientific information in a relevant and persuasive manner will enhance the
ability of the Agency to retain this
leadership position in a global economy that requires a broadly shared
knowledge base.
The Review Panel recognizes that
continued relevance and success of
the American plant safeguarding
system is contingent upon a
comprehensive statutory framework
from which a clear conceptual plan
and specific goals are derived. The
Agency must embrace several
fundamental values in shaping an
effective organizational structure.
Dynamic leadership is required to
envision a progressive and
transparent system design, but
commitment at all levels within the
Agency is key to implementation of
this vision. The Agency vision must
create an organizational culture that
facilitates efficient administration,
optimal alignment, and empowerment
of personnel at all levels. Leadership
must maintain a transparent process
for executing safeguarding mandates,
a process that instills trust through
effective communication with all
stakeholders. Decisions must be
based on scientific evaluations and
consider application of relevant
technological innovations. The Review
Panel addresses these issues through
discussions of core competencies in
leadership, risk-based management,
partnership development,
communication, information retrieval,
research and technology, and other
Safeguarding American Plant Resources
3
overarching issues. Committee reports
present detailed findings and
pertinent recommendations in each of
four areas: pest exclusion, pest
detection and response, international
pest information, and permits. The
interactive nature of the safeguarding
system is reflected by overlapping
recommendations in committee
reports and overarching issue
sections. This is intentional as it
provides continuity.
the importance of USDA participation
was pointedly obvious. The role of
USDA, and APHIS-PPQ in particular,
in executing this order as it pertains
to invasive plant pests cannot be
overstated. The Agency must now
strategically position itself to retain a
leadership role in protecting American
plant resources.
The Agency must now strategically
position itself to retain a leadership
role in protecting American plant
resources.
APHIS-PPQ has a unique opportunity
to create its own future by defining
the AgencyÕs emerging role in regulating invasive pest risks arising from an
expanding and complex world economy. Relevance of the Agency in this
operating environment is contingent
upon its ability to effectively discharge
functions in safeguarding, importation, and trade facilitation. Societal
benefits of these functions reach far
beyond agriculture by insuring a
healthy environment and an extensive
natural resource base. All of society
benefits from the exclusion of harmful
invasive species and bears the consequences of introduction in the form of
the added tax burden for management
programs, increased food costs, or reduced recreational value of public and
private lands. Recognizing the societal
benefits of protecting the environment
from invasive species, President
Clinton issued Executive Order 13112
on February 3, 1999. The goal is to
prevent the introduction and minimize the impact of invasive species in
all types of ecosystems. By establishing the Invasive Species Council with
oversight by the Secretaries of the
Interior, Agriculture, and Commerce,
4
REPORT
Safeguarding American Plant Resources
C h a p t e r
O n e
Overarching Issues
1.1 Authorities and
Obligations
Background: International
Obligations
The World Trade Organization (WTO)
Agreement on the Application of
Sanitary and Phytosanitary Measures
(SPS) deals with measures specifically
for the protection of plant life and
health. The SPS clarifies the rules and
discipline guiding the development of
plant quarantine (phytosanitary) measures. To prevent these measures
from impeding international trade,
they must be based on scientific principles and justified by risk assessment; provide a level of protection
appropriate only to the risk posed;
and, not unduly restrict trade. In addition member countries have agreed
that quarantine actions are to be
based on, and limited by, necessity,
and are developed to meet the standards of harmonization, equivalence
and transparency.
The International Plant Protection
Convention (IPPC) is a multilateral
treaty deposited with the DirectorGeneral of the Food and Agriculture
Organization of the United Nations
(FAO) and administered through the
IPPC Secretariat located in FAOÕs
Plant Protection Service. Currently
107 governments, including the U.S.,
are contracting parties to the IPPC.
The purpose of the IPPC is to secure
common and effective action to prevent the spread of pests of plants and
REPORT
plant products and to promote measures for their control. The
Convention provides a framework and
forum for international cooperation,
harmonization and technical exchange in collaboration with regional
and national plant protection organizations. The IPPC plays a vital role in
trade as it is the organization recognized by the WTO-SPS Agreement as
the source for international standards
for phytosanitary measures (ISPMs)
affecting trade.
Following the adoption of the WTOSPS agreement, the IPPC was revised
to better enable it to fulfill its role as
the body to provide guidance and disciplines for the application of the SPS.
The FAO Conference unanimously
adopted amendments to the IPPC in
November 1997. These changes update the IPPC and reflect its role in
relation to the SPS, primarily the institutional arrangements for standard
setting. Changes included provisions
that formalize the Secretariat and
standard setting as well as establish
the Commission on Phytosanitary
Measures. The revised IPPC will enter
into force only after ratification by
two-thirds of the contracting parties.
The North American Plant Protection
Organization (NAPPO) is a Regional
Plant Protection Organization (RPPO)
created under the authority of the
IPPC. NAPPO was formalized through
the signing of a Cooperative
Agreement by representatives of
Canada, the United States of America
and Mexico to encourage cooperation
in the field of plant protection.
Safeguarding American Plant Resources
5
NAPPOÕs objectives are to ensure that
cooperative efforts are made between
the member countries to prevent the
entry, establishment and spread of
regulated plant pests, while facilitating intraregional and interregional
trade in plants, plant products and
other regulated articles.
NAPPO develops and adopts regional
standards to harmonize member
countriesÕ phytosanitary measures to
facilitate the safe movement of regulated articles into and within the
NAPPO region; to support the work of
the NAFTA and the Sanitary and
Phytosanitary Measures Committee;
and to harmonize plant pest management programs in the NAPPO region
through the coordination of pest surveys. NAPPO encourages the development of hemispheric phytosanitary
standards through participation in
the Interamerican Coordinating Group
in Plant Protection; and collaborates
with other RPPOs and other international organizations to protect the
hemisphere from regulated pests; and
assists in the development and delivery of training and technical assistance programs in the hemisphere.
Risk analysis is viewed as the key to
evidencing effective, defensible
quarantines, and therefore key to
any SPS disputes.
On a global level NAPPO supports the
IPPC by assisting in the development
of international standards for phytosanitary measures and monitoring
their application within the NAPPO region; and exchanges technical information with other RPPOs and FAO,
concerning all aspects of plant protection.
As deepening integration of the world
economy continued to blur the lines
6
REPORT
between what would earlier have been
considered ÒdomesticÓ versus ÒinternationalÓ, measures to restrict imports have logically come under the
closest scrutiny. The SPS Agreement
seeks the high ground between allowing protection while disallowing protectionism. As written, the SPS
Agreement reflects the crafting of a
careful balance of rights and obligations designed to ensure that an SPS
measure is in fact intended to protect
against the risk asserted, rather than
to serve as a disguised trade barrier.
At the same time, implementation to
date makes it clear that the SPS does
not require what has been termed
Òdownward harmonizationÓ. No WTO
member is required to adopt an international standard if doing so would
result in a lower level of human, animal or plant health protection than
that government has determined to be
appropriate.
In practice, the SPS Agreement is generally viewed as a nascent legal system, with interpretation of the
Agreement evolving via case law. In
the short time the Agreement has
been in place, decisions made by the
Appellate Body (AB) have indeed supported a countryÕs right of sovereignty, that is, its right to determine
its appropriate level of protection.
However, members that adopt the
standards recommended by the IPPC
will be considered Òrebuttably presumedÓ to be in compliance with the
Agreement (Roberts, 1998).
In any case, transparency will become
more important as countries continue
to complain that phytosanitary measures represent non-tariff barriers to
trade. Compliance with the transparency provisions (especially the rationale for assumptions) is seen as
the key to effective and justifiable implementation of the SPS Agreement.
Risk analysis is viewed as the key to
evidencing effective, defensible quarantines, and therefore key to any SPS
Safeguarding American Plant Resources
disputes. Also important is the expectation of exporting members to evidence that the current phytosanitary
requirements of the importing contracting party(ies) are met.
That regulatory processes can be
ÒcapturedÓ by interest groups with a
vested interest in limiting competition
is well known. If the SPS Agreement
succeeds, it will be regarded as an important institutional innovation that
can withstand the influences of domestic interest groups that might
lobby for SPS measures for that reason alone (Roberts, 1998).
It is interesting to note that since its
adoption, the Agreement has brought
about a broad regulatory review
among WTO members in concert with
the agricultural industry. Many regulatory agencies are proactively modifying regulations to comply with the
Agreement. The United StatesÕ regionalization approach to animal quarantine issues is particularly notable in
this regard (Roberts, 1998).
At the conclusion of the Uruguay
Round, the WTO signatories agreed to
review the SPS three years after its
entry into force. The review, scheduled to occur in 1999, is to focus on
progress in implementing the SPS
Agreement. It will evaluate provisions
relating to the requirement that measures be based on science and risk
assessment, transparency and notification procedures, harmonization of
international sanitary and phytosanitary standards, and distinctions between the levels of sanitary and
phytosanitary protection established
in different situations. In particular,
the U.S. will be assessing the contribution that implementation of the SPS
makes to the reduction of unjustified
barriers to agricultural trade, while simultaneously preserving U.S. safeguarding capabilities.
REPORT
Background: Domestic
Authorities
APHIS-PPQ programs are currently
implemented under authorities found
in 11 different statutes dating back as
far as the Plant Quarantine Act of
1912. The laws were generally passed
to address Òcrises of the day;Ó both
overlap and gaps exist. A number of
specific regulations have been promulgated under these statutes. For
the purposes of the safeguarding review, those found under 7 CFR 319,
such as the regulations governing importation of fruits, vegetables, propagative material, logs, lumber and
unmanufactured wood, as well as
noxious weed regulations (7 CFR 360)
are most relevant. Because these regulations are components of pest exclusion strategies, specific discussion
appears in the Pest Exclusion section
of this report.
The Plant Protection Act is a legislative proposal introduced in the 106th
Congress as H.R.1504 and S.910,
with broad support from an array of
stakeholders. It was developed over
the last decade to streamline and consolidate the 11 plant-related statutes
that provide APHIS its authorities. A
key motivation for this revised legislation is to address the growing need for
transparency in plant quarantine laws
as part of the global approach to trade
dispute settlement. Also compelling is
the need to create enforcement provisions that serve as a deterrent to increasing illegal activities that threaten
U.S. agriculture and the environment.
The Plant Protection Act would clarify
APHIS authority to squarely address
invasive plant pest threats to natural
areas and Ònon-economicÓ plant resources as well as agriculture. It
would also provide enhancements in
such key areas as the regulation of biological control agents, and authorities to better identify and manage
noxious weeds. The current legislation
Safeguarding American Plant Resources
7
reflects consensus-building efforts in
the mid-1990Õs in response to changing demands on the plant protection
functions of the government.
Enhancements contained in the proposed Plant Protection Act are consistent with international obligations.
Executive Order 13112 on Invasive
Species (EOIS) was issued by the
Clinton Administration on February 3,
1999. The EOIS seeks to coordinate
and enhance Federal government efforts to prevent the introduction of invasive species and to provide for their
control. The EOIS calls for a council
comprised of key Federal agencies,
charged with coordinating activities
and developing an Invasive Species
Management Plan. A stakeholder advisory committee is also to be established. It is widely believed that the
EOIS will sharpen the focus, and resources, devoted to Federal, state,
and local invasive plant pest safeguarding and management activities.
Findings
While APHISÕs statutory authorities
have served the agency reasonably
well over the years, the patchwork of
laws has not kept pace with changing
needs resulting from trends in technology, commerce and travel. The 11
statutes are poorly coordinated; at
times, APHIS has been unsure which
authority to apply in a given case.
The need for transparency of statutory authorities is greater than ever,
given the move toward regionalization
and the mandate that quarantines be
risk-based. Regulatory transparency
and uniformity will help to facilitate
both domestic and international
trade, consistent with pest safeguarding goals and international obligations.
National goals to safeguard plant resources are only achievable if adequate enforcement capabilities are
8
REPORT
provided for in the statutory framework of APHIS. A comprehensive set
of penalties, investigative and enforcement tools will help deter violations
and ensure that any enforcement action is consistent with the violationÑ
thus strengthening the safeguarding
system. The current enforcement and
investigative authorities of APHIS are
inadequate to meet the pest safeguarding challenges facing the U.S.
As the primary Federal agency responsible for safeguarding plant resources from invasive plant pests,
APHIS programs should be foundational to the success of the EOIS. The
APHIS has historically focused on
pests of agriculture. The Review determined that the goals and operational
aspects of safeguarding both agriculture and natural ecosystems are too
intertwined to be parsed out and delegated to different agencies. The APHIS
must step up to the plate with regard
to environmental resource protection.
The Review found the Plant Protection
Act initiative to be supportive of and
compatible with EOIS implementation.
A clear, streamlined, and modern
statutory framework will facilitate the
achievement of pest safeguarding
goals, including effective pest exclusion, detection and emergency response, and management. Many
specific proposals found within this
report depend on the clarity and enhanced authorities that would become
reality with the passage of the Plant
Protection Act.
Recommendations
■ 1 Work with Congress and stakeholders toward enactment of the Plant
Protection Act, as introduced in the
106th Congress as H.R.1504 and
S.910.
■ 2 Show leadership in acceptance of
Safeguarding American Plant Resources
the revised text of the IPPC by encouraging official notification of acceptance to the FAO by the U.S.
Department of State.
■ 3 Take a leadership role in implementing the SPS Agreement. With regard to the upcoming round of WTO
negotiations, the SPS Agreement
specifically should not be reopened.
The existing text represents a delicate
balance of rights and obligations
which, as interpreted so far, is consistent with pest safeguarding goals and
a science-based approach for assessing and managing pest risks.
■ 4 Set an international example
through a commitment to continually
improve the safeguarding system, providing a leadership precedent for
other countries.
■ 5 Participate fully in the implementation of the Executive Order on
Invasive Species.
1.2 Risk Based
Management
One of the most important emerging
roles of government has been the regulation of risk. As APHIS moves away
from interdiction as its primary safeguarding strategy, predictive models
will become increasingly important to
target activities and resources, and to
justify quarantine regulations.
Continuous improvement of all predictive models will be key to future
regulatory decisions in all areas of the
safeguarding program.
The three components of risk analysis
are risk assessment, risk mitigation,
and risk communication. Pest risk
analysis, as a tool, estimates as far as
possible the level of risk and potential
harm presented by an activity. It can
be used to evaluate and predict high
or low risk pests, pathways and commodities, and can estimate and chart
changes in the levels of risk posed.
REPORT
The APHIS has models for pest, commodity and pathway analysis that can
and are continually modified and
used for this purpose. These models
were derived from a generic process
designed to be flexible and dynamic
enough to accommodate a variety of
approaches to pest risk depending on
need and to evolve with the state of
the art. Development of this generic
process leaned heavily on the National
Research CouncilÕs 1993 ÒEcological
ParadigmÓ project (Orr, 1993).
A general obstacle to advancing the
science of biological pest risk analysis
has been the lack of research directed
towards invasion biology. More to the
point, a major obstacle to the evolution of the APHIS pest risk analysis
process has been, and remains, the
lack of reliable data. In the absence of
robust data, APHIS relies on a
process that analyzes potential pest
introductions based largely on highly
subjective and uncharacterized expert
judgment in the assignment of risk
values. Yet, reliable information is
critical to understanding and predicting invasion threats, evidencing necessity of phytosanitary measures,
and managing resources effectively
and efficiently.
Tile from China with solid wood packing material infested with
Cerambycid beetle larvae. Shipment arrived in containerized maritime
cargo at Long Beach, CA.
Safeguarding American Plant Resources
9
associated with them will constantly
change, and AQIM provides the
means to track these changes. For
this initiative to succeed, APHIS must
re-communicate and re-train its staff
on importance of pathway analysis
and data collection, then use the data
to make its operations more effective
and efficient.
Solid wood packing material under inspection for presence of
Cerambycid larvae
Risk Analysis and RiskBased Management
APHIS is working to integrate risk
analysis-generated information in
order to prevent the entry and establishment of invasive plant pests and
expedite entry of passengers and
cargo. This information is also used in
budget development, resource allocation, program design, and in port operations task prioritization. An
example of where this management
strategy is used is the Agricultural
Quarantine Monitoring (AQIM)
Program. AQIM, as well as other random survey projects, gather (survey)
information to estimate pest threat
rates and deterrence effectiveness to
target resources and staff more efficiently and effectively. Over 40 ports
collect random sample data to evaluate port performance and pest risk.
Unfortunately, the effectiveness of this
program is hampered by concerns
over the accuracy of data collected.
These concerns relate to a lack of field
staff training, an institutionalized
culture trained to ÒprofileÓ; and, fear
that the data will be used to reduce
staffing. However, information
developed to date can be used to
establish an informational baseline.
As pathways are dynamic, the risks
10
REPORT
Risk management for inspection activities relies on an accepted tolerance
(confidence level) to statistically determine the inspection level and methodology to be used. In the late 1980Õs,
APHIS began using fixed-risk (hypergeometric) sampling systems in inspection sampling programs. This
sampling system is used successfully
for pear leaf blister moth and light
brown apple moth for apples from
France and Australia, respectively.
Use of this tool should continue to be
expanded.
Pending import permit requests awaiting APHIS pest risk analysis date
back to 1991. This backlog was unavoidable after the unit responsible
for risk analysis took a deep cut during the AgencyÕs downsizing effort. In
addition to staff augmentation, one
possible method to alleviate the workload pressure would be make the
process more efficient by categorizing
and prioritizing import requests based
on an initial pre-assessment or assumption of risk. Some movement in
this direction has already occurred,
with the more in-depth quantitative
risk analysis reserved for use only in
the case of major rulemaking. Further
progress would entail the development
and refinement of additional pest risk
assessment models that would incorporate and standardize levels of information needed to perform the
analysis. Another would be involvement of external stakeholders in the
identification of issues and establishment of timeframes for completion of
rule development.
Safeguarding American Plant Resources
Pest Risk Analyses: The Role of Information
Sound Pest Risk Analyses are essential tools for choosing appropriate policies
aimed at avoiding exposure of plant resources to unacceptable pest risks. In
order to obtain reliable data for conducting relevant and sound Pest Risk
Analyses, the official safeguarding agency will utilize information sources and
study protocols as follows:
¥ To import a specific commodity, compile all literature, correspondence and
other documentation, and search all pest/commodity databases dealing with
potentially invasive plant pest species associated with the commodity of interest. (A similar approach is employed to determine the possible pathways for
entry and establishment for an invasive plant pest of concern, without a particular commodity import request.)
¥ Conduct a rigorous evaluation of the literature and other documents,
pest/commodity databases, and create a summary database. Evaluate conflicting or incomplete reports and the expected accuracy of various reports or databases.
¥ Engage scientists with relevant expertise in the area of production, and/or invite interested parties to contract for studies, or have the official safeguarding
agencyÕs specialists conduct scientific studies in the export region on the commodity of interest and any invasive pest species.
¥ Build a knowledge base derived from detailed country surveys on indigenous
and introduced pests and associated commodities that may eventually be exported to the U.S.
¥ Replicate studies across commodity variety, commodity maturity, source of
commodity (region; cultural and pest management treatments utilized, etc.),
and environmental or physical conditions present within the expected range of
mitigation treatments. Find the limit(s) where mitigation measures partially fail.
¥ Carry out transparent Pest Risk Analyses following international standards
and guidelines.
¥ Validate assumptions and mitigation measures with a feedback system using
data generated from U.S. inspections at ports of entry, random inspections of
particular loads (especially during the early years of an export program or when
conditions have changed), and new sources of data from the exporting country,
for example. Periodically evaluate changes in conditions and re-examine actual
or proposed import plans or processes in order to optimize risk mitigation.
REPORT
Safeguarding American Plant Resources
11
Risk Analysis and
Rulemaking
Risk analyses are used to scientifically justify quarantine action (phytosanitary measures) as required by
international standards (WTO-SPS,
IPPC, NAFTA). These standards require that such actions be transparent based in necessity. To
scientifically justify the need for plant
quarantine regulations, risk analyses
estimate the likelihood of successful
invasive plant pest introductions, and
potential impacts and severity.
International standards also require
that phytosanitary measures employ
the least restrictive measures necessary to accomplish their stated objective. The emergence and development
of new information, and mitigation
strategies, will continue to make pest
risk estimations dynamic. Thus, it will
be even more essential that pest risk
analysis methodologies continuously
improve to adequately, consistently,
and transparently assess, mitigate,
and communicate all the risk factors
so that in the end regulatory decisions made are fully justified and
legally defensible.
Though the risk analysis methodology
used by APHIS continues to evolve
and improve, the risk characterization
portion of each assessment is not yet
well developed. Whereas, the process
is being made more transparent, the
assumptions chosen for individual
analyses and the characterization of
uncertainty are usually absent.
It should be noted that a weediness
assessment has now been added as
the first filter to improve the process,
but the science of weediness risk assessment is a work in progress.
Therefore, any model in current use
must be considered limited in its ability to characterize weediness and this
uncertainty should be characterized
accordingly in any assessment.
12
REPORT
As risk analysis is essentially a tool
for extrapolating and applying scientific data, it must be understood that
the process is assumption- and valueladen (Carnegie Commission Report,
1993; Orr, 1993). At this time, the
analysis methodology has not yet developed a means to effectively characterize and communicate uncertainty
and the degree of uncertainty, nor
does it provide a careful evaluation
and documentation of use of expert
judgment and the assumptions chosen.
Assessment questions arise in the
pathway-initiated qualitative model,
for example, because climate-host interaction is limited to plant hardiness
zones and neither seasonality nor relative humidity is considered under
this risk element or under dispersal
potential. As a result pathogen risks
in particular are vulnerable to mischaracterization. Host range is based
on potential to cause damage to one
or many hosts, but impact analysis
tends to be limited to the host proposed for entry.
Movement of a potential pest to a
suitable area has been based on geographical suitability and does not take
into consideration demographic factors. The likelihood that a product will
move to a suitable area is highly dependent on the population of an area.
Further, it bases the ability to successfully colonize on introduction into
a commercial production area, not on
the equally or more likely initial introduction into an urban setting. Finally,
there is no mechanism to evaluate the
impact of aggregate risks when multiple pests are being analyzed.
Risk Communication
The APHISÕ rulemaking process is
viewed both internally and externally
to be in a state of Òparalysis of analysisÓ. It is viewed this way for two reasons: lack of adequate communication
Safeguarding American Plant Resources
and understanding of risk and inadequate stakeholder outreach and collaboration.
Expansion of APHISÕs risk communication efforts, particularly those targeting stakeholder collaboration prior
to rulemaking, are particularly important because there are so many conflicting interpretations about the
nature and significance of risks.
Besides providing a bridge to knowledge gaps, collaboration facilitates an
understanding of perception and values and enables informed decisionmaking. Collaboration enables
participation. Collaboration at the beginning of the processÑincluding information solicitation from the
academic communityÑcan deflect polarization, minimize opposition and
blocking efforts, and preclude the
need for a more formal time-consuming peer review process.
For as long as risk analysis has been
used to evidence regulatory action, all
involved parties have struggled with
the characterization of risk, or risk
perceptionÑwhat constitutes Òacceptable riskÓ or Òappropriate level of protectionÓ. What risk assessment (and
thus analysis) methodologies cannot
do is determine what is acceptable or
appropriate because these are value
judgments characterized by variables
beyond the systematic evaluation of
information (Orr, 1993).
Initial assumptions that plant protection regulatory agencies could rely
solely on the ÒhardÓ sciences as a
basis for risk analysis was logical.
But, perception of risk, thus the need
for protection, is largely a value judgment. Among other factors, what is
valued (or feared) in a society influences where and how its policymakers
will seek appropriate protection.
Several major disputes over necessity
have arisen and remain unsettled because of differences in risk perception. In other cases, the supporting
REPORT
risk analyses have been judged inadequate.
As they already provide standardized
measuring systems to assess necessity, transparency and equivalence,
scientifically based strategies to estimate the importance of cultural differences may in the future offer potential
for assessing the validity of a determination of equivalence in regulatory
rulemaking. Information that provides
some understanding of cultural values may help reduce controversy and
litigation, enhance risk communication, and facilitate dispute resolution.
The use of cost benefit analysis in
quantitative risk analysis offers the
potential to evidence economic and
environmental impacts by comparing
the strength of measures proposed for
risk mitigation, and the cost, against
a quantified estimate of the benefit.
Recommendations
■ 6 Provide the resources necessary
to continuously develop a thorough
and relevant knowledge base for pest
risk evaluations, one that upgrades
its scientific literature and its pest interception database. Make continuous
improvement a core value for risk
analysis throughout the Agency.
■ 7 Fund research on invasion biology.
■ 8 Prioritize and provide adequate
staffing for pest risk analysis activities
and upgrade the education, training
and tools of the risk analysis staff to
enable continuous improvement of the
risk analysis models.
■ 9 Continually educate and communicate with PPQ staff on the importance and need for risk based
decision-making.
Safeguarding American Plant Resources
13
■ 10 Revise funding and staffing allocation guidelines for port operations
based on information developed by
risk analysis and management tools.
■ 11 Incorporate stakeholder collaboration and scientific consultation into
its risk assessment development
process. With stakeholder consultation, identify issues and develop time
frames for completion of rule development, and models for risk communication.
1.3 Leadership
Background
The Review Panel found that politics,
economic pressures and changing expectations have created a profound
shift in the environment in which
APHIS-PPQ leaders must perform. The
geometric increase in demands on
APHIS from the Secretary of
Agriculture, the U.S. Congress and
even the White House reflects the increasing recognition of technical or
scientifically-based trade barrier resolution as the key to future trade. This
has come about with the global reduction in tariff barriers through the
Uruguay Round of the General
Agreement on Tariffs and Trade, the
subsequent adoption of the
Agreement on the Application of
Sanitary and Phytosanitary Measures
(WTO-SPS), and regional trade agreements whether including the U.S. as a
signator or not.
Demands for information, which may
not exist or be organized for the needs
of the moment, are now made with
turn-around time of hours rather
than days. Some of the countryÕs
highest-visibility trade disputes in the
past five years, in particular, fall in
this realm of WTO-SPS issues, for
which APHIS is the responsible
agency regarding animal and plant resources and trade. At the same time,
the U.S. Congress and numerous
14
REPORT
stakeholders are calling for accountability on apparently more frequent
breaches in the safeguarding system.
Simultaneous to these pressures, conflict and dissonance appear to characterize the relationship between
APHIS-PPQ and APHISÕs employee
union. In fact, the entire culture of hierarchical organizations in the United
States has gone through a massive
change in both the private and public
sectors. This change is not yet complete. Models and approaches are still
being developed, and many corporate
employees as well continue to feel unsettled or threatened. Just one
change Ñ automation and computerization of the work place Ñ is revolutionary for anyone without early
training in these skills.
Any career personnel at the leadership level today entered the Agency
when the mission was clearly focused
on protecting American agriculture.
Now, in addition to its primary responsibility to prevent the entry and
establishment of invasive plant pests,
APHIS must facilitate trade, expedite
the entry of passengers and cargo,
and take on other emerging issues related to the safeguarding mission,
such as biotechnology oversight.
These multiple roles have led to conflicting cultures, competition for attention and resources, and employee
confusion regarding the Agency mission. Although core public service values, including customer service,
innovation, continuous learning, creativity, and a sense of meaning and
job importance still permeate the
Agency, APHISÕs current corporate
culture can be characterized in terms
of alienation rather than alignment.
The new approaches to management,
the new generation work force that
has no sense of job security and
perhaps the loyalty that goes with it,
and economic fluctuations that
impact workload and funding are key
Safeguarding American Plant Resources
ingredients to the new environment
that APHIS-PPQ leaders face. These
challenges are framed by the overall
governmental climate of downsizing
and unfunded new mandates without
the long view or strategic planning.
During the government downsizing
effort, the Agency lost both its
knowledge base and its next
generation of leadership. Anchoring
and institutionalizing change will
require sufficient commitment, time
and effort to identify and develop new
leadership and to ensure that
management personifies the new
approaches.
Findings
An example of good leadership was
found in the creation of the Trade
Support Team (APHIS-TST) during the
negotiations for the NAFTA and GATT
Uruguay Round Agreements. The addition of these multilateral negotiations on top of on-going bilateral
negotiations and disputes put APHIS
in a reactive mode on information
generation and analysis and decisionmaking. When this was recognized, a
new division was created and staffed
using crosscutting expertise from
within the Agency. Key to the present
success of this initiative was its timely
formation as an experiment and the
thorough, in-depth review that took
place two years after its creation. The
review did lead to changes in staffing
and a statement of the mission of this
division: ÒTo add analytical and
strategic value to the APHIS trade
mission of maintaining and expanding
trade while ensuring a biologically
sound and consistent trade policy.Ó
The establishment of the New Pest
Advisory Group (NPAG), and the
APHIS-PPQ Center for Plant Health
Science and Technology (CPHST) in
Raleigh where the NPAG resides, are
even more recent examples of leadership recognizing the need for strategic, preventive and preparatory work
REPORT
as an on-going function of APHIS in
order to successfully carry out the
emergency programs. The institutionalization of a strategizing resource
available to the leadership is critical
for an Agency that is by definition
constantly charged with handling
emergencies.
Despite some successes, each Review
Committee identified deficiencies in
leadership as hampering the safeguarding process. Each committee report points to opportunities, similar to
these successful examples given
above, for the formation of a strategic
focal point in the Agency for functions
in support of the safeguarding mission. The assignment of accountability, authority and resources seems to
have become clouded in the recent
years of rapid change.
APHISÕs Past Visioning
Efforts
In 1994 APHIS-PPQ conducted a
Future Search Conference to form a
vision and set the AgencyÕs course for
the future. A design team drafted the
vision statement that was distributed
in 1995 to all employees and a number of external stakeholders for review. Later in 1995 the PPQ
Management Team identified nine
component strategies that could be
implemented immediately and signed
a commitment paper for implementation. In 1996 PPQÕs National
Partnership Council established nine
vision core teams to implement the
listed strategies. These items have
since been implemented and management is in the process of drafting a
second commitment paper. These
teams also identified additional vision
goals in the areas of partnership and
teamwork, learning, communication,
accountability and the changing
workforce. Other initiatives and initiative updates can be accessed by employees on APHISÕs intranet visioning
Web site.
Safeguarding American Plant Resources
15
Repeatedly, APHIS staff has asserted
that the catalyst that led to its visioning efforts was Dr. Lonnie King,
Administrator of APHIS from 1992 to
1996. While some staff still strive to
implement the visioning goals, most
efforts were largely abandoned when
he left the Agency. The process had
not been institutionalized or carried
on. With the partial failure of past efforts, each new effort to work from a
Agency-wide vision will confront a
stronger culture of cynicism and disbelief that does not trust leadership or
management.
Possibility for the Future
The Review Panel affirmed that management and leadership initiatives developed in the private sector are
relevant to a government organization
such as APHIS. Many of the recommendations stem from this fundamental conclusion. These new models
for leadership are discussed more in
the section on Management and
Organizational Design.
The movement towards quality as the
operating model for business and
government is continuing to expand.
This model, taken from the
professional services industry, is
founded in principles of leadership
and empowerment enabled by trust
(Peters, 1994). In an environment of
constant change and uncertainty, this
kind of model, founded on trust, will
be the key to successful
organizational change and survival.
Though trust may be difficult to
define, elements include integrity,
honesty, predictability, reliability,
responsibility and accountability.
Without it, APHIS-PPQ employees will
never be empowered to take
responsibility or assume risks to
continuously improve the
organization. The ability of PPQ
leadership to generate and
institutionalize a trust culture will lie
in its ability to reflect these elements
16
REPORT
along with a commitment to value and
to empower its employees. Leadership
trustworthiness must be the
foundation. Leadership must create
and obtain the structure and
resources (both human and material)
to carry out the work, or they cannot
become ÒtrustworthyÓ.
New Zealand, where safeguarding efforts are now largely privatized, has a
system so streamlined and transparent that Plant Protection officials can
put the decision back to Parliament
as to which program to cut if new demands are made without additional
funding. Often when presented with
such clear choices, political leaders
find new sources of funding. This level
of transparency may never be
achieved within the byzantine funding
mechanisms for APHIS, but upcoming
changes in the budgeting process present an opportunity to try.
The potentially-paralyzing circumstances present APHIS-PPQ with the
choice to either wear down its employees and leadership, and perform in a
non-stop crisis mode, or to create its
future: to rediscover, reconnect and
align itself to its mission, vision and
values. Based on comments received
by the Panel, APHISÕs role in trade facilitation is the most misunderstood
Agency activity. This role must be
clarified, both for employees and external stakeholders. The emergence of
trade facilitation as an important
mechanism to assure the continued
protection of AmericaÕs plant resources co-evolved with the development and implementation of the
WTO-SPS and NAFTA. While it is industryÕs role to seek and gain market
access, APHIS has a critical role in
the assurance that plant quarantine
actions for imports as well as exports
are scientifically justified and do not
represent an unnecessary barrier to
trade. The integration of all areas of
its safeguarding mission will hinge on
a harmonization of its own import
Safeguarding American Plant Resources
and export strategies. Both must be
brought into conformance with plant
quarantine principles and international standards of necessity, harmony, transparency and equivalence.
The power of a culture unsupportive
of change is currently well illustrated
in USDAÕs Food Safety and Inspection
ServiceÕs (FSIS) dilemma. FSIS and its
employees are on opposite sides in
court fighting over the AgencyÕs
Hazard Analysis and Critical Control
Point (HACCP) program.
Implementation of this program
caused a culture clash within FSIS
that has caused its employees, fearful
of the future, to challenge and
threaten what many consumers and
scientists view as the future of regulatory science for food safety
(Government Executive, February,
1999). This occurred because the organizational culture was not prepared
for the AgencyÕs movement towards a
more innovative regulatory strategy of
indirect oversight, away from its tranditional one of direct oversight. APHIS
has experienced a similar cultural
road block as it has sought to implement its agricultural quarantine monitoring program. As APHIS-PPQ looks
to innovate, it must create an environment and a process that allows
APHIS-PPQ to realign with its values
and to eliminate misalignment and
obstacles.
The APHIS-PPQÕs vision of its future
must guide assignment of staff and
resources as well as align and motivate all employees to take responsibility for achieving this vision in the face
of daily obstacles. Real change will
take time and effort. The APHISÕs past
reinvention efforts in this area have
been only marginally successful because the basic approach was incremental, the Agency did not measure
and acknowledge its successes, and
there were multiple turnovers in leadership before a vision and commitment to change was institutionalized.
REPORT
To implement this very daunting
process of continuous change and improvement, PPQ leadership must
begin making meaningful promises to
its employees that it can and will keep
(Covey, 1991). This will require anticipating the organizational and individual changes necessary to be able to
fulfill these commitments. With this in
mind, the Review Panel and each of
the four committees developed recommendations to serve as a blueprint
and, in the next phase of this process,
as an implementation plan for successful change. The challenge before
leadership is to value, invest in, empower and trust its front line employees. The challenge before APHIS-PPQ
as a whole is to become empowered,
responsible, and accountable for the
accomplishment of the AgencyÕs mission to safeguard AmericaÕs plant resources.
Recommendations
■ 12 Select and assemble a leadership coalition of 20 to 50 staff representing all levels of the organization
that will report directly to the deputy
administrator, to revise or clarify the
mission, vision and then identify the
values associated with the mission.
Then submit their findings to all employees for approval and acceptance.
■ 13 Identify education sources and
where necessary begin re-training the
Agency in the development of mission,
vision and value statements.
■ 14 Recognize and celebrate past efforts at mission and vision development.
■ 15 Require the coalition to identify
misalignments between the AgencyÕs
mission, vision, and values, and to
recommend how APHIS needs to address those misalignments.
Safeguarding American Plant Resources
17
■ 16 Identify Agency activities that directly fulfill the mission, then outsource, privatize or otherwise
re-assign the remaining activities.
1.4 Management and
Organizational Design
Extraordinary leadership alone will
not attain and sustain high performance, in the absence of good management systems. Global integration
and a surplus agricultural economy
mandate an organizational design
that will give the Agency the ability to
move fast and add value, that is deliver quality service (Peters, 1994;
Bennis and Nanus, 1997).
successful changes in this area with
the formation of the state plant health
director system. This change has
brought the Agency into much closer
communication with the states and
industry and its external collaborators
have benefited.
Adding value, particularly once the
Agency reconnects with its mission,
will also come from its ability to capture, process, analyze, apply and
communicate its unique reservoir of
knowledge on sanitary and phytosanitary issues and to quickly bring it to
bear as needed in close collaboration
with its external stakeholders.
Government, by design, is positioned
to be the lynchpin that brings many
Moving fast means that the
Government, by design, is
AgencyÕs structures and systems must change, so that
positioned to be the lynchpin that
the AgencyÕs front line can be
brings many different interests and
in touch with its upper mancultures together to develop
agement. Management must
be able to communicate
effective science-based safeguarding
closely with its front line
strategies.
staff, create a safe environment for participatory decision-making and, in return,
different interests and cultures toemployees must be able to formulate
gether to develop effective sciencemeaningful proposals. Survival in a
based safeguarding strategies.
knowledge economy (Drucker, 1998),
Particularly in trade negotiation and
mandates a collapsed organizational
international standards development,
design that recognizes trust as the
APHIS-PPQÕs ability to target and
most critical efficiency and values the
shape a message persuasively and,
importance of learning, sharing, and
more important, the ability to listen
using information. The professional
and hear concerns and different viewservices industry model has been unipoints will provide the Agency a
versally adopted because it came into
greater voice and influence in trade
being specifically to expeditiously
negotiation and issue resolution.
manage and leverage knowledge as
the means to gain, effectively service,
and keep its customers (Peters, 1993).
Development of a servant leadership
paradigm to serve society at large, as
well as its other stakeholders, must
The right design can provide for the
be a core value (Peters, 1994). The
removal of layers without any loss in
APHIS management paradigm continefficiency, improve accountability, and
ues to be one of control, yet the
save money while allowing the Agency
rapidly changing operational environto shift personnel and funding dollars
ment clearly shows that perpetuation
to the front line. The APHIS-PPQ has
of command and control paradigm is
already made some strategic and
18
REPORT
Safeguarding American Plant Resources
inefficient and unresponsive. The
APHISÕs continued adherence to this
paradigm has resulted in an Agency
that is always in a crisis mode with
no time or energy to remember, let
alone be directed by, its mission.
The APHISÕs historic management approach seems rooted in the belief that
people cannot work without careful
supervision. Such misalignments tend
to occur because years of ad hoc policies and practices have become institutionalized and have obscured the
AgencyÕs underlying values. The task
then is to create an environment and
a process that will enable its people to
safely identify and eliminate these
misalignments. Successful change will
likely require an Agency policy and
culture shift away from dependence
upon management and manuals to
one that is self-organized, well integrated and interdependent. The new
agency must be organized with the
mindset that management will lead
while lower level employees will manage.
Recognition of Employees
as Primary Stakeholder and
Agency Asset
An important component to the
AgencyÕs success will be the recognition that its employees are its most
important stakeholder and asset, and
as such deserve its highest investment. Under present conditions, with
downsizing of staff, frequent reorganizations, unfilled positions, lack of direction and supervision, staff morale
has deteriorated. This has led to a
fragmentation of the Agency where
staff are placed in positions without
proper training and without proper
supervision because frequent staff rotation policies do not recognize levels
of expertise needed for effective program implementation.
Beginning in 1993, externally directed
staff cuts of unparalleled size necessi-
REPORT
tated by funding shortfalls and reinvention initiatives were carried out
with little regard for the long term impact on the ability of the Agency to
carry out its mission. None of these
efforts took into consideration such
factors as core responsibilities and
skills balance. This effort accomplished only one thingÑit made the
organization smaller. One of the
lessons learned is that employees
need more skills and technology training to handle larger workloads and
changes in goals and methods.
It will be important for APHIS to develop a strategic work force plan that
encompasses its vision to assure an
adequate number of staff are allocated where needed. A flattened system can only work if staffed by a new
kind of employeeÑone that is trained
to broaden his/her skill sets and is
motivated to take risks. Most employees are not ready to take on these
kinds of jobs. Moreover, new experiences are needed to erase corrosive
beliefs, and some of that can be done
well with training (Kotter, 1993).
Recognizing that few know how to
make an agency work better than its
people, the first step will be for the
APHIS to begin valuing and servicing
its employees as its greatest asset and
a source of institutional knowledge
about what is needed to enable and
fulfill the mission well. Instead of
being viewed as the lower levels of the
pyramid, they should be viewed as the
front line that deserves the highest
level of service and given freedom to
make decisions, take risks, and make
mistakes.
Management and Union
Relations
The complaining and finger-pointing
between APHIS-PPQ management and
its labor union must stop in order for
the very difficult job of agency reform
to begin. For too long an adversarial
Safeguarding American Plant Resources
19
climate has predominated in this relationship, creating an internal climate
of pessimism while feeding an external cynicism about the AgencyÕs continued relevance. Management and
labor must open new and substantive
channels of communication.
Management must involve its employees, including union leadership, in its
decisionmaking; and in response, the
union must give up its protective policies of entitlement (Winter, 1993).
1.4.3 Employee
Empowerment and
Development
The only way the Agency can hope to
effectively rebuild itself will be by regaining the trust of its employees.
This will mean that APHIS must begin
treating all employees in the organization as though they can be trusted. It
must, among other things, begin
sharing information with everyone. As
knowledge is power so sharing information is sharing power, and the result is empowerment. But,
empowerment cannot be given, it
must be chosen (Bennis and Nanus,
1994; Covey, 1991; Peters, 1993 and
1994), and the leadership of the
Agency must enable it via organizational design, an investment in training and the removal of obstacles to
leave space for people to empower
themselves.
Choosing empowerment means that
employees also accept responsibility
and accountability for their attitudes
and actions, that is, become trustworthy. While it is convenient to believe
that certain external forces, or other
people, are solely responsible for the
quality of the work environment, the
reality is that every individual is responsible for choices made, and powerlessness is an individual choice.
Over time, choices become habits and
eventually are institutionalized and
become the environment in which
work is accomplished.
20
REPORT
One of the most powerful incentives
for work performance is control over
the job. For work to be fulfilling, and
for risk to be worth taking, employees
must be able to have some control in
the decisionmaking process.
Creating a learning agency that can
add value will mean that training
units must review and revise their
programs to include a broader range
of skills, such as computer and communication skills. Professional development must emphasize broad,
outcome related learning over specialization to enable fulfillment of Agencyidentified competencies. As most work
now needs all the skills and effort of a
team, employees need to know how
team building works and must be
trained in goal setting and conflict
resolution. These skills will be particularly useful as APHIS begins to
cross-train its AQI and its domestic
staff in preparedness for emergency
response, port surveillance, and quarantine inspection and enforcement.
Managers must relearn their jobs too.
They must develop the same skills
package and change their role from
one of supervision and discipline to
one of coaching, listening, benchmarking, mentoring and championing
that empowered employees will require. In this new role, managers will
guide and help staff to gain the required skill sets, develop best practices, encourage and support
employee input, and share information and knowledge.
While the need for training resonates
throughout APHIS, training and education in turn require funding. The
Agency must work towards developing
and protecting its training and equipment budgets and view such support
as part of the compensation package.
Instead of, or in addition to, funding a
training center, employees could be
given learning contracts with a
Safeguarding American Plant Resources
specified dollar amount and allowed
to spend this money on training,
within mission-based guidelines. This
would provide both an incentive for
learning and competition for training.
Additionally, pay increases based at
least in part on skills acquisition that
supports APHISÕs mission would
provide both an incentive and reward,
and ultimately benefit both the
Agency and the employee. The
greatest incentive is the opportunity
to use the skills learned in a
meaningful way on the job.
Performance and
Succession Planning
The basic purpose of the civil service
system, to hire the most talented of
AmericaÕs citizens into government,
has been lost over time. Recognizing
that a decentralized merit system can
help agencies address hiring, pay, diversity, and performance, in 1996, the
Office of Personnel Management
(OPM) granted broad latitudes for all
Federal agencies to design their own
performance systems. The Agency
must look towards development of a
standard whereby every personÕs behavior is judged equitably.
The PPQÕs workforce vision already includes goals to foster workforce diversity, ensure that PPQ has the right
people in the right positions, discovery of leadership potential for succession planning, appropriate
assignment of officers and technicians, improved hiring processes and
staff assignment in lieu of overtime.
The Review Panel believes that APHIS
should showcase and celebrate this
effort and use these goals as it redesigns the organization. The Panel
also believes that partnership with the
union can help achieve some of the
reform necessary for high performance.
Strategic hiring and succession planning must be fully exploited.
Concurrently, changing American
REPORT
(and world) demographics coupled
with the need to understand and
value other cultures in international
quarantine strategy development,
mandate that APHIS create a workforce that mirrors and values cultural
diversity.
One strategy for staffing flexibility
could be to reduce the number of job
categories by grouping job titles. A
simpler pay and promotion structure
could allow greater flexibility in rewarding good employees and lateral
movement among work units; a small
number of broad pay bands and a series of steps could replace the grade
and step system. This would allow
managers to reward employees without having to give them a new grade
or job title. At some point, performance assessment must be re-designed to include performance
measures that will evaluate management as well as employee performance goals.
In successful transformations, executives lead the overall effort and leave
most of the managerial work and
leadership of specific activities to their
front line employees. Each and every
APHIS employee, from its leadership
to its front line, must take responsibility and become accountable for the
success of the mission. The collaboration and commitment of employees
and support from external stakeholders must occur for APHIS to work
more effectively and efficiently, remain
relevant and accomplish its mission.
Recommendations
■ 17 Redesign the Agency structure to
be self-organized, self-responsible,
self-accountable. Make its structure
compatible with the vision and remove unaligned structures that block
needed action.
Safeguarding American Plant Resources
21
■ 18 Create a learning agency by
restoring employee training and education.
■ 19 Consider the establishment of
learning contracts.
■ 20 Base pay on performance and
the development of mission related
skill sets.
■ 21 Develop performance contracts
that specify desired results, set guidelines, identify available resources, define accountability, and determine the
consequences.
■ 22 Use, or expand the use of, intern
programs to provide additional
sources and opportunities for management to find and evaluate potential
permanent employees.
■ 23 Expand the use of the InterGovernmental Personnel Act as another staffing source.
Many external stakeholders feel
estranged from government and this
has forced a move towards political
or legislative remedies.
1.5 Stakeholder
collaboration in APHIS
programs and policy
development
Stakeholders are those with a ÒstakeÓ
in the primary mission of the organization, the protection of AmericaÕs
plant resources. Direct stakeholders
outside the Agency include other
Federal agencies, other countriesÕ national plant protection organizations,
state plant protection regulatory agencies, academia, scientists, re-
22
REPORT
searchers, scientific and professional
societies, affected industries, and
other special interest groups such as
environmental organizations.
Indirectly, all of society benefits from
the successful exclusion of harmful
invasive species, and alternatively
bears consequences in the form of tax
burden for management programs, increased cost of food and other plant
products, or reduced recreational values of public and private lands if safeguarding efforts fail. Participation of
direct stakeholders in APHIS decisions is a critical precursor to increasing understanding of and
confidence in those decisions.
Many external stakeholders feel estranged from government and this
has forced a move towards political or
legislative remedies. Low stakeholder
confidence in APHISÕs decisionmaking
processes and outcomes is an impediment to APHIS fulfilling its responsibilities. Increasingly, APHIS decisions
are under attack from an array of
stakeholders. The estrangement of
stakeholders and resulting search for
political remedies disrupts the normal
flow of work, and may erode support
for the safeguarding system. Political
interference contributes to the Òparalysis of analysisÓ noted throughout the
Review.
In order for the U.S. pest safeguarding system to succeed, there must be
broad support among lawmakers, policymakers and the public that invasive plant pest safeguarding is a
societal priority. All stakeholders
should be viewed as critically important partners if safeguarding efforts
are to ultimately receive the cooperation and resources needed to ensure
success.
Evolution and Role of
Public Participation in
Regulatory Decisions
Early in this century, regulatory decisions were made by agencies with
Safeguarding American Plant Resources
broad statutory powers. Agency experts were relied upon to regulate in
the public interest. They wrote standards and issued permits under these
broad grants of power.
Decades later, agencies had become
viewed as ÒcaptiveÓ entities under
undue influence of the regulated industries. Pressure grew for government to expand its regulatory
authority and move toward Òinterest
representationÓ in which regulations
were arrived at through the interplay
of contending interest groups.
[McGarity] This approach relied heavily on input from experts representing
contending groups such as consumer
advocates and industry representatives. Policymakers then sought middle ground among contending forces.
Public participation became a staple
ingredient in the policymaking
process. [Stewart, 1975]
As external participation in the regulatory process evolved and regulatory
decisions became more complex, a
logical approach was to delegate regulatory standards development to identified experts. But the reformers who
had insisted upon public participation
were unwilling to place their trust in
the hands of experts.
That distrust has not diminished. Vice
President Gore and his reinvention
team have made restoration of public
trust a keystone measure of Federal
management success with a recognition that this can only occur by convincing stakeholders that things have
changed. A recent survey showed that
60% of Americans basically do not
trust the Federal government; by contrast, in 1964, 75% did trust that the
Federal government did the right
thing most of the time. 24% of people
who do not trust government cite poor
management as the main reason. 91%
of those who say the government does
a poor job managing its programs
think that Washington will never or
REPORT
only sometimes do the right thing,
suggesting a direct correlation between trust and performance.
The demands for public participation
in risk regulation stem from a distrust
of experts, a corresponding distrust of
regulatory decisionmakers, and the
conviction that risk regulation issues
are not resolvable solely by reference
to expertise. When stakeholders are
excluded from the process or do not
have their interests considered, they
can and do use every means available
to confront the Agency, including political intervention. The APHIS has
often encountered such confrontation.
For example, during the 1997 negotiations leading up to a revised IPPC,
several non-governmental organizations labored to block U.S. ratification
of the convention because they felt
APHISÑand the IPPC itselfÑignored
environmental resource protection
concerns. In our modern society,
some level of stakeholder collaboration is inevitableÑand healthy. In addition to building trust and
understanding, meaningful public
participation may even result in better
decisions. Meaningfully involving
stakeholders in regulatory policy development and rulemaking presents
APHIS with both a strategic challenge
and a strategic opportunity.
At this time, APHIS follows a rulemaking procedure prescribed by the
Administrative Procedure Act. Most
commonly, APHIS develops a proposed rule, then publishes it for public review. Interested parties are
welcome to submit views and the
Agency is obliged to give Òdue considerationÓ to all relevant facts and arguments. Then, the Agency must explain
why it chose the option it adopts.
While public participation is a key
feature of this model, it has the following drawbacks:
¥ It presumes a neutral decision
maker who is swayed only by the
facts;
Safeguarding American Plant Resources
23
¥ Since it makes no attempt to bring
affected interests together to achieve a
resolution, it usually yields winners
and losers;
¥ APHIS usually takes a position in
advance of the public notice, putting
stakeholder groups on the defensive
at the outset.
¥ APHIS typically relies most heavily
on its internal information and analysis, a potential impediment to bringing the most robust science to bear
on a decision.
McGarity concluded that the Òdue
considerationÓ model is better adapted
to issues that are policy dominated
and for which factual accuracy is not
essential. In addition, because stakeholders are less involved in the actual
decision making process, suspicions
are easily raised that the Agency is
not really giving due consideration to
other points of viewÑespecially when
it adopts the option that it initially
proposed.
Ad hoc APHIS outreach efforts have
targeted traditional stakeholders,
such as state plant regulatory officials
and agricultural producer groups.
Such limited outreach is often Òafter
the factÓ rather than in the early policymaking stages.
For policy directions not subject to
rulemaking, no routine process exists
for stakeholder collaboration. For example, state agency cooperators often
learn of APHIS administrative interpretations after state officials have
taken an action on a plant or plant
product shipment, only to discover
that APHIS policy has changed. The
APHIS once sent regular alerts of
such changes to state cooperators,
but this practice ended when the
Agency changed its electronic communication system.
Closer collaboration with state plant
regulatory officials is vital for APHIS
24
REPORT
program delivery. During the review,
foreign officials expressed frustration
that their negotiations with APHIS
were undermined because states may
pursue policy directions inconsistent
with Federal policy. The same has
been true of NAPPOÕs efforts to develop regional standards; the process
has sometimes ground to a halt because of the lack of a clear U.S. position. The APHIS is making efforts in
this area, but a more formal
federal/state relationship is needed.
The APHIS must act responsibly, decisively and consistently in its dealings
with states on issues of Federal importance. States in turn must be accountable for contributing to and
delivering consensus if they are given
more voice in APHIS decisions.
Once rulemaking has been initiated
APHIS staff routinely state that they
cannot communicate on the status or
substance of the decision at hand by
invoking the ex parte communication
requirements of the Administrative
Procedure Act (APA). However, the
APA does not bar substantive discussion of the rule under development;
rather, it simply requires that any
such discussion be reflected in the
public record.
To remain effective in a climate of
change and uncertainty, the success
of APHISÕs safeguarding system will
rely on the commitment and participation of all its stakeholders. The
APHIS, industry, and all society have
a shared responsibility to assure that
quarantine protections meet societyÕs
mandate for a safe, affordable, supply
of food, plants and plant products as
well as environmental protection. But,
this partnership will only succeed if it
is founded on trust and mutual respect. To that end, APHIS will need to
learn how to exploit its own and its
stakeholdersÕ unique knowledge and
information base to develop partnerships and to communicate and educate its stakeholders on the necessity
Safeguarding American Plant Resources
and value of the plant safeguarding
system. In contrast, hiding or hoarding information will only breed continued alienation and distrust. In turn,
stakeholder participation in the governing process must move from its
historical representative form to a
participatory form. A continuation of
stakeholder involvement via countervailing lobbying is not effective and in
fact is a major contributor to the current Òparalysis of analysisÓ.
As Federal agencies have begun attempting to integrate service and enforcement mandates by adopting a
regulatory strategy that relies more on
insight (informed compliance) than
oversight, the public has raised questions of whether cooperation with industry will render regulatory agencies
impotent. Integrity and transparency
of decisions impacting plant safeguarding and quarantine will be critical values in partnership
development. These values will only
come from an agreement by government and all its stakeholders to abide
by the international rules and standards for plant quarantines in both
the export and import arenas.
The opportunity then is to redesign
APHIS policy to facilitate partnership
with its stakeholders in a relationship
based on trust, mutual respect and
responsibility in order to fulfill a
shared mission to safeguard
AmericaÕs plant resources.
Findings
Many Federal agencies are working to
increase stakeholder collaboration in
policy and program development and
implementation. Some have responded by altering their practices.
The Food and Drug Administration
routinely posts draft guidance documents on its Web site, and seeks comments for three months. Outreach
efforts take place during this period at
relevant trade and professional meet-
REPORT
ings. As the Environmental Protection
Agency has proceeded with Food
Quality Protection Act implementation, cries for process transparency
and stakeholder collaboration grew so
loud that Vice President Gore finally
intervened, announcing principles for
openness and sound science that
Integrity and transparency of
decisions impacting plant
safeguarding and quarantine will be
critical values in partnership
development.
have begun to reshape the process.
The trend toward stakeholder collaboration is international. Other national
plant protection organizations have
made great progress toward stakeholder collaboration and transparency
in decisionmaking processes.
Australia and New Zealand are examples. Notably, Australia has published
detailed guidelines on its processes
for major and routine decisions. The
role and timing of stakeholder collaboration are fully characterized.
The need for innovation in regulatory
agenciesÕ approach toward stakeholder collaboration has been recognized at the highest levels of
government. The National
Performance Review stated Òopenness
is the best way to restore credibility to
the regulatory process.Ó Executive
Order 12866, ÒRegulatory Planning
and Review,Ó encourages agencies to
consult with the public before taking
any regulatory actions.
APHIS currently differentiates between ÒroutineÓ (minor) and Ònon-routineÓ (major) decisions requiring risk
assessments. Less complex qualitative
assessments are used for routine decisions, and quantitative assessments
are used for complex decisions.
Safeguarding American Plant Resources
25
Similarly, the Review identified a need
for a simpler, streamlined stakeholder
process for routine decisions, and a
more involved collaboration process
for major decisions, such as a review
and realignment of Quarantine 37 or
Quarantine 56.
Collaboration with other Federal agencies has been advanced through initiatives such as the Border Trade
Alliance coalition. The success of the
Miami reinvention lab demonstrates
the value of strong relationships with
other agencies such as the Customs
Service. Similarly, APHIS has made
some progress toward stakeholder collaboration. For example, a series of
Òplant roundtablesÓ with Florida
stakeholders have increased program
awareness and input. The NAPPO
Industry Advisory Group has also established effective lines of communication on NAPPO issues.
All stakeholders seeking a greater
role in APHIS decisions must be
accountable for becoming educated
on the background and potential
outcomes associated with pending
decisions.
The National Plant Board (NPB) cooperates with APHIS-PPQ in the delivery
of plant pest prevention and management programs. The NPB plays a
uniquely important role as a primary
APHIS-PPQ stakeholder. The cooperative relationship has worked well in
recent years because of increased
communication efforts. These efforts
include: participation by APHIS-PPQ
headquarters and field staff in regional and National Plant Board meetings and issue resolution; three
formal meetings per year between the
NPB Council and the APHIS-PPQ
Management Team to discuss APHISPPQ program direction, updates and
26
REPORT
budget; weekly conference calls between the NPB President and APHISPPQ Deputy Administrator and staffs
as necessary; participation by NPB on
ad hoc APHIS-PPQ working groups;
and cooperation on harmonization of
domestic and international plant protection guidelines, management plans
and laws. This last item is keyÑ
APHIS and the NPB must advance the
development of national standards
that bear scientific scrutiny.
Such efforts have also resulted in an
increased workload for NPB officers
whose primary responsibility remains
one of plant protection at the state
level. There is a need to advance the
structure and format for NPB involvement in APHIS-PPQ policy and decision making to further improve
program coordination and delivery.
If stakeholder collaboration is to advance, accountability must be viewed
as a shared obligation. All stakeholders seeking a greater role in APHIS
decisions must be accountable for becoming educated on the background
and potential outcomes associated
with pending decisions. Accountability
speaks to the need to look beyond
narrow self-interest to the broader
ramifications of any pest safeguarding
decision. Accountability speaks to
honoring the process rather than interfering in the process through countervailing lobbying.
Recommendations
■ 24 Establish a stakeholder registry
to facilitate communication with interested parties before and during critical decision making. In the case of
rulemaking, collaboration should be
initiated before a proposed rule is developed.
■ 25 Open the registry to any organization or interest group in the U.S. interested in participating.
■ 26 Require stakeholders to provide
a brief paragraph outlining the stake-
Safeguarding American Plant Resources
holder organizationÕs interest and potential role in the delivery of pest safeguarding programs.
■ 27 Establish a process and criteria
for assigning ÒroutineÓ or Ònon-routineÓ status to decisions subject to
rulemaking, and a process for stakeholder collaboration under each,
using the Australian approach as a
guideline.
■ 28 Use modern technologies such
as electronic notification and Internet
posting to notify and seek input from
stakeholder registry participants on
policy options and ÒnonroutineÓ decisions, prior to initiating rulemaking.
■ 29 Encourage stakeholders to get
more involved in identifying and reporting pests, and other activities that
would benefit from a greater ÒfieldÓ
presence.
■ 30 Strengthen and expand collaboration efforts with key Federal agencies with whom APHIS interacts, such
as Customs Service.
■ 31 Seek opportunities to involve
stakeholders in information-sharing
activities such as situational briefings
and cross-training.
■ 32 Establish an ongoing grant or
other mechanism to support an operational structure to facilitate interaction and support between APHIS-PPQ
and the National Plant Board. The resource commitment necessary to establish and maintain this structure
should be shared between APHIS-PPQ
and the National Plant Board under a
cost-share formula. This structure
would help to ensure a significant and
predictable National Plant Board contribution toward mutual responsibilities associated with the detection and
management of invasive pests.
■ 33 Explore mechanisms for
constructive NPB involvement in key
REPORT
bilateral negotiations, such as with
Mexico and Canada.
1.6 Budget and Resource
Allocation
Background
A recurring question regarding APHIS
safeguarding activities is whether the
level of resources invested in those
activities is adequate to address invasive plant pest threats to American
agriculture, the environment, and the
American public. Similarly, can the
current resource base accommodate
essential increases or redirections in
safeguarding efforts?
Increased volume and changing patterns of international trade and travel
translate to increase risk of invasive
plant pest entry and establishment.
This section briefly describes the history and status of APHIS-PPQ funding. Further, it considers APHIS-PPQ
resource allocation in the context of
priorities; opportunities for new or expanded revenue streams for operations and strategic initiatives; and
potential approaches to underserved
safeguarding system elements.
Historically, APHIS-PPQ relied on line
item program funding that was
strictly controlled by the legislative
and executive branches. Almost all
line item funds were annual; funds
not obligated in the fiscal year lapsed
and were lost to the Agency. Slight
modifications began to occur in the
early 1980Õs when the Secretary of
Agriculture declared an emergency for
a Mediterranean fruit fly eradication,
freeing up Commodity Credit
Corporation funds for eradication.
Later, Congress designated certain
line items, such as for grasshopper
control and boll weevil eradication, as
no-year funds; unobligated balances
could be carried forward and remain
available to the Agency until spent.
Safeguarding American Plant Resources
27
The 1990 Farm Bill authorized collection of user fees for certain
Agricultural Quarantine Inspection
(AQI) activities, drastically altering
funding and financial processes for
APHIS-PPQ. Since that time, most resources have come from fees levied
against airline tickets, air carriers,
vessels, etc. The user fees have had to
be based on the actual cost for service
provided related to exclusion activities. They are deposited into a dedicated account to be spent on the
services for which they are collected.
However, Congress also kept strict
control over user fee spending authority by requiring that expenditures be
subject to annual appropriations. This
approach had problems; PPQ collected
far more revenue than it was allowed
to spend, and needed exclusion activities could not be provided. Unspent
user fees accumulated in a no-year
reserve account dedicated to AQI activities.
In the FY1994 Appropriation Bill,
Congress allowed APHIS-PPQ to exceed the AQI spending limit contained
in the bill by 10%. This level was increased to 20% in FY1995, and in
FY1996, APHIS-PPQ was given unlimited AQI user fee reserve access, but
only with OMB approval.
The 1996 Farm Bill attempted to permanently fix the AQI user fee problem. Between FY1997 through
FY2002, the Agency has full, direct
access to all AQI user fee collections
exceeding $100 million.
Unfortunately, Congress in recent
years has appropriated only about
$88 million for AQI user fee funding,
in order to spend the difference elsewhere and still meet budget reduction
goals. The $12 million shortfall has
diverted APHIS-PPQ resources from
other activities.
New fees that more accurately reflected true costs of exclusion activities were effective September 1, 1997.
28
REPORT
The APHIS-PPQ, with USDA and OMB
approval, was given access to current
and future reserve account balances.
Requests must be justified and mandated by clearly-demonstrated AQI
needs. After FY 2002, the Agency will
have full, unlimited, direct access to
all AQI user fee collections without
further appropriation or approval. AQI
activities, both appropriated and
user-fee supported, represent approximately 74% of the overall APHIS-PPQ
budget.
Beyond AQI funding, APHIS-PPQ line
item funding has experienced a downward trend. This is especially true for
domestic programs. Over the five-year
period from FY1993 to FY1997, domestic program spending as a percentage of total APHIS-PPQ financial
resources declined from 39.3% to
25.3%. Furthermore, periodic pest
emergencies necessitating eradication
have strained the system to the limit;
no streamlined, timely process exists
for committing funds to emergency
eradication efforts.
Budget discussions invariably settle
on how to ensure appropriate resources to address increased pressures for entry and establishment of
invasive plant pests. The Review identified several significant issues related
to budget and resource allocation.
Some are addressed below. Specific
budget and resource allocation findings and recommendations will also
be found within different sections of
this Report. Detailed recommendations are found in the Pest Exclusion
Committee and Pest Detection and
Response Committee Reports.
Findings
Dramatic improvements in resource
use through improved management,
and strategic pursuit of additional resources for targeted purposes, are
necessary to position the safeguarding
system for optimal effectiveness.
Safeguarding American Plant Resources
However, obtaining new funds
through the traditional Federal budget
process is unlikely in view of the current budget reduction framework and
rigorous spending limitations for the
projected budget surplus.
Each of the Committees concluded
that resource allocation and investment must be tied to those programs
and activities that most effectively address the most significant risks. The
Review noted that various APHIS safeguarding activities have not been subjected to critical analysis regarding
how they address the Ògreatest-risks.Ó
Therefore it was difficult to determine
to what extent overall program gains
could be accomplished through reallocation of existing funds to exclusion,
detection, permitting, and response
activities which address the highest
risks. Multiple dimensions must be
considered, including tradeoffs between these major elements of safeguarding as well as decisions on
where geographically to invest the resources for greatest effectiveness. In
the absence of such analysis, one
might argue that seeking additional
safeguarding resources might be premature and not yield real outcomes.
Current APHIS Safeguarding
Core Activities
Port of entry activities funded by user
fees are by far the most resource-intensive safeguarding activity.
Traditional passenger and baggage inspection activities receive the most resources, while emerging high-risk
pathways such as smuggling and
commercial cargo are underaddressed. A range of staffing issues
must also be addressed. These issues
are discussed in detail in the Pest
Exclusion Committee Report.
Beyond resource reallocation, there
may be compelling opportunities to
realign funding sources.
Opportunities exist for expanding
user fee collection. The Review identi-
REPORT
fied areas where user fees are not collected or are inadequate to cover costs
associated with the service provided.
Reasonable expansions are warranted. Possibly, user fees could be
assessed on a scale that creates an
incentive to support the safeguarding
system through quality preclearance
inspections and Òpoint-of-originÓ risk
reduction or management activities.
The APHIS should pursue cost recovery for ancillary activities with identifiable beneficiaries such as some
import/export facilitation activities.
Finally, penalty assessments for quarantine violations may be an area
where additional revenues could be
generated, and applied directly to education and outreach activities.
Again, specific recommendations are
found in the Committee reports.
New and Underdeveloped
Safeguarding Initiatives
Safeguarding is not just an APHISPPQ issue, but a national and international issue. The Review saw a need
for consistent effort to identify and
seek global resources, affiliates and
solutions to increase the efficacy of
U.S. safeguarding efforts. Several
countries appear to be ahead of the
U.S. in having risk-based resource allocation policies and practices in
place. The U.S. should team with
them to seek international resources
and approaches to address movement
of organisms across borders and between regions.
Similarly, APHIS-PPQ is not singularly
responsible for invasive species control and management in the U.S.
Therefore, other agencies should be
encouraged to partner with APHISPPQ to strengthen underserved safeguarding elements, such as pest
detection and emergency response
(again, specific recommendations can
be found in the Pest Detection and
Response Committee report). Thus,
capabilities, assets and experiences
complementary to those residing in
Safeguarding American Plant Resources
29
APHIS could be shared rather than
duplicated. Involving organizations
and entities external to APHIS in discussions and actions related to safeguarding through outsourcing and
partnering might naturally lead to immediate broader resource availability,
as well as increased support for future budget expansion. The Executive
Order on Invasive Species offers a tool
for marshalling resources and coordinating efforts.
Normal discretionary spending limitations do not favor one-time strategic
initiatives that may facilitate major
program transformations. There is a
compelling case for strategic transformation that will pay long-term dividends in safeguarding system
effectiveness and sustainability. For
example, emerging baggage and truck
x-ray technologies may allow for more
effective pest exclusion, expedited
passenger and cargo movement, and
reduced staff needs. Emerging truck
x-ray technology could help APHIS
and the Customs Service to address
land border risks. In summary,
strategic initiatives tied to AQI program effectiveness must be planned
for and implemented accordingly.
They are legitimate investments for
user fee-generated funds, including
any potential reserve account balance
resulting from the differential collected between the appropriated
amount and the $100 million trigger.
Discussions of the need for increased
resources for APHIS and its partners
to run safeguarding programs are inevitable. Budget expansion opportunities will be enhanced if linked with a
renewed, focused sense of purpose
and priority and supported by a
broader constituency. But if stakeholders are expected to support new
or redirected funding for safeguarding, APHIS management must be fully
accountable for resource allocation
and management. In short, APHISPPQ must have its own house in
order.
30
REPORT
Without these and other changes recommended throughout the Report,
one can expect continued lack of synchrony between perceived budget
needs and funding realities to meet
the safeguarding challenge.
Recommendations
■ 34 Base resource allocations on risk
evaluations, and focus resources to
guarantee greatest impact per investment dollar.
■ 35 Expand collection of user fees to
support service delivery.
■ 36 Outsource, delegate or pursue
cost recovery for non-mandated activities that do not directly and measurably contribute to the safeguarding
mission.
■ 37 Pursue an increase in penalties
that may be assessed for quarantine
violations, and the assignment of
penalties collected to support activities such as outreach and education
or research and technology development. This will require statutory authority.
■ 38 Plan for strategic application of
the AQI User Fee revenues, including
any account reserve that may become
available in FY2003, to support critical program investments such as new
technology implementation and offshore risk mitigation.
■ 39 Advocate establishment of a noyear fund, to be replenished year to
year, to fund emergency eradication
efforts. This fund would be accessed
at the discretion of the Secretary of
Agriculture, given sufficient scientific
basis for an achievable outcome. This
fund would need to be adequately
capitalized, and APHIS should be provided investment authority to properly
maintain it. (See specific recommendation in Pest Detection and Response
report).
Safeguarding American Plant Resources
Truck X-ray facility, Otay Mesa, CA, used
principally by U.S. Customs for drug interdiction. A detailed X-ray of an entire semi truck
with cargo requires 10 minutes.
1.7 Research and
Technology Development
Background
Throughout the preparation of this report it became clear that there were
many issues dealing with Research
and Technology Development that
needed to be addressed in some cohesive manner. Each committee has defined some areas where new
technology is available outside the
Agency that could, and should, be
adapted to the needs of APHIS-PPQ
activities. The background and findings of each committee are in their respective sections. In this section, the
report will define some additional
findings and restate the individual
needs of each committee in a comprehensive format.
Findings
APHIS and ARS have working structures that do not necessarily encourage or facilitate a comprehensive plan
for safeguarding activities. There appears to be more of a competitive atmosphere for funding than a
cooperative environment for achieving
mutually arrived at and accepted
goals. When funds are channeled to
APHIS Methods Development, they
(Methods) appear to set themselves up
in a world all their own and cross
REPORT
over, in the minds of ARS, into basic
science research. Conversely, APHIS
management expresses frustration
that ARS is sometimes unresponsive
to APHISÕs basic research needs.
Scientists in the two organizations are
viewed differently within the respective groups, are evaluated differently,
and follow different systems for advancement. While some scientists and
labs enjoy excellent field-level cooperation, these general views accelerate
the competitive nature of the system
and the agencies quit communicating
effectively. There have been some very
positive results from collaboration between APHIS and ARS in the area of
quarantine treatments and control of
exotic fruit flies. This success needs
to be expanded to other research priorities.
APHIS-PPQ deserves credit for efforts
to ensure full integration of the
Methods labs and their contribution
to the following goal areas: pest exclusion, pest detection, pest eradication,
and long-term pest management
(mainly biological control). For example, APHIS has established a National
Center for Plant Health, Science and
Technology (NCPHST) Board of
Directors to provide input and guidance into project direction and funding for all APHIS Methods
Development laboratories. While
mainly comprised of APHIS headquarters staff and center directors, the
Safeguarding American Plant Resources
31
Board also includes a representative
of the National Plant Board (NPB) and
the North American Plant Protection
Organization - U.S. Industry Advisory
Group.
Recommendations
■ 40 Establish a mechanism for determining research priorities within
APHIS that includes representatives
from the regions, International
Services, headquarters staff, and
stakeholders that are involved with
the action programs. Stakeholders
should include representatives from
academic research institutions and
industry.
■ 41 As a component of the first
Recommendation, adopt a specific
project selection process that evaluates proposed research relevance to
APHISÕs mission and resources. This
process should allow for more objective project evaluation prior to
NCPHST Board funding decisions.
■ 42 Expand the NCPHST Board of
Directors to include a representative
of ARS and, if feasible, additional
stakeholders.
■ 43 Develop cooperation between
agencies within USDA, other Federal
agencies, academic institutions, and
industry research organizations to
discuss the research priorities established by the Agency and determine
the best course of action to meet the
needs.
■ 44 Formulate a comprehensive plan
from the two steps outlined above to
execute the necessary research programs. This plan should take advantage of all available resources,
including outside funding sources.
APHIS should be the agency to hold
the system accountable for meeting
the research and technology development goals.
32
REPORT
■ 45 Clearly define Methods
DevelopmentÕs role in the safeguarding system to prevent the continuation of the competitive atmosphere
that currently exits among USDA
agencies. Many of the reviewers believe that Methods Development is a
service agency function to the safeguarding system.
■ 46 Restore funding levels and resource allocations to APHIS Methods
Development to concentrate on their
assigned task of putting useable tools
in the hands of the action agencies.
Implement a strategy in line with industry standards of allocating a percentage of the budget to Research and
Technology Development.
■ 47 Encourage international cooperation and information sharing
through participation in international
technology development programs and
seminars. Become more involved in
providing leadership to the international research environment to take
advantage of knowledge gained in
other areas of the world.
The following represent specific research and technology development
needs outlined by the committees:
Pest Interception:
(a) Improve x-ray systems for passenger luggage screening and full container cargo screening.
(b) Expand and improve the use of detector dog technology. Investigate the
feasibility of cross training canines
currently in use by other agencies.
Safeguarding American Plant Resources
Quarantine technology:
Pest Detection Tools:
(a) Expand understanding of the use
of irradiation systems in quarantine
programs.
(a) Continue to develop improved detection tools for invasive species
based on risk analysis programs.
(b) Continue development of new
quarantine treatments as current
tools are phased out.
(b) Expand and develop methods of
spatial tracking of current pests and
diseases through the use of GPS and
GIS analytical systems.
Risk Assessment:
(a) Establish a system of studying the
biology of invasiveness and incorporate this information in the development of risk analysis strategies, pest
exclusion systems, and research program strategies.
(b) Develop eradication tools for potential invasive organisms based on
risk analysis programs
(c) Establish specific goals for technology transfer of new discoveries for ultimate application in emergency
response programs. Technology transfer is defined as the process used to
move information from basic research
through the analysis phase to final
application.
(d) Continue to explore the use of
biotechnology in improving detection
and response systems.
Pest Response Programs:
(a) Improve diagnostics systems for
rapid pest and disease identification.
(b) Develop new eradication tools for
current programs to replace existing
methods that are controversial or may
be phased out through FQPA.
(c) Clearly identify the fitness of tsl
strains of the Mediterranean fruit fly
currently planned for expanded production and deployment in Sterile
Insect Technique (SIT) programs to
assure compatibility with the intended
environment for release programs.
(d) Expand the capacity of U.S. sterile
fruit fly rearing facilities and seek new
collaborations with international
sources.
(e) Explore the development of improved quality control tools for analysis of pest response programs such as
improved QC of sterile fruit flies and
improved trapping technology
REPORT
1.8 Information
Management
The central role of information in
APHIS-PPQÕs ability to effectively safeguard American plant resources led
the NPB to establish a Committee on
International Pest Information (section 4). The committeeÕs report covers
a range of issues including competencies and methods for generating or
collecting information; reliability of information; information management;
information technology; and the interpretation, application and analysis of
information. This topic is discussed
from policy level decision making
through to application in field and
port operations.
In addition to this focused discussion
of pest information, the Review Panel
discovered that the issue of information collection, analysis, and application arose in every aspect of the
review. Hence, relevant recommendations appear throughout the report.
Safeguarding American Plant Resources
33
1.9 Public Information and
Education
Background
The basis for pest exclusion and successful response programs involves
widespread acceptance by the public
of the concepts of protecting our natural resources. Most travelers are
aware that requirements exist for
bringing plants and foods into the
country but are not aware of the risks
associated with violations of those
rules. Many travelers will bring fruits
or plant material back from a vacation
to recapture the wonderful memories
of their trip or because they just like
the fruits or flowers they encountered.
Making the public aware of the risks
associated with potential introductions of harmful pests and diseases
can help in the efforts to reduce the
number of food items and plant material brought through the system.
Experience in pest eradication programs has shown that the majority of
the public does not understand the
importance of the eradication effort or
the potential impact of new pest infestations on their lives. Many have expressed concern over issues that are
important to them as individuals such
as exposure to chemicals or inconvenience in travel, but in their arguments, they have shown a minimal
understanding of the overall problem
and the risks involved. This has been
evident at the public hearings and
meetings held in conjunction with
pest eradication programs throughout
the United States. In many cases,
when presented with a broader view
of the risks involved, many of the dissenters actually became supporters of
the pest exclusion concept and focused their energies toward solutions.
There is currently a need for more
public education programs to support
the pest exclusion and eradication
34
REPORT
programs. Additionally, an opportunity exists to make the public aware
of permit requirements and the availability of international information
systems.
Findings
APHIS has a Public Affairs effort in
place to respond to emergency situations and eradication programs. This
effort has been supplemented by state
and industry programs in some cases
but still remains a reactive program
in most cases. Additional help is
needed from all sectors of the stakeholders if the program is to advance
and become more proactive in its
message. The ÒDonÕt Pack a PestÓ
message is very effective but is limited
to its distribution. A wider distribution of this and other messages is required to meet the growing number of
international travelers.
Emergency response programs are
often met with widespread public opposition to mass eradication efforts. A
proactive approach that involves
stakeholder groups is necessary to inform the public of the nature of the
problem and the need for eradication
of the pest or disease. The message
must go beyond protecting agricultural economics, which is seen as big
government protecting large corporate
farming organizations at the expense
of the private citizens. Many agricultural and environmental organizations
have experience in crafting public information messages through their efforts in various issue campaigns.
This expertise can be utilized in crafting messages for APHIS safeguarding
programs that will utilize all the information distribution systems. Previous
efforts to establish a coalition of
Federal, state, and industry public relations expertise have proven effective
in targeting messages and delivering
them to the appropriate audiences.
Safeguarding American Plant Resources
An opportunity exists with the
Executive Order on Invasive Species
to involve more organizations in the
distribution of messages and informational packets. The public is becoming
more aware of the risks associated
with invasive species with the current
AdministrationÕs efforts. This is a
good opportunity for coalition building
with non-traditional organizations to
present a united message on the risks
and dangers of violating the exclusion
laws.
Recommendations
■ 48 Increase public information programs that focus on pest exclusion efforts such as ÒDonÕt Pack a PestÓ.
Accomplish this by providing leadership in collaboration with state and
industry organizations throughout the
nation.
■ 49 Develop classroom curriculum
programs for K-12 that involve the
pest risk message with eradication information. Examine the Ag-in-the
Classroom curriculum as a possible
model. Also develop adult education
programs to take the message to the
traveling public and those buyers of
smuggled products that do not meet
quarantine standards.
■ 50 Develop public information programs to describe the detection programs throughout the nation. Focus
on the positive aspects of trapping
and early detection of infestations to
point out the negative impacts of establishing new pest populations. This
will make the trapping efforts more
acceptable and encourage additional
participants in the process.
■ 51 Increase efforts in Public
Information support and materials
available to eradication programs
through cooperative efforts with state
and industry organizations in areas of
high risk. Provide leadership to the
REPORT
development of collaboration
programs in areas where negative
eradication programs could occur.
■ 52 Include information on the
Permits System in all Public
Information programs.
■ 53 Focus on the societal benefits of
pest safeguarding programs by capitalizing on the Invasive Species
Executive Order. Incorporate this concept into all message development activities to present a consistent
message from all sectors involved in
Public Information and Education.
■ 54 Develop a Public Information
campaign for the international data
systems with the objective of utilizing
private sector scientists to assist in
the gathering of data.
■ 55 Involve state organizations, industry organizations, and land grant
university Cooperative Extension programs in crafting and executing the
Public Information and Education
messages through the development of
a coalition task force. Utilize public
relations firms that have experience
with the development of industry messages, such as food safety campaigns,
to work with the coalition task force.
■ 56 Develop a character similar to
Smokey the Bear, perhaps utilizing a
beagle or some other cartoon-type figure, as a national symbol for invasive
plant pest exclusion.
■ 57 Pursue the allocation of fines
collected from violations of the quarantine rules and passenger violations,
which are currently channeled to the
general fund, to provide funding for a
national informational campaign.
There is current case law that supports this concept as a tool for public
education.
Safeguarding American Plant Resources
35
1.10 International
Services
Background
The USDA-APHIS is divided into divisions and units according to the technical area or the administrative goals
of the group. For example, a
Veterinary Services division takes the
lead on safeguarding animal and
aquaculture resources by preventing
the entry and establishment of exotic
animal diseases or pests into U.S.
production areas. Although the primary responsibility of protecting
American plant resources resides entirely within PPQ, the mission is held
by the overall Agency . The safeguarding system relies on cooperation with
USDA-APHIS International Services
and their presence in 27 countries on
six continents (through six regional
offices for: Mexico, Central America,
Caribbean, South America,
Asia/Pacific Basin and Europe/Africa
/Near East, and an office in Japan) to
provide valuable information and services in foreign countries. In fact, the
stated mission of IS is Òto provide
leadership, management, and coordination of APHIS international activities, with particular emphasis on
protecting American
agriculture/aquaculture and enhancing U.S. exportsÓ (APHIS Web site,
1999).
Findings
The role of IS in exclusion is quite
clear. Several of the IS foreign offices
expend considerable staff resources
on surveillance or control programs
created to meet the joint interests of
the host country and USDA. This is
particularly true for the Americas
since pests of key concern that are
established in land bordering countries or the Caribbean have histori-
36
REPORT
cally moved with ease into the continental United States. Current programs include the eradication and
surveillance of the boll weevil in
Mexico, Mediterranean and Mexican
fruit fly suppression and sterile-fly
barriers in Mexico and Guatemala,
and several animal disease control
programs.
The IS staff is involved in budget
preparation for exotic pest detection
because of IS staff first-hand knowledge of potential needs for detection
in American territory.
With all of these successes in mind,
however, the Panel found a general
sense of disconnect from the safeguarding aspect of the IS mission,
and a heavier time commitment and
recognition of the role of IS in international diplomacy and trade. Even
when actively participating in pest
control and surveillance programs, or
commodity preclearance programs,
even IS leaders did not articulate this
as in support of PPQ and the safeguarding mission.
There is a need for institutionalizing
collaboration on decisions ranging
from pest risk analysis of a commodity coming from a country with IS representation to research needs and
opportunities for the entire AgencyÕs
goals. Much of this will rely on the exchange of information. This is a twoway street, as data on port
interceptions, repeat offenders, and
the results of detection efforts within
the U.S. should inform the work of IS
officers on a timely basis. The
International Pest Information
Committee made several recommendations for ways to involve IS more
significantly in the mission of safeguarding, through more close coordination with headquarters and PPQ in
general. The Exclusion Committee
also found information to be a key
way in which IS could contribute to
effective exclusion of invasive plant
Safeguarding American Plant Resources
pests that threaten the U.S. (See specific recommendations in those
Committee reports).
The organizational structure of IS has
recently been changed to allow direct
input at the staff level to IS activities
that impact the PPQ mission. This
change is consistent with the vision of
the Review for strengthening the international efforts necessary for pest
exclusion and data gathering. It appears to be an excellent time to develop closer collaboration between
PPQ and IS in particular in the face of
the growing challenge to safeguarding
American plant resources.
International Services plays an important role in the success of the safeguarding system. There has appeared
to be some disconnect with the IS
program that needs to be addressed
in order to implement many of the
recommendations within this review,
particularly in terms of information
collection and sharing. Additionally,
some IS field personnel have indicated
some isolation from the mission of
protecting U.S. plant resources and
have been more focused on the opening of trade lanes. Where the review
recognizes the need to keep the trade
mission in perspective with the SPS
agreements and other WTO issues,
there still needs to be a basic understanding of the plant protection mechanisms and a balance sought that
meets both situations.
in evaluating the risk potential of new
commodities with the focus on preventing invasive pests from entering
the U.S. Improve dialog with IS personnel in risk assessment activities
early in the process to highlight potential high-risk elements that may
not be identified in the scientific literature search.
■ 60 Work with IS management to
provide training of in-country IS personnel on the needs of protecting U.S.
plant resources and raise their understanding of the safeguarding system.
■ 61 Open communications with IS
field personnel and IS management
regarding the potential sites for preclearance of passengers. Make sure IS
is involved in the debate over the
value of passenger pre-clearance and
consider the input from the field personnel in the decision making
process.
■ 62 Assure involvement with IS field
personnel in evaluating and eradicating pest populations in countries that
pose a high risk to the U.S. such as
fruit fly populations in Mexico and
Central America.
Recommendations:
■ 58 Utilize IS field personnel in
strengthening the data gathering systems in foreign countries. Engage
their help in identifying resources that
can assist in the data gathering programs.
■ 59 Engage IS personnel in risk assessment development of commodities
exported to the U.S. Utilize their input
REPORT
Safeguarding American Plant Resources
37
38
REPORT
Safeguarding American Plant Resources
C h a p t e r
T w o
Pest Exclusion
Committee Report
Background
The agricultural quarantine inspection (AQI) system is straining under
external pressures such as trends in
trade, and internal pressures such as
resource limitations, downsizings, and
continual reorganizations. Several reviews have attempted to reconcile
those pressures with the need to
maintain an effective exclusion program. In 1993, a report by the Office
of Technology Assessment concluded
that policies designed to protect us
from the introduction of harmful invasive species were not safeguarding our
national interests. It further concluded, Òthe current system is piecemeal, lacking adequate rigor and
comprehensivenessÓ, and unable to
keep pace with new pathways and
pest introductions (OTA, 1993).
The USDA-APHIS is clearly at a crossroads where the dichotomy between
its need to pursue an aggressive trade
policy and its historic barrier approach to pest exclusion may be too
burdensome to sustain. A 1997
Government Accounting Office Report
found that the increasing flow of passengers and cargo is far outdistancing
APHIS inspection capabilities despite
increases in funding, staffing and use
of technology.
Historically, exclusion efforts have
been reactive and focused on inspection at first point of entry. If a pest organism was found infesting a
commodity on arrival, measures were
taken to destroy the shipment, re-export or disinfest it. As the potential
REPORT
harm from invasive plant pests became better understood, more preventative exclusion measures were
developed and evolved into the comprehensive plant safeguarding system
that is in place today. The cornerstone of the safeguarding system is
exclusion. Pest exclusion relies on
quarantine laws and regulations as
the authority to keep harmful and invasive pest species from entering and
establishing.
Non-indigenous plants and animals
are those species found outside of
their natural ranges. Many are beneficial; for example, most cultivated
crops, livestock, and biological control
organisms are of foreign origin as are
many species used for ornamental
plantings. Nevertheless, many non-indigenous species (NIS) cause significant economic and environmental
harm. Most introduced NIS enter and
establish in the U.S. via human activity such as commerce, entrepreneurship, tourism, travel or smuggling.
Different kinds of NIS arrive by different pathways. Insects and disease
pathogens usually hitchhike with
fruits, vegetables or other plant products in commercial shipments, with
equipment, baggage, or in parcels.
Weeds often enter as contaminants in
seed, soil and debris in cargo (OTA,
1993). Many invasive plants were first
introduced intentionally for forage,
cropping, forestry, conservation, or ornamental use.
As most invasive plant pests have accidentally or deliberately been introduced into the U.S. through trade, it
Safeguarding American Plant Resources
39
is reasonable to assume that trade expansion will provide NIS with new introduction opportunities. Coupled
with technological advances in transportation that actually facilitate survival and successful colonization, it is
likely that rates of successful NIS introduction will increase as well. For
the purposes of this report invasive
plant pests will be defined as any
alien (not native) species that could
constitute a threat to AmericaÕs plant
resources on agricultural and natural
or wild lands. These include: any living stage of the following that can directly or indirectly injure, cause
damage to, or cause disease in any
plant or plant product: an animal, a
protozoan, a parasitic plant, noxious
weed, a bacteria, a fungus, a virus or
viroid, an infectious agent or other
pathogen.
The current safeguarding system is
unable to cope with the increasing
frequency of NIS introductions.
Despite the increase in resources and
staffing, the AQI program has been
unable to keep pace with the increasing pressure from its workload and
mission to facilitate trade. The harmful economic impacts of invasive plant
pests are being experienced in increased costs of production, market
access and retention, and perception
of product quality (from concerns over
pest damage and pesticide residues).
Clearly, a new approach to exclusion
is needed, one that is oriented to the
future not anchored in the past. It
must foster development of strategies
that will continue to prevent the entry
of invasive pests in harmony with international trade obligations and opportunities while recognizing fiscal
realities and the premise that a
healthy agricultural system is dependent on a healthy natural resource
base. Concurrently, APHIS must concentrate on adopting and using available technology as well as developing
new approaches for addressing its increasing invasive plant pest threats.
40
REPORT
Reluctance to do so will only exacerbate current shortcomings.
The Pest Exclusion Committee believes that ultimately, resources invested toward preventing the
introduction of potentially invasive
plant pests by employing a strategy
that is derived from a clear mission
and vision rather than history will be
returned many times over in safeguarding AmericaÕs economy and environment.
2.2 Charge and
Methodology
The USDAÕs Animal and Plant Health
Inspection Service (APHIS), the
Federal agency tasked with the responsibility for preventing the introduction of invasive plant pests, has
found expectations of its performance
being scrutinized by a variety of
sources. Criticism of its past ineffectiveness by ecologists is blunt Òwhen the outrageous economic and
ecological costs of the wanton spread
of existing exotics and continued
entry of new ones becomes common
knowledge, there will be a public outcry to mitigate the potentially dire
consequencesÓ (Niemela & Mattson,
1996). Clearly, the current safeguarding system cannot meet the changes
thrust upon it by rapidly transforming
global circumstances. Exclusion is
preemptory and the most crucial of
safeguarding activities and APHISÕs efficacy in this regard must be advanced. The Pest Exclusion
CommitteeÕs mission was to positively
chart a course of exclusion activities
to meet these challenges.
To do so, the Committee was asked to
address the following questions:
¥ What are the most effective activities
to exclude pests?
¥ What is the best way that offshore
activities can maximize the efficacy of
the safeguarding system?
Safeguarding American Plant Resources
To answer these questions the committee reviewed pertinent documents
and studies, Agency guidelines, policies and reports. Committee members
visited APHIS headquarters and met
with APHIS staff, the PPQ Executive
Team and officials from Australia,
Canada, Mexico, New Zealand and the
United Kingdom, and U.S. Customs.
While it was not possible for the committee to visit each and every port,
committee members did visit with
APHIS port staff at many locations
and work units to review activities
and gather information as follows:
¥ Miami, Florida (air passenger and
cargo operations and the plant identification station)
¥ San Ysidro, California (pedestrian,
private vehicle, and cargo clearance)
¥ Otay Mesa, California (cargo clearance and x-ray capability)
¥ Long Beach, California (commercial
maritime cargo clearance, Chilean
fruit fumigation, solid wood packing
material inspections)
¥ Los Angeles, California (air passenger and cargo clearance, and mail inspection, smuggling interdiction)
¥ Oxford, North Carolina (Vivid x-ray
technology)
¥ Raleigh, North Carolina (pest risk
assessment process)
¥ Riverdale, Maryland (APHIS staff,
PPQ Executive Team, National
Association of Agricultural Employees
and ManagerÕs leadership)
¥ Washington, D. C. (APHIS staff,
American Nursery & Landscape
Association staff, and U.S. Customs)
¥ Detroit, Michigan (review of private
vehicle clearance, smuggling interdiction efforts)
¥ Port Huron, Michigan (review of
cargo clearance, smuggling interdiction)
¥ Mexico City, Mexico (Sanidad
Vegetal)
¥ Ottawa, Canada (Canadian Food
Inspection Agency)
REPORT
Both APHIS headquarters and field
staff were asked to provide the committee with their view of what was
working, what was not working, and
make recommendation to improve
APHISÕs agricultural quarantine inspection (AQI) program and off shore
activities. The following represent the
CommitteeÕs findings and recommendations.
Findings
The APHISÕs mission is Òto provide
leadership in ensuring the health and
care of animals and plants, improving
agricultural productivity and competitiveness, and contributing to the nation economy and the public health.Ó
In reality, the Committee found that
politics and economic pressures have
created competing roles that distract
from its mission. These are: to prevent the entry of invasive plant pests,
facilitate trade, expedite entry of passengers cargo and address other
emerging roles such as the regulation
of biotechnology. This has resulted in
conflicting sectors of the Agency that
compete for attention and resources.
It is clear from the lessons learned by
Australia, Canada and New Zealand,
as well as APHISÕs Agricultural
Quarantine Inspection program, that
port of entry (POE) inspection can no
longer be considered the first and
most reliable line of defense for exclusion. While visiting but a very few of
these POEs the Pest Exclusion
Committee members made the following observations and findings.
There are 301 POEs into the U.S.
(U.S. Customs interview); existing
POE operations are struggling to expand operations while new POEs are
emerging each year. Between 1988
and 1993, six new POEs were established along the U.S./Mexico border;
only five of the 25 POEs along the
U.S./Canada border are monitored by
AQI staff. At the same time, since
1990, imports and exports increased
Safeguarding American Plant Resources
41
over 30 percent while passenger traffic doubled in volume (APHIS-PPQ,
1999).
A new risk based management
strategy that requires compliance
and mitigation of pest risk at origin
can both reduce risk and enable
expedited entry.
Volumes of air cargo are doubling
every five to six years and an increasing percentage of this cargo consists
of perishable commodities such as cut
flowers, fruits and vegetables. Seventy
percent of the air cargo projected to
enter Miami in 2000 will be perishable (Port of Miami Overview, 1998).
The trend in all cargo movement is by
way of container. Entry of containerized cargo into the Port of Long
Beach, California, more than doubled
between 1993 and 1997 (BHC, 1998).
Rail freight corridor projects to locate
railheads at POEs are underway in
several locations. These rail lines will
create a more efficient way to quickly
distribute cargo throughout the U.S.
as well as the invasive pests that may
be associated with them (ACTA,
1998).
While port of entry inspection must
continue to play an important role in
the exclusion of invasive plant pests,
the historic view that this activity can
function as the focal point for
exclusion must be abandoned. A new
risk based management strategy that
requires compliance and mitigation of
pest risk at origin can both reduce
risk and enable expedited entry.
Adequate POE inspection will require
increased and expanded use of
technology. AQI must increasingly
focus on identifying new pest
pathways and developing appropriate
interdiction strategies. AQI and
domestic program staff must be
42
REPORT
cross-trained to facilitate destination
inspections.
Most importantly, APHISÕs organizational redevelopment must be derived
from the AgencyÕs mission, not its history. Regulatory oversight must be redesigned to incorporate strategies of
cooperative compliance, consultative
decision-making and shared responsibility and accountability for environmental protection.
2.3 Authority
The APHISÕs ability to prevent the
entry of invasive plant pests must be
grounded in adequate and relevant
statutory and regulatory authority.
Currently, APHIS continues to rely on
a variety of plant quarantine laws and
regulations that date back to 1912.
While these laws and regulations have
served the Agency well, there is a
clear need to streamline, modernize,
and enhance these laws to address
the new challenges and opportunities
presented by international trade
treaties, scientific advancements, and
natural resource protection.
The APHISÕs continued ability to effectively exclude invasive plant pests is
contingent on the modernization of
the current system of plant quarantine laws and regulations. Pursuit and
implementation of the many specific
Committee recommendations can only
follow passage of updated plant quarantine legislation. Legislation drafted
by APHIS and known as The Plant
Protection Act will realign 11 different
plant quarantine laws and clarify and
enhance APHISÕs ability to address
the risk associated with the entry of
invasive plant pests.
Recommendations
■ E-1 Work with Congress and stakeholders to have the Plant Protection
Act passed during the current
Congressional session.
Safeguarding American Plant Resources
2.4 Quarantine
Regulations
2.5 Civil Penalties
The APHISÕs plant quarantine regulations co-evolved with the enactment of
its plant quarantine laws.
There is a need to update and harmonize plant quarantine regulations to
assure their adequacy to effectively
address current and emerging invasive plant pest introduction pressures
and to assure adherence to requirements of international law. It is universally held that the risk of pest
introduction and establishment posed
by propagative material is greater
than that posed by products destined
for consumption (fruits and vegetables). Yet, the Fruits and Vegetables
Quarantine (7 CFR 319.56 or Q56) is
based on a Òprohibited unless found
safeÓ approach, while the Nursery
Stock Quarantine (7 CFR 319.37 or
Q37) is based on a Òenterable unless
found unsafeÓ approach. The Noxious
Weed regulation needs to be amended
to address societyÕs concern for invasive weeds. Provisions to assess weediness may ultimately need to be
incorporated into all regulations that
cover propagative plant material.
Recommendations
■ E-2 Review each of its quarantines
for conformance with the Plant
Protection Act and adherence to international standards for quarantine regulations.
■ E-3 Develop a strategy of quarantine development tied to pest risk potential that is reasonable, enforceable,
and transparent.
■ E-4 Begin its quarantine revision
process with the revision of its Fruits
and Vegetables (Q56) and Nursery
Stock (Q37) quarantines. Target completion within five years.
REPORT
The current civil penalty structure
has changed little since civil penalty
authority was first granted to the
Agency (found in 7 USC 149 (b),
150gg, and 163). The civil penalty
guidelines and penalty fee structure
currently employed by APHIS are inadequate and fail to serve as an effective deterrent. The APHIS-PPQ can
currently assess a maximum fine of
$1000 for passengers and cargo violations. The civil penalty fee structure
as proposed in the Plant Protection
Act would provide more effective deterrence. U.S. Customs assesses
penalties based on cargo value and
loss of duty revenue; the National
Marine Sanctuary laws allow for
penalties based on environmental
damage to living resources.
Although it is APHIS policy to substitute itself as the defendant if an employee is sued during the proper
conduct of his or her duty, many employees expressed an unwillingness to
assess penalties based on a fear of
being held personally liable.
Recommendations
■ E-5 Develop civil penalty procedures that incorporate a tiered
penalty structure based on cargo
value but within the allowances found
in the Plant Protection Act.
■ E-6 Review current law regarding
employee liability and, if warranted,
amend or develop legislation to provide adequate employee liability protection.
2.6 User Fees
In 1990, legislation was passed
authorizing the Secretary of
Agriculture to prescribe and collect
user fees for agricultural quarantine
inspection (AQI) activities. Ultimately,
APHIS chose to levy user fees against
Safeguarding American Plant Resources
43
commercial air carriers, maritime
vessel, trucks, railcar, air passenger
baggage and cargo arriving in the U.S.
from foreign origins. As the legislation
was developed, language was added
making expenditure of the fees
subject to the appropriation process
in order for the Agriculture Committee
to receive credit for the budget
savings achieved through the
collection of fees (FR, 1993).
To address problems arising from limits placed on discretionary spending
and impacting user fee appropriations, Congress adopted amendments
to the user fee authority as part of the
1995 Farm Bill. These amendments
made only the first $100 million of
annual expenditures subject to the
appropriate process. Since then,
Congress has annually appropriated
less than the threshold amount. The
shortfall then must be covered by the
available reserve, effectively reducing
the amount available for program
growth. In any case, the 1995 amendments also exempted the AQI program
from staff year ceilings limitations established under the Federal Workforce
Restructuring Act, enabling the program to establish staffing levels commensurate with program workloads
(USDA-APHIS-LPA).
At this time APHIS continues to assess user fees for all types of vessels
(air, maritime, rail, truck), and air
passengers. There is no fee for any
entry from Canada. No fees are imposed for cargo, and the truck fee is
inadequate to fund the necessary inspections, particularly at the land
border crossings.
Recommendations
■ E-7 Revise current user fee regulation (7 CFR 354) to adequately fund
APHIS inspection and enforcement responsibilities and fully incorporate
overtime needs, and to compensate
44
REPORT
for the current appropriation shortfall
and any shortfalls resulting from implementation of a tiered assessment
program.
■ E-8 Develop a tiered fee assessment
schedule to provide for a reduced fee
structure as a monetary incentive to
encourage participation in pre-departure clearance initiatives, implement
public awareness programs, supply
amnesty bins, etc.
■ E-9 Implement user fees for agricultural inspection at ports of entry
between the U.S. and Canada.
■ E-10 Implement a user fee for cargo
to enable adequate inspection levels,
particularly at land border crossings.
2.7 Executive Order
On February 3, 1999, President
Clinton signed Executive Order
13112, Invasive Species, to prevent
the introduction and minimize the impact of invasive species. This order establishes an Invasive Species Council
to be co-chaired by the Secretaries of
Interior, Agriculture, and Commerce.
In addition, this order requires the
Interior Secretary to establish an advisory committee, consisting of stakeholders, to provide information and
advice for consideration by the
Council and to recommend plans and
actions at local, tribal, state, regional
levels to achieve the management
planÕs goals and objectives.
Recommendations
The committee believes that APHIS
should be a full participant in this effort and as such recommends that
APHIS:
■ E-11 Determine its role and fully
participate in the development of the
Council and appoint any and all
Safeguarding American Plant Resources
necessary staff to assure full
participation.
■ E-12 Identify areas where it will
lead and partner with other agencies
in implementation.
■ E-13 Take any appropriate action to
ensure that APHIS stakeholders are
represented on the Advisory
Committee.
■ E-14 Assure that the introduction
pathways for arachnids and snakes,
and any other invasive plant pests not
under the direct jurisdiction of APHIS,
are adequately addressed and mitigated.
2.8 APHIS Employees as
Primary Stakeholders
By definition, stakeholders are all
those with a ÒstakeÓ in the success of
the mission of the organization, i.e.,
the protection of AmericaÕs plant resources. Stakeholders in this effort include APHIS employees, state plant
quarantine regulatory agencies,
forestry, industry, special interest
groups (environmentalists, etc.) and
all of society. The exclusion of invasive plant pests benefits all members
of society.
Internally, the Committee observed a
disturbing disconnection between
APHIS and its mission, an observation
confirmed by staff at all levels of the
organization. Its corporate culture can
be best characterized in terms of
alienation rather than alignment.
Management and headquarters staff
are alienated from the field; domestic
programs have no connection with
AQI; there is little communication
from port to port; there is little technical support available for field operations.
REPORT
If it is accepted that ÒstakeholdersÓ
are all those who have a stake in the
success of the mission of an organization, APHIS employees should be considered by the organization as its
primary stakeholders. As such, they
should receive the same investment
and service as APHIS provides to all
its other stakeholders.
Recommendations pertinent to this
finding are itemized under the
Leadership and Management and
Organizational Design sections of this
report.
2.9 Risk Analysis
Risk assessment is a tool for extrapolating data and is used to estimate
the likelihood that an introduced organism will become established and
cause economic and/or environmental
harm (Carnegie Commission, 1993).
The ability of an introduced organism
to survive and thrive in a new environment is predicted based on a series of probabilities.
Currently, APHIS conducts risk assessments for all import permit requests without any reimbursement.
Although there is a mechanism for
outsourcing risk assessments, it is little known or used. These risk assessments are performed as a service to,
and primarily benefit, the country or
importer requesting a permit. Yet
staffing levels for this function have
been downsized and unprocessed fruit
and vegetable import permits requests
date back to 1991 while permit processing is prioritized by politics and
trade negotiations (APHIS-PPD, 1999).
Models or templates needed to more
accurately assess different types of organisms as well as other risk mitigation strategies need to continuously
evolve. At the same time, as countries
develop pest information databases
for risk assessment, compatible databases and pest species information
sharing programs can help expedite
Safeguarding American Plant Resources
45
risk assessment and mitigation strategy development.
International Services (IS) has the responsibility for obtaining, through
local foreign networks, information on
established pests that may pose a
threat to U.S. plant resources.
Unfortunately, APHIS has not made
its informational needs known and, as
a result, political agendas oftentimes
make this information unavailable.
Recommendations
■ E-15 Revise and advertise its contracting guidelines for private-party
risk assessment preparation.
■ E-16 Seek full cost recovery from
exporting countries or exporters for
the development of risk assessments
needed to evaluate import permit requests or allow exporters or exporting
countries to conduct pest risk assessments under APHIS guidance.
■ E-17 Continuously improve its pest
risk assessment models.
■ E-18 Make existing interception
data used to develop risk assessments
electronically available to all Federal
and state regulatory staff.
■ E-19 Share international pest risk
assessment data by developing compatible systems and procedures
(under IPPC and FAO).
■ E-20 Exploit use of web technology
to facilitate information exchange.
■ E-21 Identify, with International
Services, pest data information needs
based on import permit inquiries and
predicted trade flows to facilitate risk
assessment needs.
46
REPORT
2.10 Offshore Activities
Pest risk mitigation at the point of origin, i.e., offshore, is the most viable
approach to pest exclusion and mitigation. Necessary and associated activities include the identification of
invasive plant pest and disease
threats, development of preventative
and control measures, and directed
research with a mutual benefit to be
received by the U.S. and the country
of origin. This approach also provides
a means of identifying potential high
risks so that appropriate preparedness and response strategies can be
developed in case of, or in advance of,
an invasive pest introduction.
Offshore monitoring and surveillance
should initially and primarily focus on
pests and pathways associated with
adjacent countries and major importing countries, that is, on countries
that have significant contact with the
U.S. through trade and tourism. One
such initiative already underway is
the North American Forestry
Association/Insect and Disease Study
GroupÕs work towards compilation of
a list of exotic insects and pathogens
with the potential to cause significant
damage to North American forest reserves to facilitate international forest
pest risk assessment.
The export of U.S. expertise in pest
and disease diagnostics, surveillance,
and suppression should be maximized
and elevated in importance in trade
facilitation negotiations. An offshore
exclusion strategy that incorporates a
commitment by the U.S. to assist
countries in transition would provide
an opportunity for the U.S. to use its
expertise to identify and mitigate currently unquantified pest risks.
There is also an opportunity for
specific monitoring of pests and
diseases that could harm American
species that are being raised or grown
in other countries, such as New
Safeguarding American Plant Resources
Zealand plantations of Monterey pine.
This kind of information would enable
assessment of the susceptibility of
native species to pests and diseases
that are endemic in other countries
but have not yet been found in the
U.S.
The APHISÕs current policy of non-acceptance of phytosanitary certification
from other countries inhibits the ability to expand offshore activities. This
policy is archaic and needs to be discarded. Specific problems regarding
phytosanitary certification by foreign
countries, such as the lack of phytosanitary certificate expiration requirements, need to be identified,
isolated, and solved. Responsibility for
quarantine compliance should belong
to the exporting country.
Recommendation
■ E-22 Change its policy to accept
phytosanitary certification from countries with valid export certification
programs.
2.11 Pest and Disease
Suppression
Currently, APHIS participates in a
number of offshore programs
(including border programs or
adjacent country programs. These
include programs for Mexican fruit fly,
cotton boll weevil, silverleaf whitefly,
the establishment of pest free areas
for targeted fruit fly species,
development of cold and irradiation
treatment schedules, and
development of biological control for
suppression of pink hibiscus
mealybug (PHM). The migration of
PHM into the Caribbean at one time
posed a serious threat for natural
entry into Florida. Successful pest
suppression via the development of
biological control in the Caribbean
has reduced population levels so
significantly that artificial
REPORT
introduction into Florida is much less
likely. If and when PHM introduction
into Florida does occur, response will
be supported by a reservoir of natural
enemies and a base of technical
knowledge on their efficacy.
APHIS and the California Department
of Food and Agriculture (CDFA) currently conduct a preventative release
program (PRP) of sterile
Mediterranean fruit flies to create a
hostile environment for establishment
of introduced populations in the Los
Angeles Basin. Since the inception of
this program only one infestation of
Mediterranean fruit fly has been detected within the PRP area. This infestation was small in size and easily
eradicated by the release of increased
numbers of sterile flies. Eradication
efforts against Mediterranean fruit fly
have been conducted outside PRP
areas in southern California and
Florida.
Recommendations
■ E-23 Expand the use of pest suppression efforts, sterile fly corridors
and preventative release programs in
areas particularly vulnerable to invasion such as those along the
U.S./Canada and Mexico borders as
well as southern California and
Florida.
■ E-24 Work with Mexico and the
U.S. border states to develop a strategy to eradicate or develop a pest-free
area for Mexican fruit fly along the
U.S./Mexico border.
■ E-25 Identify other pests in
Canada, the Caribbean and Mexico
that may migrate into the U.S. naturally and develop suppression strategies to prevent or postpone entry.
■ E-26 Expand production capacity of
sterile insects to support existing and
potential sterile release programs.
Safeguarding American Plant Resources
47
2.12 Preclearance
Preclearance is the inspection and
clearance in the country of origin performed by persons duly authorized by
the plant protection organization of
the country of destination.
Passengers, commodities and other
regulated articles may be the subject
of preclearance. The APHIS currently
conducts preclearance activities in 29
countries; specific programs include
Chilean stone fruit, mangos from several South American and Caribbean
countries and Taiwan, bulbs from
several European countries and citrus
from Spain. The country of origin generally funds programs under a trust
fund agreement with APHIS.
The North American Plant Protection
Organization has adopted a standard
for preclearance programs between
member countries. These programs
not only mitigate the pest risk at origin, but also provide a mechanism for
expedited entry at POEs. Preclearance
programs offer an opportunity for any
failures in the system to be addressed
at origin, rather than necessitating an
eradication program at destination.
APHIS programs to preclear passengers and cargo at origin should be expanded but not substituted or
prioritized over the development of
other offshore programs. The use of
the preclearance approach is most
suitable for countries in transition
that lack the technical capability to
develop and implement eradication or
suppression programs.
A study to determine feasibility of
implementing a pilot test offshore
passenger prescreening in Guatemala
was developed but the program was
never implemented. Regrettably, this
1996 plan could have established
baseline evaluation of pest exclusion
activities for passenger interceptions
from high risk Central American
countries. In an effort to avoid
48
REPORT
redundancy with that proposal,
recommendations found below are in
addition to those already suggested in
the Guatemalan plan.
The Canadian Food Inspection Agency
has recently announced plans to reinstate passenger preclearance at
Canadian airports. The APHIS has
been invited to participate in this preclearance program. The roadblock to
APHIS involvement is the development
of complementary enabling legislation
to grant immunity to inspectors performing preclearance activities.
Recommendations
■ E-27 Work with the government of
Guatemala and affected air carriers to
implement a pre-departure passenger
clearance program and evaluate it
within two years.
■ E-28 Determine the highest-risk locations offshore and implement the
most effective procedures found in the
Guatemala program.
■ E-29 Pursue legislation to enable
participation with CFIA in pre-departure clearance of U.S. destined passengers at Canadian ports of
departure.
2.13 Regionalization
As countries continue to develop international standards on a regional
basis, the need to harmonize pest exclusion strategies between countries
becomes more compelling. In the context of this report, ÒregionalizationÓ
refers to the harmonization of quarantines, exclusion strategies, and other
pest safeguarding initiatives among
countries in geographic proximity to
one another.
Most compelling initially for the U.S.
is the case for regionalization within
North America and the Caribbean.
With thousands of miles of shared
Safeguarding American Plant Resources
borders and large areas of similar climate and flora, an invasive plant pest
that enters and establishes in one
North American country may quickly
endanger the others. Regionalization
offers the promise of greater efficiency
and shared success at excluding and
managing invasive species, while facilitating a lively regional economy.
The U.S. needs to pursue harmonization of its plant quarantines and other
mitigation strategies with both
Canada, Mexico and the Caribbean
Basin and develop a regional approach to pest exclusion. The North
American Plant Protection
Organization (NAPPO) provides a
forum for dialogue and coordination
of such efforts. The U.S. has also
been a leader in the development of
the Free Trade Agreement of the
Americas, an upcoming agreement
aimed at creating a single trading
block throughout all of the Americas
rivaled only in size by the existing
European Union.
the U.S. and Canada enjoy an open
trading relationship. For example,
Canada is the only country exempt
from the U.S. general prohibition on
plant imports established in growing
media under Quarantine 37. This
openness reflects a long-standing assumption that trade between the two
countries represents a low risk of
harmful invasive species introduction.
Unfortunately, recent experience has
made that assumption obsolete.
Exotic fruit fly host material has
found its way into the U.S. in both
commercial-volume shipments and via
the traveling public. Such materials
are prohibited entry into the U.S., but
freely enter Canada. Canada is unconcerned because fruit flies will not
permanently establish due to climate.
CanadaÕs entry requirements for a variety of other offshore-produced commodities, such as nursery stock and
propagative material, are also inconsistent with those of the U.S.
Ultimately, and in keeping with the
proposed Free Trade Area of the
Americas, hemispheric regionalization
should be pursued. Mexico is already
a partner with other Central American
countries toward this goal. Beyond
NAPPO, the U.S. is already positioned
to partner with the Caribbean Plant
Protection Commission (CPPC), the
Asian and Pacific Plant Protection
Commission (APPPC) and the Pacific
Plant Protection Organization.
Canada is the largest trading partner
for the U.S., and the trading environment between the two countries has a
history of relative openness. The
North American Free Trade Agreement
(NAFTA) further advanced that openness by eliminating tariffs and many
non-tariff barriers to trade. Indeed,
phytosanitary requirements represent
the last major category of restrictions
on trade between the two countries.
Even from a phytosanitary viewpoint,
REPORT
A truck crossing from Canada through the Port Huron, MI, border crossing attests to emerging regional trade relationships.
Safeguarding American Plant Resources
49
It bears noting that Canada is also
vulnerable to breaches in the U.S.
safeguarding system. Canada reports
in-transit shipments across the U.S.
arriving with missing or broken seals.
The APHIS should work with Canada
and U.S. Customs Service to bring enforcement actions if seals are broken
or missing. Progress toward harmonizing perimeter requirements will
benefit both. In many respects,
Canada has progressed further toward risk-based management in its
plant protection programs. Canada
has already initiated a review of entry
requirements for offshore propagative
materials.
The APHISÕs response to this Òpartially open door to pest introductionÓ
via Canada has involved direct negotiation, initial efforts at harmonization,
increased compliance checks and
smuggling interdiction efforts. While
commendable and partially successful, this response has been unable to
match the scope of the problem. The
documented risk of pest introduction
via the northern border compels
APHIS to pursue one of two policy
choices:
(a)
Dramatically strengthen and
expand pest exclusion activities at the
Canadian border by placing adequate
staff at Canadian border crossings,
adapting work shifts to reflect trading
patterns across the border, and aggressively expanding smuggling interdiction efforts; or,
(b)
Vigorously pursue regionalization through U.S. and Canadian
adoption of equivalent ÒperimeterÓ
safeguards, with the long-term goal of
deemphasizing traditional border inspection activities.
Given mutual interest, willingness
and commitment by the U.S., Canada
and Mexico, the Review determined
that regionalization offers the most viable policy direction consistent with
evolving patterns of travel and commerce, and societal expectations.
50
REPORT
Several recommendations relevant to
the goal of regional cooperation and
harmonization appear above under
Pest and Disease Suppression and
Preclearance. Additional recommendations follow.
Recommendations
■ E-30 Vigorously pursue regionalization through U.S. and Canadian
adoption of equivalent ÒperimeterÓ
safeguards, with the long-term goal of
deemphasizing traditional border inspection activities; or,
■ E-31 Dramatically strengthen and
expand pest exclusion activities at the
Canadian border by placing adequate
staff at Canadian border crossings,
adapting work shifts to reflect trading
patterns across the border, and aggressively expanding smuggling interdiction efforts.
This approach should emphasize
equivalence in quarantine regulations
governing off continent imports, harmonized measures for commodity
movement within North America, and
cooperation on mutually beneficial
pest safeguarding initiatives. The following specific recommendations offer
near-term opportunities to harmonize
phytosanitary requirements and pest
safeguarding activities in support of a
North American trading bloc:
Canada, Mexico and the United States
should
■ E-32 Begin implementation, including intra-regional implementation of
the North American Plant Protection
Organization standard for solid wood
packing materials. Pursue global harmonization for solid wood packing
material pest mitigation.
■ E-33 Explore opportunities to share
databases, using solid wood packing
material interception and rejection
data as a focus.
Safeguarding American Plant Resources
■ E-34 Cooperate to develop a strategy to reduce the risk of pest introduction associated with in-transit
shipments within North America.
demonstration of support for Mexico,
which has a substantial olive production area near the U.S. border.
Canada and United States should
The Caribbean Basin and the United
States should
■ E-35 Begin developing plans for the
harmonization of phytosanitary requirements that apply to other countries (the Òperimeter approachÓ) with
the existing preclearance activities
such as the program for flower bulbs
from Holland.
■ E-43 Develop a longer-term initiative that includes plans for export of
exclusion and detection capabilities
and specific pest and disease suppression activities, to apply the
perimeter approach.
■ E-36 Develop a longer-term initiative to apply the perimeter approach
to pests such as exotic fruit flies.
■ E-37 Support CanadaÕs proposed
analysis of existing statutory authorities that could target and discourage
movement of prohibited fruit fly host
materials into the U.S.
■ E-38 Explore opportunities for collaboration with Canada to study and
respond to potential pest introduction
pathways into the Pacific Northwest,
and pursue biological control strategies for pests that have become established in both countries.
Mexico and the United States should
■ E-39 Assist with funding and technical support the exotic fruit fly eradication initiative in Central America.
■ E-40 Eradicate, or establish a pestfree area for Mexican fruit fly on both
sides of the U.S./Mexico border (see
recommendation under Pest and
Disease Suppression).
■ E-41 Develop and implement a plan
to slow the spread of brown citrus
aphid from Belize into Mexico and ultimately the U.S.
■ E-42 Continue the effort to eradicate olive fruit fly in California as a
REPORT
2.14 Pathways
Organisms Intentionally
Introduced for Propagation
Living organisms (including plants,
animals and microbes) may be imported intentionally for the purpose of
further propagation. These imports
are regulated loosely according to the
perceived risk associated with
pathogens or pests that can be associated with plant material (7 CFR
319.37), the potential for such organisms to be pests themselves (7 CFR
330.200) or the potential of plants to
become noxious weeds (7 CFR 360).
There are significant disparities in the
rigor of APHISÕs estimation of risk in
these regulations, especially in contrast with other regulations, such as
the importation of fruits and vegetables under 7 CFR 319.56. Propagative
material is generally viewed as of
greater risk because it can be a living,
growing, reservoir for plant pests. Yet,
under current regulations, propagative plant materials are presumed safe
unless found otherwise and listed as
prohibited or restricted in the regulation (whatÕs termed a Òdirty listÓ approach). Fruits and vegetables though
presumed safer, a priori, are treated
under the more restrictive approach
of presumption of hazard, thus are
prohibited, unless found to be safe
(whatÕs termed the Òclean listÓ
approach).
Safeguarding American Plant Resources
51
Both rigorous risk analysis and regulatory realignment in this area are
needed. Furthermore, seed, imported
in small quantities for research and
breeding purposes, and in substantial
commercial quantities for sale and
distribution, is largely overlooked in
spite of its potential to carry pests
and diseases. This represents yet another area needing application of the
risk assessment process.
Federal regulations (7 CFR 319.37)
recognize three classes of plant importation from outside the U.S. based on
risk of introduction of pests and diseases, admissible, restricted and prohibited nursery stock. Such plants or
seeds arriving in the U.S. as admissible articles are, at most, inspected at
one of the plant inspection station at
port of entry. Admissible articles can
be imported in unlimited quantities.
More restrictive protocols come into
play with the other classes. Some
plant materials are restricted and others are prohibited from importation
from certain countries or regions.
Restriction or prohibition results
from a determination that there is an
unacceptable probability of pests of
high hazard to U.S. interests accompanying the plant material.
Restricted articles are allowed to enter
in unlimited quantities, subject to inspection and (typically) a two-year period of post-entry quarantine and
observation by state authorities.
Prohibited articles are only allowed to
enter in limited quantities (as specified in the permit allowing import).
With a few exceptions prohibited articles are imported by and under the
supervision of USDA, Agricultural
Research Science (ARS) scientists or
scientists in a university system recognized as experts with the crop and
capable of testing for and detecting
the specific pests of concern. When
imported for private concerns most
prohibited articles are brought in
under the supervision of the National
Germplasm Center and released after
testing and observation are complete.
One key issue here is that risk
assessment in this system is based
solely on known pest and disease
problems of the plants on the
established lists. Everything is
admissible unless specifically listed as
restricted or prohibited. This assumes
there is no risk associated with the
unknown, an alarming assumption
given the resources at stake and the
quality of information available.
Where information concerning pest
complexes is poor (e.g. developing
countries), or outdated, there may be
pests and diseases that are not
recognized as associated with a plant
species in a particular region. When
new problems in a region are
identified, changes in regulations may
Inspecting cut flowers from Colombia
arriving at Los Angeles International
Airport. Air cargo shipments of cut
flowers at Miami and Los Angeles are
a high volume, daily occurrence requiring routine inspection for quarantine pests.
52
REPORT
Safeguarding American Plant Resources
be extremely slow relative to the risk.
Likewise, new species of plants that
have not been subjected to risk
assessment can enter channels of
trade with no regulation. Since these
are not listed, they are by default
admissible and subject to the least
stringent protocol regardless of their
potential to carry pests or diseases, or
become invasive themselves.
It is also assumed in 7 CFR 319.37
that all pests and diseases associated
with admissible and restricted articles
can be detected by visual inspection.
Only prohibited articles are actually
tested. There are diseases (e.g. those
caused by phytoplasmas,
Nepoviruses, and others) that have
wide host ranges but have not been
studied in every possible host. It is
fallacious to assume they will be detected by visual inspection and that
prohibition of their most important
economic hosts will exclude them.
This may be especially true in consideration of diseases carried in seed.
Restrictions and prohibitions are
listed by plant host species, with reference to the pest or disease of concern. In some cases a disease of
concern is known to be associated
with a wide range of plant hosts but
these hosts are not regulated. Finally,
some diseases (e.g. rose wilt virus),
not recognized as such by the scientific community, are the bases for restriction or prohibition of certain
hosts.
In none of these situations is the potential for plants to become invasive
themselves considered. If a plant is
not included on the lists supporting
the Federal Noxious Weed Act it is
considered to be safe, even if its invasiveness has not been evaluated.
Passage of the Plant Protection Act
would eliminate legal interpretations
that have limited full, effective application of the Federal Noxious Weed
Act, and facilitate broader consideration of invasiveness potential.
REPORT
Furthermore, a private sector dialogue
among the nursery industry, weed
scientists, and public/private entities
engaged in plant exploration may
yield appropriate models for screening
new plant introductions for invasiveness.
Recent revisions to the IPPC have created the framework for legitimate regulation of nonquarantine pests under
certain circumstances (see regulated
non-quarantine pest definition in the
glossary). By definition, the application of this concept is limited to pests
that have an undesirable economic
impact and are associated with propagative material. In addition, any
measures applied to imports must be
no more stringent than those applied
to domestic production. U.S. plant
regulatory officials and export-focused
segments of agriculture have expressed concerns about potential
abuses of this concept in the international trade arena. Implementation of
this concept will require the development of new regulations or revision of
applicable regulations, as well as
close collaboration with other NPPOs
and industry.
Recommendations
■ E-44 Begin to work towards a goal
of establishment of a global list of
pests and diseases with supporting
pest risk analysis to drive exclusion
regulations. Apply these risk analyses
to revision of 7 CFR 319.37, 7 CFR
330.200.
■ E-45 Require and initiate risk assessments for seed importation.
■ E-46 Consider adopting a modified
Òclean list approachÓ for propagative
material, specifying what is
permissible subsequent to risk
assessment, rather than the current
Òdirty listÓ that prohibits or restricts
specific articles only. To begin this
process, work with subject experts to
Safeguarding American Plant Resources
53
develop a prototype assessment
process upon which subsequent
regulation could be based.
■ E-47 Require sampling and testing
as a part of all plant importation activities. This would require research
and technology development to allow
rapid generalized testing, for plant
viruses and phytoplasmas, for example; testing could be at point of origin
or port of entry.
■ E-48 Purge lists of Òphantom diseasesÓ, like the rose wilt virus, that
are not recognized by the scientific
community.
■ E-49 Coordinate noxious weed and
invasive species initiatives with review
of 7 CFR 319.37 and 330.200 based
on rigorous risk assessment.
■ E-50 Work with the National Plant
Board and NAPPO to lead by example
in the development of regulations and
implementation of the Òregulated nonquarantine pestsÓ concept for certain
types of propagative material.
Grapevine, deciduous fruit trees, and
chrysanthemum propagative material
offer potential models.
2.15 Smuggling
Interdiction
APHIS is working with its Investigative
and Enforcement Services (IES) and
other Federal and state regulatory
agencies to develop task forces to
detect smuggling operations and
ensure trade compliance at entry
points. Trade compliance teams are
being formed from PPQ, IES,
Customs, state departments of
agriculture, local law enforcement,
and tribal authorities while ports are
assigning trade compliance officers to
act as liaisons. Primary interdiction
activities are intensified border
inspections (border blitzes) and
market surveillance. Border
54
REPORT
inspections consist of unpredicted,
targeted and random cargo
inspections at northern and southern
land borders. Market surveys consist
of inspections of fruit, vegetable and
plant markets. Intercepted prohibited
items are traced back to origin and
forwarded to destination. Alerts are
placed in the Customs Automated
Commercial System; identified
violators are prosecuted for
quarantine violation.
The CLAMP Project (Closing the Los
Angeles Area Marketplace Pathway) is
a multi-agency team initiative begun
in May 1997 to identify entry pathways for smuggled agricultural products. Its goal is to identify smuggling
pathways and develop strategies to
close them using the following procedures:
¥ Investigate tips and alerts;
¥ Compile intelligence;
¥ Intercept infested commodities;
¥ Perform public outreach to facilitate
compliance and provide a presence for
deterrence;
¥ Establish a network of contact with
industry and government.
¥ Serve as a clearinghouse to receive
and distribute information and smuggling alerts;
¥ Complement other smuggling interdiction activities.
In 1997-8, CLAMP took quarantine
enforcement action 225 times, seized
72,435 pounds of prohibited commodities with an estimated retail
value of $310,594. Pests intercepted
included arthropod, disease, noxious
weed and CITES (plants protected
under endangered species laws)
species (CLAMP Annual Report,
1998).
The Florida Interdiction Smuggling
Team (FIST) has identified a smuggling operation importing longans and
litchis from Thailand to Florida via
Safeguarding American Plant Resources
Canada (Vancouver and Toronto) and
New York and selling these fruits as
Florida product. Trade Compliance
Program teams along the Canada border have intercepted prohibited fruits,
vegetables; noxious weeds and cut
flowers as well as product from
Thailand, Europe and Mexico mismanifested as Canadian origin (TCP
Report, 1998).
Recommendations
■ E-51 Develop a strategic plan for its
smuggling interdiction efforts to identify staffing and funding needs.
■ E-52 Secure an increase in
Agricultural Quarantine Inspection
user fees for expanded smuggling interdiction activities based on the
strategic plan.
■ E-53 Investigate and identify the
motives for smuggling to enable development of more effective mitigation
strategies.
■ E-54 Use the information gathered
to identify commercial product development opportunities.
2.16 Transshipment and
Limited Distribution
Various Federal regulations authorize
the entry and transportation of noncompliant prohibited and restricted
agricultural product through the U.S.
for foreign export (transportation and
exportation or immediate movement
(immediate transport) through port of
entry for inspection and treatment at
approved locations. The safeguarding
regulation (7 CFR 352) provides
APHIS-PPQ with broad authority to
issue permits and prescribe safeguards at ports of entry for transit
shipments of regulated products.
Permits for transportation and exportation (T/E) allow the entry and movement of non-compliant agricultural
products, under Customs bond to a
specified export port. Movement over
land is authorized via specified travel
corridors. T/E permits for movement
through the U.S. are issued for product entering from foreign countries
destined for foreign export, but many
are issued for ultimate entry into the
Canadian market.
APHIS has a national safeguarding
team that is charged with the formation of policy for issuance of transit
permits, but there is no process in
place for permit review at the national
level. Guidelines for the issuance of
Illegal longans from
Thailand intercepted in a
passenger’s personal luggage at Los Angeles
International Airport.
REPORT
Safeguarding American Plant Resources
55
permits and safeguards are provided
in PPQÕs Operational Guidelines for
Transit (1995). The transit guidelines
provide port staff with assistance
when issuing transiting permits but
APHIS staff have advised the committee that these guidelines are inadequate.
Permit issuance is time consuming at
high volume POEs and there are few
training opportunities available to
port staff at the smaller POEs; and
there is a lack of uniformity in permit
issuance. In addition, there are no
risk assessment guides to assist PPQ
staff in assessing whether the potential pest risk to the U.S. outweighs
the service transshipment provides to
the exporting and importing countries. Moreover, there is no database
or communication network to determine if pest population levels at any
one time may be exacerbating the risk
for a particular commodity or production season. There is no regulatory
provision or mechanism to refuse issuance of a transit permit if the pest
risk appears too high. Transit guidelines do not allow the inspection of
transiting material solely because PPQ
cannot disallow transiting if a shipment is pest infested. The pest risk
consequences can be illustrated with
the following example. An outbreak of
Mediterranean fruit fly in Spain resulted in the entry and transport of
heavily infested Spanish clementines
between eastern U.S. ports and
Canada. After an extensive investigation, the subsequent discovery of infested clementines at several eastern
locations was ultimately considered to
be a result of the failure of the T/E
system, not the cold treatment.
Under a T/E permit, a shipment is
placed under Customs bond and is issued a permit with transit directions
and port of exit instructions. But,
there exists no mechanism for enforcement other than a paperwork
match at port of exit. This paperwork
56
REPORT
reconciliation is time consuming as
ports of exit can and do change with
notice to Customs, not PPQ. There is
no estimated time for transit and exit
required, and no means for tracking
shipments to assure adherence to the
corridor restrictions.
To illustrate some potential pest risks,
Mexican mangoes, citrus and avocados are regularly authorized movement from Mexico to Canada through
a specified transit corridor. Violation
of the transit corridor is only identified when uncertified Mexican mango
and avocado trucked shipments are
intercepted at California agricultural
inspection stations. Adding to the pest
risk is the regular and routine interception of Mexican mangoes and avocados re-entering at the U.S./Canada
border, at California agricultural inspections stations and during market
surveys. Also problematic is mango
truck contamination by fruit fly larvae
and pupae. These trucks enter
Canada, are offloaded, and may be reloaded with non-agricultural product
that would not then be subject to
agricultural inspection upon re-entry
into the U.S. Only empty trucks or
trucks identified as having carried
Mexican mangos and found infested
with fruit flies are required to be
cleaned prior to re-entry into the U.S.
Immediate transport (IT) and residue
cargo (RC) permits provide a means to
clear commercial cargo container
shipments at specified inland locations. Commercial cargo shipments
entering the U.S. under an Òimmediate transportÓ permit are not inspected at the POE but immediately
move to a designated location for inspection and/or treatment as necessary. Although Òimmediate transportÓ
permits are used mainly to enable devanning and facilitate treatment, this
permit system could be used to facilitate the entry of commercial cargo
when seasonal entry peaks overwhelm
the inspection capability at POEs.
Safeguarding American Plant Resources
Other regulations provide for limited
distribution as a pest mitigation
method. Currently, regulations provide for the limited distribution of citrus from Japan and Cheju Island,
Korea for citrus canker mitigation,
Hass avocados from Mexico and melons from Ecuador for a several insect
pests. But, no enforcement mechanisms are available to ensure compliance. Limited entry citrus are
regularly intercepted at California
agricultural inspection stations
prompting the smuggling interdiction
staff to begin to monitor markets for
compliance.
Recommendations
■ E-55 Prohibit the T/E entry of
plants and plant products not in compliance with U.S. entry requirements
until and unless the following recommendations have adequately mitigated
the invasive plant pest risk associated
with this pathway.
■ E-56 Revise the safeguarding regulation (7 CFR 352) to incorporate pest
risk into the decision-making process
for permit issuance.
■ E-57 Review and update its transit
guidelines, provide headquarters staff
support and develop a permit review
process for port staff.
■ E-58 Develop a risk assessment
process to evaluate transit permit requests.
2.17 Port of Entry
Inspection
Port of entry inspection (POE) is performed by APHIS-PPQÕs agricultural
quarantine inspection (AQI) program.
It is funded at air and maritime POEs
primarily through user fees assessed
to the air carriers and shipping lines.
Trucks entering the U.S. from Mexico
REPORT
are charged user fees; trucks entering
the U.S. from Canada are not. Rail
and international mail inspections are
also part of this inspection program.
APHIS-PPQ is one of the three primary Federal Inspection Service (FIS)
agencies responsible for monitoring
the entry of cargo and passengers into
the U.S. In addition to conducting
quarantine inspections, APHIS-PPQ
inspectors are responsible for reviewing and issuing certificates for agricultural exports, working temporary
duty assignments away from their
normal work location, and performing
other duties such as smuggling interdiction and fumigation supervision. In
response to government reinvention
initiatives, PPQ is working with the
other FIS to expedite clearance of international passengers and cargo. As
target clearance times have been met,
new targets have been established.
For example, passenger clearance targets of 45 minutes have been reduced
to 30 now 20 minutes.
The presence and availability of
APHIS-PPQ staff is directly related to
the level of quarantine compliance
and the cooperation it receives from
other FIS agencies. But, PPQÕs ability
to participate in port quality improvement initiatives let alone staff emerging POEs is lacking due to staff and
resource constraints. As a result,
cross training and work sharing opportunities for Federal inspection service (FIS) agencies are largely
unexplored.
Based on the best available data from
agricultural quarantine inspection
monitoring (AQIM) data and other
surveys, the pest introduction potential appears to move from greatest to
least in the following order: smuggled
products, air cargo, reefer cargo, passenger baggage, and cruise ships.
Information regarding the pest risk
from ballast water, private aircraft
and garbage remain unassessed.
Safeguarding American Plant Resources
57
Despite additional resources, APHIS
cannot hope to keep pace with the
continuing increases in passenger and
cargo movement.
Implementation of technology improvements can help expedite clearance. The development of ÒsmartÓ
x-ray equipment will provide for
quicker baggage inspection. Advances
in video imaging capabilities, where
available, enable species identification
within hours instead of days.
Recommendations
■ E-59 Work with other FIS and port
authorities to assure that adequate
staffing and equipment are identified
and in place prior to the establishment of new ports of entry.
■ E-60 Implement the use of ÒsmartÓ
x-ray equipment, as it becomes commercially available.
■ E-61 Place video imaging equipment
at plant inspection stations to expedite species identification.
■ E-62 Use existing agricultural quarantine inspection monitoring data to
target port of entry inspection priorities, assess port of entry activities,
and estimate the risk presented by
new or unstaffed ports of entry.
2.18 Traveling Public
International passenger traffic is anticipated to continually increase and
will further overwhelm APHIS-PPQÕs
program effectiveness in excluding invasive plant pests. Education to make
passengers and air carriers more
aware of the potential pest introduction via this pathway (informed compliance) must be considered the most
effective means to mitigate this risk.
Industry involvement is crucial in developing procedures that, through education and cooperation, encourage
voluntary compliance by the traveling
public. Increasing the efficiency of
passenger inspection and shifting
some responsibilities to the air carrier
will permit PPQ staff to pursue other
duties.
Remote surveillance capability using
closed circuit television will soon
Backlog of trucks arriving from
Canada at the Port Huron, MI, border crossing. Construction of an
additional bridge will accommodate increased truck traffic but further challenge inspection program.
58
REPORT
Safeguarding American Plant Resources
begin at Miami International Airport
at Customs and Immigration and
Rover Command Centers and will be
available for APHIS use.
Recommendations
The Committee recommends the following to strengthen quarantine enforcement upon entry. Other related
recommendations may be found
under Offshore Activities and Public
Education and Awareness.
■ E-63 Require all passenger baggage
to be subject to examination using
ÒsmartÓ x-ray technology that detects
quarantine material.
■ E-64 Work with Customs to place
APHIS staff at preprimary roving location areas at all high traffic ports of
entry.
■ E-65 Develop legislation to prohibit
all unprocessed food and plant products or require phytosanitary certification in passenger baggage.
■ E-66 Explore the possibility of privatizing air passenger clearance.
Public Education and
Awareness
foreign travelers, governments and
commercial importers is not
uncommon and needs to be
addressed at points of contact.
Ticketing is a critical feature of airline
travel and a process that can be made
more useful in safeguarding efforts.
Agents at points of departure speak
the native language and can ask
travelers if they possess agricultural
materials. They can then remind
potential passengers of U.S.
quarantine regulations and the
penalties imposed if they are
disregarded. Airline personnel would
not prescreen travelers, only advise
them of PPQ expectations.
A ticket-sized quarantine regulation
insert should be prepared in the native language(s) and placed in the
ticket packet by the airline. This
would be much the same as the procedure employed to instruct passengers occupying exit row seats on
aircraft. The desirability of this procedure is that it would be a highly visible reminder to boarding passengers,
could be done economically, and is
compatible
with airline
ticketing
procedures.
The general public must understand
that exotic pests and pathogens can
be introduced accidentally via the
movement of people and goods. Target
audiences for a public awareness program should include schools, ethnic
communities, industry, and travel and
trade representatives. Programs
should be developed to address each
audienceÕs particular area of concern,
in the appropriate language, and reflect cultural differences.
Education of both travelers and air
carriers is fundamental to assuring
that plant quarantine efforts are
successful. A lack of knowledge of
U.S. plant quarantine regulations by
REPORT
A sample of illegal agricultural product intercepted in passenger luggage at
Los Angeles International Airport arriving from Italy and Australia.
Safeguarding American Plant Resources
59
In conjunction with passenger education efforts, means for safe disposal
should be conveniently provided and
clearly marked in each departure terminal. PPQ should not expect the air
carrier to maintain such bins or dispose of regulated material; PPQ
should contract for such services and
monitor for quality compliance.
Recommendations
■ E-67 Request that U.S. Customs
amend its declaration (Customs Form
6059) to clarify plant quarantine requirements.
■ E-68 Negotiate with the U.S.
Department of State to include a public education flyer in its visa applications within the coming year.
■ E-69 Negotiate with air carriers to
include a public education flyer with
passenger ticketing information in the
language of the country of origin and
to include a question regarding possession of agricultural products when
ticket agents perform safety prescreening within two years.
■ E-70 Negotiate and contract with
air carriers to provide amnesty bins at
points of departure with two years.
■ E-71 Develop and foster close and
effective working relationships with
other Federal inspection service
agencies.
2.20 Commercial Cargo
Agricultural quarantine inspection
monitoring (AQIM) data, based on volume and pest interceptions, show
that the pest introduction potential is
greatest for commercial cargo shipments. AQIM, for fiscal year 1998,
shows that 91 percent of the estimated pounds of prohibited material
missed came from sea and air cargo,
60
REPORT
the remaining nine percent was from
passenger baggage. The trend to containerize all cargo and development of
container movement strategies to expedite movement from the POE to
destination, such as the Alameda
Corridor, and the increased sharing of
vessel container space, will continue
to preclude inspection at POEs. The
increased sharing of vessel container
space will continue to make inspection even more problematic. The future for effective pest exclusion for
commercial cargo shipments must
focus on the development of effective
offshore mitigation and certification
strategies, coupled with inspection capabilities at destination.
Timber used for dunnage and as
packing for goods carried in containers, almost by definition is mostly of
low grade and the risk of pest infestation is relatively high. Based on increased pest interceptions APHIS
recently regulated solid wood packing
materials from China and Hong Kong
and has published an advanced notice of proposed rulemaking to solicit
recommendations for a long-term solution to this problem.
Rail shipments are essentially unmonitored; the pest risk for this pathway is unknown. At this time,
monitoring of rail shipments is by way
of access to Customs shipment processing databases such as the automated commercial system (ACS), the
automated manifest system (AMS)
and the rail line release system.
Monitoring at several Canadian land
border crossings is conducted via access to Customs AMS. Two of the
major southern border crossings are
currently exploring the possibility of
utilizing this system for compliance
monitoring.
Known agriculturally regulated articles entering via rail are primarily
grain and lumber. Pest pathway risk
for rail entry at the Calexico crossing
Safeguarding American Plant Resources
is unknown for commercial cargo, as
it has never been monitored.
Nevertheless, the Border Cargo
Release Program, developed to expedite the entry of historically low risk
product from Mexico is a good example of how pest risk data can be used
to mitigate pest risk and expedite
commodity entry. Currently in use to
expedite truck entry, this strategy,
coupled with the use of Customs line
release system, should be explored for
expanded use where pest risk data indicates a low risk for invasive plant
pest entry and establishment.
Recommendations
2.21 International Mail
and Private parcel Carriers
APHIS-PPQ is responsible for the inspection of all foreign parcels entering
the U.S. via private parcel carriers
and the U.S. Postal Service.
Traditionally, APHIS-PPQ has relied
on labeling to select parcels for inspection. More recently, x-ray equipment and dogs have begun to be
placed in facilities to enable screening
parcels for agricultural material.
There may be opportunities to upgrade mail and parcel inspection
when facilities are redesigned, e.g.,
Los Angeles international mail inspection facility.
■ E-72 Support and encourage training for use of and access to Customs
databases.
Recommendations
■ E-73 Implement the North
American Plant Protection
Organization standard for solid wood
packing materials with the long-term
goal of a world wide prohibition of
solid wood packing materials in cargo
transport.
■ E-79 Install smart x-ray equipment
on international mail and private parcel belts in order to examine all foreign origin mail and parcels.
■ E-74 Require that all empty containers be free of all plant and animal
residue prior to entry.
■ E-75 Expand the border cargo release program to all ports of entry.
■ E-76 Develop a destination inspection program for low risk cargo.
■ E-77 Develop a destination inspection program for immediate transport
cargo at approved devanning facilities
for high-risk cargo during seasonal
peak traffic periods.
■ E-78 Conduct a pathway risk assessment for rail shipments and monitor this pathway based on the risks
that are identified.
REPORT
The Committee recommends that
APHIS-PPQ work with the USPS and
private parcel carriers to:
■ E-80 Use dogs to screen mail at all
international mail and parcel ports of
entry until x-ray equipment is installed.
2.22 Private Air and
Cruise Ships
APHIS-PPQ staff monitor private aircraft and cruise ships for compliance
with quarantine regulations. Costs for
monitoring are partially recovered
based on a set fee structure. AQI
monitoring data shows the compliance approaches 98 percent and a
current inspection effort of 18.4 percent. Based on inspection and interception records this pest risk pathway
appears to be minimal (AQIM Report,
1998).
Safeguarding American Plant Resources
61
Recommendations
■ E-81 Conduct a specific pest pathway risk analysis to determine the invasive plant pest entry and
establishment risk posed by private
airplanes and cruise ships and revise
its monitoring levels accordingly.
■ E-82 Use renewable compliance
agreements to assure proper handling
or disposition for repeat entries as a
monitoring and pest mitigation strategy.
2.23 Garbage
Traditionally, AQI staff monitor air
and maritime garbage disposal primarily to guard against the introduction of animal diseases. In the past,
introductions of hoof and mouth disease, hog cholera and vesicular swine
fever have been traced back to foreign
garbage. Whereas, airport garbage
handlers are under compliance agreement for garbage disposal, disposal of
maritime garbage is still performed
under direct supervision.
Recommendations
■ E-83 Conduct a pest pathway risk
assessment for air and maritime
garbage to identify and evaluate the
actual pest risk.
■ E-84 If warranted, place disposal of
maritime garbage under a compliance
agreement.
2.24 Ballast Water
Ballast water from ships is a primary
source for the introduction of aquatic
nuisance species. In 1991, ballast
water introduced cholera into the
shellfish beds of Mobile, Alabama.
Other documented introductions include: yellow fever into Alaska, zebra
mussel, spiny water flea and
62
REPORT
European ruff into the Great Lakes,
and Asian clam into Los Angeles and
Long Beach. The Aquatic Nuisance
Species Prevention and Control Act of
1990 (16 USC 4701) resulted in the
establishment of regulations for ballast water management for control of
non-indigenous species and placed
enforcement responsibility with the
U.S. Coast Guard. Its regulatory authority can be found under 33 CFR
151.1510. But, current regulations
only cover Snell Lock, Massensa, New
York, the Hudson River north of the
George Washington Bridge, and navigation in the Great Lakes. Compliance
at other U.S. ports is voluntary.
Recommendations
■ E-85 Request that the Invasive
Species Council established under
Executive Order 13112 coordinate
further actions to mitigate ballast
water risk with APHIS and the Coast
Guard.
■ E-86 Request that the Invasive
Species Council review the Coast
GuardÕs regulation (33 CFR 150.1510)
and suggest revisions if necessary to
include other POEs based on the
identified risk.
2.25 Technology
Application and Research
Needs
APHIS activities are supported by
USDA-Agricultural Research Service
(ARS) basic research, while APHISÕs
Methods Unit provides both basic and
applied research and technology. In
recent years, development of new
technologies and applications has
been hampered by laboratory closures
and funding shortfalls. The APHISPPQÕs ability to continue excluding
pests, providing commodity treatment
solutions, and developing pest-free
Safeguarding American Plant Resources
and pest mitigation programs to facilitate the access and retention of export
markets will depend, in part, on its
ability to develop new technologies
and applications.
The development of the Center for
Plant Health Science and Technology
is a positive step toward what has
been viewed as a longstanding need.
While regional methods labs are designed to provide solutions for AQI
needs, there is little evidence of routine interaction. Instead, basic research and publishing results appear
to be a primary goal of Methods staff.
Its principal function should be to
provide the technological answers in
support of field operations requirements. Evaluation of Methods center
directors and their staff should be
based on this premise. The recent
diminution of support for Methods
functions may be related to its perceived relevance to APHISÕs mission.
■ E-91 Develop rapid generalized testing for target species
2.26 Detector Dogs
The use of dogs to detect meat and
plant products is employed at a number of POEs. Dogs are used to monitor
international mail, air passengers and
certain cargo entries. The APHIS-PPQ
plans to integrate The Beagle Brigade
Program into a number of AQI operations including airport baggage clearance, international mail facilities,
cargo inspection, land border surveillance, and smuggling interdiction. It
also has plans to explore other areas
outside AQI where use of dogs may be
helpful and to explore crossutilization possibilities.
Recommendations
■ E-87 Evaluate Methods staff performance according to their accomplishments in providing solutions to
identified Agricultural Quarantine
Inspection needs at least every three
years.
■ E-88 Develop an annual list of
ÒneedsÓ by Agricultural Quarantine
Inspection staff for submission to
Methods for its consideration.
■ E-89 Provide a listing of studies and
development programs to Agricultural
Quarantine Inspection staff on an annual basis to inform them of supportive work that may be coming on line.
■ E-90 Have Agricultural Quarantine
Inspection representatives participate
in the development of Methods annual
work plans to assure Agricultural
Quarantine Inspection needs are incorporated and met.
REPORT
The San Ysidro, CA, border crossing from Mexico with the normal daily
volume of vehicular traffic. Note the Customs officer with a detector dog
conducting a primary inspection for controlled substances.
At this time PPQÕs program is constrained by a commitment to use beagles and a specific passive training
technique. Customs and CaliforniaÕs
dog programs use both passive and
aggressive search and alert techniques specific to the assigned task
and select breeds based on the traits
Safeguarding American Plant Resources
63
desired for a specific task. As a result,
APHIS is self-limited in its ability to
expand its use of dog scenting.
Recommendations
■ E-92 Place detector dog teams at all
high-risk ports of entry to facilitate
passenger and baggage clearance.
■ E-93 Review its training and breed
selection program to maximize use of
different screening techniques and
breed capabilities.
■ E-94 Negotiate with Customs to
cross-train its dogs to screen for agricultural products at smaller ports of
entry.
2.27 X-Ray Application
X-ray equipment is currently used to
screen passenger baggage for pre-departure and at some ports of entry, at
international mail facilities, and for
cargo containers at various high volume locations and devanning sites
along the U.S./Mexico border.
Customs plans to install additional
truck x-ray equipment at additional
southern border locations and at
northern border crossing locations as
funding allows.
The development of tomographic x-ray
equipment to facilitate inspection at
POEs is currently stalled. Originally
under development by the Federal
Aviation Agency to facilitate explosion
detection, funding by that agency was
rescinded when this technology failed
to detect sheet explosives at the required levels.
Vivid Technology has developed a dual
energy x-ray system that will enable a
high speed analysis of baggage for
quarantine commodities which uses
the atomic number, mass, and density of objects to discriminate targeted
materials from non-targeted objects.
Implementation of this x-ray technology is planned to begin at JFKÕs
Terminal One as a pilot program and
then expand to other international
airports.
Other x-ray technology under development in addition to heavy pallet x-ray
and improved truck x-ray capability
include imaging and relocatable inspection systems (IRIS or VACIS) and
a railcar inspection system that uses
gamma rays to detect objects as a
train moves slowly through the equipment.
Recommendations
■ E-95 Develop or abandon development of tomographic x-ray technology.
Truck X-ray facility, Otay Mesa, CA, used principally by U.S.
Customs for drug interdiction. A detailed X-ray of an entire semitruck with cargo requires 10 minutes.
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REPORT
■ E-96 Acquire and begin using Vivid
TechnologyÕs dual energy x-ray system, and any other identified smart xray equipment to expedite screening
and clearance of cargo, baggage and
mail.
■ E-97 Negotiate with Customs to use
its truck x-ray capability to screen
cargo containers.
Safeguarding American Plant Resources
■ E-98 Test the utility of Vividª x-ray
equipment at high-risk ports of origin,
i.e., Guatemala City, Guatemala.
■ E-99 Develop and use genetic mapping to identify interception origins
and support pathway risk models.
2.28 Future Possibilities
and Research Needed
■ E-100 Monitor how Customs uses
remote surveillance and adopt this
strategy at other locations if it is determined to be a useful and effective
clearance strategy.
Many commodities could be screened
for pathogens more rapidly and accurately if currently available technologies for rapid biomedical pathogen
identification (PCR, RAPID) were
adapted by APHIS. The development
of a Bacillus thuringiensis implanted
genetically engineered organism has
been successful for cotton and should
be incorporated into the pink boll
worm program.
The plasma arc contraband destruction system (PACDS) utilizes an alternating current plasma torch to
convert 99.8 percent of the organic
and Òthin walledÓ inorganic material
treated into benign gases. Treatment
can be performed in the original packaging. This system will be tested at
Otay Mesa, California.
Currently, the ARS is developing plum
pox resistance in fruit trees. The development of disease resistant cultivars needs to be expanded for other
quarantine disease organisms. The
development of gamma, x-ray, and
electron-beam irradiation is in its infancy. Its use against disease
pathogens, e.g. citrus canker, is just
beginning to be developed.
In recent years the chemical/pharmaceutical industry has identified a new
class of compounds known as membrane incorporated molecules (MIMs).
One of these compounds has been
shown to be effective against the citrus canker causal bacterium. This
discovery has also led to the idea of
exploring the use of benign plant
virus delivery systems to enable a
plant to fend off disease organisms by
means of anti-disease peptides production.
REPORT
■ E-101 Monitor and provide funding
for the development of new x-ray technologies.
2.29 Business
Practices/Services
Services
AQI staff, in addition to their quarantine enforcement duties, performs
various services to both importers and
exporters. These include post-entry
quarantine, export certification, and
treatment to meet entry requirements
at the POE. In addition to other duties, headquarters staff pursue market access, process import permits
and perform risk assessments. These
various services are either fully or
partially funded from the APHIS budget. The APHIS-PPQ staff, under a
trust fund arrangement, performs
preclearance operations in other
countries as requested by the exporter. However, replacement costs of
inspectors assigned temporarily to a
preclearance program are absorbed by
APHIS-PPQ and these positions frequently go unfilled. These services
provide a direct benefit to the industry by facilitating both import and export trade opportunities and are given
high priority by APHIS-PPQ to the
detriment of quarantine enforcement
duties.
2.29.2 Recommendations
■ E-102 Seek full cost recovery via a
fee for service, or privatize service
functions not mandated by law under
close APHIS oversight. These services
Safeguarding American Plant Resources
65
include certain trade facilitation activities, development of export programs,
export certification, post-entry quarantine, etc.
■ E-103 Require and budget for staff
replacement at ports of entry when
staff are on temporary duty assignments for preclearance.
2.30 Employee
Development
In many of its discussions with APHIS
staff, the Committee found that
APHIS staff at all levels and locations
are committed to pest exclusion and
the protection of American agriculture
and the environment. But, in many
cases, staff are frustrated by the lack
of training and equipment available to
enable them to perform as effectively
as they would like. Some of the more
commonly expressed concerns included:
¥ An inability to perform necessary inspections due to workload and lack of
sufficient resources.
¥ A desire to work more with industry,
other FIS agencies and the public to
assure compliance.
¥ A need for more training and additional tools such as computer equipment and training, training videos,
access to training technologies to
identify and target inspections.
¥ A need for effective communication
with headquarters and other field offices for consistency and uniformity of
inspections.
To facilitate uniformity of inspection
and quarantine enforcement, APHISPPQ relies on manual guidelines. In
its many discussions with APHIS-PPQ
staff, the Committee observed that
this manual approach, over time and
absent other education and training
opportunities, has fostered staff focus
at all levels on process rather than
accomplishment of the Agency Ôs
66
REPORT
mission. In other words staff tend to
view the solution as more simply a
need for more resources to do more of
the same, i.e. the focus is on Òdoing
things rightÓ in lieu of Òdoing the right
thingsÓ to exclude pests.
More problematic, staff expressed a
powerlessness to make even the most
minor of decisions for process improvement. As a result, it was not uncommon to see port specific and
stand alone computer systems and
guideline development as a coping
strategy.
Recommendation
■ E-104 Provide ongoing staff training
in quarantine laws and regulations,
computer and equipment use, and
data and risk management and education on the impacts of invasive
pests.
■ E-105 Increase communication
channels horizontally and vertically
between headquarters and port staff
by prioritizing and scheduling staff
meetings, etc.
■ E-106 Allocate individual port budgets to the port directors for local level
resource management.
2.31 AQI Staff
Assignment
Currently, staffing is allocated based
on formulas associated with the Work
Accomplishment Data System. This
database has come under a great deal
of criticism and, in part, the AQI monitoring surveys were developed to assess this database as well as identify
emerging pest introduction pathways.
According to the current staffing
guidelines, many POEs are greatly
understaffed, but these guidelines estimate staffing needs based on quarantine material interceptions (QMIs).
Safeguarding American Plant Resources
A QMI is one regulated item from one
country, there is no weight or priority
assigned based on volume or estimated risk. To illustrate, an air passenger carrying one apple, orange,
peach and pear would be considered
four QMIs; a container of untreated
mangos from a regulated country
would consist of one QMI. Countries
are assigned a high, medium, or low
risk rating based on the number of intercepted QMIs.
In addition, there is no policy or
guidelines to staff POEs during peak
entry hours. The workload at many
major POEs is continuous, that is 24
hours/day. Yet these ports are almost
entirely staffed with one regular work
shift (8:00 a.m. to 4:00 p.m.) and 16
hours of overtime on weekdays; and,
24 hours of overtime (at time and one
half) on Saturday and Sunday (double
time). At new, or emerging ports,
where the need for permanent staff is
indicated yet the workload primarily
occurs during non-traditional work
hours, it seems counterproductive to
staff and fund a daytime tour of duty
(with 16 hours of overtime) to address
a primarily after hours work load. To
date, alternate work shifts have been
implemented for Miami air passenger
inspection only.
The APHISÕs current policy and
regulation (7 CFR 354) exclude
weekends from the scheduled work
week assignment. This report also
noted that 50 percent of the Sunday
overtime charges came from five ports
(Honolulu, New York, Miami, San
Juan and Los Angeles) while 46 highvolume ports accounted for 93
percent of the Sunday overtime. A
recommendation to make Sunday a
regular workday has never been
implemented. Recommendations
found in APHISÕs 1998 Overtime
Report have not yet been developed
for implementation. Suggested
strategies to reduce overtime costs
included recommendations to ensure
REPORT
that tours of duty correlate with work
loads, scheduling of regular overtime
in lieu of call backs where feasible.
Also included in this report were
recommendations to conduct a review
of commuted travel time (CTT) at all
ports for which CTT exceeds one hour
to ensure accuracy and
appropriateness and to examine the
policy which grants CTT in
conjunction with scheduled overtime
and holidays. A draft analysis of
commuted travel time at selected
locations is currently under
development.
A January 1999 Analysis of
Upgrading Grade 9 PPQ Officers and
Implementing a $30,000 Cap on
Premium Pay noted that in fiscal year
1997, 284 PPQ officers earned more
than $30,000 in premium (overtime)
pay. In addition to the premium pay
cap, it recommends an upgrade for
many of the Grade 9 PPQ officers currently performing Grade 11 work and
suggests an increased use of Grade 5
employees to perform routine (and
overtime) inspections.
Recommendations
■ E-107 Require port staff to collect
and use agricultural quarantine inspection monitoring data as it was intended and annually use it to revise
the workload accomplishment data
guidelines and codes accordingly.
■ E-108 Redefine quarantine material
interceptions to include country of
origin pest risks and commodity volume.
■ E-109 Initiate and implement work
shifts to coincide with workload and
where workload criteria justify a second shift (i.e., an average of two call
back inspections/day) and hold management accountable for implementation.
Safeguarding American Plant Resources
67
■ E-110 Assign staff at ports of entry
where evidence shows the need for
permanent staff.
■ E-111 Expand the use of technical
positions for activities such as passenger baggage clearance and upgrade APHIS-PPQ officers where work
assignments warrant such upgrades.
■ E-112 Revise its overtime regulation
and policy to provide for the establishment of scheduled weekend tours
of duty.
■ E-113 Explore the feasibility of an
overtime cap.
2.32 Database
Management
At all POEs visited the committee
found that APHIS was hindered from
assessing risk due to myriad standalone databases it uses and the quality of the data entry. Moreover, there
is no database capability to track
quarantine violations/violators to target efforts towards repeat offenders.
In addition, the committee learned
that:
¥ Staff lack training in computer and
database operation.
¥ There is no budget allotment for
equipment, i.e., computers and upgrades and where funds are available
purchases and contract development
is highly regulated.
¥ The relevance of AQI Monitoring versus WADS data needs further evaluation.
¥ Port staff are not collecting and
using the AQIM data as designed.
¥ Computer communication outside
USDA is lacking.
¥ Usefulness of data collected is questionable.
¥ Software programs are inadequate.
¥ Reports are not available from port
to port to assist in enforcement
68
REPORT
decisions, data analysis and risk
assessment.
¥ There is a need to Òidentify the universeÓ to capture and quantify pest
pressures at each port.
¥ Development of a database to enable
better data use and targeting of resources is needed.
¥ There is no mechanism available to
account or react to differential growth
at individual POEs.
¥ Computerization/electronic access
to APHIS operational manuals and
training is needed.
¥ There is no way to query and sort
pest interception network (PIN) data
by field.
¥ Establishment of a database management team.
Moreover, electronic communication
capabilities are lacking, and information-gathering efforts are hampered
by database systems that are all
stand-alone and cannot be queried.
Recommendations
■ E-114 Request an agricultural
quarantine inspection program work
plan from its information technology
support staff.
■ E-115 Integrate its information
technology resources and staff under
the agricultural quarantine inspection
program management.
■ E-116 Physically co-locate information technology staff with agricultural
quarantine inspection staff at entry
port locations.
■ E-117 Explore the feasibility of outsourcing data entry to reduce workload.
Safeguarding American Plant Resources
2.33 Civil Penalty
Guidelines
Recommendations
There is lack of uniformity in the implementing of this authority from port
to port. Also, there are no civil penalty
guidelines employed for violations of
APHIS-PPQ regulations in commercial
cargo and detected cases of smuggling.
In addition to revision of the civil
penalty guidelines, a commitment by
PPQ employees and management to
uniformly apply and administer civil
penalties is requisite. The guidelines
should state that penalties should be
uniformly applied in instances when
passengers have prohibited agricultural contraband and deny that they
are carrying such (for example, two
ÒnoÓ responses in the procedure
should require assessment of a fine).
The ability to negotiate a penalty
should be limited to the full amount
or one half of that amount. There
must be a commitment on behalf of
PPQ employees and management to
uniformly apply and administer a system of civil penalties.
The use of civil penalties should be
considered when violations of rules
governing the importation, entry, exportation or movement in interstate
commerce of plant pests, plants, biological control organisms, noxious
weeds, animal pests and articles, or
any means of conveyance are detected
in commercial shipments capable of
harboring such. Guidelines for the application and amounts of such civil
penalties should be developed using
standards followed by Customs
Service for fines when drugs, etc. are
found in commercial shipments.
REPORT
■ E-118 Revise its civil penalty guidelines to clarify enforcement provisions
in consultation with APHIS port staff.
■ E-119 Develop a civil penalty structure to provide consistency in penalty
assessment.
■ E-120 Revise its training program
and provide staff ongoing refresher
training for civil penalty assessment
■ E-121 Require ports to track and
account for civil penalty actions
taken.
2.34 Unaddressed Issues
Solely due to timeframe constraints,
the committee was unable to sufficiently examine other potential
and/or emerging issues and pathways
as follows:
¥ Emerging pathways, such as bioterrorism, biotechnology (genetically
modified organisms, biological control
agents, etc.).
¥ The risk from the trend towards establishment of corporate airstrips to
receive international cargo.
¥ The role of invasion biology.
¥ The role of APHIS in newly enacted
Executive Order on Invasive Species.
¥ Long-term application of the Òregulated non-quarantine pestÓ provisions
of the IPPC.
Safeguarding American Plant Resources
69
70
REPORT
Safeguarding American Plant Resources
C h a p t e r
T h r e e
Pest Detection and Response
Committee Report
Introduction
Safeguarding AmericaÕs vast and important food and fiber resources from
incursions of invasive plant pests requires vigilance and expeditious intervention. Central to this mission is the
need for a seamless process by which
pre-border, border, and post-border
activities mesh to form a barrier to
the establishment of invasive plant
pests. Pre-border and border activities
are preventative in nature, whereas
post-border activities serve to detect
and respond to any breach of these
exclusion mechanisms. The organizational structure of the safeguarding
process should achieve an effective
flow of information and elicit the appropriate response to invasive plant
pest threats or incursions at all levels.
Program strengthening, with particular emphasis on enhancement of preborder and post-border activities, is
imperative for the Safeguarding of
American Plant Resources.
Safeguarding is a responsibility that
must be shared among Federal and
State governments, industry, and the
general public. Coordination of safeguarding activities resides with
Federal agencies, although participation at all levels must be encouraged
to ensure early detection of, and
prompt response to, the introduction
of invasive plant pests. Effective emergency response is essential to contain
and eliminate such introductions with
minimal financial and environmental
costs. The reorganization of APHISPPQ to appoint State Plant Health
REPORT
Directors has been a positive step in
providing leadership at the state level
as it applies to pest detection and response activities.
The Animal and Plant Health
Inspection Service (APHIS) plays an
integral role in the administration of
regulatory programs by the United
States Department of Agriculture
(USDA). The APHIS-PPQ is charged
with protection of commercial crops
and native ecosystems from damage
caused by invasive plant pests as well
as certification of export commodities.
Trade is facilitated by detection and
control of invasive plant pests in
order to meet phytosanitary standards
for export. These roles are not inherently conflicting or mutually exclusive. Indeed, proper attention to the
regulatory role results in automatic
fulfillment of the enhanced export
function through the ability to certify
products for shipment. By these actions, U.S. agricultural products may
avoid trade restrictions, while producers realize reductions in the cost of
post-harvest treatments to meet international quarantine requirements.
The Committee recognizes that detection and response activities contribute
not only to agricultural production
and enhanced marketability of U.S.
agricultural products, but that these
activities also benefit the community
as a whole. Among the most obvious
benefits are reductions in costs associated with control programs in terms
of dollars spent and pesticide load,
with its concomitant effects on
human and environmental health.
Safeguarding American Plant Resources
71
Safeguarding of native flora and
fauna, by exclusion of invasive plant
pests which may adversely impact
natural ecosystems, provides protection of endemic and indigenous organisms thereby maintaining native
biodiversity.
The Plant Pest Detection and
Response Committee carefully considered the many complex issues relative
to safeguarding plant resources
through post-border activities. The
Committee met with members of the
APHIS-PPQ management team for an
open discussion of APHIS-PPQ pest
detection and response activities.
Plant protection officials from New
Zealand, Australia, and Great Britain
interviewed in Riverdale indicated that
problems and concerns which the
United States faces in Safeguarding
American Plant Resources are in no
way unique. After careful consideration, the Committee developed issue
statements and recommendations to
facilitate establishment of well organized, scientifically valid, and adequately funded invasive plant pest
detection and response programs
within APHIS-PPQ. Several committee
members visited the Centers for
Disease Control and Prevention (CDC)
in Atlanta, Georgia to focus on the
CDC information exchange and response activities for human
pathogens and their potential application to post-border detection and response of invasive species threatening
plant health.
The Committee solicited information
on the current condition of invasive
plant pest detection and response
programs within the United States. A
questionnaire (Appendix E) prepared
by the Committee was distributed to
all State Departments of Agriculture
via the National Plant Board and to
State Forestry officials via the U.S.
Forest Service. Receipt of 51 replies,
representing 42 states, is indicative of
the importance that state plant
72
REPORT
protection officials assign to these
activities. These responses (Appendix
E) aided the Committee in identifying
areas of concern and in determining
the relative importance of the various
issues under consideration.
3.1. Organizational
Structure for Invasive
Plant Pest Detection and
Response Activities
3.1.1. Organization of Invasive
Plant Pest Detection Activities
Background
A clearly defined, comprehensive, and
coordinated invasive plant pest detection program within the United States
is of utmost importance to our agricultural industries and the nation as
a whole. Early detection of invasive
plant pests that pass through exclusion barriers increases the likelihood
of timely eradication, if feasible, or the
initiation of cost effective mitigation
measures. Coordinated detection initiatives at the state, regional, and national levels are essential to assure
that detection objectives are properly
defined and executed in a timely manner.
The Cooperative Agricultural Pest
Survey (CAPS) program, administered
by the APHIS-PPQ, was created to
provide a national pest detection network by combining Federal and State
resources for pest surveys (NAPIS,
1999). The program targets invasive
plant pest surveys and response activities in three areas: invasive plant
pest detection, APHIS-PPQ export certification, and cooperative domestic
programs, i.e., fire ant management
and biological control. CAPS detection
Safeguarding American Plant Resources
activities are coordinated by APHISPPQ through regional committees,
however, there is considerable disparity in its administration.
program focus in some States.
Incentives for scientific surveillance
have been eliminated and information
dissemination does not occur.
Findings
(5) A critical need exists for a comprehensive invasive plant pest detection
system in the United States. An effective State and Federal partnership is
needed to establish pest detection priorities and clearly defined action
plans for coordination of pest detection activities at the state, regional,
and national levels. This need is underscored by the concerns surrounding the entry and establishment of
invasive plant pests.
(1) The APHIS-PPQ does not exert a
leadership role in coordinating plant
pest and disease detection activities
on a national level. This situation has
largely resulted in APHIS-PPQ abdication of pest detection activities by
shifting them to the States. The States
lack necessary resources, authority,
and, most importantly, coordination
to conduct effective detection activities on a nationwide basis. Further,
Federal funding, pest priorities, and
cooperative activities are inconsistent
from state to state and from region to
region. This disparity was evident in
questionnaire responses from state
plant regulatory officials (Appendix E).
Thirty-eight state respondents indicated a need for better organization
and coordination of pest detection at
the regional and national level.
(2) The CAPS program has failed to
provide a unified national pest detection system. This program is not functioning efficiently due to inadequate
funding, lack of Federal coordination
and oversight, and because the authority to conduct surveys may not
necessarily reside with agencies which
are responsible for their execution at
the regional and state levels.
(3) The CAPS program has been effective in some participating States by
providing a framework and funding
mechanism for pest survey or detection efforts. Unfortunately, states
which lack matching funds, technical
staff, and management, or which encounter stakeholder sanctions do not
participate in CAPS activities.
(4) Politics, not scientific validation,
determines much of the CAPS
REPORT
(6) The Centers for Disease Control
and Prevention (CDC) has developed a
nationwide surveillance program for
human illnesses that identifies organisms and areas of the United States
that are considered to be high risk
(Hutwagner et al. 1997; United States
Department of Health and Human
Services, Centers for Disease Control
and Prevention, 1998 a & b). A nationwide surveillance program for invasive plant pests is crucial to the
implementation of pest detection and
response activities.
Recommendations
■ D-1 Restructure the existing
Cooperative Agricultural Pest Survey
program to create a Federal and State
Cooperative Invasive Plant Pest
Survey Program (CIPPS) under the supervision of the National Invasive
Plant Pest Coordinator. Empower this
Coordinator to set invasive plant pest
detection and response priorities and
implement survey and detection activities in the United States. Designate
the position of the Coordinator to report directly to the APHIS-PPQ Deputy
Administrator. The Coordinator will be
a permanent member of the Standing
Committee on the Collection and Use
of Intelligence on Exotic Pests (see I38).
Safeguarding American Plant Resources
73
■ D-2 Institute a three-tiered committee system to assist the National
Coordinator in identifying and prioritizing plant pest and disease detection
and response activities in the United
States.
3.1.2 Organization of Invasive Plant
Pest Response Activities
■ D-2a. State committees, composed
of key stakeholders in pest detection
activities, should be identified by the
lead State and Federal plant protection officials in each state.
Agricultural productivity forms a cornerstone in the foundation of
AmericaÕs prosperity. Crop diversity
and abundance allows the United
States to feed not only its citizens, but
also to export agricultural products
worldwide. Clearly, United States
plant resources are of paramount importance in maintaining the rich and
abundant agricultural base, which is
vital to national security. The high
standard of living results, in large
part, from the quality and abundance
of agricultural production in the
United States. This creates a focal
point for tourism and agricultural
trade. With these attributes comes the
risk of invasive plant pest introductions. Such introductions in
California, Florida, Hawaii, and New
York over the last decade dramatically
illustrate this problem. Indeed, incursions in the past two years show an
alarming increase in invasive plant
pest introductions. Improvements in
exclusion barriers as well as detection
systems and response mechanisms
for exotic agricultural pests that
breach these barriers are of utmost
importance. The impact of invasive
plant pests entering the United States
extends beyond agriculture to public
health and disruption of natural
ecosystems wherein native flora and
fauna may be adversely affected.
Finally, the threat of bio-terrorism,
the intentional introduction of agricultural pests, cannot be ignored.
Considered in their entirety, these issues underscore the absolute necessity of strengthening United States
invasive plant pest response activities.
■ D-2b. Regional committees should
include the State and Federal plant
protection officials and Regional Plant
Board members from each state in
the region.
■ D-2c. The National Committee
should include representatives from
each of the Regional committees. The
National Committee should be chaired
by the National Coordinator.
■ D-3 Develop and endorse a conceptual design for the Cooperative
Invasive Plant Pest Survey Program
(CIPPS) that will:
■ D-3a. Establish a nationwide surveillance program to identify potential
pest organisms and high risk, sentinel
areas for introductions,
■ D-3b. Standardize invasive plant
pest detection activities at the state,
regional, and national levels, and
■ D3-c. Support export certification
requirements and domestic program
duties.
Background
The APHIS-PPQ Emergency Programs
Manual (USDA-APHIS-PPQ, 1996a)
74
REPORT
Safeguarding American Plant Resources
provides an outline of general procedures for initiating response activities.
Guidelines for exotic fruit fly incursions, the best example of cohesive
strategic planning and comprehensive
protocols, exist because frequent introductions require them. Emergency
response guidelines are available for
only fifteen other pests. This means
that most response plans must be formulated after new introductions are
detected. Valuable response time is
lost while a literature search and a
pest risk assessment (PRA) are conducted (USDA-APHIS-PPQ, 1997a).
Concurrently, additional detection activities are initiated to determine the
extent of the pest incursion. The response activities are carried out
through establishment of a New Pest
Advisory Group (NPAG) by the APHISPPQ Center for Plant Health Science
and Technology (CPHST). The NPAG,
comprised of a core group of APHISPPQ technical specialists and operations managers, supplemented by
representatives from States,
Universities, Industry, and applicable
International and Domestic Agencies,
must formulate an action plan for
containment and control. The NPAG
mechanism, recently assigned to
CPHST, requires prompt implementation and is most effective when stakeholder involvement occurs at the early
stages of planning.
Trained individuals with experience in
emergency programs are essential in
the initial stages of emergency responses. Unfortunately, preparedness
activities have received low priority
and very limited resources are available for this purpose. Regions responsible for maintaining rapid
response teams are the primary sites
for training. In the past, personnel
acquired these essential survey, regulatory and control skills through participation in domestic programs,
programs which have been reduced
significantly, or are no longer in place.
Emergency response team members
REPORT
assigned to collateral duties in the
ports could gain practical training by
participating in survey and regulatory
activities in early detection programs
around ports.
Several factors impede prompt implementation of emergency programs.
National plant protection laws often
do not provide authority to implement
important regulatory activities essential to emergency invasive plant pest
response activities. Delays occur because APHIS-PPQ personnel with
management duties in emergency response programs have limited authority for procurement and personnel
decisions. Program managers themselves are hesitant to expend funds in
emergency programs because allocations for such programs are often delayed.
APHIS-PPQ has initiated a plant safeguarding system that involves, not
only emergency eradication protocols,
but also long-term management of
plant pests (USDA-APHIS-PPQ,
1996b). The principal approach for
APHIS-PPQ management programs is
to develop and apply tools to mitigate
the effects of introduced exotic pests,
particularly invasive plant pests.
Although any number of Federal
agencies (e.g., U.S. Forest Service,
USDA-ARS, Department of Interior,
and Bureau of Reclamation) can address non-eradication responses, only
Safeguarding American Plant Resources
75
APHIS-PPQ has the mandate to conduct surveillance activities. This mandate, taken together with the
statutory authority, infrastructure,
and technical expertise of APHIS-PPQ
imparts the Agency with a unique capability to carry out management activities. Management programs are
targeted at Invasive plant pest that
threaten plant resources and ecosystems, i.e., the boll weevil, grasshopper, pink bollworm, as well as general
programs for biological control and
noxious weeds. The APHIS-PPQ has
defined its mission in the Biological
Control Program to be that of a cooperator, with State and other Federal
agencies, in the implementation of biological control techniques (USDAAPHIS-PPQ, 1995).
Findings
(1) The APHIS-PPQ does not have a
well coordinated invasive plant pest
response plan to involve State and
Federal plant regulatory agencies and
industry stakeholders.
(2) Emergency response guidelines are
available for only a small number of
potential pests. This results in delays
in the initiation of response to detection of other pests.
(3) APHIS-PPQ emergency response
activities are often delayed due to limited authority for implementation,
procurement, and personnel decisions.
(4) There is a critical need for coordinated management of invasive plant
pests, including noxious weeds, plant
pathogens and invertebrates, which
have become established in the
United States. Lack of a coordinated
response has lead to confusion on the
part of States seeking Federal assistance in controlling invasive plant
pests.
(5) APHIS-PPQ pest management
76
REPORT
programs are inadequately funded to
meet the goal of controlling
established invasive species in the
United States.
Recommendations
■ D-4. Review and revise the APHISPPQ Emergency Programs Manual on
an annual basis to ensure that it
meets pest response needs.
■ D-5. Revise available emergency response guidelines to reflect current
response technology and biological
data.
■ D-6. Prepare emergency response
guidelines for plant pests which pose
an eminent threat to American plant
resources. The comprehensive exotic
pest list currently under development
by the Entomological Society of
America, the American
Phytopathological Society and the
Weed Science Society of America
under contract by APHIS-PPQ will assist in the determination of species
with the highest potential risk. These
are the species for which emergency
guidelines are most urgently needed.
■ D-7. Establish a nationally coordinated pest response plan that is administered under supervision of the
National Invasive Plant Pest
Coordinator (D-1). Use the threetiered committee system (D-2) to review response guidelines and set
response priorities, and in cooperation
with the Director of the Methods
Development Unit, recommend response development priorities.
■ D-8. Coordinate, and augment
when appropriate, the development
and implementation of response tools
to mitigate impacts from established
invasive plant pests, i.e., biological
control methodology.
■ D-9. Secure funding to expand and
establish the infrastructure required
Safeguarding American Plant Resources
to develop and implement effective
plant pest management programs
when eradication is not deemed feasible.
■ D-10. Identify United States
Department of Agriculture organizational and procedural deficiencies
which hinder rapid response to invasive plant pest detection. Develop and
implement procedural enhancements
to expedite the most efficient and effective emergency response mechanisms. Empower personnel for
immediate response in all program
areas, including procurement of essential resources.
3.1.3 Comprehensive Laws and
Regulations for Invasive Plant Pest
Response Activities
Background
Efficient invasive plant pest response
systems in the United States must be
backed by a system of laws and regulations which are comprehensive,
while providing opportunities for individual states to enact complementary
statutes and regulations. Regulations
need to be reviewed on a regular basis
to ensure relevance and adoption of
the latest technology. The Office of
General Counsel (OGC) must agree to
support, without reservation, the consolidated statute under development
by APHIS. Statutory authority must
be backed by legal counsel that will
enforce the statute without fear of litigation. A tentative agency is an ineffective agency.
REPORT
Findings
(1) Currently APHIS-PPQ enjoys
broad, sound legislative authority for
its programs and agencies. However
legislative authority is fragmented into
various statutes, many of which are
unrelated, and defensible authority to
take swift unequivocal action to halt
the introduction or spread of invasive
plant pests is sorely lacking.
(2) Many regulations are outdated and
in need of review to determine their
relevance. Regulations are inflexible
regarding the application and use of
new technology.
(3) APHIS-PPQ relies heavily on state
authority to conduct basic inspection
programs and implement mitigation
measures when deemed necessary.
Recommendations
■ D-11. Work with Congress and
stakeholders to have the Plant
Protection Act passed during the current Congressional session (AUTHORITY).
■ D-12. Review all regulations pertaining to invasive plant pest response
activities (AUTHORITY) to determine
relevance and ability to adapt to new
technology or management systems.
■ D-13. Meet pest management
needs, in part, through compliance
agreements which provide an opportunity for involvement of growers,
dealers, and other stakeholders. Allow
stakeholders to provide needed services subject to inspection and monitoring for compliance by official
agencies.
Safeguarding American Plant Resources
77
3.2 Funding Mechanisms
for Invasive Plant Pest
Detection and Response
Activities
3.2.1 Funding Mechanisms for
Invasive Plant Pest Detection
Activities
Background
Funding invasive plant pest detection
activities in the United States is accomplished by several mechanisms.
Federal appropriations expended
through cooperative agreements with
States and/or direct expenditure for
Plant Protection and Quarantine (PPQ)
staff time and costs are the primary
sources. The PPQ received $19.5 million as 1999 appropriations to Fruit
Fly Detection, Miscellaneous Plant
Diseases, and Pest Detection. Of this
amount approximately $12 million is
dedicated to invasive plant pest detection activities. Although not clearly
defined at this time, additional responsibilities resulting from the
Invasive Alien Species Executive
Order are expected to augment current funding levels.
The Exotic Pest Detection budget line
item request prepared within PPQ and
International Services (IS) is subject
to approval by the United States
Department of Agriculture (USDA),
Office of Budget and Program
Analysis (OBPA) and United States
Office of Management and Budget
(OMB) prior to Congressional consideration. Directive language from the
House and/or Senate is typically part
of the appropriations process. Fixed
USDA and Animal and Plant Health
Inspection Service (APHIS) overhead
costs of 30% are deducted from the
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REPORT
Exotic Pest Detection appropriation
prior to allocation of the net funds by
APHIS-PPQ and IS. The APHIS-PPQ
management then allocates funds to
locations, projects, agreements, or
purchases based on plant pest or disease priorities. Priority listings are
driven by any of the offices that prepare, approve, consider or enact the
budgetary item. In many cases, objective science-based decision making is
lacking in determining priorities for
funding of invasive plant pest detection activities.
The Pest Detection Line-Item spending
for FY1998 was $6,302,000 and, of
this amount, $939,000 was allocated
to the Cooperative Agricultural Pest
Survey program for survey activities
and data entry into the National
Agricultural Pest Information System
(NAPIS). The Western Region received
$325,000, followed by the
Northeastern with $262,000, the
Southeastern with $224,000, and the
Central Region with $128,000.
Cooperative agreements with the
States supported survey activities for:
noxious weeds, Tropical Soda Apple,
Flag Smut, Stewart Wilt, Golden
Nematode, Soybean Cyst Nematode,
greenhouse pests, Brown Citrus
Aphid, Bark Beetle, Cereal Leaf
Beetle, Japanese Beetle, Khapra
Beetle, Pine-shoot Beetle, Sweet
Potato Weevil, Asiatic Rice Borer,
False Coddling Moth, Gypsy Moth,
Apple Tortrix, Cherry Bark Tortrix,
Cherry Ermine Moth, Hessian Fly,
and other invasive plant pests.
In general, Cooperative Agricultural
Pest Survey funds received by the
States for each target pest were relatively small amounts of less than
$10,000. These funds were typically
used for salary and travel costs associated with specific survey activities.
Funds in the amount of $589,000
were allocated for Karnal bunt national survey activities and program
operations were supported by
Safeguarding American Plant Resources
$1,103,000. The APHIS-PPQ expenses
used to conduct specific and invasive
plant pest surveys as well as to monitor cooperative agreements totaled
$2,165,000. These APHIS-PPQ detection funds were divided between the
regions: Northeastern, $766,000;
Central, $629,000; Southeastern,
$492,000; and Western, $278,000.
authority and expenditure of user
fees, State cost-sharing, and greater
industry involvement.
Exotic pest detection contributions by
State Departments of Agriculture are
variable. Allocation of State funds is
limited by availability, which in turn
determines the commitment level of
individual states to invasive plant pest
detection activities. Similarly, agricultural industry contributions are dependent upon their cost-benefit
perceptions, commitment level, and
the size and complexity of the interest
group.
(4) Improved technology is an essential component of invasive plant pest
detection activities. Effective mechanisms to provide an adequate funding
base for research and development is
critical.
Agricultural Quarantine Inspection
(AQI) user fees currently cannot be
used for invasive plant pest detection
outside of ports of entry environs. In
many cases the threat of invasive
plant pest introductions extends well
beyond the initial entry point. This is
especially true in the case of cargo
containers that are devanned at remote final destinations. There is no
AQI user fee on cargo containers and
no authority to apply such a fee to invasive plant pest detection.
Findings
(1) There is a pressing need to institute an efficient and equitable allocation procedure for invasive plant pest
detection funds within the United
States. The funding mechanism for
the Cooperative Agricultural Pest
Survey (CAPS) program may serve as
a starting point to achieve this goal.
(2) New and innovative funding
mechanisms for invasive plant pest
detection are needed. Possible
mechanisms include expanding
REPORT
(3) Importance of the detection and
mitigation of Invasive Alien Species
has been reinforced by Executive
Order #13112 (AUTHORITY, E-11, E12, E-13).
Recommendations
■ D-14. Appoint and empower the
National Invasive Plant Pest
Coordinator (NIPPC) (D-1) to manage,
with guidance from the three-tiered
committee system (D-2), allocation of
invasive plant pest detection funds.
This is inclusive of funding for research and development needs (I-38).
■ D-15. Establish, through the
National Plant Board, criteria for a
State and Federal cost sharing formula for Exotic Pest Detection activities. Include incentives for State and
industry participation.
■ D-16. Revise and expand the user
fee authority and structure to impose
a fee for imported cargo and containers as these increase the risk of introducing invasive plant pests. Allocate
a portion of cargo user fees for Exotic
Pest Detection activities throughout
the nation, with emphasis on high
risk areas where cargo containers are
devanned (E-10).
■ D-17. Aggressively seek a just, proportional share of the funding made
available by Congress to address the
Invasive Alien Species issue in order
to establish and maintain viable pest
detection and early response activities
(AUTHORITY, E-11, E-12, E-13).
Safeguarding American Plant Resources
79
3.2.2 Funding Mechanisms for
Invasive Plant Pest Response
Activities
Background
Adequate baseline funding is critical
for the implementation of an effective
response to invasive plant pest incursions. It is impossible to predict the
number, location and time of detection events, so that availability of
Federal contingency funds is necessary to ensure an immediate response
to invasive plant pest incursions.
Funding mechanisms for response to
invasive plant pest introductions are
from three primary sources depending
on the size and scope of the emergency. Response to small outbreaks is
funded in amounts of $50,000 or less
from annual Regional allocations. The
APHIS-PPQ miscellaneous plant pest
detection funds, a $10 million appropriation, provide higher level funding
for emergencies and other unforeseen
events. This fund typically supports
several activities throughout APHISPPQ Action Units. Large-scale emergency programs require redirection or
transfer of funds by the U.S.
Department of Agriculture. Authority
for declaration of emergency status
and transfer of funds from other
Department programs is held by the
Secretary of Agriculture. Funding requests to the Commodity Credit
Corporation (CCC) are reviewed and
modified by OMB. Other sources for
emergency funds include redirection
within the unit or Agency and supplemental appropriations by Congress.
There are obstacles to securing emergency funds especially in sentinel
areas with a high risk of invasive
plant pest introductions.
Agricultural Quarantine Inspection
(AQI) user fees cannot be expended
for invasive plant pest response
80
REPORT
activities outside the scope of the port
of entry. In many cases invasive plant
pest introduction at remote locations
result from the movement of cargo or
people from the ports of entry. This is,
therefore, strong justification to
expand the use of AQI user fees to
address emergency invasive plant pest
response activities.
Response activities require collaboration between Federal and State governments. Cooperative documentation
that clearly defines the shared responsibilities in allocation of funds
and resources are of two types,
Memoranda of Understanding (MOU)
and cooperative agreements (USDAAPHIS-PPQ 1996a). Memorandum of
Understanding, as signed by all
states, permit the Agency to initiate
immediate emergency response to
plant pest introductions. Cooperative
agreements and MOUs both define the
duties and responsibilities of the
Federal and State participants, however, only cooperative agreements
allow the transfer of funds. The development of the financial plan for cooperative agreement is not standardized
and cost sharing ratios vary according
to the availability of funds at the
Federal and State level. Cooperative
agreements must be approved before
the project begins if cooperators are to
be fully reimbursed for their expenditures. Preagreement costs can be authorized by the APHIS-PPQ Regional
Director and an Authorized
Departmental Officer.
Findings
(1) Adequate base level funding is not
available to respond to the increasing
number of pest incursions occurring
throughout the United States.
(2) There is presently no standardized
formula in place to identify the
funding responsibilities or
partnerships between the Agency and
Safeguarding American Plant Resources
its cooperators (Federal, State, and
Industry) with respect to pest
response activities and their resulting
financial obligations.
(3) There is no mechanism for transfer
of financial obligation from the
Federal government to States or
stakeholders when emergency status
is no longer in effect. The multi-state
pest insurance fund, Interstate Pest
Control Compact (IPCC), is available
for invasive plant pest response on a
limited scale, but is inadequate to
fund major programs.
(4) Identifying and determining the
role of stakeholders or primary beneficiaries of response activities is difficult.
(5) AQI user fee authority does not
allow utilization of fees for response to
invasive plant pests.
Recommendations
■ D-18. Estimate the baseline funding
level necessary to permit the Agency
to cover start-up costs to eensure a
rapid response to invasive plant pest
incursions.
■ D-19. Amend existing Federal and
State cooperative agreements to include a standardized cost sharing
agreement with State cooperators for
pest response activities.
■ D-20. Identify and justify the role of
stakeholders in invasive plant pest response activities, during both initial
emergency programs and long-term
control strategies, i.e., in-kind contribution of personnel for trapping and
participation on technical advisory
panels.
user fees, to develop a $50 million,
no-year, contingency account for
emergency invasive plant pest response activities. This fund should be
administered in a manner similar to
the Interstate Pest Control Compact.
■ D-22. Expand the scope of
Agricultural Quarantine Inspection
user fees to include cargo containers
and provide a mechanism for use of
these fees for invasive plant pest response activities beyond the ports (E10).
3.2.3 Methods Development for
Detection and Response Activities
Funding for the Methods Development
Unit comes from three primary
sources: the Federal budget line item,
emergency funds, and transfers from
other APHIS line items. The major
funding base, the Federal budget line
item, shows a steady decline in monetary support over the last decade. The
highest net funding from the Plant
Methods line item was $4.212 million
in 1993 and the lowest was $3.789
million in 1999. This funding base
has been further eroded by salaries
and other permanent project costs
that have steadily increased to consume an ever larger percentage of the
budget. The number of programs supported by the Methods Laboratories
has increased at least 2.5 fold during
this same period. The result is that
the Methods Development Unit is expected to do more with fewer resources. Supplemental monies from
emergency funds and transfers from
other line items are made available
specifically for response to crisis situations. However, these funds are regularly used to maintain the laboratory
infrastructure.
■ D-21. Continue to explore appropriate methods, including the use of
Agricultural Quarantine Inspection
REPORT
Safeguarding American Plant Resources
81
3.3 Invasive Plant Pest
Detection and Response
Activities
3.3.1 Invasive Plant Pest Detection
Activities
Background
Myriad international travel and commerce opportunities expose U.S. borders to the world. Invasive species
respect no political boundaries and
would flow into the U.S. over extensive shared borders with Canada and
Mexico if not for regulatory exclusion
barriers. Detection activities pose a
second line of defense in the safeguarding process by identifying any
breach of the exclusion barriers so
that a rapid response can be mounted
to the incursion.
Detection of invasive plant pest
incursions may occur by two
disparate means, passive detection
and active surveillance. Passive
detection of invasive plant pests
occurs during other scientific field
work, such as crop surveys,
population studies, faunal or
biodiversity surveys, endemic species
inventories, incidental reports from
the general public, and other such
activities. Active surveillance
documents the presence or absence of
pest species, generates information
that assists international trade, and
provides input into the risk analysis
process. The Agreement on the
Application of Sanitary and
Phytosanitary Measures (SPS
Agreement) stipulates that scientific
means must be employed to establish
pest-free status. Only active
surveillance using scientifically valid
methods produces results that can be
used to statistically infer the absence
Active surveillance is target-specific and requires basic knowledge of invasive plant pest threats, pathways, and effective detection methodology
82
REPORT
Safeguarding American Plant Resources
of an invasive plant pest, that is, to
document pest-free zones. Passive
surveys establish presence only.
Active surveillance is target-specific
and requires basic knowledge of invasive plant pest threats, pathways, and
effective detection methodology. The
Exotic Pest Detection Manual (USDAAPHIS-PPQ, 1991a) provides detection
survey guidelines for sixteen species
of insects. This includes information
on the basic biology of each pest and
general trapping guidelines. Detection
survey guidelines are also available in
the National Exotic Fruit Fly Trapping
Protocol (USDA-APHIS-PPQ, 1991b)
for several species in the genera
Anastrepha, Bactrocera, Ceratitis,
Dacus, and Rhagoletis. The National
Karnal Bunt Monitoring Program
(USDA-APHIS-PPQ, 1999) and the
Golden Nematode Plan are available
in draft form (USDA-APHIS-PPQ,
1998a) and guidelines for Asian longhorned beetle are under development
(USDA-APHIS-PPQ, 1998b).
Detection methodology is critical to
successful surveillance activities.
Target pests are unique and traps for
one species cannot, with a few exceptions, be used for active surveillance
of other pest species. Biological parameters dictate the species-specific nature of detection methods. This means
that proactive measures must be employed in order to develop and implement appropriate detection strategies.
An invasive plant pest cannot be detected in a timely manner if no one is
looking for it. The first step in a
proactive detection strategy is identification of potential invasive plant pests
associated with high risk pathways
into the United States. Biological data
can be collected and used in the development of the tools, trapping protocols and effective traps and lures,
which are necessary to look for the invasive plant pest. An excellent example of a proactive APHIS-PPQ program
is the Pink Hibiscus Mealybug in the
REPORT
Caribbean (USDA-APHIS-PPQ, 1997b).
Detection methodologies are developed by the APHIS-PPQ Methods
Development Unit. This Unit has sixteen facilities which include ten Plant
Protection Centers (Beltsville,
Bozeman, Hawaii, Mission, Niles, Otis,
Oxford, Gulfport, Phoenix, and
Raleigh), four Methods Stations
(Brawley, Gainesville, Guatemala, and
Starkville), the National Plant
Germplasm Center, and the National
Biological Control Institute. Personnel
in these facilities are responsible for
application of new technology or research results for development of detection and response methodology.
Findings
(1) Invasive plant pests respect no political boundaries. Management of
plant pest and disease incursions is
inherently difficult due to extensive
common international borders and
rapidly expanding international travel
and trade.
(2) Active surveillance is better suited
to regulatory issues than is passive
survey documentation of invasive
plant pests. Active surveys require adequate funding support, a knowledge
base, and appropriate species-specific
detection methods.
(3) The efficiency of active surveillance
is enhanced by targeting high-risk
sentinel areas.
(4) Exotic Pest Detection Survey
Guidelines (USDA-APHIS-PPQ,
1991a,b) are available for only a few
of the hundreds of potential invasive
plant pests which threaten American
plant resources. Detection methodologies are an absolute necessity in order
to conduct effective surveillance activities.
(5) The availability of new or
enhanced detection methods is
severely hampered by inadequate and
declining Federal and state funding.
Safeguarding American Plant Resources
83
Recommendations
■ D-23. Provide a level of funding for
the Methods Development Unit that
allows this unit to provide the best
available detection tools. The Methods
Development Unit must maintain a
staffing structure which not only allows the Unit to respond to the current needs for pest detection, but also
to expand its work to meet demands
for new technology. Unit staff should
be encouraged to consult experts outside APHIS-PPQ when appropriate.
■ D-24. Assign to the Regional
Committees (Section ) the task of
identifying survey needs, coordinating
involvement by states, and allocating
funds subject to approval of the
National Invasive Plant Pest
Coordinator. Regional Committees will
make broad recommendations on survey methods after conferring with the
Methods Development Unit.
■ D-25. Identify potential invasive
plant pests and corresponding sentinel areas at high risk for their entry.
Utilize comprehensive invasive plant
pest lists currently being compiled by
several professional societies (i.e., the
Entomological Society of America and
the American Phytopathological
Society) and international databases
(see International Information
Systems) to facilitate this process.
■ D-26. Establish and periodically revise Exotic Pest Detection Guidelines,
including trapping methodology, for
potential invasive exotic pests.
Detection guidelines are necessary for
all species identified as potential invasive plant pests (see D-25) which pose
an eminent threat of entry into the
United States.
3.3.2 Invasive Plant Pest Response
Activities
Background
Effective control and containment of
invasive plant pests require efficient
application of control technology.
Appropriate technology must be readily available or developed within a
short time period for integration into
pest management strategies. Given
this premise, APHIS-PPQ must provide these methodologies either
through resident expertise or through
collaborative efforts. Development of
pest control tools requires a strong
scientific and technical staff in the
APHIS-PPQ Methods Development
Unit. While it is not the responsibility
of APHIS-PPQ to conduct basic research, the Agency does have the responsibility of recognizing and
applying technological advances. The
Agency has the responsibility to coordinate technological needs and collaborative efforts to provide necessary
pest response methodologies. This is
especially important because it is difficult to predict specific pest response
needs beyond generic terms.
Practicality dictates the need to possess expertise for critical review of scientific literature and application of
technology to solve real problems. The
housing of this expertise within
APHIS-PPQ, perhaps together with an
alliance of Federal, State, and academic technical resources under contract to APHIS-PPQ, would be
beneficial to both the Agency and
State cooperators. The APHIS-PPQ
does have a mandate to safeguard
American agricultural and environmental resources from Invasive plant
pest incursions.
New Pest Response Guidelines (NPRG)
outlined in the APHIS-PPQ Emergency
Programs Manual (USDA-APHIS-PPQ,
1996a) form the foundation for
emergency eradication program
84
REPORT
Safeguarding American Plant Resources
implementation. Of the 23 NPRG
available, specific protocols and plans
for exotic fruit fly incursions are the
most current and complete because
they occur so frequently. Response
guidelines for other pests provide
minimal information and have not
been updated within the past five
years (USDA-APHIS-PPQ, 1998a). The
APHIS-PPQ has prepared a strategy
for responding to the Asian
longhorned beetle which remains
under development pending new
control methodology (USDA-APHISPPQ, 1998b).
Findings
(1) The APHIS-PPQ Methods
Development Unit is highly regarded
by the Federal and State plant protection community. Staffing of the
Methods Development Unit has traditionally had a high level of professionalism which permitted peer exchange
with scientists of academic institutions, private industry and other government agencies. However, staffing
levels have fallen in recent years.
(2) The identification and development
of methods applied in invasive plant
pest response activities has become
seriously jeopardized through reductions in financial support for the
AgencyÕs Methods Development Unit.
For example, in FY1999 the budget
was reduced by $355,000.
(3) Federal and State cooperative programs initiated in response to incursions of invasive plant pests are often
conducted without the benefit, application and use of optimal control
technologies (Appendix E).
(4) Methods development expertise
resident in USDA Agricultural
Research Service (USDA-ARS), and
previously housed at APHIS-PPQ locations, has been withdrawn or reassigned to the detriment of new
REPORT
-technology development and cooperation between APHIS-PPQ and USDAARS.
(5) Federal agencies with parallel interests and responsibilities, i.e.,
USDA-ARS and the Forest Service,
have not modified their research priorities to address the loss of expertise
in APHIS-PPQ Methods Development.
Coordination of methods development
is unlikely to occur without distribution of funds by APHIS-PPQ to encourage other entities to align
themselves with the applied research
initiatives identified by APHIS-PPQ.
Recommendations
D-27. Increase funding to the APHISPPQ Methods Development Unit and
its collaborating technical researchers
for development of novel methods for
invasive plant pest response activities.
A 40-50% increase over the FY1999
allocation is necessary for Methods to
maintain a minimal level of activity for
development of detection and response methodologies. Further funding increases are necessary to expand
Methods activities to adequately meet
the technical needs of APHIS-PPQ and
the States.
■ D-28. Prioritize invasive plant pest
response methods needs under direction of the Methods Development
Director and the National Coordinator.
■ D-29. Fill key managerial and research positions in the Methods
Development Unit with highly trained,
well-qualified scientists, i.e., insect
pathologists and plant pathologists.
■ D-30. Form stronger partnerships
with external research agencies such
as USDA-ARS and other Federal,
State, and research institutions for
methods development.
Safeguarding American Plant Resources
85
■ D-30a. Encourage USDA-ARS,
through administrative channels, to
conduct research that meets the practical needs of APHIS-PPQ.
■ D-30b. Combine relevant response
activity research expertise in USDAARS or the Forest Service with APHISPPQ through relocation of work
stations or inter-agency transfers.
■ D-30c. Award contracts to outside
entities, when appropriate, to secure
needed expertise.
■ D-31. Establish a liaison position
within APHIS-PPQ to facilitate communication between APHIS-PPQ and
USDA-ARS.
■ D-31a. Reassign an existing employee with research experience and
an understanding of regulatory needs
to provide required expertise.
■ D-31b. Provide funds to establish
cooperative arrangements with USDAARS staff to conduct the required research.
3.3.3 Effectiveness and Relevance
of Control Technology
Findings
(1) APHIS-PPQ reviews control program effectiveness on an informal
basis. This review is provided by staff
reaction and cooperator input.
(2) The existence and quality of pest
management programs is often determined by the budget process.
Recommendations
■ D-32. Institute a formal peer review
process for evaluation of invasive
plant pest management programs. A
scientific review panel composed of
relevant experts from academia, industry and regulatory agencies, would
provide a systematic and critical evaluation of pest management programs.
For long term programs, this scientific
review should be conducted at least
every three years.
■ D-33. Provide adequate funding (see
D-27) for the Methods Development
Unit to enhance the UnitÕs ability to
conduct thorough quality control and
assurance evaluation of mitigation
methodologies.
3.3.4 Loss of Pesticides as Pest
Response Tools
Background
Selection and application of effective
pest control technology is essential to
the success of pest management programs. Once selected, mitigation measures must be subjected to quality
control and assurance. These
processes are integral components of
all control programs as ineffective
control technology or misapplication
of effective methods can result in program failure. In some instances, quality control parameters do not exist or
require re-evaluation, i.e., quality control parameters of mass-reared
Mediterranean fruit flies.
86
REPORT
Background
Residue tolerance review by the
Environmental Protection Agency
(EPA) as mandated by the Food
Quality Protection Act of 1996, is anticipated to result in the loss of most
organophosphate, carbamate, and B-2
pesticides between August 1999 and
August 2000. These categories of pesticides represent approximately 90%
of the chemicals currently used to
meet regulatory and interstate shipping requirements, including such important pesticides as malathion,
Safeguarding American Plant Resources
azinphos methyl, and chlorpyriphos.
In addition, methyl bromide, the
major fumigant option for food and
fiber quarantine pest treatments, is
scheduled to be phased out by the
year 2005. Reassessment of tolerance
levels of important pesticides such as
malathion, guthion, and chlorpyrophos may signal future loss of these
pest management tools as well. Many
other pesticides may be lost as manufacturers voluntarily withdraw labels
to meet the Òrisk cupÓ requirements of
EPA. Some pesticides may be available through the Section 18 registration process on an emergency basis
only. Research and development for
registration of new pesticides continues to decline because of the high
costs, including those associated with
meeting EPA standards prior to registration. This is especially evident for
compounds with minor uses including
fruits, vegetables, nursery and floral
crops.
Findings
(1) Pesticide recommendations for
quarantine purposes often do not recognize current label requirements or
product availability.
(2) The need to manage potential impacts of FQPA will require APHIS-PPQ
staff with expertise in pesticide issues.
(3) EPA is not fully responsive to the
needs of USDA or agriculture in general, i.e., the continued availability of
critical pesticides for use in eradication and management programs, such
as exotic fruit fly control in Florida.
Recommendations
■ D-34. Dedicate a position to coordinate pesticide needs with EPA, particularly as it relates to pesticide
registration and the impact of Food
REPORT
Quality Protection Act of 1996 (FQPA).
This should be facilitated through
USDA Office of Pesticide Management.
■ D-35. Institute an Assistant
Director level employee exchange program between the APHIS-PPQ and
EPA to facilitate communication between these agencies relative to the
use of pesticides in plant pest and
noxious weed quarantine, eradication
and management. Through this exchange, EPA would gain knowledge of
the pest management challenges
faced by APHIS-PPQ and APHIS-PPQ
would benefit from knowledge of the
pesticide registration process, labeling
requirements and tolerance reviews.
The agencies should work closely in
the registration of ÒsofterÓ pesticides
and biological control organisms.
3.4 Information Systems:
National Invasive Plant Pest
Information Center, including the
National Invasive Plant Pest
Laboratory and National Invasive
Plant Pest Database
Background
APHIS-PPQ currently has a system to
find and identify invasive plant pests
detected at the ports of entry into the
United States. The system employs
1500 APHIS-PPQ officers as trained
identifiers at the ports who screen for
commonly encountered species which
include spiders, scales, and aphids
among others. There are 50 local
identification specialists who are
trained to identify commonly
encountered organisms. The extant
system exists to support the
regulatory efforts at the ports. It is
not designed, and never was intended
Safeguarding American Plant Resources
87
to, support detection programs other
than border activities. All
identification activities reflect the
regulatory mandate. Thus
identifications are taken to the level
necessary to make a regulatory
decision.
Local identifiers send unusual or unknown species to designated specialists. Some ports are equipped with
video capacity that allows immediate
identification without physical transfer of the specimen. The APHIS-PPQ
maintains a small staff of specialists
in a number of fields including entomology, botany, and plant pathology.
Upon receipt, specimens are either
identified by APHIS-PPQ personnel or
sent to an appropriate specialist.
Organisms found by the states, by
USDA outside the ports of entry, by
university scientists, or other agencies
can be submitted to APHIS-PPQ or
the Systematic Entomology
Laboratory for identification or sent
directly to an appropriate specialist.
The APHIS-PPQ maintains a computerized system for reporting of specimens identified at ports of entry.
However, the format of the database
does not allow for ready analysis.
Identifications done by individual specialists are computerized at the discretion of that individual.
Findings
(1) Pest identification functions are
necessary to facilitate rapid response
to introduction of invasive plant pests
into the United States.
(2) APHIS-PPQ does not have a system
for collection of data on all invasive
plant pests discovered in the United
States.
(3) APHIS-PPQ does not have a database covering all invasive plant pests
discovered in the United States.
88
REPORT
(4) The development and use of the
video identification system at the
ports is an excellent example of
APHIS-PPQ finding and employing
new technology to improve its effectiveness.
Recommendations
■ D-36. Establish a National Invasive
Plant Pest Information Center (NIPP
CEN) with two functional entities, the
National Invasive Plant Pest
Laboratory (NIPP LAB) and the
National Invasive Plant Pest Database
(NIPP BASE).
■ D-37. Establish the National
Invasive Plant Pest Laboratory (NIPP
LAB) as a ÒvirtualÓ clearinghouse for
specimens to be identified. Assign
NIPP LAB staff primary responsibility
in obtaining confirmatory identification of invasive plant pests submitted
by port personnel or other agencies.
Perform identifications at APHIS-PPQ
or send them to external cooperators
when necessary (e.g., the Systematic
Entomology Laboratory, the
Smithsonian Institution, university
personnel). By acting as a national
clearinghouse, the NIPP LAB will
maintain control of, and have access
to, information on all invasive plant
pests incursions through its final
identifications role (see International
Information Issue 1.).
■ D-38. Staff the National Invasive
Plant Pest Laboratory with a relatively
small group of professionals with expertise in entomology, botany, plant
pathology, mycology, and molecular
biology. Include molecular diagnostics
capabilities for insects, weeds and
pathogens.
■ D-39. Expand the video identification of invasive plant pests to cover all
ports. It is imperative that this be instituted as soon as possible to improve the efficiency of APHIS-PPQ in
meeting its regulatory role.
Safeguarding American Plant Resources
■ D-40. Contract with external specialists through cooperative agreements to provide their services in
confirming identification of species
which are not readily categorized by
National Invasive Plant Pest
Laboratory staff (see International
Information report).
■ D-41. Deposit all intercepted specimens in a permanent collection within
the National Invasive Plant Pest
Laboratory. Preserve specimens in a
manner that facilitates DNA analyses
of strain differences and identification
of sibling species.
■ D-42. Develop molecular diagnostic
tools for frequently introduced or difficult to identify species groups via
partnerships with USDA-ARS or external researchers.
■ D-43. Establish the National
Invasive Plant Pest Database (NIPP
BASE) as an integral function of the
National Invasive Plant Pest
Information Center. The NIPP BASE
will function as an information hub.
The NIPP BASE will coordinate data
on all invasive plant pests identified
by the National Invasive Plant Pest
Laboratory, port of entry staff, cooperators on retainer, and external experts. The NIPP BASE will include
links to databases of the National
Agricultural Pest Information System
(NAPIS) (1999), USDA Systematic
Entomology Laboratory (1999), the
Smithsonian Institution, U.S. Forest
Service (1999), Federal Noxious Weeds
Database, among others. The goal of
the NIPP BASE is to provide a comprehensive and timely reporting
mechanism for invasive plant pests in
the United States.
graphics, point of interception and related pathway information, reproductive status, global distribution
including distribution within the
United States, point of origin, pest
status, biology, and known detection
and control methodology.
■ D-45. Provide access to the National
Invasive Plant Pest Database via the
Internet. Include in this database a
secured input function that will allow
specialists to enter identifications.
Screen submitted information prior to
final database entry to ensure compliance with database guidelines.
Guidelines will ensure that only validated information is entered into the
database. Provide public access to the
database as a read only Web site.
■ D-46. Institute a computerized system, perhaps in the form of a simple
e-mail group list, to notify regulatory
officials and stakeholders of new invasive plant pest introductions in their
regions.
■ D-44. List all pertinent information
on the invasive plant pests in the
National Invasive Plant Pest Database.
This includes, but is not limited to:
scientific and common names, identifying characteristics with supporting
REPORT
Safeguarding American Plant Resources
89
90
REPORT
Safeguarding American Plant Resources
C h a p t e r
F o u r
International Pest Information
Committee Report
broad range of highly reliable information on international pests
is needed to enable APHIS-PPQ
to effectively safeguard AmericaÕs
plant resources. The critical information includes, but is not limited to,
identification of pest threats; analysis
of pest risks; development of pest risk
management strategies; promulgation
of quarantine and other regulations;
development of pest detection and
eradication strategies; allocation of resources; provision of staff, stakeholder, and public training; and trade
facilitation.
A
Specific information needs include
pest biology, spread potential, distribution; host and environmental requirements; damage and economic
importance; control, suppression and
eradication methodology; pathways;
diagnostics including identification;
etc. The determination and development of vital business information
sources; efficient and effective capture, storage, access and transfer;
and sharing of information are essential functions. Information technology
hardware and software can be combined to create powerful and valuable
tools for the performance of all of the
Agency Õs essential business functions.
4.1 Current PPQ
Information Management
System
Information Technology
Coordination
There are 202 information technology
(IT) personnel in APHIS, nine of whom
are in the Information Technology
Coordination Unit. Seven are on a
Project Leadership Team, 95 in
Customer Services, 35 in Technology
Resources Management, 44 in
Applications and Information
Management and 12 in Forecasting
and Planning.
A small Information Technology
Coordination Unit comprised of a
chief information officer (CIO), four
functional area coaches, a ÒTrail
BossÓ, a Y2K program manager, and
two administrative staff members. The
CIO reports to the APHIS
Administrator. The IT Coordinating
Unit works towards accomplishment
of the Agency Õs mission and vision
with two advisory groups: the APHIS
Integrated Planning Team (AIP) and
the Customer Council.
The AIP has identified 14 IT projects.
IT managers, sponsors, AIP members,
and planning liaison persons are
assigned to each project. In addition,
there are three mandated projects,
making a total of 17 IT projects. These
projects can be characterized as
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Safeguarding American Plant Resources
91
access, compliance, financial/
management, networking, system
conversion or upgrade, technical
infrastructure, and tracking. The
most urgent project at the time of the
NPB Review was Y2K compliance.
Thus, there is a considerable infrastructure and resources within APHIS
that can be used to meet the business
needs of the PPQÕs safeguarding system.
Web Site
The United States Department of
Agriculture maintains a home page
with links to the Animal and Plant
Health Inspection Services (USDAAPHIS), Plant Protection and
Quarantine (USDA-APHIS-PPQ),
International Services (USDA-APHISIS), Forest Service (USDA-FS),.and
Agricultural Research Service (USDAARS). The PPQ home page presents
information relevant to ÒScientific
ServicesÓ. The USDA-APHIS-PPQ web
site serves public and education and
regulated community functions. The
Committee found the Biotechnology
Permits link to be well developed and
useful.
Diagnostics
The PPQÕs diagnostics needs are satisfied variously by identifiers at air,
land and sea foreign ports of arrival,
the various ARS systematic laboratories, and other specialists. Port
Identifiers are granted identification
authority or Òdiscard authorityÓ for
particular identifications when their
competence has been demonstrated to
the satisfaction of the Agency . The
Miami port is equipped with an electronic system which enables identifiers to place specimens under a
microscope and digital camera for
electronic image transfer and identification by specialists at the ARS laboratories and elsewhere. This system
allows quick identification of certain
specimens for which Port Identifiers
92
REPORT
do not have identification authority. It
appears to work well and serves as a
good example of the Agency Õs efforts
to employ new technology to meet its
business needs.
Databases
The PPQ has developed and maintained several databases for specific
business functions and purposes.
At ports there is Port Information
Network (PIN - 309) which is a database for insect and plant pathogen interceptions. The information in this
database is potentially quite useful for
analysis of pest risk, including that
associated with various pest pathways, origins where there is high pest
risk, etc. However, interviews with
port personnel suggest that it is not
extensively used by inspectors and
identifiers, apparently due to a combination of time available, slow connections, a difficult query interface, and a
lack of built-in analytical tools (such
as alerts for unusual occurrences).
PIN-309 is also useful for evaluating
program and employee performance.
In fact, the Work Accomplishment
Data System (WADS) database has
been developed for those same purposes.
The APHIS Library subscribes to and
frequently uses the DIALOG (over 500
databases) and Lexis/Nexis databases. They also have the AGRICOLA
and CAB international CD-ROM products available on the APHIS network
for desktop access. These are the
most frequently used bibliographic
databases. Supplemental information
not desktop available is derived from
BIOSIS Previews, Biological and
Agricultural Index, Life Sciences
Collection, AGRIS International,
Zoological Record, Pesticide Fact File,
CRIS (Current Research Information
System)-USDA-ARS. Accordingly, PPQ
has access to a wealth of published
information.
Safeguarding American Plant Resources
A list of other databases currently
used by PPQ staff housed in the
Riverdale, Maryland, headquarters appears as an Appendix F.
Automated Information
Systems
In addition to the PIN - 309 and
WADS systems already mentioned in
connection with foreign ports of arrival, PPQ employs a number of automated information systems including
the Port Information NetworkOperations (PIN-OPS), Automated
Broker Interface (a module of U.S.
CustomsÕ Automated Commercial
System in which brokers and filers
submit import entries and entry summaries to Customs), Automated
Commercial Environment (A Customs
upgrade of its ACS system which includes the CustomsÕ Automated
Targeting SystemÑalso used by PPQ),
Automated Manifest System, Advance
Passenger Information System,
Agricultural Quarantine Inspection
Monitoring, Vessel Garbage Violation
Database, Interagency Border
Inspection System, Harmonized Tariff
Schedule, International Trade Data
System, Plant Quarantine 280
Tracking System for imports,
Selectivity (A U.S. Customs system for
targeting inspections), Violations databases to track predeparture and other
violations, and Treasury Enforcement
Communication System.
The use of these systems further
demonstrates PPQÕs responsiveness to
new technology and its collaboration
with sister Federal agencies to meet
its safeguarding needs.
Pest Surveillance and
Survey
The PPQ administers the Cooperative
Agricultural Pest Survey (CAPS). This
is a cooperative effort with the state
departments of agriculture whereby
special surveys are conducted as
REPORT
needed and general pest detection,
field survey and laboratory diagnostics data is fed into the Agency routinely. The data is entered into the
National Agricultural Pest Information
System (NAPIS). The CAPS program
provides for electronic information exchange and strong interagency and
interpersonal networks.
United States Commodity
Export Support
The PPQ plays a key role in facilitating global trade in agricultural products. The PPQ officers participate in
bilateral trade negotiations and issue
phytosanitary certificates affirming
compliance with the quarantine requirements of trading partners. The
validity and reliability of the phytosanitary certification system is
highly dependent on EXCERPT, a
database containing the phytosanitary
requirements for most countries to
which the United States exports agricultural products. State collaborators,
who issue the vast majority of the
Federal phytosanitary certificates, can
access this database and determine
what requirements must be met,
make the appropriate inspections or
tests or apply specified treatments,
and issue certificates containing
agreed upon declarations of compliance.
This system is maintained by Purdue
University. It illustrates the AgencyÕs
collaboration with the states and universities and serves as an example of
appropriate outsourcing of an IT function.
Some major deficiencies of
the current APHIS information structure in meeting
PPQÕs needs
The issues of accountability and
transparency have become critical
concerns in the development,
Safeguarding American Plant Resources
93
94
maintenance and use of data
management systems. In government,
as in industry, the amount and type
of ad hoc information flow is a
measure of the organizationÕs lack of
process transparency and of its
inefficiency. This is particularly true
for agencies with regulatory
responsibilities, given the inherent
desirability of protocols, standards
and consistency. While APHIS-PPQ
holds a wide variety of useful
information, as described above,
much appears to have been developed
ad hoc in response to particular
analysis or reporting mandates,
rather than as a result of a
comprehensive review of overall
information needs and priorities. It is
not clear that the existing database
content reflects the range of priority
issues faced by APHIS-PPQ, or that
they may be used interoperatively to
address cross-reaching issues not
contemplated by their designers.
tools, Òfront endsÓ and secondary applications for internal data. There is a
fundamental need to capture electronically and share widely data from the
core competencies of programs - detection, risk assessment, off-shore
surveillance, pathway analysis, control and eradication strategies, measures of effectiveness and efficiency,
etc. These core program activities
must be directed by programmatic experts but strongly supported and facilitated by information technologists.
Further essential legacy data (lists of
pests intercepted, pathway analyses,
outcomes of off-shore surveillance
and domestic detection, analyses of
eradication campaigns, pest risk assessments, etc.) should be digitized (to
at least an image file) and catalogued,
and standards for standardized electronic submission of new data should
be developed. These capabilities will
not arise as add-ons to existing workloads.
The Review recognizes that much of
the ad hoc flavor of APHIS information management arises out of a history of an overburdened programming
staff. As a result, current data products represent an accumulation of incremental tactical decisions made
under conditions of crisis management rather than a program, which is
consistent and integrated. The
International Pest Information
Committee believes that development
of consistent and integrated and datastandard-compliant registries, vocabularies, and reusable data structures
will in the long run save resources as
well as increase effectiveness.
Optimally, PPQÕs data management
system should be designed by a cooperative partnership of the non-information technology PPQ personnel
whose work both requires and produces information, private stakeholders impacted by the Agency Õs
regulations, other agencies with overlapping or complementary mandates,
and university cooperators with the
biological and computer/telecommunications expertise required to actually develop the system economically.
Cost-effective applications throughout
the organization certainly will require
USDA-APHIS to make full use of
Internet technology.
However, a substantial up-front investment in user needs assessment,
standardized protocols, and interoperable designs is needed. Data managers need the time to evaluate
business process throughout the organization, participate in interagency
standards and data interoperability
groups, and to develop data access
A comprehensive information strategy
involves at least six components: (1)
cataloguing, assessing, and documenting current data holdings; (2) adequate access, (3) protocols for
appropriate information flow, (4) databases to house and archive the information, (5) tools for data discovery
and visualization, pattern analysis
REPORT
Safeguarding American Plant Resources
and invasiveness prediction, and (6)
interactive database searching and
linking for both in-house and external
information.
Cataloguing, assessing, and
documenting current data
holdings
It appears that relatively few people
within APHIS-PPQ have a comprehensive overview of the data holding
and relations among data sets on
plant diseases, invasive species, and
safeguarding protocols within the
Agency , much less among cooperating organizations. In particular, many
field officersÕ knowledge and use of
shared data seem quite limited.
Consequently, a critical first step is to
systematically inventory and classify
useful data products, develop a comprehensive on-line catalog of data
holdings, and to develop systematic
metadata useful for locating and assessing the usefulness of data sets.
Without a synoptic overview of data
holdings, it is difficult to assess gaps
in data coverage and priorities for new
initiatives.
At the most basic level, the PPQ needs
an on-line data registry giving content, contact, and access information
for all major data resources developed
and used by PPQ analysts and field
personnel. The Government (or
Global) Information Locator (GILS)
protocol (http://www.gils.org) provides the most basic elements, has
become fairly standard within the
Federal government (see, for example,
http://www.whitehouse.gov) and a
number of states (for example,
California, http://ceres.ca.gov), and is
covered by executive orders in the
U.S. and agreements among the G7
states. GILS is also a profile of
Z39.50, a specification for data description that encompasses the
Library of CongressÕs USMARC bibliographic database and the Federal
Geographic Data Committee (FGDC)
REPORT
metadata standard (discussion follows). As a result, server software exists to permit straightforward
distributed access to GILS and other
Z39.50 data, maintained on multiple
servers; and therefore simplifies data
discovery in a spatially fragmented organization. It seems appropriate that
PPQ institute a data holdings registry
modeled on GILS (or one of several
closely related approaches, such as
the ÒDublin CoreÓ).
Implementation of more detailed
metadata within APHIS/PPQ also
needs attention. Among the mainframe Oracle databases held centrally,
traditional internal documentation
(data dictionaries, commented code,
etc.) appears good. User level descriptions of methods, suitability for various uses, QA/QC measures, etc. (the
electronic equivalent of a ÒMaterials
and MethodsÓ section in a technical
publication) is much weaker, and
does not, as a whole, correspond to
the approaches to biological metadata
pioneered by the Federal Geographic
Data Committee and used by most
other Federal agencies for biological
data. (See the National Biological
Information Infrastructure,
http://www.nbii.gov, and the Global
Change Master Directory,
http://gcmd.gsfc.nasa.gov/). The
FGDC specification is currently mandated by Executive Order for geospatial (mapped) information held by
Federal agencies. The PPQ should certainly develop FGDC-compliant metadata for all of its GIS coverages. As a
consistent format for electronically
documenting other biological data, it
would be worth examining the USGS
proposal for a Biological Metadata
Profile (a variant of FGDC) and the recent AIBS review of that proposal.
Other documentation
strategies
Other documentation strategies such
as those advocated by the Ecological
Safeguarding American Plant Resources
95
Society of AmericaÕs FLED (long term
ecological data) initiative
(http://esa.sdsc.edu/FLED/FLED.html
) may also be fruitful, and the choice
of detailed formulations should be
delegated to program experts and
stakeholders. However, the current
lack of even a data catalog, much less
consistent electronic documentation,
appears to have confused both APHIS
personnel and outside users as to the
nature, availability, and usefulness of
APHIS data holdings.
Adequate access
With available technology, all PPQ
personnel should have high-speed access to the Internet (TCP/IP specifically), with dial-up access available
for telecommuting where necessary.
Every PPQ station should have at
least the equivalent of a 56K line per
individual and computers capable of
connecting at those speeds and operating the latest generation of access
software (e.g., Netscape). Less than
this level of access is simply inadequate for PPQ personnel to do their
jobs. For most locations, 56K per person currently requires either a Frame
Relay or fractional T1 line, but other
high-bandwidth technologies, including Digital Subscriber Lines, cable
modems, and wireless or satellite
links should become widely available
(at much lower costs) over the next
several years. The fact that different
high-bandwidth technologies are
being rolled out in different regions is
in itself an argument for decentralized
control of Internet access strategies
(discussed later). The dynamic nature
of communications technology implies
that minimums must be periodically
upgraded to industry standards.
Protocols
Although some protocols exist, they
do not deal with information flow and
storage. There must be clearly defined
protocols for all statutory decision
processes and other information
flows. These protocols should be in
96
REPORT
the public domain and should include
the types of information to be used,
the decision process itself, and the
methods of information transmittal
and storage. These protocols should
make full use of Internet and secure
Intranet technologies for information
creation, sharing and archiving. This
includes not only PPQ directly, but
also interactions with other units
within APHIS (e.g., reporting of new
pests by International Services) and
external to APHIS (e.g., bills of lading
from Customs, aquatic nuisance
species from USGS, detection activities by states). These protocols must
assure the availability of information
and its appropriate use.
Databases
Databases are the key to information
storage and efficient retrieval of information. Internet technologies have
changed our concepts and definitions
of databases. In addition to traditional
databases (e.g., Oracle and other SQL
servers, Access or FoxPro PC database
software), ÒindexesÓ of large numbers
of documents can now be created,
making them fully searchable online.
In particular, extensible markup language (XML) is beginning to be supported by most major database and
Internet software vendors as a solution to indexing and cross-referencing
documents (and other non-tabular
Òdata objectsÓ such as images and
audio-visual data) in searchable data
warehouses. XML ÒparsersÓ (viewers)
are expected to be integrated into the
next major releases of Netscape and
Microsoft Web browsers, making XMLbased data repositories accessible to
field personnel with minimum equipment and computer training, or lowlevel Internet access. The APHIS
should explore XML and related Òdocument-centricÓ Internet technologies
for such data types as risk assessment reports, images and instructions
for pest identification, and educational materials.
Safeguarding American Plant Resources
In addition to the present in-house
databases (e.g., PIN-309, NAPIS,
Regulated Plant Pests, Permits,
WADS, etc.), there are key databases
not yet developed. Foremost among
these are:
(a) ÒInternational Services WarningÓ
database consisting of Òpest alertsÓ
from outside the U.S. The APHIS-IS
should have direct web access to securely enter information into this
database via a web browser and the
database should be available internally to all PPQ;
(b) ÒRisk AnalysesÓ database consisting of all risk analyses made by PPQ.
This database may have to have a
start date, as entering all previous
Risk Analyses may not be feasible.
The database should include key assessment criteria, authors, references,
and basic biological and taxonomic
information (see the Exotic Forest
Pest database as an example http://www.ExoticForestPests.org);
(c) ÒInvasive SpeciesÓ databases which
provide information on the most ÒdangerousÓ exotic pests with potential to
invade the U.S. This effort is already
underway, but there is no clear-cut
design. Databases of this kind are
being explored by other organizations,
such as the National Biological
Information Infrastructure (see
http://www.nbii.gov/iabin/), and it is
likely that this capability is best developed as a cooperative effort with
organizations monitoring a wider
range of non-indigenous species;
(d) ÒTrainingÓ database(s) designed to
help educate new PPQ employees and
to keep current employees up-to-date
on current issues including new regulations, threats or pest pathways;
(e) A field projects database, documenting participating organizations,
locations, contacts, pests treated,
REPORT
methods, and outcomes. A useful prototype is underway for noxious weeds
in California (http://endeavor.des.ucdavis.edu/weeds/); and
(f) ÒPublic AwarenessÓ databases of
key and potential invaders detailing
both the importance of, and instructions for identifying, Òleast wantedÓ
species. This database must have a
highly attractive Òfront endÓ to capture public attention and provide a
high profile to these pests. The latter
databases could be a portion of other
databases (see Database Access and
Interaction below).
Analysis and modeling tools
In addition to data archiving, there
needs to be much more consistent
use of information collected by PPQ
and others in understanding and predicting threats to American agriculture. Decision support tools, which
analyze patterns in the PIN-309 database and the ÒInternational Services
WarningÓ database previously suggested, need to be developed and
used. Are there bioterrorism efforts
presently underway? Do spatial
analyses of known data indicate useful patterns? This could involve not
only human and animal diseases, but
noxious weeds, severe plant diseases
or explosive insect pests. The interception records and foreign warnings
could be analyzed to target origins
and/or organizations for investigation.
As PPQ moves away from interdiction
(as it must), the role of predictive
models becomes increasingly important. Such modeling requires information from PPQ and external
databases. Results of these predictive
efforts need to be available to PPQ in
the same form as the ÒInternational
Services WarningsÓ and the ÒInvasive
SpeciesÓ databases described earlier.
An example of an effort to combine
range and population records, out-
Safeguarding American Plant Resources
97
break data, and modeling of potential
future spread is the INVADERS database for invasive plants in the
Northwest
(http://invader.dbs.umt.edu). The
USGS (http://nas.er.usgs.gov) performs comparable analyses for nonindigenous aquatic plants, fish, and
molluscs. Predictive models, combined
with observational information, are
the keys to regulatory decisions and
defense actions by PPQ.
Database access and interaction
terminology (vocabulary). For
concurrent access to diverse
databases, the development of
dictionaries (or more formally
ÒthesauriÓ or Òcontrolled
vocabulariesÓ), which define allowable
usages and cross-reference terms, is
an absolute requirement. With the
inclusion of external databases, the
need to cooperate with national and
international efforts to develop
taxonomically based dictionaries and
ÒmetadataÓ is a primary consideration
for any information management
system that PPQ may develop.
As database development and maintenance costs can exceed the benefits if
user needs are not considered upfront, a careful analysis of information needs and report content must
be made for each major user group.
One major advance provided by the
Internet is that databases originally
developed for narrow purposes can
now be shared. Not only can databases be shared, but different parts of
the same database can be provided to
different groups. For example, the
PIN-309 database could be analyzed
for the most frequent interceptions
during the past month. This Òhit listÓ
could be linked to the ÒInvasive
SpeciesÓ database and/or the ÒRisk
AssessmentÓ database to provide detailed warnings to port officers daily,
using a secure connection.
4.2 INFORMATION
SYSTEM VISION FOR
PPQ/IS SAFEGUARDING
PROGRAMS
Likewise, using only non-sensitive information in the databases, ÒTrainingÓ
databases could be linked to ÒInvasive
SpeciesÓ, ÒRisk AssessmentÓ and external databases to produce a constantly changing and updated
ÒAmericaÕs Most Unwanted Hit ListÓ
home page for public consumption.
Public school classes could link in
order to find out about PPQ and invasive species, with full color pictures
and details of biology and transport.
Bruce Rosenstein, in the March 8,
1999 issue of USA TODAY newspaper,
quotes Charles Wang, CEO of
Computer Associates, on the role of
information technology in business:
National Plant BoardÕs vision of the
information system for the safeguarding programs of the Plant Protection
and Quarantine and International
Services Units is:
ÒOptimal use of current information technology in the performance
of all of the AgencyÕs business functions.Ó
Efficient and effective capture, storage, access and search, transfer, and
sharing of information must be a core
competency.
ÒI cannot be clearer than this: Give up
any idea you may have about how information technology can support
your business. Your business is information, and information is your business.Ó
All linked databases, internal and
external, must share the same
98
REPORT
Safeguarding American Plant Resources
General Strategy and
Strategic Thrusts
The general PPQ/IS strategy must
be collaboration and cooperation with
internal and external clients/stakeholders to design an information system that:
(1) efficiently, effectively and economically employs current technologies to
meet the Agency Õs current business
needs, and (2) is flexible and responsive enough to adopt new technologies
as appropriate to meet future changes
and challenges.
Internal and external clients/stakeholders at least will include PPQ personnel whose work both requires and
produces information, private stakeholders affected by the AgencyÕs actions, other agencies with overlapping
or complementary mandates, and collaborating university personnel who
possess biological and
computer/telecommunications expertise.
¥ Business process evaluation
¥ Organization of IT responsibilities
and personnel by programmatic area
with management by end-users
¥ Collaboration with data managers in
the development of interagency standards and inter-operability groups,
data access tools, Òfront endsÓ, and
secondary applications for internal
data
¥ Priority setting for stepwise resolution of key protocol, database, and
database connectivity projects
¥ Development of consistent and integrated and data-standard-compliant
registries, vocabularies, and reusable
data structures
¥ Facilitating use of Internet technologies for office and employee access
and connectivity
¥ Determining which legacy data (pest
risk assessments as an example)
should be digitized, catalogued, and
stored
The primary strategic thrust of the
general strategy must be:
¥ Standardization of electronic submissions of new data
Leadership via an ÒInformation
Management TeamÓ headed by a nonIT person (1) highly knowledgeable
about the mission, vision and core
values relevant business needs of PPQ
and its collaborators, and (2) possessing excellent analytical, integrative,
leadership (including direction, listening and communications, support,
feedback, etc.), organization, partnering, strategic thinking, and other administrative and managerial skills.
The members of this team should be
composed of PPQ and IS programmatic personnel.
¥ Cost-effectiveness analyses to determine which purely technological functions/services could be met best by
outsourcing
This team should concentrate efforts
on core competencies of content
rather than technology. Among others
to be determined, responsibilities in
no particular order would include:
4.3.1 Information Technology in
APHIS
¥ Collaborative and cooperative strategic thinking and planning
REPORT
¥ Encouraging external client/stakeholder participation in IT processes
and making effective use of external
expertise
4.3 PPQ Information
System Issues, Findings
and Recommendations
A fundamental and overriding
consideration for the PPQ is
determining whether IT is better
treated as a stand-alone department
Safeguarding American Plant Resources
99
or incorporated within programmatic
divisions. Similarly, it is becoming
increasingly efficient and cost-effective
to outsource information services,
particularly in areas of rapidly
changing technology (such as the
Internet) and to concentrate efforts on
core competencies of content rather
than technology.
Local support is essential to productivity, although cost effectiveness is a
consideration for offices with a very
small staff. There are companies that
provide tech support for a reasonable
fee, and PPQ should at least consider
outsourcing technical services outside
of its core competencies in information content and analysis.
Findings
In this time of powerful yet inexpensive servers, distributed computing,
and an increasingly sophisticated
user base, there is little justification,
at the expense of local infrastructure
and control for the maintenance of a
national or regional IT structure, as is
now the situation within APHIS. The
establishment of local office IT staff,
working with and for the local/regional PPQ staff and local ISPs could
easily establish a network of secure
servers maintaining and linking the
diverse databases and information
flow critical to PPQÕs missions. This
might be accomplished for less than
PPQÕs present contribution to the IT
budget.
The PPQ needs to re-evaluate whether
a freestanding IT program meets it
current needs. There appears to be
little evidence that the APHIS-IT group
is meeting its responsibilities to PPQ
or is capable of doing so within the
current organizational and funding
structure. The need for access and
good connectivity using Internet technologies is the single greatest information need for PPQ today. This need
cannot be met with the present IT
structure and personnel. From computer repair, to providing access for
networking, there appears to be a
consensus that APHIS-IT is not responding to the needs of PPQ. Users
report significant delays in repairing
hardware, with long downtimes for
both PCs and servers, causing major
losses in PPQ employee efficiency and
productivity.
A major component of the problem is
that the IT group is responsible to
APHIS in general and not to PPQ. The
belief is common within PPQ (and
documented by numerous complaints
and specific examples from PPQ staff),
that APHIS-IT, in fact, is not meeting
PPQ needs and cannot do so as long
as there is no IT command structure
within PPQ (and from outside the IT
group itself).
More generally, there is little evidence
of the existence of cooperative planning and mutual respect that is necessary within any information
management effort. There appears to
be almost independent efforts by IT
and non-IT staff to provide solutions.
100
REPORT
Recommendation
■ I-1 APHIS should decentralize the IT
organizational responsibilities and
personnel to programmatic areas,
with management by the end-user
groups.
4.3.2 Leadership/Management
Continuity
Consistent leadership/management is
necessary to provide a vision and the
planning necessary to bring that vision into fruition. When absent, the
results are fragmented programs, low
morale, and a reaction mentality.
Findings
There appears to be widespread
agreement that PPQ has lacked consistent leadership and visions for
Safeguarding American Plant Resources
managing information. There are and
have been numerous ÒinterimÓ personnel actions and empty positions.
Responsibilities and assignments of
individuals are changed without
warning, due to Òunplanned emergenciesÓ which occur frequently and incessantly. The ÒSolid Wood Packing
AssessmentÓ is a current example.
Recommendations
■ I-2 Based on the content of this
Report the Office of the Deputy
Administrator of PPQ should determine what knowledge, expertise,
skills, and abilities are needed to lead
and manage IT processes and activities.
■ I-3 Based on this determination of
needed IT knowledge, skills and abilities, recruit and hire people who possess these qualities for IT leadership,
development, and maintenance positions.
■ I-4 Fill vacant positions requiring IT
expertise at appropriate GS and SES
levels.
■ I-5 Assemble and develop an ÒIT
Crisis Management TeamÓ whose job
would be to respond to the always
present ÒunexpectedÓ. Thus PPQ
would be able to minimize the disruption of responsibilities of staff.
4.3.3 Ad Hoc Nature of Information
Flow
Much information can be lost or not
delivered to all parties in need if consistent protocols (e.g., surveillance
warnings from International Services)
are not developed and followed Ñ particularly protocols specifying formats
and vocabularies for information
transfer and archiving.
REPORT
Findings
There appear to be no set procedures
for APHIS personnel to report potential outbreaks or new pests internationally nor for the distribution,
handling, and storage of risk assessments.
Recommendations
■ I-6 Develop protocols for reporting
key information (such as risk assessments, in standardized electronic formats and for the dissemination and
archiving of information).
Development to be accomplished by
teams that include all of the information stakeholders, including those
outside APHIS-PPQ.
■ I-7 Take measures to assure that
the needs dictate the protocols.
■ I-8 Give high priority to adopting
web-based information technologies in
developing a system for managing the
acquisition, analysis, dissemination,
archiving and retrieval of information
relevant to exotic pests.
■ I-9 To the maximum extent practicable, exchange information with
pest, disease, and invasive species
data initiatives in other agencies, including the Forest Service, the
Department of the Interior (U.S.
Geological Survey, the Park Service,
the Bureau of Land Management), the
National Biological Information
Infrastructure, and some state and
NGO efforts.
4.3.4 Access to Useable
Information (Databases)
Consistent and standardized information resources, such as digital data
warehouses for key documents, relational databases for detection and risk
data, and geographic information systems for mapping and modeling, are
Safeguarding American Plant Resources
101
needed for training, risk assessments,
public awareness, forecasting, and
other critical aspects of PPQÕs mission.
Findings
The PPQ has suffered from pervasive
Òreinventing the wheel.Ó Important information frequently has not been
preserved, cannot be found, or is not
in a usable format available to most
people in the organization. Risk assessments, when available, are found
in boxes after ad hoc phone calls and
the vagaries of individualÕs memories.
There is rarely an electronic version
and no electronically searchable recovery system.
There is no system to extract information developed for one purpose to
serve another, such as using PIN-309
records to warn other ports of new
threats, or modifying training information to educate the public, except
on an individual and ad hoc basis.
Many APHIS personnel appear either
unaware of useful APHIS data applicable to their assignments, or unsure
of how to access it. A mechanism to
discover and find out how to access
relevant data sets is sorely needed.
Recommendations
■ I-10 Develop archival databases of
key information in a prioritized sequence, that are available and searchable through web-based technology.
■ I-14 As a critical first step, catalog
data resources important to PPQÕs
mission in a systematic fashion, using
a standard vocabulary and a websearchable format. Thus records
should, at a minimum, contain the
ÒmetadataÓ information assembled in
the clearinghouse mechanisms for
other U.S. government environmental
and natural resource programs.
■ I-15 Assure that the content of the
catalog of data resources would at
least include descriptions, lead agencies, contacts, subject, geographical
and methodological keywords, access
instructions, and guidelines/restrictions on use. This requirement could
be met in part by emulating aspects
of the National Biological Information
Infrastructure (http://www.nbii.gov),
the Global Change Master Directory
(http://gcmd.gsfc.nasa.gov/), the
Government (Global) Information
Locator Service (GILS Ñ
http://www.gils.net), and the
California Environmental Resource
Evaluation System (CERES http://www.ceres.ca.gov/catalog).
4.3.5 Access to the Internet and
Connectivity (bandwidth)
■ I-11 Maintain sensitive information
on an Intranet, internal to
APHIS/PPQ, but much information
should be ÒrepackagedÓ for use by
stakeholders, for public awareness
and for international dialog.
PPQ personnel from border inspectors
to risk assessment experts are increasingly dependent upon rapid access to field data, graphical decision
support materials, and remote consultations. Effective use of knowledge requires near instantaneous access,
through reliable Internet connections
with sufficient bandwidth, to required
information.
■ I-12 Assure that each database has
an independent reason for existing.
Findings
■ I-13 Assure that a strong effort is
102
made by teams of all the stakeholders, to develop multiple and combined
uses for the various databases.
REPORT
Extremely poor Internet connectivity
exists throughout the PPQ system.
Safeguarding American Plant Resources
Part of the problem is that critical information resources are not connected to the Internet. In particular,
many of the existing databases are
available/searchable only on centralized mainframes, limiting their use off
of the LAN, and others are standalone PC applications, which are next
to impossible to keep updated systematically throughout a large organization.
programs to justify their connectivity
levels, based upon identifiable needs.
■ I-18 Station IT personnel at PPQ
locations to meet local needs. IT specialists should be responsible to the
local program leader.
4.3.6 Surveillance and Analyses of
Risks Posed by Exotic Pests
End-user connection to the Internet is
also inadequate. Many PPQ locations,
including major sites such as the
Raleigh Center for Plant Health,
Science and Technology (CPHST),
have totally inadequate electronic
communications capabilities. The setting of 64K lines to be shared by 20+
individuals in many locations represents far less access than is available
in third world countries via dial-up
networks. The problem is compounded by the IT requirement that
these lines go through a national PPQ
server, which is itself often out of service, precluding any Internet access,
including even email.
Countries such as Australia and New
Zealand, in carrying out successful
safeguarding programs, have made
major systematic efforts to identify
and analyze the risks posed by pests
associated with a given commodity
with respect to all countries where the
latter is produced. For example, New
Zealand has developed comprehensive
Pest Lists for 600 of its most important imported commodities. Moreover,
New Zealand placed each exotic pest
in one of three Quarantine Risk
Groups and has defined an algorithm
for determining the appropriate defensive response against pests in each
risk group.
A high degree of connectivity also is
required so that PPQ
computer/Internet systems can communicate readily with a variety of
other systems used by organizations
throughout the world with safeguarding responsibilities. The interconnection of systems involves stringent
technical requirements with respect to
cabling, connectors, interfaces, protocols, etc.
Australia conducts a systematic and continuous program of monitoring, surveillance and public
awareness across northern Australia
and in neighboring areas of Papua
New Guinea and Indonesia.
It is questionable whether countries
that fail to operate an effective early
warning system, or that have not conducted a comprehensive study of exotic pests, can adequately justify their
phytosanitary requirements, critically
evaluate alternative preventative approaches, or quantitatively predict actual invasive pathways for specific
types of invaders.
Recommendations
■ I-16 Appoint an ÒInformation
Management TeamÓ headed by a nonIT person in order to lead and manage
the IT functions in PPQ.
■ I-17 Allow individual locations to
deal with local Internet Service
Providers and allow individual
REPORT
Findings
In spite of major advances in
quantitative areas such as population
dynamics and crop modeling, GIS,
economic analyses, and weather
Safeguarding American Plant Resources
103
modeling, PPQ has made scant effort
to comprehensively assemble the
existing information on exotic pests
and to quantitatively predict
invasiveness or population
management of invaders. Likewise
there has been scant effort to link the
large amount of information which
PPQ collects in PIN-309 and other
databases to any type of pattern
analysis for detection of pathways of
entry or for potential bioterrorism
attempts.
general, with concurrent pattern
analysis of present and future
databases, particularly those with
distributional and interception
information. This will require an
increase in dedicated personnel, with
cooperation among the various
Federal and state agencies
responsible for the data collection and
archiving. A recently developed
technology, Internet Map Server,
could be used to spatially represent
the geographic and severity of
outbreaks over the Internet.
Recommendations
■ I-19 Make a concerted effort to assemble and organize all available information on pests not known to
occur in the United States. The first
step in this process should be to develop a plan to accomplish this task
and to estimate the level of effort that
would be required to substantially
complete this task within five years.
■ I-20 Concurrently acquire and assemble readily available information
such as the CABI database and the
commodity-related pest lists including
the corresponding bibliographic and
taxonomic information which
Australia, New Zealand and the
United Kingdom seem willing to
share.
■ I-21 Develop and implement a
process of placing each pest not
known to occur in the United States
into a Quarantine Risk Group, perhaps using the New Zealand procedure modified to meet U.S. needs.
This process should result in the
identification of those species that are
most dangerous and that warrant
special attention, and the first iteration of the process should be completed within six years.
■ I-22 PPQ and IS should undertake a
significant effort in geo-referenced
modeling of invasive species in
104
REPORT
4.3.7 Coordination with Other
Agencies and Expertise
Half a dozen Federal agencies, many
states, and a wide variety of private
and international organizations have
major initiatives to develop information on detection and management of
exotic species relevant to PPQÕs safeguarding mission. It is important that
PPQ understand the goals, data holdings, and technical protocols and
standards used by those organizations, and that its experts participate
to the extent required to assure interoperability in data products.
Findings
There is little interaction among
APHIS groups themselves, except in
an ad hoc manner. There appears to
be even less cooperation with agencies
and organizations outside USDA, including other Federal agencies with
interest in and responsibilities for invasive species data (specifically USGS
and EPA). There has been some cooperation with land grant universities
for data access, but this has been primarily with the universities in a service role, rather than a cooperative
mode. There appears to be even less
cooperation internationally except
where dictated by export restrictions
or political considerations.
Safeguarding American Plant Resources
Recommendations
■ I-23 The PPQ and IS should develop
and implement a coordinated plan to
integrate the various database efforts
on pests not known to occur in the
United States with those of other organizations, both nationally and internationally. Thus PPQ and IS should
seek out mutually beneficial arrangements with USGS, EPA, U.S. universities, and international organizations
(FAO, IPPC, etc.).
■ I-24 Assign or hire IT personnel to
participate in interagency standard
setting groups and long term planning
exercises. Particular efforts should be
made to adopt standardized vocabularies (e.g. ITIS nomenclature) and
data structures (for example
GILS/FGCD/Z39.50 metadata specifications) as they become widely used
within the Federal government or
among important collaborators. If existing personnel are assigned technical liaison and standard-setting tasks,
they must be provided with matching
release from other responsibilities.
■ I-25 The PPQ and IS should take
advantage of opportunities to connect
to international databases on species
distributions. These include a number
of national programs, for example,
Environment Australia,
http://www.biodiversity.environment.
gov.au/; Base de Dados Tropical,
http://www.bdt.org.br/bdt/, in Brazil;
INBIO, http://www.inbio.ac.cr , in
Costa Rica; and CONABIO,
http://www.inbio.ac., in Mexico; and
several emerging international
biodiversity networks, including
BIN21 http://www.bdt.org.br/bin21/
bin21.hmtl, , the Biodiversity
Conservation Information System
(http://biodiversity.org/), and
MABNetAmericas
(http://www.mabnetamericas.org/ma
bnet/home.html). All of these efforts
have major emphases on nonindigenous species, and are especially
important in assessing threats from
REPORT
invasive species that already have
erupted elsewhere. A particular
opportunity to develop more foreign
database links and standardization is
in the proposal to the Inter-America
Biodiversity Information Network
(IABIN) to develop information sharing
on invasive species (initially fish and
vascular plants) among participants
in the Summit of the Americas (see
http://www.nbii.gov/iabin/torpilot.ht
m). These initiatives all share a goal of
using the protocols developed under
the Clearinghouse Mechanism of the
Convention on Biodiversity, and are
working toward common uses of
biological nomenclature (see the
Integrated Taxonomic Information
System, http://www.itis.usda.gov/
plantproj/itis/index.html.) Unless
there are overwhelming reasons to do
otherwise, APHIS-PPQ should
participate in these efforts and adopt
their clearinghouse standards and
vocabulary uses for international
species data.
■ I-26 Strive to play a leading role in
shaping invasive species policy, since
the stake in this policy of American
plant resources is immense. The PPQ
can play a leading policy role only if
its information systems are inter-operable with the increasingly standardized approaches being adopted by
standard-setting organizations and
other agencies.
4.3.8 Taxonomic Services
The Committee found deficiencies in
information support, identification/diagnostic tools, and work space and
need for greater involvement of the
wider taxonomic community.
Importance of taxonomic
services
Correct taxonomic identification of
organisms is critically important to
the work of PPQ. The consequences of
misidentification of a pest or its
Safeguarding American Plant Resources
105
natural enemies and lack of
understanding of its biology can have
severe consequences in decisionmaking (Rosen 1978). The existence of
cryptic species and those, which
cannot be cultured greatly
complicates the tasks of identifiers. It
is probably safe to say that the
complexity of identification is not well
understood except by taxonomists or
systematists. Correct identification or
diagnosis is the first step in gaining
knowledge of a pest species including
its bionomics, life history, pest
management strategies, and economic
importance. This task is daunting
because (1) the number of estimated
number of world species (the
spectrum including arthropods,
mollusks, animal and plant
pathogens, vascular plants, and
vertebrates) is approximately 32
million, yet only two million have been
described (Klassen 1986), and (2)
within many known taxa there are life
forms or developmental stages which
have not yet bee described (Batra,
1978; Rosen 1978).
The ability of scientific staff (identifiers, specialists) to provide accurate
identifications presupposes a comprehensive knowledge of the worldÕs
fauna and flora. But this supposition
is far from having been realized because of the vast number of life forms
and the diversity of developmental
stages.
Significantly Batra et al (1978) noted
that ÒSystematics is the synthesizer of
information from all fields of biologyÑ
organizing the data into a classification that groups related species. A
classification is most useful if specialists can predict with a satisfactory degree of probability relatedness among
taxa on the basis of previously uninvestigated character systems, and if a
few diagnostic characteristics of a
newly discovered taxon enable us to
relate it to previously known taxa
(Cronquist 1969).Ó
106
REPORT
Taxonomic competency
PPQ has a long tradition of relying on
certain Federal, State and private taxonomy/systematics laboratories or
groups for urgent identifications as a
basis for actions to be taken when an
exotic pest is encountered at a port of
entry that cannot be reliably identified
by a PPQ ÒArea Identifier.Ó Since the
scientific name of an organism is the
key to searching the literature, the expert taxonomist has routinely provided not only the scientific and
common names, but also basic information on hosts, distribution, pest
status, diagnostic characters, biology,
natural enemies, and other critically
important biological data.
Each PPQ Area Identifier is required
to develop a level of proficiency in correctly identifying a certain number of
exotic pest species. This level of proficiency is variously referred to as
Òidentification authorityÓ or Òdiscard
authority.Ó Identification authority is
earned in part by demonstrating to a
taxonomic authority on three separate
occasions that a given exotic pest has
been correctly identified. In the past
Òdiscard authorityÓ had to be renewed
every fifth year. Regulatory decisions
of great moment are based on identifications/diagnoses. Therefore the
highest standards should exist for
this first step of many in a regulatory
decision. The importance of the ability
to make scientifically competent taxonomic identifications/diagnoses as
well as interpret other available biological information cannot be over emphasized.
Taxonomic resource support for
Area Identifiers
Efficient and effective work
performance of the identifiers and
specialists employed by USDA-APHISPPQ is dependent on a motivated
work force provided with adequate
resources such as work space,
identification/diagnostic tools, and
information support.
Safeguarding American Plant Resources
REPORT
Safeguarding American Plant Resources
107
Involvement of the wider taxonomic community and the New
Pest Advisory Group
In past decades, USDA-APHIS- PPQ
has used ÒStatus of Potential Pests
Not Known to Occur in USA
CommitteesÓ or ÒNew Pest/Disease
Detection Evaluation CommitteesÓ as
mechanisms to assess potentially
dangerous intercepted organisms. The
PPQ would significantly involve ARS
and university taxonomic/systematic
scientists on these committees depending on their expertise. Currently,
USDA-APHIS-PPQ uses the New Pest
Advisory Group (NPAG), which consults university and ARS scientists.
However in many instances the specialists who identified the organisms
in question are no longer included in
follow up discussions as in previous
years. Indeed, it appears that many of
the specialists who do authoritative
identifications have not been involved
in such deliberations in recent years.
Nevertheless, the New Pest Advisory
Group seeks counsel of university and
ARS specialists, but largely on a last
resort basis. The result is that the
specialist who identified a dangerous
pest rarely learns what is being done
to mitigate the risk.
The New Pest Advisory Group (NPAG)
was established in the PPQ Center for
Plant Health Science and Technology
in Raleigh on January 1, 1998. The
NPAG function previously resided at
PPQ Riverdale headquarters on the
Domestic and Emergency Operations
staff. NPAG assesses exotic pest detections in the USA and systematically prospects for reports of new
infestations from a network of contacts and information sources. NPAG
recommends to the Deputy
Administrator the most appropriate
response for PPQ. New detections
often are first noted outside of PPQ
channels. Many of the reported detections require no action by PPQ due to
widespread distribution, minimal economic or environmental impact, etc.
108
REPORT
However at least two dozen new pest
situations per year warrant some follow up action by NPAG such as
preparing a data sheet, convening a
meeting, or writing a report with recommendations. NPAG does not treat
those exotic pests having emergency
guidelines in place such as medfly or
citrus canker.
The chair of NPAG designs the composition of the new pest assessment
meetings and teleconferences to best
address the specific pest. Participants
include appropriate scientific authorities and regulatory officials who can
help the group reach consensus on
scientifically valid, operationally
sound recommendations. Typically
meetings are conducted by conference
call and convene about 10 participating stations.
During 1998 NPAG operated in a
reactive mode. In 1999, NPAG has
placed emphasis on also being
proactive, and is attempting to recruit
staff with data management skills in
addition to knowledge of the biological
sciences to conduct trend and
pathway analysis and help predict
potential pest invaders. NPAG is
engaging scientific societies
(Entomological Society of America,
American Phytopathology Society, and
Weed Science Society of America) to
construct prioritized lists of exotic
pests of concern. NPAG plans to
eventually produce various lists
useful for key commodities or
environmental/ geographical areas.
The lists should help PPQ to more
effectively produce regulations, issue
permits, and utilize resources for
training, exclusion, and survey
activity.
The NPAG has been engaging specialists in the APHIS Professional
Development Center, Frederick, MD in
the preparation of exotic pest data
sheets.
Safeguarding American Plant Resources
Findings
At least in some instances, PPQ appears to have granted identification
authority to some Area Identifiers who
have not been trained and tested by
professional taxonomists, and has
waived the requirement that discard
authority be renewed periodically. In
addition, PPQ has elevated some of its
Area Identifiers to ÒspecialistÓ status
for particular taxonomic groups.
There is concern that adequate taxonomic standards may not be in place
to accurately assess the competencies
of identifiers and specialists, and that
reviews of competency may no longer
be conducted on a regular basis.
Currently, there are deficiencies in the
resources provided to many identifiers
and specialists. Too often work space
is cramped, inappropriate for slide
making and other operations and
lacks adequate ventilation removal of
noxious chemicals used to prepare
pest samples. Many microscopes have
substandard optics. Hard copy literature (especially books) and other types
of reference literature available vary
but tend to be grossly inadequate.
The work load for some identifiers requires that many hours each day
must be devoted to preparing samples
for identification (e.g., preparing microscope slides), and this leaves insufficient time for actual taxonomic
identification. Routine preparatory
work could be delegated to assistants.
The amount of time allowed for training of new identifiers and for maintaining taxonomic competency has
declined considerably in recent times.
Some new identifiers are receiving inadequate introductory training.
Factors influencing this shortfall include the ongoing decline in numbers
and availability of outside expert taxonomists and experienced Agency
Identifiers. Less training, and therefore less working-knowledge, seems to
be resulting in an increasing number
of identification/diagnostic reports
REPORT
with Ònr. speciesÓ or Òprob. species.Ó
Certainly, not in all cases is a binomial species diagnosis required for a
regulatory decision; however, the lack
of ability to do so when needed can
and will result in poor regulatory decisions. The economic, environmental,
and political impact from an inaccurate identification can be severe. Also,
the amount of time has declined significantly for identifiers to attend and
participate in identification/diagnostic
workshops and for general or specialty training with taxonomic experts.
Retention of experienced identifiers is
much less than desirable, in part, due
to few opportunities to increase salary
levels and yet remain as an Area
Identifier. Two immediate costs are incurred: loss of experience and cost of
training a new Area Identifier.
From time to time, some APHIS administrators, in their well-intentioned
quest for cost savings, have expressed
the view that the maximum possible
percentage of pest identifications
should be done by PPQ Area
Identifiers and that the services of
Federal, State and private
taxonomy/systematics laboratories or
groups should be reduced to a bare
minimum. In recent years PPQ appears to have substantially reduced
the involvement of extramural taxonomic specialists, and this minimal
use has continued since the formation
of the NPAG. The many advantages of
substantial involvement of extramural
taxonomists and systematists in a variety of institutions appears no to be
appreciated by PPQ management. The
APHIS, in its self-interest, needs to
urge universities and research organizations to maintain and strengthen
their commitments to taxonomy and
systematics.
Recommendations
■ I-27 Make greater substantial use of
highly competent taxonomists and
Safeguarding American Plant Resources
109
systematists in a variety of institutions.
■ I-28 Take measures to assure that
the extramural specialists engaged by
PPQ for making identifications are involved as appropriate in the work of
the New Pest Advisory Group and are
kept informed of any actions taken
against those dangerous exotic pests
that come under the purview of the
extramural specialist.
■ I-29. Assure that each Area
Identifier is trained and tested by one
or more taxonomists/systematists
who are recognized authorities on the
taxa assigned to the Area Identifier.
■ I-30.. Assure that the identification
authority of all identifiers is renewed
at appropriate intervals (normally
every 3rd year and never less frequently than at 5 year intervals).
■ I-31. Take concrete measures to
foster a strong sense of collegiality between and among Area Identifiers and
taxonomists/systematists in other organizations.
■ I-32. Examine all the workspaces
assigned to Area Identifiers and specialists and correct deficiencies with
respect to safety, ergonomics and the
special requirements of the assignment.
■ I-33. Examine the needs of Area
Identifiers and specialists with respect
to instrumentation and equipment
and correct all deficiencies.
■ I-34. Examine the needs of Area
Identifiers and specialists with respect
to technical literature, information on
CD-ROMS or available on the Internet
and correct all deficiencies.
■ I-35. Examine the needs of Area
Identifiers and specialists with respect
to professional development,
110
REPORT
advancement and retention and
devise a system of continuing
education and earned promotion to
assure that capable identifiers are
advanced and rewarded to the same
extent as are those who take other
career pathways in PPQ.
4.3.9 Seed Identification Problems
at Inspection Points
Background
Many listed and potential noxious
weed species enter the United States
as seed. The seed may be a contaminant of imported seed, mislabeled imported seed, or introduced through
another means. Identifers are sometimes given as little as 2 hours of
training in very general seed biology
and are expected to be able to identify
species from that. Each inspector is
given a book with devitalized seeds
but there is very little formal training.
Inspectors may add to the book if
they are motivated, but that is up to
the individual. Unidentified seeds may
be sent to the single National
Identifier who identifies ÒUrgentÓ seed
immediately. If the inspector does not
mark the seed as ÒurgentÓ it joins a
backlog of unconfirmed or unidentified seeds that is currently at 6,735
samples. It is impossible to hold up so
many shipments and they are generally approved for entry. Visiting scientists may be asked to identify problem
seeds from their countries, but only
opportunistically, not routinely.
Findings
Training in seed biology for inspectors
and even Area Specialists is inadequate and there is insufficient support. Many weed species are very
likely entering the United States because of this. Seed biology is a technical field and experts are distributed
throughout the world. International
expertise is currently being little used.
Safeguarding American Plant Resources
Recommendations
■ I-36. As prerequisites to serving as
a seed inspector, give each prospective
inspector several hours of seed biology training, and should test the
prospect with respect to reliability of
ability to identify important weed taxa
in the seed stage. Subsequently PPQ
should require each inspector to take
advantage of periodic retraining opportunities.
■ I-37. Hire additional National Weed
Seed Identifiers to decrease the backlog of current plant seed samples and
to process the taxonomic identification of samples of plant seeds in a
more timely manner in the future.
■ I-38. Engage the assistance of international plant taxonomists with weed
seed expertise more often. With remote imaging technology a system
could be implemented that would
allow foreign biologists to quickly
identify the taxa of seeds of their native species, with U.S. seed biologists
reciprocating when needed.
4.3.10 Development and Assembly
of New Information on Exotic Pests
Background
The capacity to cope with exotic pest
threats to the United States requires
highly reliable and adequate knowledge of (1) the identity of exotic organisms which are likely to be serious
pests if introduced into the United
States, (2) exotic pest biology, ecology,
host range, (3) pathways that may
permit entry of the pest, (4) likelihood
of survival in each pathway, (4) ways
of tracing a pest population back to
its origin, (6) effective and efficient
methods of detection and survey and
(7) effective methods for managing or
eradicating the pest. This information
REPORT
and technology are needed for (a) reducing the likelihood that the pest
will penetrate into the United States
and (b) for coping with the pest in the
event that it does gain a foot-hold in
the United States.
Gaps in information on exotic pests
can render worthless pest risk assessments. Not all knowledge of destructive exotics resides in scientific
literature. For example the avocado
thrips, Scirtothrips perseae, was undescribed in the scientific literature
when the pest risk assessment for importing the Hass avocado from Mexico
was conducted. Subsequently the pest
has caused tremendous damage in
CaliforniaÕs avocado groves. In interviews with the California Avocado
Commission, Mexican growers readily
disclosed that they had long known
that this pest existed (see 20 April
1999 letter from Tom Bellamore to T.
A. Batkin and C. Regelbrugge).
Approaches to conducting research
and development on exotic pests have
been described for arthropods by
Calkins (1983), for plant pathogens by
Pusey and Wilson (1983) and for
weeds by Patterson (1983). In large
measure the acquisition of high quality data requires well planned surveys
and taxonomic or diagnostic tools that
in many cases are inadequate or not
available. Not all reports in the scientific literature can be taken at face
value. Scientists everywhere vary
greatly in their taxonomic and diagnostic skills and in their understanding of the biologies of various pests.
In order to better gauge the potential
destructiveness and invasiveness of
an exotic pest species, every opportunity should be taken to study any of
its populations that has been displaced from the speciesÕ center of origin to new localities. The potential
destructiveness of many plant pests is
not apparent in their centers of origin
probably because their hosts have
Safeguarding American Plant Resources
111
evolved significant tolerance or resistance and/or a cohort of natural enemies has been assembled which
provides substantial suppression.
However when such pests are transported to new habitats where the host
plants are not resistant or where the
natural enemies do not exist, the full
destructiveness of the pest may be revealed (Kim 1983; Myerdirk, personal
communication; Polston and
Anderson, 1997; Schuster et al.
1990).
Highly destructive pests become widespread throughout the Caribbean region usually in 3 to 5 years after
arrival, because the phytosanitary capacities of the island nations are too
weak, first to prevent the pests from
gaining a foot-hold, and then from
rapidly spreading from island to island. Because of the extensive travel
that has developed between the
Caribbean and the rest of the world
during the past two decades, the
Caribbean has become one of the important staging areas for invasion of
the U.S. mainland. Similarly northern
Mexico and southern Canada are
areas where exotic pests assemble before invading the United States. These
situations seem analogous to the
threat to Northern Australia posed by
pests which assemble in neighboring
areas of Papua New Guinea and
Indonesia (Stynes 1999).
The likelihood of invasion increases
sharply when invasive pests assemble
in areas proximate to the border of
the United States because of natural
spread and because of the tremendous volume of pedestrian, automobile, boat and small aircraft traffic.
During the 1920s Stakman demonstrated that during late summer
spores of wheat stem rust from the
Canadian prairies were blown southward too infect newly emerged winter
wheat on the plains of the southern
U.S., and in the spring spores from
the southern Grat Plains were blown
112
REPORT
northward to infect newly emerging
wheat as far north as Canada. Karnal
bunt and the Russian wheat aphid
may have been carried by wind from
Mexico into the United States. The
seeds of many species of plants are
adapted for wind transport, and certain microbial spores and insects are
know to be transported hundreds of
miles by weather systems with strong
storm cells or jet streams. Asian citrus canker spores in Florida is spread
on moist warm winds, and in 1997 a
tornado spread this disease from
Miami well into Broward County to
the north. The pattern of distribution
of the Black Sigatoka pathogen in
south Florida suggests that it was not
carried from Cuba into Florida by
wind but that it arrived through
human transport. Each year the
Mexican fruit fly expand its range in
Mexico by flying into the Rio Grande
Valley. Indeed many species of insects
which depend on transient host resources have developed remarkable of
powers of dispersal and migration as
part of their survival strategies.
The paramount necessity of tracking
the movements of exotic pests outside
the USA borders was strongly emphasized by Kim (1983). He stated: ÒPort
inspection is a necessary part of regulatory plant protection. However emphasis should be given to the
worldwide movement of Éa number of
high-risk pests, since no quarantine
and regulatory control program can
provide complete protection against
the entry and establishment of exotic
pests. As discussed earlier, ecological
factors of the habitat or agroecosystem relating to climate, physical condition, and biotic resistance are more
important barriers to colonization
than are port inspection and quarantine activities.Ó
Findings
There is neither an individual nor one
unit in APHIS that is responsible and
accountable for the collection and use
Safeguarding American Plant Resources
of all of the intelligence collected and
developed on exotic pests either at
ports of entry or abroad. Thus collection and use of intelligence are haphazard. The importance of up-to-date,
accurate biological information for
successful regulatory decision-making
of USDA-APHIS-PPQ can not be overestimated. The timely acquisition,
analysis, and reporting of biological
information (including taxonomy, bionomics, life history, pest management
strategies, and such) and the timely
development of effective pest detection
and suppression technologies are cornerstones to the success of the many
program functions of USDA-APHISPPQ.
Currently, biological data are collected
from many sources and entered into a
multitude of databases. Data analyses
and reporting are regularly done for
specific goals and objectives. However,
it appears that inadequate effort is expended to (a) periodically reviewing
the needs and procedures of data acquisition, analysis, and reporting, (b)
ensure that data collected for one use
are actually used to serve multiple
purposes, and (c) assuring that technology is on hand when a new pest
emergency arises.
APHIS-IS has a far-flung global infrastructure, and has occasional spectacular successes in collecting
information and organizing effective
cooperative programs on exotic pests
abroad. However, IS does not have a
comprehensive and systematic program for collecting intelligence pertaining to exotic plant pests or for
disseminating/archiving/analyzing
that information in other than an ad
hoc manner. International Services
(IS) does not receive a regular allocation for pest surveillance abroad, and
does not treat exotic plant pest survey
as a regular program. Thus IS fails to
systematically plan and coordinate
this activity. Moreover no durable
mechanism has been created whereby
REPORT
(a) PPQ and IS would work together to
determine what pest species should
be surveyed for and in what countries, and (b) PPQ could provide adequate training for IS personnel in the
field on how to set up the specific survey desired.
International Services has officers in
27 countries on 6 continents and coordinates field operations from seven
offices, six of which are regional:
Mexico, Central America, Caribbean,
South America, Asia/Pacific Basin
and Europe/Africa/Near East.
International Services participates in
pest surveillance and control programs abroad, and some of these
have proven to be highly effective in
protecting American agriculture. The
cooperative MOSCAMED program in
Mexico and Guatemala was initiated
in 1976 to halt the northward movement of the Mediterranean fruit fly.
This program continues to serve both
Mexico and the USA very well, but the
benefit to Guatemala is less since
funding to eradicate the medfly and
other tropical fruit flies from
Guatemala and Central America has
not materialized.
Similarly APHIS is involved with surveillance and control/quarantine programs against the carambola fruit fly
in Suriname, Brazil and Guyana,
Mexican fruit fly in Mexico, surveillance/control/eradication of the boll
weevil in Mexico, and
surveillance/control of hydrilla with
triploid carp in Mexico. In addition
APHIS provides some worldwide technical assistance for cooperative surveys for pests of concern to the United
States. The APHIS has conducted
smaller scale tropical fruit fly surveys
in Costa Rica, Panama, Colombia,
Venezuela, Ecuador, Kenya and South
Africa.
APHIS has conducted and sponsored
a great deal of excellent R&D on
technology to detect, suppress and
Safeguarding American Plant Resources
113
eradicate exotic tropical fruit flies.
Thus APHIS working through the
FAO/IAEA has been involved in
studies on improving traps and lures
in countries surrounding the
Mediterranean Sea, Latin America and
Southeast Asia. In Guatemala, APHIS
and the Government of Guatemala are
conducting pioneering work on the
rearing and handling of male-only
strains of the Mediterranean fruit fly.
In past decades USDA sponsored a
great deal of research on the taxonomy, biology and control of foreign
pests in Asia and in Europe (Batra et
al. 1978; Pusey and Wilson, 1983;
Spaulding, 1958, 1961; Watson 1971).
In some instances U.S. plant materials were planted abroad to observe
pest attack. Much R&D was conducted very effectively through the P.
L. 480 Foreign Currency Program and
through offshore laboratories of ARS.
In addition significant studies on invasive and introduced pests have
been sponsored or conducted by
CSREES and ERS. As a result of a series of reorganizations the responsibility in USDA for R&D in foreign
countries has become fragmented and
now falls under ARS, FAS and APHIS.
ARS conducts research on a variety of
exotic insects, plant pathogens and
weeds in its European Parasite
Laboratory, Montpellier, France, in its
Asian Parasite Laboratory, Seoul,
Korea and at the Foreign Disease and
Weed Science Research laboratory,
Frederick, MD and at facilities on St.
Croix Is. And Puerto Rico. Also ARS
administers the very effective and
well-endowed U.S.-Israel Bi-national
Agricultural Research and
Development Fund (BARD) whereby
all projects are conducted cooperatively by U.S. and Israeli scientists.
The FAS R&D programs come under
the Deputy Administrator for
International Cooperation and
Development of USDA Foreign
Agricultural Service. This Service has
114
REPORT
a Research and Scientific Exchange
Division. The latter conducts a
Scientific Exchange Program, a Bi-national Research Program, a Foreign
Currency Research Program and a
Reimbursable Research Program. On
the whole there appears to be inadequate coordination between and
among the ARS, CSREES, ERS, FAS
and APHIS programs on exotic pest
R&D. Also there appear to be no firm
agreements between and among
APHIS, ARS, CSREES, ERS and FAS
on the minimum level of effort that
each agency will devote to the exotic
pest R&D needed to support the PPQ
safeguarding mission. In addition ARS
conducts research on a small number
of exotic and dangerous plant
pathogens, insects and weeds at the
Foreign Disease & Weed Science
Research Laboratory, Frederick, MD.
A major program on exotic animal diseases is conducted by USDA in a high
security facility at Plum Island, NY.
Screwworm research requiring sophisticated laboratory approaches has
been conducted for about two decades
in a high security facility first at
Fargo, ND and now at Lincoln, NE.
Frequently invasive organisms new to
science but of potential regulatory significance are reported in foreign countries. Often the taxonomic or
diagnostic tools are lacking to identify
quickly and reliably such organisms.
Also needed are (1) information on the
likely degree of destructiveness of
such organisms in U.S. environments,
(2) means to readily detect and monitor their populations of the organisms, and (3) means to strongly
suppress them. A great deal of anticipatory research is needed. In addition, some reports in scientific
journals require validation by independent investigations. USAID has
sponsored very significant programs
against exotic pests. The APHIS-PPQ
could benefit from this effort by maintaining liaison with USAID. The
CGIAR system has conducted a great
Safeguarding American Plant Resources
deal of research on exotic pests. This
system consists of a network of sixteen international agricultural research centers funded by the World
Bank, the FAO, the United Nations
Development Programme (UNDP), and
the United Nations Environment
Programme (UNEP). Since the CGIAR
is headquartered in Washington, DC,
APHIS should have little difficulty in
establishing an effective liaison.
The North American Plant Protection
Organization (NAPPO) is in process of
establishing a Working Group on
Emerging Pests. Recently PPQ has assigned the chair of its New Pest
Advisory Group to serve on the
Working Group. Similar liaisons have
not been established with EPPO and
the other Regional Plant Protection
Organizations.
Many university faculty members and
other scientists who work for the private sector and for the Federal or
state governments have substantial
involvement in international programs
and they discover and obtain much
valuable information on exotic pests.
However PPQ has no mechanism to
systematically obtain such information on a timely basis.
The Committee also found that no
systematic evaluations of the effectiveness of the safeguarding system are
being made and released to the public. The PPQ lacks the resources
needed to identify dangerous exotic
pathogens, which may accompany
lots of seed imported for planting. The
National Seed Health System being
developed by PPQ and the American
Seed Trade Association will focus on
identifying seed-borne pathogens in
seed lots intended for export from but
not importation into the USA.
Recommendations
■ I-39 Appoint an International Pest
Information Officer whose primary re-
REPORT
sponsibility would be to develop and
lead a program on the systematic collection and discovery of intelligence
on pests not known to occur in the
United States. This officer should report to both the Deputy Administrator
for International Services and the
Deputy Administrator for PPQ.
■ I-40 The PPQ and IS should appoint
a Standing Committee on the
Collection and Use of Intelligence on
Exotic Pests. The National Plant Pest
Coordinator will be a permanent
member of this Standing Committee.
This Committee should report to the
International Pest Information Officer
whenever appropriate but no less
than two times per year. Specifically
the Committee should do the following:
First year
¥ Develop a description of current programmatic uses of biological information.
¥ Consult with a representative subset
of biological information users to determine their desired or optimum dayto-day information needs.
¥ Identify and describe additional resources needed to achieve optimal biological information that can be
acquired, analyzed, and reported in
an effective manner.
¥ Identify mechanisms to provide
analyses of data and subsequent
means to disseminate to targeted information users. Designated scientists
or experts must have the responsibility to provide both general and specific views of the exotic pest issue and
construct short- to long-range radar
for anticipated exotic pests.
¥ Present a written recommendation
to a larger review group of biological
information users to ensure an accurate capture of the biological information needs.
¥ Deliver a report containing recommendations to program applicators
and policy-makers for implementation.
Safeguarding American Plant Resources
115
Second year and thereafter
¥ Review status of recommendations
made previously.
¥ Re-survey biological information
users to determine current needs and
future needs.
¥ Prepare and deliver a report containing findings and recommendations
to program applicators and policymakers for implementation.
■ I-41 The Standing Committee shall
include one representative each from
(a) Office of Deputy Administrator for
PPQ, (b) Office of Deputy
Administrator for International
Services, (c) Center for Plant Health
Science and Technology (d) NPAG (e)
Biotechnology and Biological Analysis
(f) National Identifiers, (g) APHIS
Library (h) Phytosanitary Issues
Management, (i) National Biological
Control Institute, (j) Port Information
Network, (k) one liaison officer from
the North American Biodiversity
Information Network (l) one liaison officer each from ARS, FS, CSREES and
FAS and (m) others as deemed necessary by the Deputy Administrator of
PPQ.
■ I-42 The APHIS should create a
mechanism whereby IS and PPQ will
work together with the Standing
Committee on the Collection and Use
of Intelligence on Exotic Pests in setting priorities, defining protocols, providing training, etc. for such a global
exotic pest surveillance program.
■ I-43 The IS and PPQ should develop a global program to monitor the
movements of especially dangerous
pests. The APHIS should develop comprehensive systematic programs of
pest-intelligence gathering especiallyÑbut not exclusivelyÑfor the
Caribbean, Mexico and Central
America and Canada with defined
protocols and an accessible database
for storage, sharing, and analysis of
the information collected.
116
REPORT
■ I-44 Update the various lists of
classes of exotic plant pests (arthropods, plant pathogens, molluscs,
weeds, etc.). The taxa in each list
should be placed in a rank order from
most threatening to least threatening.
Such rankings should be done at 3 to
5 year intervals in cooperation with
representatives of professional societies, Agricultural Research Service,
State Departments of Agriculture,
CICP, FAO, etc. These ranked lists of
exotic pests should be used to identify
those taxa that should be targeted for
(a) special exclusion efforts and (b)
special surveillance abroad and (c)
R&D.
■ I-45 The PPQ and IS should engage
statisticians to construct improved
sampling schemes for detecting and
monitoring targeted pest species.
Detection rates are likely to be a function of the pest population densities
in the areas from which commodities
are exported to the U.S.A., the opportunities for the pest to follow a pathway into the USA, etc. Statisticians
should be able to generate detection
probability functions based on various
sampling schemes.
■ I-46 The APHIS should also employ
ancillary approaches to obtaining data
on exotic pests by working cooperatively with international organizations.
One approach would be to provide
small grants to foreign scientists who
are appropriately located to conduct
surveys and studies. In addition small
grants could be made to university
faculty, and other U.S. scientists who
are already engaged in international
programs. In any case the latter
should be queried periodically concerning new observations on exotic
pests.
■ I-47 The IS or PPQ should negotiate
with each Regional Plant Protection
Organization on the possibility of assigning a representative or liaison officer to each RPPOÕs working group on
emerging pests or its equivalent.
Safeguarding American Plant Resources
■ I-48 The PPQ and IS should develop
mechanisms to glean information on
exotic pests from programs of USAID,
CGIAR, FAO, IAEA, UNDP, UNEP and
other international organizations and
bodies.
■ I-49 Glean information on the capacity of various taxa to penetrate the
U.S. safeguarding system. A good
basis for such analysis is the review
of annual interceptions of specific invasive species at ports of entry. An indicator of capacity of a given taxon to
penetrate the safeguards is the length
of time elapsed from the first interception to the time that the pest was first
documented to occur in the United
States.
■ I-50 Each year PPQ and IS should
develop a list of research needs on invasive organisms not known to occur
in the U.S., and which may have the
potential to be significantly destructive if they were to gain entry and become established. This list of needs
should be formally transmitted to
ARS, CSREES, ERS and FAS, as appropriate. Similarly those research
needs pertaining to invasive pests
that have gained footholds in the U.S.
and which may be candidates for
eradication or other regulatory action
should be communicated to the appropriate sister research agencies.
■ I-51 In order to leverage the resources of sister USDA research agencies, APHIS during the course of
annual budget development should
identify the need for a dedicated extramural research fund of no less
than $2,000,000 recurring annually.
These funds should be allocated and
managed based on guidance from the
Standing Committee on the Collection
and Use of Intelligence on Exotic
Pests (See Recommendation I-38).
■ I-52 At the beginning of each fiscal
year APHIS should submit a comprehensive report to the National Plant
REPORT
Board and to other stakeholders on
(1) the research projects being conducted on invasive pests in relation to
the needs defined by APHIS, (2)the
most important needs on which little
or no research is being conducted,
and (3)a summary of communications
that APHIS has had with its sister
USDA agencies concerning research
needs relevant to invasive plant pests.
4.3.11 Surveillance of Genetically
Modified Organisms
Background
The genetic improvement of crops
through Ògenetic engineeringÓ is being
pursued vigorously in the United
States, Canada, China, Australia and
several other countries. Genetic engineering has greatly strengthened the
capacity of molecular biologists to
take useful genes from one species
and insert them into other species.
For example, genes that determine
the production of herbicide -metabolizing enzymes have been moved from
bacteria into soybeans. The scientific
community in the United States has
adopted elaborate precautions to
guard against unauthorized releases
of recombinant DNA to the environment. In spite of this, fears are prevalent, especially in European countries,
that (1) the release into the environment of genetically engineered organisms will result in some unintended,
grievous and permanent damage or
loss to people, plants, animals or the
environment and that (2) genetically
engineered crops may themselves become intractable weeds and/or that
genetically engineered crops will
transfer genes to wild weedy relatives
that enhance the weediness of the latter.
Just as the U.S. is the world leader in
agricultural biotechnology, so is
USDA-APHIS the world leader in
regulatory oversight of genetically
modified or engineered plants (GMOs),
Safeguarding American Plant Resources
117
especially for commercialization.
Using risk analysis and performancebased standards for evaluation,
APHIS has developed and
implemented protocols that assess
whether the plant in question is likely
to become a plant pest or contains
some plant pest properties. Largely at
APHISÕs own initiative, regulations
have been modified over the last
decade, as data have accumulated on
the performance of plants in U.S. field
trials. If field trials show no untoward
effects towards other plant species, or
to the environment over several
different seasons and locations,
plants are released for potential
commercialization, unless the plants
also fall under the jurisdiction of the
Environmental Protection Agency.
If genetically modified plants have
changes in quality traits, such as
changes in oil composition and herbicide resistance, then their release requires only USDA approval. On the
other hand if pesticidal properties
have been imparted to the genetically
engineered plants, e.g. the gene for
the Bacillus thuringiensis toxin engineered into plants and efficacious
against certain insects, then EPA approval is also needed.
GMOs, i.e. organisms manipulated by
newer biotechnological techniques,
may pose new problems in
environments in which the organisms
were neither tested nor produced.
Some of these problems can be
anticipated; others cannot. GMOs of
microorganisms, insects, plants and
animals introduced into new habitats
may present risks, which for the
purpose of APHIS are in two
categories. One is that of transgenic
transfer of one or more introduced
traits into either desirable or
undesirable species, with the potential
for displacement of the indigenous
species beyond that of a newly
introduced wild-type organism, i.e.
non-GMO. For sterile insects, plants
118
REPORT
and animals, transgenic transfer may
be moot. Techniques, such as the
Òterminator technologyÓ for plants
may prevent transgenic transfer. The
second issue is the potential for
GMOs to demonstrate different
degrees of susceptibility to a pest or
pathogen, which may or may not be
previously known. Such susceptibility
is known to occur with conventionally
bred or newly introduced organisms.
With GMOs, these areas of concern
are not likely to be a potential
problem until large areas or numbers
are produced for varying lengths of
time. In the U.S., thousands to
millions of acres of genetically
engineered crops are now being
grown. Some of these crops are now
being grown in other countries
including countries with minimal
scientific infrastructures. Therefore
the time frame for potential problems
to arise is approaching.
Findings
APHIS has assumed that if genetically-modified plants pass the test of
field trials, that the plants and any
associated pests and pathogens will
behave in the same manner as unmodified plants except for the specific
traits(s) imparted to the plants.
Unfortunately, the release by USDA
from being a plant pest risk for commercial production does not guarantee that other problems cannot occur.
No monitoring or surveillance of
GMOs is being done by APHIS, nor is
any required of the sellers of GMO
seed and other propagules, except for
that mandated by EPA with respect to
surveillance of the development of Bt
resistance in target pest populations.
Recommendations
■ I-53 As a prudent measure, conduct
- or require others to conduct - monitoring and surveillance of genetically
modified organisms for gene transfer
to crops and weeds, and new pests
Safeguarding American Plant Resources
and pathogens not previously detected
to affect the parent plant. These actions can be taken in conjunction and
cooperation with states, crop consultants, university personnel domestically and in other countries.
■ I-54 Assemble a database that
specifically includes categories for
GMOs. Such a database is likely to be
helpful in formulating policy, dealing
with trading partners, and instilling
confidence in consumers and buyers,
whether domestic or foreign. A sunset
clause in such a database may be appropriate if no problems are forthcoming, e.g. over the next decade, beyond
those seen with non-GMOs.
REPORT
Safeguarding American Plant Resources
119
120
REPORT
Safeguarding American Plant Resources
C h a p t e r
F i v e
Permit Committee
Report
oes the present permit system
function as an efficient and effective tool to help ensure that
the safeguarding system protects the
United States from the introduction of
plant pests and diseases, and if not,
what changes can be made for improvement?
D
5.1 Background
The current system
Under the authorities of the Plant
Quarantine Act of 1912, the Federal
Plant Pest Act of 1957 and the
Federal Noxious Weed Act of 1974,
the United States Department of
Agriculture (USDA) prevents the introduction and dissemination of crop
and environmental pests through its
agricultural quarantine and regulatory inspection programs. Regulations
were adopted in 1986 to apply this
authority to genetically engineered organisms modified by recombinant
DNA techniques (7CFR340), if there is
reason to believe they pose a plant
pest risk. The programs are based on
the premise that, if allowed free entry,
invasive species, pest invertebrates,
pathogens, or noxious weeds might
establish, spread, and cause serious
economic damage to crops and the
environment, which may result in the
increased use of pesticides and loss of
export markets. Native flora and
fauna, including endangered species,
as well as the environment, may also
be harmed. Permits issued by USDA
enable the purposeful importation, interstate movement, and environmen-
REPORT
tal release of certain species for educational, research, and commercial
purposes.
The Plant Protection and Quarantine
(PPQ) Scientific Services (Permit Unit)
has responsibility for assessing risks
and benefits when evaluating permit
applications, and is charged to consider the interests of U.S. agriculture,
the environment, and the consumer
in their decisions to issue permits or
if making a determination that no
permit is required. They also have the
responsibility to coordinate with the
state departments of agriculture in regard to these efforts.
Any person, including individuals,
and those employed by companies,
academic institutions, and governmental agencies, desiring to import a
live plant pest or a regulated commodity that may become or carry a
live plant pest into the United States
must first obtain a permit. Applicants
may include hobbyists and researchers. Regulated commodities include plants, plant products, soil,
fruits, and vegetables. Requests for
such permits are sent by the applicant to the Permit Unit of PPQ. An
analysis of the request is made to determine the safeguards necessary to
allow for the requested use of the material.
The PPQ officer at the port of entry
reviews the shipment for compliance
with permit conditions and inspects
the material as appropriate. When the
shipment is in compliance with
permit conditions and free from
Safeguarding American Plant Resources
121
quarantine (actionable) pests, the
officer takes those steps necessary to
expedite the release of the
shipment. If a permit violation or pest
is found, the material may be seized,
treated, or refused entry and
appropriate penalties can be imposed,
including criminal or civil.
PPQ/state cooperation
The permit system also involves other
governmental entities. At the state
level, the degree of involvement varies,
but usually includes review of
requests for plant pest, soil,
biotechnology, departmental, and
post-entry quarantine permits. The
state regulatory officials make
recommendations to PPQ regarding
approval, modification, or denial of
the request and specify conditions to
safeguard against pest risk. The
States may also participate as
cooperators by inspecting facilities,
inspecting post-entry plant material,
monitoring permit compliance,
conducting destination inspections of
shipments, and taking enforcement
action when necessary.
Permit Authority
Permits are issued in accordance with Title 7, Code of Federal Regulations, for
the following commodities and live organisms:
319.8
Foreign Cotton and Covers
Cottonseed cake and cottonseed meal
Processed lint, liners, and waste
Hull fiber and gin trash
Sugarcane-bagasse and related sugarcane
products
Corn
Nursery stock, Plants, Roots, Bulbs, Seed,
and Other Plant Products
Logs & lumber and other Unmanufactured
Wood Articles
Indian Corn or Maize, Broomcorn and
Related Plants
Rice
Fruits and Vegetables
Khapra Beetle
Brassware and Wooden Screens from India
Goatskins, lambskins, sheepskins, (unless
tanned)
Used jute or burlap
Exotic Bee Diseases
Live bees (other than Apis)
Dead bees
Beeswax
Used bee boards, hives, nests, or nesting
material
Honey for bee feed
Honeybees and Honeybee Semen
Movement of Plant Pests
Soil
319.15
319.24
319.37
319.40
319.41
319.55
319.56
319.75
319.76
322.1
330.200
330.300
122
REPORT
Safeguarding American Plant Resources
Nursery stock, plants, roots, bulbs,
seed, and other plant products regulated by Section 319.37 may be separated into three categories:
admissible, restricted, and prohibited.
Admissible material is usually enterable with a permit and may be required to meet specified conditions.
Restricted material is allowed entry
under a post-entry quarantine permit,
to be grown at approved sites under
restrictions while being inspected during the quarantine period. Prohibited
material is allowed entry only under
strict safeguarding conditions, for scientific and research purposes.
In addition to the permits listed
below, permits are issued by port of
entry officers to allow materials to
transit for export and by domestic
quarantine officers for limited use or
limited destination of materials.
Permits are also issued by the Permit
Unit for genetically engineered organisms (Biotechnology Permits, Form
2000).
During the 1998 Fiscal Year October
1, 1997 - September 30, 1998, 7,452
Plant Protection and Quarantine
Permits were issued. The number of
permits by type or category is as follows:
Number
Permit Type
Category
3214
Plant Pests
Form 526
Approx. 1038
Approx. 500
Nursery stock, Bulbs, and Seeds Post-entry Quarantine
Q37
Q37-7
95
Canadian Permits
Q37
890
Fruits and Vegetables
Q56
60
Mexican Avocados
Q56
443
Logs and Lumber
Q40
390
Soil (330.300)
Form 525A
254
Department Permits for Experimental/Research Purposes
Form 588
124
Corn
Q41 & Q24
20
Brassware
Q75
18
Cotton
Q8
12
Rice
Q55
REPORT
Safeguarding American Plant Resources
123
5.2 Findings
h. Penalties for permit violations are
not sufficiently high to encourage
compliance and are not uniformly applied across and among permits.
Permit System:
a. The permit system provides a legal
mechanism to import, maintain, use,
and move admissible, restricted, or
prohibited materials. It provides for
the documentation of shipments as
authorized while controlling pest risk
through conditions, which establish
safeguarding methods. The system
has a protective role in preventing adverse events from occurring.
b. The permit system is a support
system which is an integral part of
the safeguarding system.
c. The permit system reduces decision
pressures at ports of entry and enables expedited movement/entry of
shipments
d. The permit system was developed
many years ago and may not accurately reflect the current global situation, pest risks, and needs of the
country.
e. The permit system, because it is
cumbersome, has resulted in the
avoidance of the system, which has
resulted in an increased likelihood of
smuggling.
f. There are permits not issued in a
timely manner, as perceived by applicants for permits among stakeholders
interviewed.
g. There has been a recent change in
the submission of plant pest permit
applications (Form 526) which appears to be more cumbersome and
time-consuming than the former system. The change is to submit the applications directly to USDA for review
and forwarding to the states for response back to USDA, rather than
submitting them first to the states for
comments and forwarding to USDA.
124
REPORT
i. Records are not maintained of permit applications that are denied or
withdrawn, or are revoked because of
a violation, making follow-up difficult.
There are difficulties in revoking permits when certain conditions are violated.
j. There are no fees charged for the
processing of permits. Processing permits without charge encourages compliance with the system.
k. The inspector or other agricultural
official often accepts the identification
of the materials in the shipments as
agreeing with the materials in the permit, without verification of their identity.
l. Departmental permits are successfully used for the introduction of
germplasm, which would otherwise be
prohibited and are considered essential in meeting the needs of industry
and researchers.
Rationale for Permits and Relation
to Plant Pest Risk:
a. Lapses in the permit system do not
account for the majority of new invasive pest and disease introductions.
There have been very few documented
failures of the permit system in which
a new invasive pest outbreak can be
traced to a properly permitted entry,
and those involved Òhitch-hikingÓ
pests.
b. The permit system resources
should be most heavily invested
where the greatest pest risk occurs.
The level of oversight should be commensurate with the level of risk.
c. Plant pest permits are not required
to import invasive plant species, other
Safeguarding American Plant Resources
than those listed under the Federal
Noxious Weed Act of 1974. This Act
provides authority for PPQ to regulate
noxious weeds and requires PPQ to
adopt regulations listing those weeds.
Unless a weed is listed in the regulation, no noxious weed permit is required. As a result, some unlisted
invasive weed species are allowed
entry into the country without permit/restrictions.
d. Permits issued under Quarantine
56 (fruits & vegetables) are redundant, because port inspectors process
importations of all fruits and vegetables according to the inspection manual procedures, rather than relying on
any permit specifications.
e. The requirement for a PPQ permit
for interstate movement of many plant
pests between confined facilities (laboratories) is viewed as unnecessarily
cumbersome and time consuming,
and risks should be manageable by
means other than a PPQ permit.
f. The regulatory basis for issuance of
permits for various materials is inconsistent. Quarantine 56 prohibits fruits
and vegetables unless approved for
entry. Quarantine 37 allows the importation of plants unless specifically
restricted or prohibited. This may be
indicative of a difference in the pest
risk analysis/decision-making process
conducted for materials imported
under these two quarantines, but is
confusing and illogical.
g. For the most part, the biotechnology permit system is working and the
level of permitting is adjusted to be
commensurate with new data relative
to pest risk. However, there are inconsistencies between PPQ requirements
for the permitted material at its destination/containment facilities and the
recommendations for similar material
by the National Institute of Health
Guidelines for Research with
Recombinant DNA Containing
Organisms.
REPORT
h. Containment conditions are inconsistent with the level of risk and are
not uniformly interpreted.
i. There are apparently no specific
permit restrictions for the importation
of seed to enable protection of
American agriculture from the importation of seed-borne pathogens and
other invasive exotic pests. This appears to be a pathway for the introduction of invasive pest organisms
which is not currently being addressed.
Oversight and Follow-up:
a. There is inconsistency in the level
of monitoring of permitted shipments
by various ports of entry. Too often,
materials entering under permit are
not adequately inspected. The imported materials may not always be
those authorized by the permit, may
be contaminated, or may be commingled with contraband material.
b. There is a low level of monitoring of
permitted activities with infrequent
inspection of permit recipient facilities, including laboratories, to determine compliance with the permit
conditions.
c. Permits are required to import
some commodities from Canada; however, since Canadian border inspection stations are not operated on a
24-hour basis, permit enforcement is
inadequate.
d. Coordination of the post-entry permit system between the states and
USDA is essential because the states
have the responsibility for post-entry
quarantine plant material oversight
and must have adequate monitoring
capabilities.
e. Information Collection, Use, and
Communications:
Safeguarding American Plant Resources
125
f. Good communication is often lacking among Permit Unit staff members,
resulting in poor follow through in
processing/expediting permit applications, causing delays in permit issuance.
g. Few, if any, electronic databases
have been established to enable good
communication between headquarters, ports, states, and all other cooperating agencies. This leads to poor
communication, inconsistent enforcement, and inadequate monitoring of
regulatory compliance.
¥ State Plant Health Directors and
State Agriculture Department personnel have limited access to the status
of permits and permit applications.
¥ Limited access to databases hinders the ability of Federal and state
regulatory officials to set priorities for
inspections of permitted shipments
based on the level of potential risk
and to target suspect permit violators.
¥ No searchable/accessible database exists for quick access to current
manual/regulations and permit information for non-propagative plant material (admissible fruits and
vegetables, Q56).
¥ No searchable/accessible database exists for quarantine (non-admissible) propagative material
information (Q37), including permit
requirements.
¥ It has been documented that
some importers place prohibited (nonpermitted) materials in positions
within the load that cannot be examined.
to the point of destination (where the
commodity is unloaded), so they can
be examined by State Plant Health
Directors or by State Agriculture
Department personnel.
h. Violators, whose permits have been
terminated, often use other business
identities to obtain new permits.
i. There is a lack of complete identification of post-entry quarantine plant
material (ex. species, variety, cultivar)
during the post-entry quarantine
process.
j. Animal and Plant Health Inspection
Services, International Services, may
not always notify PPQ about pest outbreaks or pest problems in foreign
countries. Without this notification,
permit issuance may continue even
though the pest risk for the permitted
article has changed.
k. Interaction and communication between the Permit Unit and the field
staff is often inadequate. Information
regarding changes in permitting, including denied or revoked permits,
should be provided to the ports in an
expeditious manner. Specific information regarding problems with permits
and/or permit recipients should be
documented at the ports and the information relayed to the Permit Unit.
l. Permit conditions often lack clarity
which may result in non-compliance
by the permit recipient.
Communications between the permit
recipient/applicant and the Permit
Unit are often inadequate. Applicants
are not always informed that some of
the materials they have requested are
not being approved under the permit
issued.
¥ There is a lack of tracking of
permitted shipments to the destination points which would enable monitoring of shipments. It is extremely
important that containers be tracked
126
REPORT
Safeguarding American Plant Resources
Standardization of Operating
Procedures:
a. Documentation is lacking regarding
the Permit UnitÕs policies, protocols,
and operating standards, leading to
an inconsistency in how permits are
to be issued. These policies and protocols are not sufficiently detailed to
guide the different types of permit decisions and processes. The Permit
Unit does not have a clearly defined
mission statement with goals and objectives.
b. Post-entry quarantine permits require that the materials be visually inspected for a set time period, usually
two years. New technologies that
could detect certain pathogens at an
earlier stage and decrease the inspection time are not being utilized in
monitoring and inspection procedures, because these technologies
have not been approved as alternatives to inspection.
c. No performance standards have
been established for permit recipients,
relative to the level of performance desired for the safeguarding of specific
materials and how these standards
can be met.
Organization:
a. Plant Protection and Quarantine
lacks clear leadership, direction, and
supervision due, in part, to downsizing, reorganizations and staff fragmentation.
b. Fragmentation of the organizational
structure of the Permit Unit appears
to lead to inconsistencies and tendencies toward individual actions. There
appears to be little leadership support
resulting in the individuals in the
Permit Unit having to act independently.
not result in effective and efficient use
of staff. An example is the disproportionate use of staff in the issuance of
Quarantine 56 (Fruits and vegetables)
and plant pest permits.
d. PPQ permit and permit enforcement staff at Riverdale and the ports
appear to be seriously affected by excessively frequent reorganizations.
Frequent staff rotation policies do not
recognize the levels of expertise necessary to accomplish permit related activities.
e. There is a lack of information technology support staff for the Permit
Unit at Riverdale and in the regions.
f. Issuance time frame guidelines, to
be conscientiously followed by staff,
have not been instituted for many
types of permits. These guidelines
should distinguish between permits
for interstate movement and for importation. Predictability is important
to industry, researchers, and other
applicants.
5.3 Recommendations
Short term
■ P-1 Combine the present two organizational structures within Scientific
Services Unit under one Assistant
Director. Such restructuring will eliminate personnel fragmentation and
provide for efficient use of staff.
(Finding 1.k, 4.a, 6.a, 6.c., 6.d)
■ P-2. Develop standard practice
guidelines for the various types of permitted materials. These guidelines
should provide for greater permit recipient involvement, responsibility,
and awareness. They should allow a
risk appropriate level of flexibility in
the manner of performance standards. (Finding 5.c)
c. The existing permit system does
REPORT
Safeguarding American Plant Resources
127
■ P-3 Initiate expanded use of compliance agreements, memoranda of understanding, or other legally binding
documents with industry, research
and educational institutions to reduce
the number of permits issued/needed.
(Finding 6.c)
■ P-4 Institute a system to review
permitted activities to ensure compliance with permit conditions, including verification of identification of
imported material and final disposition of the permitted materials.
(Finding 1.i, 3.a, 3.b)
■ P-5 Civil penalties for permit violation need to be uniformly and fairly
assessed in respect to the nature of
the violation. The cost of civil penalties should be increased to encourage
compliance. Penalties should be vigorously pursued when appropriate for
intentional permit violations. (Finding
1.h, 3.c, 4.c)
■ P-6 Bring into concordance with
similar condition requirements and
performance standards, those organisms covered by both PPQ biotechnology regulations and NIH Guidelines
for Research and Recombinant DNA
Containing Organisms. (Finding 2.g)
■ P-7 Modify containment requirements for organisms, being imported
under the authorization of plant pest
permits, to be made consistent with
the level of pest risk. (Finding 2.h)
■ P-8 Develop procedures that will
include complete identification information of the plant materials in each
shipment in/with the post-entry quarantine paper work for arrival notification, which is used to track the
materials during the quarantine period. (Finding 4.d)
■ P-9 Initiate a conscientious effort to
stabilize headquarters and port staff
rotation as necessary to maximize
128
REPORT
permit system effectiveness and to
make staff policies consistent.
(Finding 6.d)
■ P-10 Develop an external feedback
/communications mechanism for
stakeholders to advise the Permit Unit
of concerns, provide scientific input,
or suggestions for improvements.
(Finding 4.g, 5.a)
Medium term
■ P-11 Develop a strategic plan that
will assure uniformity within the
Permit Unit providing for its mission,
goals, objectives, policy and operational standards. The plan should
focus permit system emphasis where
risks to agriculture and the environment are the greatest. (Finding 2.b,
4.a, 5.a, 6.a, 6.b, 6.f)
■ P-12 Develop with a sense of urgency an electronic database for permit status, tracking, and permit/entry
requirements for both propagative and
non-propagative materials. If necessary to expedite the development of
these databases, contracting with an
outside entity is advised. (Finding 1.g,
1.i, 4.a, 4.b)
■ P-13 Incorporate new technologies
into the permit systemÕs inspection
and monitoring programs to improve
effectiveness, reduce quarantine time
periods, reduce costs, and provide for
better utilization of personnel. For example, under post-entry quarantine
permit procedures, plants are inspected for specific diseases usually
for a two-year period. Testing methods, such as ELISA, could be employed to test the plant materials,
which make it possible to eliminate or
shorten the post-entry inspections
and quarantine period. Using sound
newer technologies and monitoring
procedures should reduce costs and
utilize personnel in a more efficient
manner. (Finding 2.b, 3.a, 4.b, 5.b)
■ P-14 Develop an education and
Safeguarding American Plant Resources
training program for permit system
personnel, cooperators, industry, researchers, educators, students and
the general public. Documents about
importation requirements, distributed
both with permits and as general informational, should be made more
user friendly and should be specific to
the types of material to be imported.
(Finding 4.a)
■ P-15 Conduct an annual or biannual review of the permit system utilizing a committee of Federal, state,
university and industry representatives. With the changing world and
national pest risk conditions, the development of rapid communication capabilities, and the development of new
technologies, the permit system
should be flexible and dynamic.
(Finding 4.e, 5.b)
■ P-16 Amend regulations that will
promote the use of Departmental
Permits as to allow appropriate facilities to import plants in response to
industry needs while maintaining necessary safeguards. Departmental
Permits as they are currently being issued are not always legally defensible
under existing regulations. (Finding
1.l)
■ P-17 Provide continuing education
and training to maintain or improve
PPQ permit system personnel competency. (Finding 4.g, 6.c)
■ P-18 Time frames for issuance of
permits must be reduced.
Organizational standards should include specific time frames for review
and issuance of each type of permit.
(Finding 1.d, 1.e, 1.f. 4.a, 4.b)
■ P-19 Develop an electronic or
Òpaper lessÓ system that should be incorporated into an electronic database. Such system would expedite the
issuance of permits and improve efficiency of the Permit Unit. (Finding
1.d, 1.e, 1.f. 4.a, 4.b)
REPORT
■ P-20 Develop and maintain a documentation system as needed to support the denial or revocation of
permits. The permit system database
should include information regarding
permit denials or revocations and this
information should be made available
for use by Federal and state inspectors. (Finding 4.b, 4.f, 5.a)
■ P-21 Apply the permit system to
mitigate all invasive pest risks associated with the importation of seeds.
(Finding 2.i)
Long term
■ P-22 Discontinue the requirements
for Federal permits for interstate
movement of plant pests, except those
under Federal quarantine because
they are not known or occur or are of
very limited distribution in the United
States. This will have to be reconciled
with the fact that some states have
mandatory plant pest permit requirements. (Finding 2.e, 6.c)
■ P-23 Discontinue the issuance of
Quarantine 56 permits for admissible
materials which do not have exceptionally unusual specific requirements. (Finding 2.d)
■ P-24 Develop a list of invasive plant
species which, in addition to those
listed in the Noxious Weed Act, would
be restricted through permit requirements. This list should be developed
in cooperation with and using expertise of the states, weed science and
environmental organizations, universities and industry. (1.d, 2.c)
5.4 Unaddressed Issues
a. The plant pest risk and need for
permits to regulate the pet trade/hobbyists should be evaluated. This may
necessitate coordination with U.S.
Fish and Wildlife Services and other
agencies, which may have jurisdiction.
Safeguarding American Plant Resources
129
b. The permits issued at ports of
entry (ex. transit and export, import
and re-export) should be evaluated
and with consideration given to the
development of standard operating
procedures for use at ports and a
database for tracking the permitted
materials.
c. The issuance of permits under the
authority of Federal domestic quarantines by Federal quarantine officers
should be reviewed (ex. limited use or
limited destination) for consistency
and effectiveness.
130
REPORT
Safeguarding American Plant Resources
C O N C L U S I O N
Implementation and
Accountability
he Review Panel has attempted
to describe the status of the system for safeguarding of American
plant resources. The foundation of
this system is solidly in place within
the APHIS-PPQ organization. The recommendations of the Review Panel
are numerous and offer specific actions for facilitating evolution of the
Agency to meet the challenges presented by the ever-changing global
marketplace. This report is just the
beginning of a long and arduous
process. Designing approaches to implement the roughly 300 recommendations made by the Review Panel
must be a collaborative effort based
upon endorsement by APHIS-PPQ personnel and communication with external stakeholders. Organizational
change and growth will be realized
only with full participation by all interested parties. Everyone must be
willing to set aside narrow, short-term
agendas, and nurture growth of the
Agency through successful implementation.
T
■ The Panel asks APHIS management to lead and to trust.
Leadership must commit focus and
resources to the process, appoint a
broad-based Agency guiding coalition,
empower that coalition, and support it
fully. In return, management will
benefit from a highly motivated work
force interested in mission-oriented
solutions rather than protecting the
status quo.
■ The Panel asks APHIS field staff
to accept some personal sacrifice
for the long-term survival and good
of the Agency and the safeguarding
REPORT
mission. In return, field staff should
expect greater job satisfaction from
working for an organization that values their contributions, and listens to
their ideas. They will benefit from an
organization that provides training,
professional development, and the
tools and technology to do their jobs
well. They will enjoy greater local
control over program and budget
management.
■ The Panel asks APHIS program
staff to be open to new, more collaborative approaches to risk analysis and other functions that
support the safeguarding mission.
In return, they will benefit from
greater confidence in Agency decisions, less political interference in
those decisions, and the professional
growth that results from regular interaction with leading scientists and
other outside experts in relevant
fields.
■ The Panel seeks for state cooperators, principally the Plant
Boards, the opportunity for greater
participation in APHIS decision
making. In exchange for a greater
voice, state cooperators must commit
to building, maintaining, and implementing consensus among their
peers.
■ The Panel seeks for other
external stakeholdersÑnotably
industry and other special interest
groupsÑthe opportunity to
participate, that is, to receive
information and offer input on
APHIS safeguarding decisions early
Safeguarding American Plant Resources
131
and meaningfully. In exchange,
external stakeholders must commit to
becoming informed beyond their
focused interests. They must commit
to work within the process to support
APHIS in carrying out its primary
missionÑplant resource
safeguardingÑin a complementary
fashion with its other critical
supporting roles to facilitate trade and
expedite the movement of passengers
and products.
■ The Panel envisions for all of society an abundant and safe food,
plant and plant product supply system, a more productive economy
and a healthier environment.
The groundwork for the implementation process will be laid by an
Implementation Panel of APHIS-PPQ
personnel and external stakeholders.
To ensure continuity, the APHIS-PPQ
Steering Committee and the Review
Panel will form the core of the Panel.
In addition, the Review Panel requests
that the APHIS Steering Committee
form the nucleus of the APHIS-PPQ
guiding coalition. The Implementation Panel will be responsible
for clarifying recommendations in
order to help APHIS set priorities, formulate objectives and timelines for
implementing specific recommendations, and document progress towards
these goals. Progress will be the
shared responsibility of the Implementation Panel and APHIS-PPQ
management. A guiding coalition will
be assembled to work closely with the
APHIS-PPQ management and the
Implementation Panel to ensure that
progress is sustained. The APHISPPQ Executive Team must develop a
budget that provides the guiding
coalition with adequate resources to
perform this function.
implementation process. These
groups will assist in legislative initiatives and other activities requiring focused Congressional involvement.
The Review Panel requests that
APHIS-PPQ present an implementation plan for discussion at the
National Plant Board and NASDA
meetings in August and September,
respectively. The Implementation
Panel looks forward to assisting as
needed toward the development of
this implementation plan. A legacy
document highlighting findings, conclusions, and progress towards
achieving the implementation plan is
envisioned at the end of the two-year
implementation phase.
This Review would not have been possible without the determination and
perseverance of the Review Team and
the APHIS-PPQ Steering Committee.
Together with the Implementation
Panel, they have vowed to make a
good Agency even better.
As primary stakeholders, the National
Plant Board and National Association
of State Departments of Agriculture
(NASDA) will play a critical role in the
132
REPORT
Safeguarding American Plant Resources
Comments
to the
U.S. Department of Agriculture
Animal and Plant Health Inspection Service
on
Proposal for
Importation of Moth Orchids in Approved Growing Media
from Taiwan
[Docket No. 98-035-3]
Submitted by the
SOCIETY OF AMERICAN FLORISTS
FLORIDA NURSERYMEN & GROWERS ASSOCIATION
and the
AMERICAN NURSERY & LANDSCAPE ASSOCIATION
June 9, 2003
The Society of American Florists (SAF), the Florida Nurserymen & Growers Association
(FNGA), and the American Nursery and Landscape Association (ANLA) thank the U.S.
Department of Agriculture's (USDA) Animal and Plant Health Inspection Service (APHIS) for this
opportunity to comment on a proposal to amend 7 CFR Part 319, the “Quarantine 37”
regulations, to allow the importation of Phalaenopsis spp. orchids established in growing media
into the United States, from Taiwan, as published in the May 9, 2003, issue of the Federal
Register.
The Society of American Florists (SAF) is the national trade association representing the entire
floriculture industry, a nearly $19 billion component of the U.S. economy. Our membership
includes nearly 15,000 small businesses, including growers, wholesalers, retailers, importers
and related organizations, located in communities nationwide and abroad. Our industry
produces and sells cut flowers and foliage, foliage plants, potted flowering plants, bedding
plants, and landscape plants.
The Florida Nurserymen and Growers Association represents Florida’s environmental
horticulture industry. The Association represents the interests of nearly 2,000 foliage, woody
and floriculture producers, landscape contractors and interiorscapers, retailers and allied
suppliers. Representation, professional education and marketing encompass the services
provided to its members and the industry. USDA statistics show that Florida is one of the top
three states producing potted orchids in the U.S., with a 1997 value of sales at wholesale of
nearly $18 million dollars.
The American Nursery & Landscape Association (ANLA) is the national trade association for the
nursery and landscape industry. ANLA represents 2,500 production nurseries, landscape firms,
retail garden centers and horticultural distribution centers, and the 16,000 additional family farm
and small business members of the state and regional nursery and landscape associations.
The Association's grower members are estimated to produce about 75% of the nursery crops
moving in domestic commerce in the U.S. that are destined for landscape use.
I. BACKGROUND ON THE INDUSTRY
According to the USDA’s National Agricultural Statistics Service (NASS), the nursery and
greenhouse industry remains the fastest growing agricultural sector in cash receipts. The 1997
Census of Agriculture shows that nursery, greenhouse and floriculture crop sales totaled $10.9
billion in 1997, up from $7.6 billion in 1992. This represents a 43 percent increase in sales over
the previous 1992 Census. Together these crops make up 11 percent of total U.S. farmgate
receipts, up from 10 percent. Some 33,935 farms produced nursery plants as their principal
crop; floriculture farms numbered 21,824.
In crop value, nursery and greenhouse crops have surpassed wheat, cotton, and tobacco and
are now the third largest plant crop – behind only corn and soybeans. Nursery and greenhouse
crop production now ranks among the top five agricultural commodities in 24 states, and among
the top 10 in 40 states. Growers produce thousands of varieties of cultivated nursery, bedding,
foliage and potted flowering plants in a wide array of different forms and sizes on 1,305,052
acres of open ground and 1,799 million square feet under the protective cover of permanent or
temporary greenhouses.
II.
CONCERNS REGARDING SPECIFIC Q-37 CHANGES PENDING CHANGES TO THE
Q-37 REGULATION OVERALL
We would like to thank APHIS for its continued efforts to address the concerns of our industry
as it considers proposed revisions to the Quarantine 37 regulation. Concerns regarding the
risks and benefits of international trade are just as strong in our segment of U.S. agriculture as
in any of the other major segments. Economically, it is advantageous to us to participate in the
international marketplace. However, such participation must be undertaken in a way which
protects U.S. agriculture and the environment by, in APHIS’ own words, “reducing pest risk to
an acceptable level.” Our industry has demonstrated that we understand and agree with the
necessity of U.S. compliance with international treaty phytosanitary obligations, as well as with
protecting U.S. agriculture and the environment from imported pests and pathogens. However,
such compliance must apply to all segments of all industries in all countries.
As outlined in these comments, however, we have grave concerns with APHIS’ continued
proposals to continue allowing specific exceptions to the Quarantine 37 regulations in light of
concerns that have been raised by SAF and other segments of the U.S. agriculture industry,
environmental community, and others, about the procedures and methodology used to support
such proposals. SAF and FNGA oppose, and will continue vigorously to oppose, any change in
the Q-37 regulations that will unacceptably increase the risk of disease or pest infestation to the
agricultural crops or environment of the U.S. It has been and continues to be our intent to
protect the floriculture and environmental horticulture industry as well as all of crop agriculture
from unreasonable biological risks associated with the movement of plants in growing media
into the United States.
It is our understanding that the USDA is planning a major review of the Quarantine 37
regulation. In the light of that upcoming review, it seems unwise to proceed with approving the
Phalaenopsis proposal at this time. The problems recently experienced with import of serious
pests and diseases on propagative material argue strongly for improved measures for
evaluating and mitigating the risks associated with such imports. We support the APHIS review
of the Quarantine 37 regulation, and would ask, respectfully, that approval of the Phalaenopsis
proposal be delayed pending the completion of that review.
We further question the procedure that APHIS has chosen to follow in this instance, of
publishing an Environmental Assessment, while not addressing the very detailed comments
received on the original Pest Risk Assessment. The environmental impacts, alone, could be
severe in tropical states like Hawaii and Florida. However, the impacts on the domestic
industry, and on other segments of U.S. agriculture, have not, in our opinion, been adequately
addressed. We incorporate, by reference, our comments provided on the original proposal,
dated December 2, 1998, some of which are reiterated below.
We urge APHIS to deny the current proposal to allow importation of Phalaenopsis orchids in
growing media. In addition, we urge APHIS to go back and re-examine its underlying pest risk
assessment and analysis procedures and policies to ensure that they are consistent with current
levels of scientific knowledge and on-the-ground exclusion capabilities.
III.
THE ORIGINAL PRA PROVIDES INSUFFICIENT INFORMATION ON WHICH TO
JUSTIFY A DECISION.
Orchids are not a major agricultural commodity and, as such, have not had the extensive
research that such major products typically endure. Since research has not adequately
Page 2
addressed pest problems associated with orchids, few literature citations exist in the databases
used by APHIS’ Biological Assessment and Taxonomic Support (BATS). In fact, there is a
considerable lack of data for many of the pest species. Thus, the PRA cannot address them,
especially since the authors use literature citation to develop the pest list.
Even worse, literature searches are further confused by insects with more than one common
name. For example, the Spiraling whitefly has also been referred to as the “Keys whitefly” in
southern Florida, as the “Spiral whitefly” in Taiwan, and is spelled by some authors as
“spiralling.” With this amount of confusion over a pest already scarce on research, it is not
surprising that the preparers of the PRA list missed it. However, it should have been included.
The unreliability of literature searches is further increased by the fact that they are made by title
words, so it requires researchers to know the many common names of the pest, if the scientific
name was not included in the title.
Finally, it has been indicated by several orchid growers in the U.S. that they are receiving bareroot orchid plants from Taiwan which appear to have resistance to bacteria. Those growers
believe that Taiwan has been using chemicals in its production systems which may be creating
"super-bacteria" which are then uncontrollable by U.S. recipients of the plant material. We
would suggest that this inference should be further investigated prior to any final decision.
The original PRA stated:
“recognizing [the uncertainty of biological information about the plant pests identified]
this pest risk assessment focused on those organisms for which biological information is
available. We hope that detailed and sound pest risk assessments will lay the
groundwork for developing appropriate mitigation measures during the management
phase of risk analysis. These same mitigation measures would also mitigate any risk
posed by these unknown organisms.”
It is extremely difficult to understand why, in light of the admitted shortcomings and gaps of the
information contained in the PRA, and the fact that where risks were identified, they were rated
“high,” APHIS continued with this proposal. It is, surely, a leap of faith, and most likely an
unwise leap, to assume that in the face of known “high” risk ratings, mitigation will reduce the
risk to acceptable levels. Yet that is what APHIS has done. We strongly disagree.
Even though APHIS may have complied with the letter of its own regulations, we would argue
that it has failed to comply with their intent. The PRA, as incomplete as it is, does not even
appear to have been used by the decision makers. In fact, the final paragraph of the PRA
completely abdicates its regulatory responsibility, pushing all responsibility for pest exclusion to
the “mitigation” side of the scale.
We in fact, however, do not believe that APHIS has followed its own PRA procedures. The
whole purpose of a pest risk assessment is to provide, in APHIS’ own words, “a link between
scientific data and decision makers.” Decision makers must have accurate and adequate
scientific data upon which to base their decisions. In this case, there is barely any pretense of
presentation of scientific data. We believe that, were the data presented and properly
evaluated, the decision makers’ only logical course of action would be to continue the present
policy on orchid imports.
Page 3
IV.
INSUFFICIENT MITIGATION OF THE RISK IS PROPOSED
The proposed mitigation requirements may not be sufficient to control adequately the
pest risk, even if they are complied with. However, APHIS does not have sufficient
resources to ensure compliance with these mitigation requirements.
We believe that APHIS places, in making this proposal, far too heavy reliance upon inspection
and upon protocols which are not clearly spelled out, and for which there is little guarantee of
ensuring compliance.
Further, some of the requirements are inadequate, and it would be impossible for APHIS to
require stricter protocols, once this proposal had been approved. Our original comments
pointed out that screens of .6 mm are inadequate to keep out certain important pests.
Equipping entryways with automatic closing doors is of little protection, unless these are double
door systems, and the production areas are under positive pressure. Requiring an inspection of
the greenhouse to be “found free from evidence of plant pests and diseases ... no more than 30
days prior to the date of export to the United States” is inadequate. In this period of time, any
number of pests could establish and develop, and therefore be imported to the U.S.
Aside from the obvious problems of detection, there is a major concern associated with pest
identification by quarantine officers. Robert Kahn, in his books on plant protection and
quarantine, states that “One of the most important problems [associated with pest quarantine] is
our inadequate knowledge of identification characters for even the known pests, and the
generally inadequate development of classification systems that provide the level of predictive
capability needed.”
Insect identification is additionally complicated by the fact that insects have four or more
developmental stages, some of which are equally good as or better than the adult stage at
“hitchhiking” because of their typically smaller size and tendency to hide in the plant, aiding their
ability to evade detection. [Kahn, 1989b] What makes these immatures a problem is that, for
most groups, only <10% of immature stages have been described for known species, so even if
they happened to be seen, it is likely that quarantine officers would be unable to identify them,
or could easily misidentify them.
In summary, one of the fundamental flaws in the issue of plant imports is that risk mitigation is
often dependent on visual inspection as the basis for pest and pathogen detection. Obviously,
many soil-borne insects, nematodes, and most pest pathogens are not visually detectable.
V.
CONCLUSION
Trade in live plants in media presents special, and more difficult, problems than trade in
other agricultural commodities. APHIS’ procedures must recognize the increased risk
presented by trade in live plants established in growing media. This risk is greatly
increased in trade from subtropical regions.
The U.S. cannot eliminate the Q-37 regulations because their purpose is a valid, biological one:
to protect against the infestation of alien pests and diseases. Exceptions to the Q-37
regulations must be clearly shown to be justified in a scientific showing that an unacceptable
risk of such infestation will not result. There is no such scientific showing in the PRA or in the
orchid proposal. Instead, there is some suggestion in the underlying paperwork of a quid pro
Page 4
quo arrangement that is simply a trade-based negotiation between two countries. In no way
should that kind of arrangement be allowed to substitute for good science.
This proposal clearly points to a need for APHIS’ risk assessment and mitigation procedures to
better reflect the increased risk presented by trade in live plants in media. The risk cannot be as
easily mitigated as for many other commodities. The risk for pests and diseases traveling
undetected on a growing plant or in media is very high. “Insects harbored in soil” is listed as
frequently encountered during inspection. All too often, U.S. growers have to bear the
economic brunt of those failures.
We strongly commend APHIS for continuing to design adequate mitigation procedures, such as
certification programs. We further commend APHIS for its review of the entire Quarantine 37
regulation and urge, as noted above, that that review be completed prior to approving any
further relaxation of the existing regulation.
In closing, we urge APHIS to consider that the best way of controlling pests is for everyone
involved -- both the industry and the government regulatory agencies -- to discuss problems and
to present the evidence clearly and openly upon which decisions must be based. Arbitrary or
non-transparent actions by agencies will have harmful effects on the wider patterns of trade,
and will undermine agencies’ own efforts.
We strongly recommend that APHIS not allow importation of orchids established in growing
media into the United States other than as they are presently allowed. The risk posed is, at
present, inadequately assessed. Neither are the mitigation measures suggested to bring that
risk to an “acceptable level” adequate.
Finally, we urge that APHIS continue its excellent work with industry and members of the
academic community to review and strengthen APHIS’ risk assessment and mitigation
methodology, as well as its review of the Quarantine 37 regulation, so that Q-37 can continue to
protect domestic U.S. agriculture and the U.S. environment from pests as further amendments
are considered.
We thank you for the opportunity to comment on this proposed ruling.
Page 5
Thrips palmi
Thrips palmi
Why is it important?
Thrips palmi is a notifiable pest
in the UK. It can cause damage
to a wide range of glasshouse
ornamental and vegetable crops,
particularly plants in the families
Cucurbitaceae and Solanaceae,
such as cucumber, aubergine and
sweet pepper. Adults and
nymphs feed by sucking the cell
contents from leaves, stems,
flowers and the surface of fruits,
thereby causing silvery scars and
leaf chlorosis. Plant growth can
be stunted and fruits can be
deformed and heavily scarred. A
severe infestation can kill the
entire plant.
Adults tend to be concealed
within crevices of host plants
photograph courtesy of Zenkoko Noson, Kyoiku Kyoiku Co. Ltd, Japan
http://www.defra.gov.uk/planth/pestnote/thrips.htm (1 of 3)6/16/2003 5:15:14 AM
This pest originates from southeast Asia and is now common
throughout the tropical areas of
Asia. It is also found in parts of
Africa, Australasia, Central and
South America, the Caribbean
and in Florida. Within Europe,
outbreaks of T. palmi have
occurred in the Netherlands and
have been eradicated. T. palmi
has the potential to introduce and
spread several non-indigenous
Thrips palmi
viruses from the same group as
Tomato spotted wilt virus
(Tospoviruses.) These viruses
could infect a wide range of
plants, particularly cucurbits.
T. palmi and the viruses it transmits are not established in the EU and therefore their potential
economic impact has not yet been fully assessed. If these viruses were introduced to the UK with
imported plant material established thrips species may be able to act as vectors. Alternatively, T.
palmi may act as another vector of Tomato spotted wilt virus which is already present in the UK.
What does it look like?
All thrips are very small and difficult to detect. Plants should therefore be checked regularly for signs
of damage caused by feeding. T. palmi adults can only be distinguished from those of other thrips
species, such as the Onion thrips (Thrips tabaci), Western flower thrips (Frankliniella occidentalis)
and the Yellow flower thrips (Thrips flavus), by laboratory examination. These thrips are all found
throughout the UK.
Adult T. palmi are about 1 mm long and
yellow with dark brown hairs on the body.
The eggs are laid within the plant tissue
and are not visible to the naked eye. The
nymphal (immature) stages are creamy
yellow to pale orange and resemble adults
without any wings. They are similar in
appearance to other indigenous thrips
species and visually cannot be identified
to species at this stage. The nymphs feed
on the aerial parts of the plant, then they
drop to the soil to pupate.
The pupae are a darker orange colour than
the nymphs. However, they are unlikely to
be seen as they are remain concealed in
the soil for several months. When the
adults emerge, they return to the aerial
parts of the plant to feed and lay eggs.
T. palmi nymphs
photograph courtesy of Zenkoko Noson, Kyoiku Kyoiku Co. Ltd, Japan
How is it introduced?
http://www.defra.gov.uk/planth/pestnote/thrips.htm (2 of 3)6/16/2003 5:15:14 AM
Thrips palmi
Routine import inspections for this pest have been carried out for a number of years. The first UK
interception of T. palmiin 1997 was on imported orchid flowers and findings on orchids have
increased since then leading to specific EC measures in respect of orchid flowers from Thailand. It
has the potential to be imported on a wide range of vegetables, ornamental cuttings, pot plants (such
as Ficus) and other cut flowers (such as chrysanthemums). Introduced T. palmi may also be carrying
plant viruses which can be transmitted to suitable hosts. These viruses can be retained by thrips
throughout their life. Alternatively, both virus and vector may be introduced, for example on young
plants of Cucurbitaceae. However, Tospoviruses are not thought to be seed borne.
What should I do?
●
●
●
●
●
●
Seek assurance from your plant supplier(s) that plants are free from this pest as part of any
commercial contract.
Ensure that any known hosts of T. palmi, such as orchids, are treated prior to import.
Keep any imported material for ‘growing on’ separate until it has been thoroughly inspected
and found to be free from T. palmi and any suspect virus symptoms.
Monitor your crop during the growing season and erect sticky traps. Blue traps are
recommended for thrips, in preference to yellow. Check traps regularly for the presence of
thrips.
Never combine ornamental and vegetable crops in the same cropping area. This minimises the
problems presented in control programs and the potential of virus spread.
If any life stages of the pest are detected, inform DEFRA immediately to ensure the prompt
implementation of an eradication programme.
This is a notifiable pest. If you see or suspect the presence of Thrips palmi on
your nursery, you must immediately inform your local DEFRA Plant Health and
Seeds Inspector or the PHSI HQ, York (Tel: 01904 455174, Fax: 01904 455197
Email:[email protected] ).
Department for Environment, Food and Rural Affairs CENTRAL SCIENCE
1998 PB 3594(b)
LABORATORY
Back to Pests and Diseases page
This page was last updated on 6 August 2001
http://www.defra.gov.uk/planth/pestnote/thrips.htm (3 of 3)6/16/2003 5:15:14 AM
INSV or TSW Virus and the vector Western Flower Thrips
Plant Disease Facts
Cooperative Extension - The Pennsylvania State University
Impatiens Necrotic Spot Virus, Tomato Spotted Wilt Virus and
the vector Western Flower Thrips
Gary W. Moorman, Professor of Plant Pathology
Two closely related viruses, Impatiens Necrotic Spot (INSV), and Tomato Spotted Wilt Virus (TSWV),
once called the I-strain and L-strain of tomato spotted wilt, have been widespread and devastating in the
greenhouse industry. Hundreds of thousands of dollars worth of crops have been destroyed by these
viruses. However, growers aggressively attacking the problem can avoid crop losses by controlling
thrips, carefully inspecting new plants brought into the greenhouse, and maintaining the health of plants
already in the greenhouse.
Below are the steps required to aggressively attack the viruses and western flower thrips in greenhouse
production.
IMPATIENS NECROTIC SPOT AND TOMATO SPOTTED WILT VIRUSES
These viruses cause a wide variety of syptoms including wilting, stem death, stunting, yellowing, poor
flowering, 'chicken pox-like' sunken spots on leaves, etches or ring spots on leaves, and many others. In
other words, symptoms will not tell you anything except that there is SOMETHING wrong with the
plant. That something could be virus or any one of 1000 other things. Virus symptoms depend upon
what time of year the plant is infected, its age when infected, its physiological state when infected,
growing conditions in the greenhouse, the strain of virus present, and other factors not fully understood
at this time. In fact, some plants found to be infected do not exhibit any unusual symptoms.
Positive diagnosis is made by submitting the plant to a plant disease clinic capable of either inoculating
special indicator plants or of running chemical tests to determine if the virus is in the sap. Separate tests
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INSV or TSW Virus and the vector Western Flower Thrips
are run to look for each strain of the virus. A plant may have either or both in its sap. The Pennsylvania
Department of Agriculture, Bureau of Plant Industry Clinic in Harrisburg (contact through your state
plant inspector) can test for the virus. If a sample is sent to the Plant Disease Clinic at Penn State, we
will forward it to a commercial company that specializes in running the test.
Management of INSV- and TSWV-caused diseases:
Inspect all incoming plants for symptoms. Those found with suspicious symptoms must be immediately
isolated until the presence or absence of the virus is confirmed.
Isolate incoming plants from all other plants in the greenhouse until certain they are free of the virus. If
the plants are free of the virus, maintain their isolation unless certain all other plants in the greenhouse
are free of the virus. In other words, don't put all your plants in one greenhouse.
Destroy infected plants. Infected plants cannot be cured. Do not vegetatively propagate infected plants.
The only way the virus is maintained and spread in a crop is through vegetative propagation if western
flower thrips are not present.
WESTERN FLOWER THRIPS
Detection of thrips activity:
Inspect all incoming plants for thrips. Especially check white and yellow flowers. Isolate incoming
plants from all other plants in the greenhouse until certain they are free of thrips. If the plants are free of
thrips, maintain their isolation unless certain all other plants in the greenhouse are free of thrips. Use a
hand lens. Tap the plant with a pencil while holding a sheet of white paper to catch any falling insects.
Since the thrips are very small and stay hidden most of the time, they are difficult to detect. Yellow or
blue sticky cards placed at crop height are excellent for monitoring thrips. Blue is effective for thrips
while yellow is a good all around color for trapping other insects including whiteflies and fungus gnats.
One to 3 cards per 1000 sq. ft. is recommended. Effectiveness depends on number used per sq. ft. and
placement rather than the size of the card. Place some near vents, doors, and other openings. If you are
uncertain of the identity of the insects you have trapped, contact your state inspector, the Department of
Agriculture, your County Extension Agent, or the Penn State Department of Entomology for assistance.
Change the cards regularly. For ease of handling, cover used cards in one layer of cellophane or similar
clear plastic wrap when they are removed. Record the number of thrips trapped each week to determine
if the population is increasing or decreasing.
The thrips-virus relationship and controlling the thrips:
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INSV or TSW Virus and the vector Western Flower Thrips
A single application of any material IS NOT ADEQUATE. Applications are made at 5-day intervals if
allowed as stated on the chemical label. Use one pesticide for one generation of thrips. That means,
apply one pesticide 2-3 times over a a 14-15 day time. Then switch to a different class of pesticide. DO
NOT USE TANK MIXES OF DIFFERENT CHEMICALS (See the list below.). Thrips lay their eggs
inside the plant tissue where they are protected until they hatch and emerge 3 to 4 days later. The first
enstar (larva) is clear. Feeding larvae acquire the virus but do not transmit it from plant to plant. The
larvae retain the virus until they mature into feeding adults. The second larva is yellow at first. Both the
first and second larval stage hide among the bud and flower parts of the plant. The second larva turns
white just before it molts and moves to the soil or leaf litter. Adults emerge from the soil 2 to 5 days
later and may be yellow or dark brown. They hold their wings flat over their backs. Adults can live 30 to
45 days and transmit the viruses to plants throughout their life. The viruses do not pass into new eggs.
Each new generation of larvae must feed on an infected plant to acquire the virus. The first chemical
application should kill winged adults while the second and third should kill newly emerged wingless
individuals. Thorough coverage is required. It is also suggested that methods of application be rotated.
Fogging and spraying should be employed.
If there are no INSV or TSW virus-infected plants in the greenhouse, no crops will be lost to this virus
even if western flower thrips are present.
Contact the Pennsylvania Department of Agriculture for a current list of insecticides registered for use
on the plants you wish to treat for thrips.
Maintain strict thrips control on all plants kept in the greenhouse. Eliminate all weeds in the greenhouse
and ones close to the building and all plants not being carefully tended from inside the greenhouse. Such
plants may harbor both the thrips and the viruses. Western flower thrips are known to survive outdoors
in Pennsylvania.
Partial list of plants found infected with tomato spotted wilt and/or impatiens necrotic spot virus:
African violet
Ageratum
Alstroemeria
Amaryllis
Anemone
Aphelandra
Aster
Aubrietta
Azalea
Begonia
Blue Daze
Cyclamen
Cymbidium
Dahlia
Delphinium
Dracena
Dusty miller
Easter lily
Eggplant
Endive
Exacum
Forget-me-not
Pea
Peony
Periwinkle (Catharanthus)
Peppers
Petunia
Pick-a-back plant
Phlox
Plectranthus (Swedish ivy)
Poppy
Primrose (annual, Primula)
Ranunculus
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INSV or TSW Virus and the vector Western Flower Thrips
Brassaia
Fuchsia
Romaine lettuce
Browallia
Gaillardia (Blanket flower)
Salvia
Calceolaria
Gardenia
Schefflera
Calendula
Geranium (ivy, diploids, and tetraploids) Shamrock (Oxalis)
Calla lily
Gerbera
Snapbean
Carnation
Gladiolus
Snapdragon
Cauliflower
Gloxinia
Speedwell
Centranthus
Gypsophila
Statice
Chicory
Hydrangea
Stephanotis
China aster
Impatiens (New Guinea, balsam)
Stock
Christmas peppers Kalanchoe
Streptocarpus
Chrysanthemum Lettuce
Sweetpea
Cineraria
Lily, Asiatic hybrid
Tiger lily
Coleus
Lily, Easter
Tomato
Columbine
Lobelia
Verbena
Companula
Marigold
Yucca
Coriander
Mimulus
Zinnia
Cosmos
Morning glory
Zygocactus
Nasturtium
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INSV or TSW Virus and the vector Western Flower Thrips
Last modified July 2002.
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USNA - USDA Plant Hardiness Zone Map: Hawaii
Wednesday, July 2, 2002
USDA Plant Hardiness Zone Map
Hawaii
The 2001 US National Arboretum "Web Version" of the 1990 USDA Plant Hardiness Zone Map
Check the color of the section in your area of the map with the color key below.
Zones 10a through 11 represented here.
http://www.usna.usda.gov/Hardzone/hawaii.html (1 of 3)7/2/2003 4:33:39 AM
USNA - USDA Plant Hardiness Zone Map: Hawaii
USDA Hardiness Zones and Average Annual Minimum Temperature Range
Zone
Fahrenheit
Celsius
Example Cities
1
Below -50 F
Below -45.6 C
Fairbanks, Alaska; Resolute, Northwest Territories (Canada)
2a
-50 to -45 F
-42.8 to -45.5 C
Prudhoe Bay, Alaska; Flin Flon, Manitoba (Canada)
2b
-45 to -40 F
-40.0 to -42.7 C
Unalakleet, Alaska; Pinecreek, Minnesota
3a
-40 to -35 F
-37.3 to -39.9 C
International Falls, Minnesota; St. Michael, Alaska
3b
-35 to -30 F
-34.5 to -37.2 C
Tomahawk, Wisconsin; Sidney, Montana
4a
-30 to -25 F
-31.7 to -34.4 C
Minneapolis/St.Paul, Minnesota; Lewistown, Montana
4b
-25 to -20 F
-28.9 to -31.6 C
Northwood, Iowa; Nebraska
5a
-20 to -15 F
-26.2 to -28.8 C
Des Moines, Iowa; Illinois
5b
-15 to -10 F
-23.4 to -26.1 C
Columbia, Missouri; Mansfield, Pennsylvania
6a
-10 to -5 F
-20.6 to -23.3 C
St. Louis, Missouri; Lebanon, Pennsylvania
6b
-5 to 0 F
-17.8 to -20.5 C
McMinnville, Tennessee; Branson, Missouri
7a
0 to 5 F
-15.0 to -17.7 C
Oklahoma City, Oklahoma; South Boston, Virginia
7b
5 to 10 F
-12.3 to -14.9 C
Little Rock, Arkansas; Griffin, Georgia
8a
10 to 15 F
-9.5 to -12.2 C
Tifton, Georgia; Dallas, Texas
8b
15 to 20 F
-6.7 to -9.4 C
Austin, Texas; Gainesville, Florida
9a
20 to 25 F
-3.9 to -6.6 C
Houston, Texas; St. Augustine, Florida
9b
25 to 30 F
-1.2 to -3.8 C
Brownsville, Texas; Fort Pierce, Florida
http://www.usna.usda.gov/Hardzone/hawaii.html (2 of 3)7/2/2003 4:33:39 AM
USNA - USDA Plant Hardiness Zone Map: Hawaii
10a
30 to 35 F
1.6 to -1.1 C
Naples, Florida; Victorville, California
10b
35 to 40 F
4.4 to 1.7 C
Miami, Florida; Coral Gables, Florida
11
above 40 F
above 4.5 C
Honolulu, Hawaii; Mazatlan, Mexico
Go Back to the USDA Hardiness Zone Map
USDA Miscellaneous Publication No. 1475. Issued January 1990.
Authored by Henry M. Cathey while Director, U.S. National Arboretum
Edited, formatted and prepared for the US National Arboretum web site by Ramon Jordan, March 1998 & Revised March
2001
U.S. National Arboretum, Agricultural Research Service, U.S. Department of Agriculture, Washington, DC 20002
Note: This publication is not copyrighted, and permission to reproduce all or any part of it is not required.
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Last Updated January 14, 2002
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site administrator
http://www.usna.usda.gov/Hardzone/hawaii.html (3 of 3)7/2/2003 4:33:39 AM
Growing Vanilla in Hawaii
Creating Vanilla in
Hawaii
A new marketing opportunity for vanilla
ice cream becomes a reality
By Carol Zakahi
The myth explaining the creation of vanilla recalls the days when the world was young and the gods came
to earth and mingled with its inhabitants. A beautiful young goddess, Xanath, daughter of the goddess of
fertility, frequently visited earth. During her trips, she fell in love with a handsome young Totonac warrior.
However, her dreams for a lifetime of happiness together could never come to fruition, as she was a
goddess and he a mere mortal who was forbidden to wed her. No matter how great their love for each
other, they could never be married.
Xanath was heartbroken and for a long time grieved deeply. Finally, resigned to her fate, she created a
plan to give her love forever to her warrior and his people. Using her divine magic, she turned herself into
the graceful vanilla plant. The vine’s vibrant green leaves lovingly intertwined with the trees that formed
the jungle canopy and produced beautiful yellow-green orchid blossoms, which then became the fragrant
vanilla fruit. Xanath gave of herself fully, bringing happiness and pleasure to the Totonacs.
To this day, the Totonacs cherish the vanilla plant and its fruit, which has brought them health, virility and
prosperity. In return, they pay homage to the memory of the beautiful goddess. The yellow-green orchids,
which bloom for only a day, are known to them by her name, Xanath.
Today, the goddess’s namesake blooms in the lush hills of upper Kona on the island of Hawaii. The cool
nights and warm days make this a perfect habitat for the beautiful fragrance of vanilla.
Tom Kadooka of Kona has been growing orchids since 1941. He formed an early interest in research and
basic genetics while working at the Parker Ranch from 1941 to 1945. And in 1949, he joined the American
Orchid Society, which makes him a 50-plus-year member of this organization.
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Growing Vanilla in Hawaii
During this time, an interesting vine at his sister Akie’s property in Keei, Kona caught his interest. It was
originally planted by the oldtimers, who used it and the roots of the Hawaiian ti plant (Cordyline) to make
an alcoholic drink. The vine was climbing on wild hapu’u (tree fern), guava trees and lantana. The
discovery of this vine, which produced the beautiful, fragile vanilla blossoms, shaped Kadooka’s keen
interest in the fantastic world of orchids.
In 1945, Kadooka moved from Keei to
Kainaliu, Kona and started an orchid
nursery. He prepared floral bouquets
and arrangements for weddings,
birthdays, hospitals and grand openings.
He also made tropical arrangements
weekly for the local hotels. Along with
the shop, he retained a strong interest
in genetics and continually
experimented with different plants. He
marketed the blossoms of Vanda Miss
Joaquim and selected a special cultivar
(a winter variety that produced more
flowers during the cool months, when
flowers were scarce). This deep-purple
clone soon graced the dinner plates of
thousands of guests to Hawaii.
Kadooka continued to hybridize orchids,
selecting rare, beautiful mutations and
registering new clones. He put Kona on
the orchid-collector’s map with cultivars such as Brassolaeliocattleya Ports of Paradise ‘Kainaliu’, HCC/
AOS, Brassolaeliocattleya Orange Nugget ‘Kadooka’, HCC/AOS, and a unique Vanda, the Pride of Kona. He
experimented with many types of plants but his interest in vanilla culture remained strong. Although
lacking a market or demand for vanilla, he started a vanilla enterprise, which, 60 years later, he continues
to nourish. When Kadooka discovered Vanilla planifolia in Kona, the book American Orchid Culture by
Edward A. White, published in 1945, was the only source of information available to him about vanilla.
Kadooka’s attention to vanilla culture increased in the 1980s. As one of the key members of the historic
Kona Daifukuji Buddhist Mission, he started the first orchid club in Kona and has been the advisor for the
Kona Daifukuji Orchid Club since 1983. He introduced Xanath to the members, captured their interest, and
together they embarked on a community-wide vanilla adventure. For years, Kadooka had experimented
with the growth requirements for vanilla vines, blossom formation, timing for pollination, harvesting age
for pods (also called vanilla beans), curing the beans, and grading the pods. These experiments caught the
eye of chemist Seiji Yoshimura of the Nagaoka Perfumery of Japan. Several years of experiments with the
perfumery advanced Kadooka’s desire to develop orchid production in Hawaii.
The members of the Daifukuji Orchid Club shared their vanilla adventure by creating a large display at the
Annual Honolulu Orchid Society Show in 1994 in Honolulu, Hawaii, where the trustees of the American
Orchid Society held their semiannual meeting. They made valuable new friends from all over the world,
including other vanilla enthusiasts such as Robert Itoman of the Kaimuki Orchid Society, who has been
teaching vanilla culture since the 1970s at the Lyon Arboretum in Honolulu, and Glen Fukumoto, extension
agent in the livestock program of the University of Hawaii College of Tropical Agriculture and Human
Resources in Kona. The club was aided by Kadooka’s daughter, Janice Uchida, PhD, a plant pathologist,
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Growing Vanilla in Hawaii
and his son, Chris Kadooka, assistant researcher for the University of Hawaii at Manoa, Hawaii. By this
time, Kadooka’s Orchid Nursery in Kona had a large greenhouse filled with vanilla plants in pots producing
thousands of beans.
In 1997, entrepreneurs Jim and Tracy Reddenkopp bought a 4,000-square-foot vanilla field in South Kona
and began the Hawaiian Vanilla Company with sensei (educator) Tom Kadooka. Jim expanded his operation
on the Hamakua coast on the Big Island of Hawaii and today has landed its first high-profile client: Meadow
Gold Dairies, a division of Suza Foods, Southwest Region, Dallas, Texas, which established a licensing
agreement to market Hawaiian vanilla bean ice cream. Portions of the proceeds from the sales of this
product are donated to the Tom Kadooka scholarship fund, placing a strong value on the youth of the
community and the agricultural future of Hawaii. Agriculture keeps Hawaii beautiful.
It is still too early to speculate on the sales of this new product, but, with Tom’s picture on the ice cream
carton, Meadow Gold’s campaign to promote, support, and encourage tropical agriculture for Hawaii’s
youth is well under way.
Today Kadooka, at the age of 80, continues his research
on vanilla and leads development of orchid culture in
Hawaii. He is presently striving to create a vanilla plant
that will be more resistant to diseases and pests. He still
holds onto the dream that vanilla from Hawaii will gain
worldwide recognition to equal that of the famous
gourmet Kona coffee.
MORE ---->
Tom’s Tips for Growing Vanilla
Acknowledgments
The author gratefully acknowledges the assistance of Janice
Uchida, PhD, plant pathologist, University of Hawaii; Tom
Kadooka, veteran orchid grower; Jim Reddenkopp, Hawaii
Vanilla Bean Co.; Seiji Yoshimura, chemist, Nagaoka
Perfumery; Robert Itoman, Kaimuki Orchid Society; and Glen
Fukumoto, agent, University of Hawaii College of Tropical
Agriculture and Human Resources. The ancient tale of the
goddess Xanath is courtesy of McCormick & Company.
References
http://www.theaos.org/publications/bulletin/issues/current/vanilla.html (3 of 4)6/17/2003 5:55:53 AM
Growing Vanilla in Hawaii
Conter, F.E. 1903. Hawaii Agricultural Experiment Station. Press Bulletin #6. Honolulu.
Itoman, Robert. 1986. Vanilla culture in Hawaii. Na Oki Kea O Hawaii (15):4.
Rain, Patricia. 1986. Vanilla Cookbook. Celestial Arts, Berkeley.
Schweitzer, Sophia. 2001. Chocolate and vanilla: growing flavors in Hawaii. Spirit of Aloha Magazine
January.
Spitzel, Janice. 1954. Orchids, gastronomically speaking. Orchid Digest. May-June.
White, Edward A. 1945. American Orchid Culture.
Carol Zakahi has been an AOS member since 1985. • 74-5059 Hua ’Ala Street, Kailua-Kona, Hawaii 96740
(e-mail [email protected]).
Subscribe ! ·
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Copyright © 2002 American Orchid Society. All rights reserved.
http://www.theaos.org/publications/bulletin/issues/current/vanilla.html (4 of 4)6/17/2003 5:55:53 AM
Sphagnum Moss vs Sphagnum Peat Moss
Sphagnum Moss vs Sphagnum Peat Moss
Contact: Diane Relf, Extension Specialist, Environmental Horticulture
August 1996
Don't confuse sphagnum moss with sphagnum peat moss. Sphagnum moss and sphagnum peat moss are not the
same product. Sphagnum moss is used in the floral industry to line wire baskets and make wreaths. It is the
LIVING moss that grows on top of a sphagnum bog. Sphagnum peat moss is used as a soil conditioner by
gardeners. It is the dead material that accumulates in the lower levels of a sphagnum bog. Harvesters of the
horticultural peat moss remove the top few inches of the live sphagnum moss before harvesting the peat from the
lower levels of the bog.
There has also been some confusion about which of the two is actually the source of a fungal disease called
Cutaneous Sporotrichosis, which according to Gerry Hood of the Canadian Sphagnum Peat Moss Association, is
causing some concern within gardening circles. Sporotrichosis is a chronic infection identified by ulcerous skin
lesions and is caused by coming in contact with the fungus, Sporothrix schenckii. Research has found no cases of
sporotrichosis being transmitted in sphagnum peat moss. However, the fungus Sporothrix schenckii,does live in the
top, living portion of the bog that is removed before peat harvesting.
Research done by the Mississippi State Forestry Commission, the Mississippi State Board of health, and the
University of Mississippi Medical Center found that an outbreak of Cutaneous Sporotrichosis among Mississippi
forestry workers in 1975 and 1976 was due to contaminated sphagnum moss. All of the infected persons had been
in contact with pine seedlings packed in sphagnum moss or with sphagnum moss alone, and all lesions were on the
hands and arms. The contaminated moss was believed to have come from a single source. This source probably
received a lightly contaminated batch of sphagnum moss and stored this batch outside. Being outdoors in the
moist, warm, Mississippi summer caused the fungus to increase and heavily contaminate the moss. Once it was
realized that the batch was contaminated and was causing forest workers to get sick the rest of the batch was
disposed of. The workers who contracted the disease were treated with orally administered potassium iodide.
Another study in 1988 of workers who contracted Cutaneous Sporotrichosis also showed it was caused by
handling and packing with sphagnum moss.
Precautions are taken by the industry. To guard against epidemic sporotrichosis, nurseries store all sphagnum moss
indoors, disinfect storage and packing buildings monthly, use precautions when handling moss, and regularly test
recently received and stored moss for the fungus Sporothrix schenckii. Home gardeners using sphagnum moss
should wear gloves and long sleeves to prevent coming in contact with the dried moss.
Remember, sphagnum moss is NOT the same as the safe, sphagnum peat moss you use as a soil amendment!
http://www.ext.vt.edu/departments/envirohort/articles/misc/sphagnum.html (1 of 2)6/16/2003 5:20:12 AM
Sphagnum Moss vs Sphagnum Peat Moss
(References: "Don't Confuse Sphagnum Moss with Peat Moss," by Gerry Hood, President, Canadian Sphagnum
Peat Moss Association; "Cutaneous Sporotrichosis in Forestry Workers," by K.E. Powell, A. Taylor, B.J. Phillips,
D.L. Blakey, G.D. Campbell, L. Kaufman, and W. Kaplan. JAMA 240(3):10, 12-13; and "Multistate Outbreak of
Sporotrichosis in Seedling Handlers," by T. England, M.J. Kasten, R. Martin, T. Cote, D.L. Morse, R. David, and J.
P. Davis. Journal of the Amer. Medical Assoc. 260(19):2806, 2811.)
(Prepared by Karen Nash, Consumer Horticulture Intern, Virginia Tech, Blacksburg, VA 24061-0327.)
Visit Virginia Cooperative Extension
http://www.ext.vt.edu/departments/envirohort/articles/misc/sphagnum.html (2 of 2)6/16/2003 5:20:12 AM
Sporothrix Species
June 16, 2003
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You are here: The Fungi > Descriptions > Sporothrix spp.
Sporothrix
spp.
(described by
Hektoen and
Perkins in 1900)
Taxonomic Classification
Kingdom: Fungi
Phylum: Ascomycota
Class: Euascomycetes
Order: Ophiostomatales
Family: Ophiostomataceae
Genus: Sporothrix
Description and Natural Habitats
Sporothrix is a thermally dimorphic fungus which is distributed
worldwide and isolated from soil, living and decomposing
plants, woods, and peat moss. Sporothrix schenckii is an
occasional cause of human infections. Ophiostoma stenoceras
is the teleomorph of Sporothrix sp.
Conidia arising
directly from the
hyphae and
conidia arising on
denticles from
sympodial
conidiophores
are typical of
Sporothrix
schenckii.
Despite the existence of the fungus worldwide, infections due
to Sporothrix schenckii are more common at certain
geographical areas. Peru is an area of hyperendemicity for
Sporothrix schenckii infections [1562].
Species
The genus Sporothrix contains one active species, Sporothrix
schenckii.
The species cyanescens, formerly classified in genus
Sporothrix, was later included in genus Cerinosterus and now
is classified in genus Fugomyces. Accordingly, the former
Sporothrix cyanescens is now referred to as Fugomyces
cyanescens, which is a basidiomycetous genus unlike the
ascomycetous Sporothrix. You may want to refer to our
synonym and classification page for more details and history
of this taxonomic modification to genus Fugomyces.
http://www.doctorfungus.org/thefungi/Sporothrix.htm (1 of 8)6/16/2003 5:21:27 AM
Sporothrix
schenckii has a
yeast form at 37°
C.
Sporothrix Species
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Sporothrix schenckii is the pathogenic species, while
Fugomyces cyanescens is considered to be nonpathogenic.
Macroscopic and microscopic features of these species are
different from each other. Sporothrix schenckii is a thermally
dimorphic fungus. The nonpathogenic Sporothrix sp., on the
other hand, may occasionally convert to a yeast phase at 37°
C.
See the summary of teleomorphs, synonyms and obselete
names for the Sporothrix spp.
Pathogenicity and Clinical Significance
Sporothrix schenckii is the causative agent of sporotrichosis
("rose handler's disease") [1746]. Sporotrichosis is a
subcutaneous infection with a common chronic and a rare
progressive course. The infection starts following entry of the
infecting fungus through the skin via a minor trauma and may
affect an otherwise healthy individual. Following entry, the
infection may spread via the lymphatic route. Nodular
lymphangitis may develop [1127, 2051]. Interestingly, an
epidemic of sporotrichosis after sleeping in a rust-stained
camping tent has been reported and the tent was identified as
the source of infection [340]. Patients infected with Sporothrix
schenckii may be misdiagnosed as pyoderma gangrenosum
due to the large ulcerations observed during the course of
sporotrichosis [327].
Pulmonary [612, 802, 1057] and osteoarticular infections
[589, 1203], granulamatous tenosynovitis and carpal tunnel
syndrome [1995], bursal infection [2171], endophthalmitis
[1149, 2242], meningitis [636, 1594], invasive sinusitis
[1431], and disseminated [1432, 2174] sporotrichosis have
been described. The infection remains localized in
immunocompetent individuals while fungemia and
disseminated infection may be observed in
immunocompromised patients, such as those with AIDS [46,
589, 779, 1149, 1232, 1431, 1594, 2174]. Fatal fungemia
may develop also in patients with diabetes mellitus and
alcoholism [365]. Primary (granulamatous) pneumonia
without any cutaneous disease may develop in alcoholics
[612]. Laboratory-acquired sporotrichosis has also been
reported.
Fugomyces cyanescens is frequently considered to be
nonpathogenic. It is avirulent in animal models and human
cases in general do not suggest a clinical syndrome [1929].
However, pulmonary lesions and pneumonia due to
Fugomyces cyanescens have been reported in organ
transplant recipients [2029, 830].
Macroscopic Features
I. Sporothrix schenckii. It is a thermally dimorphic fungus and
the colony morphology varies depending on the temperature
http://www.doctorfungus.org/thefungi/Sporothrix.htm (2 of 8)6/16/2003 5:21:27 AM
Young colonies of
Sporothrix
schenckii remain
white for some
time at 25°C or
when incubated
at 37°C to induce
its yeast phase.
Older colonies of
Sporothrix
schenckii turn
black due to the
production of
dark conidia that
arise directly
from the hyphae.
Sporothrix Species
of growth. At 25°C, colonies grow moderately rapidly. They
are moist, leathery to velvety, and have a finely wrinkled
surface. From the front and the reverse, the color is white
initially and becomes cream to dark brown in time ("dirty
candle-wax" color). At 37°C, colonies grow moderately
rapidly. They are yeast-like and creamy. The color is cream to
beige. The conversion of the mould form to the yeast form is
required for definitive identification of Sporothrix schenckii
[1175, 1984, 2015].
II. Fugomyces cyanescens. At 25°C, colonies are velvety to
powdery and slightly raised in texture. From the front, the
color is initially white and turns to pale purple in time. From
the reverse, an intense lavender-colored diffusing pigment
formation is typical. This pigment is produced on potato
dextrose agar after an incubation of about 3 weeks while it is
usually not expressed on Sabouraud dextrose agar. The
production of this lavender-colored pigment helps in
differentiation of Fugomyces cyanescens from Sporothrix
schenckii [2015].
Microscopic Features
I. Sporothrix schenckii. Similar to its colony morphology,
microscopic features of Sporothrix schenckii also vary
depending on the temperature of growth. At 25°C, septate
hyaline hyphae, conidiophores, and conidia are observed.
Conidiophores are sympodial and appear weakly differentiated
from the vegetative hyphae. They often have an inflated base
and arise at right angles from the hyphae. Conidia have two
types. The first type are unicellular, hyaline to brown, oval,
thin-walled, and are typically arranged in rosette-like clusters
at the tips of the conidiophores. The second type of conidia
are brown (dematiaceous),oval or triangular, thick-walled,
cessile, and are attached directly to the sides of the hyphae.
The latter type of conidia are typically present only in freshly
isolated strains. At 37°C, Sporothrix schenckii produces oval
to cigar-shaped (also called "cigar bodies") yeast cells. Single
or multiple buds may be produced by a single yeast cell
[1175, 1984, 2015].
Sporothrix schenckii var. luriei differs from Sporothrix
schenckii by producing large, often septate, budding cells and
by not assimilating creatine and creatinine [28, 483].
II. Fugomyces cyanescens. Septate hyaline hyphae,
conidiogenous cells, denticles (tooth-like conidium-bearing
projections), and primary and secondary conidia are
visualized. The terminal conidiogenous cells have an inflated
appearence. They bear denticles on their surface. The primary
conidia (4-9 x 1.5-3 µm) are hyaline and smooth in
appearence. They are ellipsoidal in shape and bear 1-3
secondary conidia on small denticles. The secondary conidia
(2.5-5 x 0.8-2 µm) are smaller than primary conidia and
pyriform in shape. The conidia rapidly dislodge and the
dislodged conidia look like budding yeast cells. The production
of secondary conidia and the absence of dematiaceous sessile
http://www.doctorfungus.org/thefungi/Sporothrix.htm (3 of 8)6/16/2003 5:21:27 AM
Sporothrix Species
conidia on the hyphae help in differentiation of Fugomyces
cyanescens from Sporothrix schenckii [2015].
III. Ophiostoma stenoceras. Being the teleomorph of
Sporothrix sp., this fungus produces a long-necked perithecia
(the round or pear-shaped structure with an ostiole and
containing asci and ascospores inside) after an incubation of 23 weeks [1984].
Histopathologic Features
Yeast cells may be observed in the infected tissues/samples
[919]. These yeast cells may be intracellular (within the
macrophages) and may have an apparent halo [653]. See also
our histopathology page.
Compare to
Acremonium
Beauveria
Blastobotrys
Lecythophora
Phialophora
Verticillium
Laboratory Precautions
No special precautions other than general laboratory
precautions are required.
Susceptibility
Available data suggest that in vitro activity of amphotericin B
and itraconazole against Sporothrix schenckii is variable and
strain-dependent [1353, 2087, 627]. (Primary) amphotericin
B-resistant isolates have been identified [607, 46]. Terbinafine
[1608], naftifine [754], and amorolfine [1725, 951] are active
in vitro against Sporothrix schenckii. On the other hand,
fluconazole, voriconazole [626] and ravuconazole [721] yield
high MICs for isolates of Sporothrix schenckii.
For MICs of various antifungal drugs for Sporothrix schenckii,
see our susceptibility database.
Potassium iodide is one of the oldest therapeutic modalities
used for treatment of sporotrichosis [2051]. Amphotericin B
[2029], ketoconazole, and itraconazole [1203] are now more
commonly used in treatment of Sporothrix schenckii
infections. Amphotericin B-resistant [46] and itraconazolerefractory cases have been reported. Initial treatment with
amphotericin B followed by long term maintenance therapy
with itraconazole may be beneficial in cases with
sporotrichosis and AIDS [589].
Search
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Sporothrix Species
PubMed
Nucleotides
GenBank
References
28. Ajello, L., and W. Kaplan. 1969. A new variant of Sporothrix schenckii.
Mykosen. 12:633-644.
46. Al-Tawfiq, J. A., and K. K. Wools. 1998. Disseminated sporotrichosis and
Sporothrix schenckii fungemia as the initial presentation of human
immunodeficiency virus infection. Clin Infect Dis. 26:1403-1406.
327. Byrd, D. R., R. A. el-Azhary, L. E. Gibson, and G. D. Roberts. 2001.
Sporotrichosis masquerading as pyoderma gangrenosum: case report and review of
19 cases of sporotrichosis. J Eur Acad Dermatol Venereol. 15:581-584.
340. Campos, P., R. Arenas, and H. Coronado. 1994. Epidemic cutaneous
sporotrichosis. Int. J. Dermatol. 33:38-41.
365. Castrejon, O. V., M. Robles, and O. E. Zubieta Arroyo. 1995. Fatal fungaemia
due to Sporothrix schenckii. Mycoses. 38:373-376.
483. de Hoog, G. S., J. Guarro, J. Gene, and M. J. Figueras. 2000. Atlas of Clinical
Fungi, 2nd ed, vol. 1. Centraalbureau voor Schimmelcultures, Utrecht, The
Netherlands.
589. Edwards, C., W. L. Reuther, III, and D. L. Greer. 2000. Disseminated
osteoarticular sporotrichosis: Treatment in a patient with acquired
immunodeficiency. Southern Med J. 93:803-806.
607. Ellis, D. 2002. Amphotericin B: spectrum and resistance. J Antimicrob
Chemother. 49:7-10.
612. England, D. M., and L. Hochholzer. 1987. Sporothrix infection of the lung
without cutaneous disease: Primary pulmonary sporotrichosis. Arch. Pathol. Lab.
Med.d. 111:298-300.
626. Espinel-Ingroff, A., K. Boyle, and D. J. Sheehan. 2001. In vitro antifungal
activities of voriconazole and reference agents as determined by NCCLS methods:
Review of the literature. Mycopathologia. 150:101-115.
627. Espinel-Ingroff, A., K. Dawson, M. Pfaller, E. Anaissie, B. Breslin, D. Dixon, A.
Fothergill, V. Paetznick, J. Peter, M. Rinaldi, and T. Walsh. 1995. Comparative and
collaborative evaluation of standardization of antifungal susceptibility testing for
filamentous fungi. Antimicrob. Agents Chemother. 39:314-319.
636. Ewing, G. E., G. J. Bosi, and P. K. Peterson. 1980. Sporothrix schenckii
meningitis in a farmer with Hodgkin's disease. Am. J. Med. 68:455-457.
653. Farley, M. L., M. F. Fagan, L. C. Mabry, and R. J. Wallace, Jr. 1991.
Presentation of Sporothrix schenkii in pulmonary cytology specimens. Acta
Cytologica. 35:389-95.
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Sporothrix Species
721. Fung-Tomc, J. C., E. Huczko, B. Minassian, and D. P. Bonner. 1998. In vitro
activity of a new orial triazole, BMS-207147 (ER-30346). Antimicrob. Agents
Chemother. 42:313-318.
754. Georgopoulos, A., G. Petranyi, H. Mieth, and J. Drews. 1981. In vitro activity
of naftifine, a new antifungal agent. Antimicrob. Agents Chemother. 19:386-9.
779. Goldani, L. Z., V. R. Aquino, and A. A. Dargel. 1999. Disseminated cutaneous
sporotrichosis in an AIDS patient receiving maintenance therapy with fluconazole
for previous cryptococcal meningitis. Clin Infect Dis. 28:1337-1338.
802. Gori, S., A. Lupetti, G. Moscato, M. Parenti, and A. Lofaro. 1997. Pulmonary
sporotrichosis with hyphae in a human immunodeficiency virus-infected patient. A
case report. Acta Cytologica. 41:519-521.
830. Grossi, P., C. Farina, R. Fiocchi, and D. Dalla Gasperina. 2000. Prevalence and
outcome of invasive fungal infections in 1,963 thoracic organ transplant recipients A multicenter retrospective study. Transplantation. 70:112-116.
919. Hayden, R. T., X. Qian, G. D. Roberts, and R. V. Lloyd. 2001. In situ
hybridization for the identification of yeastlike organisms in tissue section. Diagn
Mol Pathol. 10:15-23.
951. Hiratani, T., Y. Asagi, A. Matsusaka, K. Uchida, and H. Yamaguchi. 1991. In
vitro antifungal activity of amorolfine, a new morpholine antimycotic agent:. Jpn J
Antibiot. 44:993-1006.
1057. Kauffman, C. A. 1999. Sporotrichosis. Clin Infect Dis. 29:231-237.
1127. Kostman, J. R., and M. J. DiNubile. 1993. Nodular lymphangitis: a distinctive
but often unrecognized syndrome. Ann. Intern. Med. 118:883-888.
1149. Kurosawa, A., S. C. Pollock, M. P. Collins, C. R. Kraff, and M. O. M. Tso.
1988. Sporothrix schenckii endophthalmitis in a patient with human
immunodeficiency virus infection. Arch. Ophthalmol. 106:376-380.
1175. Larone, D. H. 1995. Medically Important Fungi - A Guide to Identification,
3rd ed. ASM Press, Washington, D.C.
1203. Lesperance, M., D. Baumgartner, and C. A. Kauffman. 1988. Polyarticular
arthritis due to Sporothrix schenckii. Mycoses. 31:1988.
1232. Lipstein-Kresch, E., H. D. Isenberg, C. Singer, O. Cooke, and R. A.
Greenwald. 1985. Disseminated Sporothrix schenckii infection with arthritis in a
patient with acquired immunodeficiency syndrome. J. Rheumatol. 12:805-808.
1353. McGinnis, M. R., N. Nordoff, R. K. Li, L. Pasarell, and D. W. Warnock. 2001.
Sporothrix schenckii sensitivity to voriconazole, itraconazole and amphotericin B.
Med Mycol. 39:369-371.
1431. Morgan, M., and R. Reves. 1996. Invasive sinusitis due to Sporothrix
schenckii in a patient with AIDS. Clin. Infect. Dis. 23:1319-1320.
1432. Morgan, M. A., F. R. Cockerill, D. A. Cortese, and G. D. Roberts. 1984.
Disseminated sporotrichosis with Sporothrix schenckii fungemia. Diagn. Microbiol.
Infect. Dis. 2:151-155.
1562. Pappas, P. G., I. Tellez, A. E. Deep, D. Nolasco, W. Holgado, and B.
Bustamante. 2000. Sporotrichosis in Peru: Description of an area of
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Sporothrix Species
hyperendemicity. Clin Infect Dis. 30:65-70.
1594. Penn, C. C., E. Goldstein, and W. R. Bartholomew. 1992. Sporothrix
schenckii meningitis in a patients with AIDS. Clin. Infect. Dis. 15:741-743.
1608. Petranyi, G., J. G. Meingassner, and H. Mieth. 1987. Antifungal activity of
the allylamine derivative terbinafine in vitro. Antimicrob. Agents Chemother.
31:1365-1368.
1725. Regli, P., and H. Ferrari. 1989. In vitro action spectrum of a new antifungal
agent derived from morpholine: amorolfin:. Pathol Biol (Paris).
1746. Rex, J. H., and P. C. Okhuysen. 2000. Sporothrix schenckii, p. 2695-2698. In
G. L. Mandell, J. E. Bennett, and R. Dolin (ed.), Mandell, Douglas and Bennett's
Principles and Practice of Infectious Diseases, 5th ed. Churchill Livingstone, New
York.
1929. Sigler, L., J. L. Harris, D. M. Dixon, A. L. Flis, I. F. Salkin, M. Kemna, and R.
A. Duncan. 1990. Microbiology and potential virulence of Sporothrix cyanescens, a
fungus rarely isolated from blood and skin. J. Clin. Microbiol. 28:1009-1015.
1984. St-Germain, G., and R. Summerbell. 1996. Identifying Filamentous Fungi - A
Clinical Laboratory Handbook, 1st ed. Star Publishing Company, Belmont, California.
1995. Stratton, C. W., K. A. Lichtenstein, S. R. Lowenstein, D. B. Phelps, and L. B.
Reller. 1981. Granulomatous tenosynovitis and carpal tunnel syndrome caused by
Sporothrix schenckii. Am. J. Med. 71:161-164.
2015. Sutton, D. A., A. W. Fothergill, and M. G. Rinaldi (ed.). 1998. Guide to
Clinically Significant Fungi, 1st ed. Williams & Wilkins, Baltimore.
2029. Tambini, R., C. Farina, R. Fiocchi, B. Dupont, E. Gueho, G. Delvecchio, F.
Mamprin, and G. Gavazzeni. 1996. Possible pathogenic role for Sporothrix
cyanescens isolated from a lung lesion in a heart transplant patient. J. Med. Vet.
Mycol. 34:195-198.
2051. Tomimori-Yamashita, J., C. H. Takahashi, O. Fichman, E. B. Costa, N. S.
Michalany, and M. M. A. Alchorne. 1998. Lymphangitic sporotrichosis: An
uncommon bilateral localization. Mycopathologia. 141:69-71.
2087. Van Cutsem, J. 1989. The in-vitro antifungal spectrum of itraconazole.
Mycoses. 32:7-13.
2171. Wang, J. P., K. F. Granlund, S. A. Bozzette, M. J. Botte, and J. Fierer. 2000.
Bursal sporotrichosis: Case report and review. Clin Infect Dis. 31:615-616.
2174. Ware, A. J., C. J. Cockerell, D. J. Skiest, and H. M. Kussman. 1999.
Disseminated sporotrichosis with extensive cutaneous involvement in a patient with
AIDS. J Amer Acad Dermatol. 40:350-355.
2242. Witherspoon, C. D., F. Kuhn, S. D. Owens, M. F. White, and J. A. Kimble.
1990. Endophthalmitis due to Sporothrix schenckii after penetrating ocular injury.
Ann. Ophthalmol. 22:385-388.
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Voriconazole
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Radford SA, et al. In vitro studies of
activity of voriconazole (UK-104,496), a
new triazole antifungal agent, against
emerging and less-common mold
pathogens. Antimicrob Agents Chemother
1997;41:841-843.
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Mycology: Lifecycles and Pathogenesis
Contents > Myc 1 > Myc 2 > Myc 3
MYCOLOGY 2: Lifecycles and Pathogenesis
I. Virulence
II. Lifecycles and Pathogenesis
A. Superficial Mycoses
B. Cutaneous Mycoses
C. Subcutaneous Mycoses
D.Yeasts
E. Systemic Infections
Lecturer: Dr. Kevin Hazen
Readings: Murray, et al. (2002) Medical Microbiology, Chapters 69 & 70
I. VIRULENCE
A. Many components of a mycotic organism contribute to its pathogenicity:
1. Cell wall
❍ Components are polysaccharides, proteins (attached, non-covalently linked and
secreted), lipids
2. Capsules-primary genus is Cryptococcus. Antiphagocytic.
3. Proteases-lead to destruction of host tissues. Examples elastase of Aspergillus spp., acid
protease of Candida albicans
4. Lipases-destruction of host tissues
5. Toxins-endotoxin-like materials associated with some fungi, e.g., Candida albicans.
Endotoxin-like activity may be related to the ability to trigger IL-1 production.
6. Melanin-mel- mutants of Cryptococcus are less virulent than wild type. Melanin is important
for various "black fungi" and possibly for some zygomycetes
7. Adhesins-mediate attachment to, for example, extracellular matrix proteins (different bonds
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Mycology: Lifecycles and Pathogenesis
are involved)
B. There is a danger of pigeonholing organisms and associated site of infection
Exceptions occur (e.g., trichosporonosis, phaeohyphomycosis)
II. LIFECYCLES AND PATHOGENESIS
A. SUPERFICIAL MYCOSES
General:
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Infection on keratinized layers of
skin
Includes: piedras, tinea nigra, and
pityriasis versicolor
1. Pityriasis versicolor. (previously called
tinea versicolor)
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Agents: Malassezia species
particularly, M. globosa, M. furfur.
Lipophilic organisms (suntan
lotions are a good source)
Disease is commonly seen in
adolescents and young adults.
Lesions are hypo- or
hyperpigmentation of skin.
Serological response is typically
absent.
NOTE: Malassezia is beginning to
emerge a more significant
opportunistic pathogen.
❍ We are seeing an increase
in fungemia due to
Malassezia speces in
newborns on
hyperalimentation.
❍ There has been a recent
case of ascending UTI with
renal abscess involving
Malassezia in a diabetic.
Eventually, organism was
Figure 2-1. Pityriasis versicolor as shown here on
a patient's shoulderblade
Figure 2-2. Pityriasis versicolor, KOH preparation
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Mycology: Lifecycles and Pathogenesis
❍
recovered in blood.
Malassizia is a cause of
folliculitis in AIDS
patients.
Figure 2-3. M. furfur in organisms in tissue. tissue,
"meatballs and spaghetti" appearance.
B. CUTANEOUS MYCOSES
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Geophilic & zoophilic organisms tend to be more acute/inflammatory
Anthrophilic organisms tend to be more chronic with less inflammatory response
Infect keratinized layers
❍ hair
❍ skin
❍ nails
Most common cutaneous disease (or fungal disease overall) is dermatophytosis (ringworm).
❍ Note other fungi can cause cutaneous disease but usually accompanies of sites of
infection.
❍ Other agents, such as Scytalidium and Arthrographis kalrai can cause cutaneous
infections but these are rare infections.
Dermatophytes: In dermatophytosis, the name is based on the typical appearance of the lesion
on body.
1. Dermophytes grow only as moulds and produce conidia
2. Initial lesion is small, erythematous patch (may be raised), spreads radially with
clearing in the center, raised borders, scaly on edges, may have vesicles within lesion.
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Mycology: Lifecycles and Pathogenesis
3. Rarely see a subcutaneous infection caused by the etiologic agents (dermatophytes).
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The etiologic agents are ubiquitous and belong to three keratinophilic genera:
1. Microsporum species
2. Trichophyton species
3. Epidermophyton floccosum-this agent does not cause scalp disease.
The dermatophytes can be differentiated by the appearance of their micro- and macroconidia.
❍ Certain Trichophyton species are distinguished by vitamin requirements.
Infections caused by dermatophytes:
1. Tinea capitis
(infection of scalp, eyelashes,
and eyebrows)
a. invasion pattern is different
from the description above for
dermatophytosis. Although
infection of the skin surface is
similar, there is also invasion of
the hair follicle and possible
penetration of the hair.
· ectothrix hair vs endothrix hair
(Wood's lamp is useful)
b. Agents are Microsporum and
Trichophyton species
c. Tough to manage. Usually
requires long term treatment.
2. Tinea corporis (Classic
"ringworm." ringworm of
glabrous skin)
3. Tinea cruris (jock itch)
a. This disease must be
distinguished from crural
infection caused by Candida
species as different treatment
may be indicated and prognosis
is different.
b. This is a disease frequently
encountered in epidemic
proportions with athletic teams.
Etiologic agents (most common
agent is Epidermophyton
floccosum) can betransmitted
through towels.
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Figure 2-4. Ecto- and endothrix hair.
Figure 2-5. Tinia pedis
Mycology: Lifecycles and Pathogenesis
4. Tinea pedis (athlete's foot)
a. Especially found on ball of
feet and interdigital areas
b. Trichophyton and
Epidermophyton
c. Chronic and acute forms seenacute form is better because
usually eliminates the organism
d. "Id" reaction-sterile vesicles
found distant from site on
infection (usu. hands)
5. Tinea unguium (nails)
a. may be chronic for years
b. difficult to find fungi
6. Tinea barbae (bearded area of
face)
a. Similar to tinea capitis but
usually much more
inflammatory.
b. Disease is stopped by removal
of beard
(may have to depilate)
Figure 2-6. Onychomycosis due to dermatophyte
Figure 2-7 Eczymatoid mycosis of the hand
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Immunity to dermatophytes
❍ Dermatophytes are not great inducers of IR but possible to demonstrate both DTH and
immediate-type hypersensitivity.
❍ Anergy can lead to chronic disease
❍ Severity and duration vary widely from person to person.
Diagnosis & Treatment
❍ Culture scrapings of skin, nail, or hair clippings.
❍ Treat with 10% KOH
❍ Culture on appropriate media
(mycosel and Sabouraud's dextrose medium)
❍ Mycosel contains cycloheximide and chloramphenicol to inhibit bacteria.
(NOTE: Exercise caution with cycloheximide)
Epidemiology
❍ mostly human to human but can obtain from animals or soil.
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❍
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* Agents appear untypable at present
Anthropophilic organisms cause chronic infection
Zoophilic and geophilic organisms usually cause more inflammatory, acute disease
Treatment
❍ Dependent upon disease
❍ Topical agents, such as miconazole or other azoles, tolnaftate, salicylate
❍ For recalcitrant onychodermatomycosis, use griseofulvin and terbinafine (Lamasil).
C. SUBCUTANEOUS MYCOSES
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Conidia, hyphal fragments gain entry as result
of injury to the skin such as thorn of rose bush
Tend to remain localized but may spread to
regional lymph nodes. Depending on
organism may convert to distinct morphology
or grow as hyphae.
Figure 2-8 Sporotrichosis of finger
1. Sporotrichosis
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Agent: Sporothrix schenckii (pulmonary
disease is also possible)
Agent found in soil, wood, moss (potting soil)
Acquired from inoculation with contaminated
splinters, thorns, etc. "Rose-handler's disease"
❍ Can be inhaled (AIDS patients)
Dimorphic organism
❍ cigar-shaped yeast at 37°C
❍ hyphae covered with conidia at room
temperature
Disease may be chronic for years
Common form is lymphocutaneous
sporotrichosis.
❍ Begins with small lesion occurring 3-6
weeks after implantation of organism.
❍ Develops into movable nodule.
❍ Eventually opens at surface and is
suppurative.
❍ Ascends up lymphatics, setting up
more nodules.
❍ Organisms are also transported up
lymphatics so ascending lesions
become evident.
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Figure 2-9. Sporotrichosis, ascending pattern
Figure 2-10. Asteroid body due to
sporotrichosis
Mycology: Lifecycles and Pathogenesis
Figure 2-11. S. schenckii in tissue, yeast forms
Figure 2-12. Sporothrix schenckii, mould (left) and yeast (right) phases
2. Chromoblastomycosis and
phaeohyphomycosis
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group of clinical entities caused by
pigmented fungi, the phaeoid fungi or
black moulds. Over 60 agents shown to
cause diseases.
Chromoblastomycosis (sometimes
called chromomycosis) is also known as
verrucous dermatitis.
❍ Occurs with hyperplasia limited
to subcutaneous areas, with the
form of the organism restricted
to "muriform, sclerotic
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Figure 2-13. Bipolaris on culture
Mycology: Lifecycles and Pathogenesis
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cells" (copper pennies in tissue)
❍ Five species have been reported
to cause true
chromoblastomycosis.
❍ Rarely will have disseminated
disease
All other forms of what was once called
chromomycosis are now designated
phaeohyphomycosis.
❍ Several agents of
phaehyphomycosis will spread
to the brain
■ Cladophialophora
bantiana
■ Bipolaris [This is a cause
of sinusitis and can
extend to brain.]
Disease is most frequently seen on feet
and legs.
❍ Other sites can occur especially
in immunocompromised
patients, after systemic spread.
Treatment depends on site but typically
includes surgery and amphotericin B.
❍ KI, 5-fluorocytosine and azoles
are infrequently effective.
❍ Recent reports suggest that
itraconazole may provide a
favorable response.
Figure 2-14. Chromoblastomycosis.
Figure 2-15. Tissue section from
chromoblastomtycosis patient,
"sclerotic" cells shown. (from: Mosby, 2002)
3. Eumycotic mycetoma
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Due to entrance of soil fungi through
skin
Destruction of bone and muscle unless
treated early
Grains are white to yellow, brown to
black.
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Mycology: Lifecycles and Pathogenesis
Figure 2-16. Cerebral haeohyphomycosis
Bacterial mycetes See Bact-14 lecture
D. YEASTS: INFECTIONS FROM CUTANEOUS TO SYSTEMIC
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This group of organisms can attack many areas of the body
❍ Most common genus is Candida, hence candidiasis (candidosis in Europe).
❍ several species may be normal flora in gut, mouth, vagina.
❍ most common etiologic agent is Candida albicans. Approximately eight species are
most commonly associated with disease.
❍ All species, except C. glabrata, form pseudohyphae in tissue (useful characteristic).
Some may also form hyphae
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Mycology: Lifecycles and Pathogenesis
Figure 2-17. Structures formed by some Candida species in tissue
1. Diseases
Vaginitis is probably the most common form of disease
❍ Oral candidiasis (thrush) is second most common
❍ Alimentary candidiasis
❍ Cutaneous and systemic candidiasis (all organs are potential targets).
❍ Presence of Candida tropicalis in cancer patients is especially significant as this
species is more virulent than C. albicans
Diagnosis
❍ germ tube test is useful presumptive test. Other rapid tests are available.
❍ Clinical findings
❍ Positive cultures (presence in sputum is not useful unless high numbers)
❍ Chlamydoconidia on corn meal agar.
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Figure 2-18. Example of chronic mucocutaneous
candidiasis.
Figure 2-19. Candidal thrush of the buccal
mucosa.
Figure 2-20. Candidal thrush of the buccal
Figure 2-21. Candida onychomycosis and
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Mycology: Lifecycles and Pathogenesis
mucosa.
paronychomycosis.
Figure 2-22. Germ tubes produced by Candida
albicans.
Figure 2-23. Candidiasis of the spleen
2. Ecology
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Organism is found in the GI and GU tracts of humans and warm blooded animal. C. albicans
and other species can be found in other env sources such as soil, plants, and polluted water
Infants may pick up org from the birth canal, from nursing or from contaminated bottles.
Wearing dentures increases the incidence of carriage of Candida
70-80% of inds carry Candida either in mouth, or in small or large intestine.
❍ In females, may also be found in vagina.
Antibacterial therapy increases amount of Candida in gut. (diarrhea??)
Immunosuppression can alter apparent virulence of species (compared to disease virulence in
immunocompetent individuals) C. albicans vs C. tropicalis vs C. dubliniensis.
Pregnancy can increase incidence of vaginal candidiasis.
C. albicans is the most common species found in colonized vaginas (69%); C. glabrata second
most common.
Skin is not normal habitat but 5% of individuals carry Candida spp (CA and CT, usually) in
intertriginous areas.
3. Epidemiology
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Dogma: candidiasis is an opportunistic disease. Many conditions can lead to development of
some form of candidiasis. In general, the form of candidiaisis that develops is determined by
the predisposing condition. For example, an individual who has functional neutrophils but low
CD4 count will develop mucocutaneous candidiasis but not (usually) systemic disease.
Other epidemiological correlations:
❍ Diabetes or endocrine disorders also encourage disease
❍ Long term exposure to broad spectrum antibiotics (especially for intestinal disease).
May see diarrhea.
The general dogma is that an individual obtains the etiologic agent from his/her own flora
(GI). Thus, knowledge of patients yeast flora can be helpful. However, this is not always true
as some species of Candida had to be acquired exogenously. This species are also usually poor
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Mycology: Lifecycles and Pathogenesis
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pathogens.
There is some evidence that occasionally a yeast isolate can be transmitted from patient to
patient (e.g., nurse who cared for bypass patients).
4. Lesions of candidiasis
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For all species exc. C. glabrata, the organism appears as yeasts with pseudohyphae in tissue.
Note that C. albicans, is most frequently seen in individuals as a commensal, and is found as a
yeast until disease occurs.
❍ In rare occasions, only yeasts were seen in lesions.
❍ This led to the idea that hyphal form is pathogenic form.
❍ Evidence suggests that is not true as yeast forms can cause disease.
❍ It has also been suggested that yeasts may be the predominant form in early lesions and
hyphae come later, but this may not be true as hyphal form may be the cause of overt
disease.
In lesion histopathology, inflammatory response may occur
❍ Depends on age of infection and host response.
Typical lesion
❍ Central necrosis surrounded by PMNs (suppuration)
❍ Usually no vascular invasion
❍ If patient is neutropenic, then necrosis and edema may occur.
5. Host defense and immunity
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Some interesting observations concerning immunity to candidiasis:
1. Patients who develop systemic candidiasis are usually neutropenic or have diminished
phagocytic activity.
2. Disseminated disease in patients who had otherwise mucocutaneous involvement
develops once neutropenia occurs.
3. Patients with mucocutaneous involvement may have intact neutrophil function but
altered cell-mediated immunity.
4. TH1 and TH2 immune mechanisms for mycoses are under extensive investigation.
■ It is clear that T 1 is important in preventing development and maintenance of
H
fungal diseases.
■ T 2 activities may lead to suppression and allowance of systemic diseases.
H
E. SYSTEMIC MYCOSES
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Agents are all dimorphic (mould in environment and yeast phase or spherule at 37°C):
conversion from mould to yeast (or spherule) in vitro required for confirmation of
identification.
All begin as lower respiratory infections
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Mycology: Lifecycles and Pathogenesis
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All appear to have restricted geographic distribution (may not be quite true for histoplasmosis)
Most infections are either asymptomatic or quickly resolved. Severe disease is likely
associated with immunologic incompetence.
One of the hallmarks of disease caused by the systemic fungi (Histoplasma, Blastomyces,
Paracoccidioides, and Coccidioides) is the pulmonary lesion characterized by an initial
inflammatory response followed by granuloma production with a prominent suppurative
component. Caseation necrosis follows and eventually, upon healing (acute disease, healthy
individual), fibrous encapsulation. Calcification is more frequent with histoplasmosis.. This
typical lesion is more variable in blastomycosis in part because lesion development is slower
and antigenicity of etiologic agent (see more neutrophils even in healing lesions) Caseation is
less common in paracoccidioidomycosis and blastomycosis.
A. Histoplasmosis (Darling's disease)
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World-wide distribution: In U.S.,
primarily found in Mississippi and Ohio
river valleys, Midwest, Virginia,
Maryland.
❍ "African" histoplasmosis caused
by different etiologic agent and is
restricted to Africa.
Etiologic agent is Histoplasma
capsulatum (sexual name: Ajellomyces
capsulatus)
❍ identified by its microconidia,
tuberculated macroconidia and
dimorphism
❍ important problem of AIDS
patients but also seen in
apparently healthy individuals
Epidemiology
❍ organisms grow best in soil with
high nitrogen content (bird
droppings- especially starlings,
chickens, blackbirds-i.e.
gregarious birds). Bats are rarely
infected with histoplasmosis but
carry organism in gut. Droppings
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Figure 2-24. Histoplasma capsulatum,
morphologies on culture.
Mycology: Lifecycles and Pathogenesis
❍
can infest bat habitats. Gives rise
to name spelunker's disease.
infections follow inhalation of
spores or fragments of mycelium.
If large inoculum, symptoms will
usually appear in otherwise
healthy individual around day 7
in individual is from endemic
area or around day 14 if patient is
from area of low endemicity.
Figure 2-25. Public Health sign for histoplasmosis.
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Disease
❍ organism converts to yeast form in lungs.
❍ yeast cells grow intracellularly in histiocytes (only true intracellular fungal pathogen)
❍ 95% of cases are benign, asymptomatic disease.
❍ lower respiratory disease which mimics TB (cavitation, calcification)
■ acute disease has overt symptoms that are not useful to differentiate disease:
fever, malaise, chills
❍ chronic disseminated histoplasmosis: spleen, liver, adrenals, lymph nodes, bone marrow
■ Infrequent result of acute disease
■ May also travel to eye orbit and cause retinal disease
❍ chronic pulmonary histoplasmosis is accompanied with calcification. Coin lesions.
Miliary lesion.
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Mycology: Lifecycles and Pathogenesis
Figure 2-26. Geographic distribution of Histoplasma duboisii
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Mycology: Lifecycles and Pathogenesis
Figure 2-27 Distribution of histoplasmin skin test positive individuals
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Diagnosis
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culture from sputum may not be successful
bone marrow aspirate is useful as intracellular organisms are visible (disseminated
disease)
lung biopsy or lavage is a good specimen
Latex bead coated with histoplasmin are used for detection of patient Ab
Immunodiffusion test for detection of either pt Abs or Ag. Look for appearance of H
and M bands. This is not a great test unless have paired sera from a patient. Appearance
of H band from pt serum is suggestive of ongoing infection or relatively recent
infection (past two years). Loss of the H band is prognostically favorable.
Complement fixation is a reasonably good test, but complicated to perform
Antigen detection by radioimmunoassay. Works best for progressive infections.
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Mycology: Lifecycles and Pathogenesis
B. Blastomycosis (Gilchrist's disease, North
American blastomycosis)
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Endemic area is east of Mississippi and
the Ohio-Mississippi river valley
Agent: Blastomyces dermatitidis (sexual
name: Ajellomyces dermatitidis)
Epidemiology: probably from inhaling
microconidia from soil enriched with
wood. Recent infection cluster
associated with beaver dam.
Diseases is more frequently seen in dogs
(useful for diagnosis)
❍ After inhalation, conidia convert
to yeast form.
❍ Disease can occur in apparently
healthy individuals
❍ immune debilitation may allow
for systemic spread
Disease
❍ pulmonary infection that can
mimic TB. Relatively slow
developing. Alveolitis leading to
granuloma. May resolve or
develop into severe, progressive
pulmonary disease.
❍ One useful characteristic of the
disease is that skin and bone
lesions occur. These lesions may
be the first sign that causes
patient to recognize disease.
Osteolytic lesions are more
common in blasto than in other
systemic fungal diseases.
❍ In disseminated blastomycosis,
patients are seen with cutaneous
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Figure 2-28. B. dermatitidis seen on
impression smear.
Figure 2-29. Blasmomycosis, florid
pseudopitheliomatous hyperplasia.
Figure 2-30. Cutaneous blastomycosis.
Mycology: Lifecycles and Pathogenesis
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lesions more often than bone
lesions.
Diagnosis
❍ By microbiology and
histopathology
❍ The yeast phase is distinctive:
single budded cells with a broad
base bud.
Figure 2-31. B. dermatitidis, yeast phase.
Figure 2-32. B. dermatitidis, mould phase.
C. Coccidioidomycosis
(Posada's disease, desert rheumatism, desert
fever)
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Area of endemicity is southwest USA,
northern Mexico, South America (see
Figure 2-36)
Agents: Coccidioides immitis and C.
posadasii (considered by some to be the
most virulent fungus).
**1992 is the centennial of the first
description of the disease.
Epidemiology
❍ Susceptibility to disseminated
coccidioidomycosis is race
dependent:
■ Filipinos > blacks >
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Mycology: Lifecycles and Pathogenesis
whites
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Lifecycle
❍ Grows as septated, filamentous
fungus in desert soil.
❍ Produces aerobuoyant
arthroconidia
■ conidia grow to form
spherules in tissue (which
are somewhat similar to
sporangia in appearance)
■ Spherules are sac-like
thick-walled structures
containing roughly 100500 endospores.
■ When the spherules lyse,
they release the
endospores that can then
travel to other tissue sites
and begin a new round of
spherule production
Figure 2-33 Coccidiodes immitis, a) arthroconidia
b) growth of conidia (note alternating dead cells)
c&d) development of spherules
e&f) endospores inside spherules
Figure 2-35. C. immitis arthroconidia
Figure 2-34 C. immitis spherule releasing endospores
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Mycology: Lifecycles and Pathogenesis
Figure 2-36. Allergic coccidiodomycosis
FIGURE 2-37. Geographic distribution of coccidiodomycosis (left); Saprophytic and parasitic
life cycles of Coccidioides immitis (right)
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Mycology: Lifecycles and Pathogenesis
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Disease
❍ Mostly asymptomatic to mild
pulmonary disease
❍ incubation period is 10-16 days
after inhalation
❍ May manifest allergic reactions
■ patient becomes skin test
+ even if asymptomatic
■ Desert bumps: erythema
nodosum (but may see
erythema multiforme)
■ Desert rheumatism:
arthralgias and arthritis
❍ Secondary coccidioidomycosis
■ ca: 2-8% of symptomatic
infections
pulmonary cavity may be
seen
■ see calcifications with
resolution of 2° forms of
disease
❍ Disseminated coccidioidomycosis
■ usually resolves
spontaneously
■ Acute meningitis
■ Multiple cutaneous and
subcutaneous bone lesions
■ May follow reactivation
due to steroid therapy
■ chronic pulmonary
disease usually shows
"coin" lesion on X-ray
Diagnosis
❍ History of travel in endemic areas
❍ Coccidioidin skin test
❍ Examine sputum for spherules
(biopsy material may be required)
❍ Comp fix versus coccidiodin
(serology of cocci is improving
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Figure 2-38. Bilateral apical fibrocavitary
coccidiodomycosis
Mycology: Lifecycles and Pathogenesis
❍
because of spherule antigens
available)
X-ray of chest may not be
helpful
D. Paracoccidioidomycosis
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Endemicity: Central and South America
(humid, mountain forests)
Etiologic agent: Paracoccidioides
brasiliensis
❍ identification based on
microconidia
("pilot's wheel"
chlamydoconidia, arthroconidia
Fig. 2-40)
Disease
❍ Frequent oral lesions
❍ primary pulmonary disease may
be inapparent but dissemination
occurs
❍ development of disease is like
that seen with cocci and blastos
(single, expanding mass in lung)
❍ May cause chronic pulmonary
diseaseMay disseminate to skin,
spleen, liver, intestines
Figure 2-39. Mucocutaneous paracoccidioidomycosis
E. Penicilliosis
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Restricted to Southeast Asia
Due to Penicillium marneffei
Converts to yeast form with separation
of progeny by fission, i.e. dimorphic
Figure 2-40. P. brasiliensis, "pilot's wheel"
F. Cryptococcosis (Busse-Buschke's disease:
European blastomycosis)
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Worldwide distribution
Etiologic agent: Cryptococcus
neoformans, most common agent but
couple other are rarely implicated
(sexual name: Filobasidiella
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Mycology: Lifecycles and Pathogenesis
●
●
neoformans)
Yeast with galactoxylomannan
polysaccharide capsule (see Fig. 2-41)
Epidemiology
❍ Acquired by inhalation of dried
pigeon feces or sites
contaminated with pigeon
droppings.
❍ Organism does not do well
without high nitrogen content
Figure 2-41. Example of capsule around yeast cells
(Cryptococcus stained with India ink. x400)
Figure 2-42. Cryptococcal meningitis, little
inflammatory response (PAS)
Figure 2-43. Cryptococci in brain (PAS)
●
Disease
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Mycology: Lifecycles and Pathogenesis
Most asymptomatic but may cause extensive pneumonia and lung lesions. Lesions may
be X-ray transparent because organism stimulates fibrotic response. Unusual to get
calcification
❍ Meningitis is most common complication.
■ May be first sign of disease.
■ May get formation of large mucoid areas in brain.
■ Cryptococcosis may involve nearly all organs.
❍ May become disseminated to skin and bone.
■ Systemic disease is associated with individuals who are immunosuppressed.
■ Also especially associated with collagen diseases, e.g., lupus erythematosus
Diagnosis
❍ Culture of sputum or spinal fluid.
❍ India ink wet mounts
❍ Latex bead agglutination (Ab coated to detect Ag). CSF titer decreases with successful
therapy.
❍
●
E. Other opportunistic fungal diseases
●
●
●
Worldwide distribution
Organisms in this group cause serious disease in debilitated diabetics, leukemics, the
immunosuppressed, or persons exposed to a large number of spores.
❍ Aspergillosis: primarily caused by Aspergillus fumigatus
■ This organism produces aerobuoyant conidia
❍ Zygomycosis: primarily caused by Rhizopus, Mucor. Disease can be rapidly fatal.
With increase in immunosuppressed patients and AIDS patients, seeing emergence of fungi
previously considered unimportant or rare agents of disease. Typically, the manifestations of
these diseases are more protean than previously described. Examples: Trichosporon, Candida
krusei, Malassezia
For comments about the class: MedMicroCourse@Virginia.
edu
For comments about this page: [email protected]
Last Modified: Friday, January 10 2003
© 1998-2001 by the Rector and Visitors of the University of
Virginia
Disclaimer Statement
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Microbiology
Jordan Hall, 1300 JPA
PO Box 800734
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The Carnivorous Plant FAQ: Sporotrichosis
What is Silicosis or Sporotrichosis?
Silicosis is a disease which is caused by inhaling particles of silica sand. The
particles lodge in the lungs and irritate the tissue. Wearing a respirator when working
with sand is advised.
Regarding Sporotrichosis, I have transcribed and summarized an article written by
Darroll D. Skilling, principal plant pathologist at N. Carolina Forest Experiment Station,
1992 Folwell Ave., St. Paul MN 55108, from Carnivorous Plant Newsletter (with
permission from the editors of that journal:
Sporotrichosis is caused by the fungus
Sporotrichum schenckii, which has been
found in soil, flowers, shrubs, and even
wooden mine props. Also found in
Sphagnum. How the moss gets contaminated
is not clear, and attempts to detect the fungus
in Sphagnum bogs have not been successful,
but it has been found in bales arriving at
nurseries. The fungus is found throughout the
US, especially in Wisconsin. As of 1984,
state forest tree nurseries no longer pack
seedling trees in moss because of this. The
Michigan USDA Forest Service nursery also
Stage I: Infection
discontinued the use of Sphagnum. Infection
occurs when the spores of the fungus are
introduced through a small abrasion or scratch in the skin. In one to four weeks a
small painless blister develops at the entry site. This blister becomes inflamed and
slowly enlarges. Other areas may become infected as the fungus spreads through
the lymph vessels. Nodules may form along the infected lymph channels, and the
lymph glands in the armpit or elbow may become enlarged and sore. If untreated,
the disease progresses slowly to the bones, abdominal organs, and uninvolved
skin. But diagnosed early, the disease can be adequately treated and is rarely fatal.
Treatment is potassium iodine taken orally several times a day for up to three
months. Expect upset stomachs. I believe there is another treatment that has been
developed which is preferred over this. Newer information indicates some
uncertainty as to the fungal species.
http://www.sarracenia.com/faq/faq3880.html (1 of 3)6/16/2003 5:26:37 AM
The Carnivorous Plant FAQ: Sporotrichosis
Another poor sufferer (S.F.) told me the disease is also called "Rosarian's disease," and
wrote:
I was one of the lucky people to get this disease, two
years ago. I believe I got it because I had a small
puncture wound (a spider bite?), and then potted up
cp's without gloves. The wound on the back of my
hand widened and opened, and was ugly and refused
to heal. It didn't hurt really, just looked awful. After a
week or so, I went to a doctor who prescribed
antibiotics (no effect, since it's a fungal infection).
When I went to my regular doctor two weeks later
(he had not been available before), I mentioned that I
dealt with sphagnum and that I knew there was some
disease associated with it. He had vaguely heard of
Rosarian's disease, and read up on it while my hand
was x-rayed (to eliminate the foreign body idea). He
sent me to a dermatologist, who took a biopsy, and
eventually (two to three weeks later) confirmed the
diagnosis. He had never seen the disease, and made
me go to grand rounds (teaching hospital), so that
everyone else could see it. Great fun.
Stage II:
An advanced case
The treatment is three months of taking Potassium iodide by mouth... I had to add
it to water and drink it three times a day. Pain in the neck, and it tastes icky. But it
worked, and no problems now. If it is NOT treated, it can eventually become
systemic, and could eventually kill you. I am not any more likely to contract it
again than I was before.
I admit I still don't always use gloves, but I AM very careful if I have any kind of
wound on my hands! Beware! (Sept. 1999)
A friend tells me that an article in the AOS Bulletin reported that New Zealand
Sphagnum (once thought safe) can carry the fungus. The bottom line is, "How
contractible is this?" In my circles I know many people who use Sphagnum extensively,
and only two have gotten the disease. But to be safe, when I work with it I try to
remember to use a mask and gloves.
A synonym for the fungus is Sporothrix schenckii.
http://www.sarracenia.com/faq/faq3880.html (2 of 3)6/16/2003 5:26:37 AM
The Orchid Works
P.O. Box 355
Hakalau, HI 96710
Ph 808.963.6233
Fax 808.963.6736
glen@theorchidworks.
com
monica@theorchidworks.
com
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Deflasking
We are oncidiniae orchid plug producers. We grow orchid plants at the most critical stage of
development, when they come out of the flask and go into the nursery environment. Most losses
occur during the shock of switching from a sugar based growing media while in the flask to a
fertilizer only diet, in the nursery. Due to our extremely unique location on the windward side of
the Big Island of Hawaii we have the perfect climate for making this transition. We de-flask over
one million orchid plants a year and grow them to plug size, which takes about nine months.
Some of our products will bloom within one year of shipment, but most will bloom within two.
Take a look at some of our fine plants on the plant list.
Plant
Acquisitions
Current Specials
Plant Archive
http://www.theorchidworks.com/index.html7/2/2003 4:56:02 AM
Deflasking instructions
DEFLASKING
Many of you have asked about deflasking,
and for every orchid grower there is a
different and valid way to deflask. I will offer
you my methods which are from my
experience and closely resemble those of
The OrchidWorks.
TYPICAL FLASK
The methods I use are based on having
large robust plantlettes in the flask. If you
are working with something that looks like
grass or is only a half inch tall, well, good
luck, and if you find a sure fire method for
dealing with those kind of plants I would like
to hear about it, because, I buy those kind of
flasks from time to time too.
The ratio between the cost of the plants and
the cost of the container is so great that I
break all my flasks, including the $3
Erlenmeyer. Put a cloth over the glass
before striking it with your favorite devise.
Notice that our favorite devise hear at the
nursery is a pair of water pump pliers, I use
a roofers hammer at home.
Remove the plants from the broken glass
and gently agitate in a bucket of water until
the root loosen, the media falls away and
the plants can be easily separated. Grade
the plants according to size so the larger
ones won't create a canopy for the smaller
plantlettes.
http://www.theorchidworks.com/Deflasking.html (1 of 4)6/16/2003 5:40:45 AM
GETTING THE PLANTLETTES OUT
Deflasking instructions
If you have a lot of room to grow these
seedlings and they are large, healthy robust
plantlettes I prefer putting them into plug
trays. This gives them a lot of light and air. If
they are smaller I often put them into
community flats. If you don't have enough
plants to make a whole flat you may
consider using the standard community pot.
Everyone uses a different growing media
and I won't presume to tell you what the best
is for your specific conditions and growing
habits. Almost anything will work well as
long as the other ingredients to culture are
appropriate (light, water, fertilizer, air
movement, humidity, etc).
GRADING THE PLANTLETTES
I usually use New Zealand sphagnum moss
for my plugs, compots, and comflats. I am
always trying new media and I would
encourage you to do the same, who knows
what will work best for you.
After the plantlettes are planted I use a
broad spectrum fungicide to drench the
media and cover the plantlettes. Many a
compot has been lost by infections occurring
in the broken roots that lay in the media, and
then move up to the base of the plant. When
the plants are sprayed with a fungicide this
level of the plant, the root zone, won't be
affected by the spray, hence the drench,
http://www.theorchidworks.com/Deflasking.html (2 of 4)6/16/2003 5:40:45 AM
It's important to maintain the roots that come
from the flask. If you loosen and separate
the plants while they are in a pale of water,
the water acts as a lubricant and causes
less root damage. When potting or flatting, it
is necessary to maintain this caution. If all
the roots are broken the plant is set back
about four months, that is, if it survives.
Deflasking instructions
also known as a sprench.
Pesticides available here in Hawaii may not
be available in your state, and visa-versa.
Go to your farm supply and ask for a broad
spectrum fungicide that is labeled for orchids
or ornamentals that can be used in a
greenhouse.
Depending on your conditions you will want
to spray, drench, or sprench as often as
necessary. In my greenhouse that turns out
to be every couple of weeks.
COMPOTS
Most of the oncidiinae varieties at this young
stage will do just fine with 1,500 foot candles
of light. If your temperatures are cool you
could add more light and if the temperatures
are warmer you may consider less light.
COMFLATS
http://www.theorchidworks.com/Deflasking.html (3 of 4)6/16/2003 5:40:45 AM
Never, ever, let them dry out!! I water and
fertilize a lot. Every watering is a fertigation.
In the summer they may be watered every
day if that's what it takes to keep them
damp. You will have to take into
consideration the moisture holding capacity
of the media, the temperatures, air
movement, etc. when determining your
watering frequency. Just remember, these
are not like cattleyas, if the roots go dry, the
roots die.
Deflasking instructions
This is the recipe I use at home and similar
to the recipe I use in the nursery. It has
worked well and I'm sure, if followed you too
will be successful.
If you have any questions or comment about
this page please give me a call or send me
an email.
Best regards and good growing from the
staff
http://www.theorchidworks.com/Deflasking.html (4 of 4)6/16/2003 5:40:45 AM
PLUG TRAY
ARTICLE
Distribution and Seasonal Occurrence of Forcipomyia taiwana
(Diptera: Ceratopogonidae) in the Nantou Area in Taiwan
YI-YUAN CHUANG, CHENG-SHING LIN,1 CHENG-HSUNG WANG,2
AND
CHIN-CHANG YEH3
Department of Entomology, National Chung Hsing University, Taichung, Taiwan 40227, Republic of China
J. Med. Entomol. 37(2): 205Ð209 (2000)
ABSTRACT We studied the distribution of Forcipomyia taiwana (Shiraki) in Taiwan, and found
this species almost island-wide. Midge seasonality was studied for 4 yr at 3 sites in Nantou, central
Taiwan, to identify the extent and causes of midge population outbreaks. The midge population in
1995 was signiÞcantly lower than in 3 other years because several typhoons inundated breeding sites.
Maximum populations of F. taiwana occurred in June, July, and August. There was a highly signiÞcant
correlation between the monthly abundance of F. taiwana and temperature and rainfall. A step-up
multiple regression indicated that temperature was the most important factor leading to the outbreaks of F. taiwana. Temperature increases from 15⬚C to near 30⬚C will increase the midge
abundance.
KEY WORDS Forcipomyia taiwana, distribution, population abundance, temperature, rainfall
THERE ARE 24 species of Forcipomyia (Lasiohelea) in
Taiwan; however, only Forcipomyia anabaenae Chan
& Saunders and F. taiwana (Shiraki) are blood-sucking pests (Lien 1989, 1991). F. anabaenae is distributed
in mountain areas in southern Taiwan. F. taiwana is a
very small (1.4 mm), slender midge. The larvae live in
dry or moderately moist soil around housing or in
shaded areas and barren soil around cultivated bamboo, tea, vegetables, or betel nuts. It is distributed
island-wide in urban and suburban habitats including
scenic sites and public parks and is one of the most
annoying blood-sucking pests in Taiwan.
Forcipomyia taiwana attacks exposed parts of the
body during the day, causing intense pruritis and
edema in sensitive individuals. Welts and lesions may
persist for several days. Bites sometimes are complicated by secondary infections (Sun 1967). Complaints
of annoying insects have increased gradually. These
pests constitute a serious problem in parks, summer
resort areas, and Þshing ponds, where they often drive
away visitors.
The outbreak and spread of this midge probably is
related to a shift in agriculture during 1988 Ð1989 in
Taiwan. Cultivated areas of tea, bamboo, and betel
nuts have increased in the lowlands and provide good
habitats for larval midges. Midge populations have
increased rapidly because of the decreased use of
insecticides for long-term, nonintensive crops. Studies
on the control of these midges are needed urgently.
1
Section of Entomology, Department of Zoology, National Museum of Natural Science, Taichung, Taiwan 40419, Republic of China.
2
Department of Public Health, National Taiwan University, Taipei,
Taiwan, Republic of China.
3
To whom correspondence should be sent: Department of Entomology, National Chung Hsing University, Taichung, Taiwan 40227,
Republic of China.
Variation in population numbers may be related to
weather, which may act directly as a stress or mortality
factor, or indirectly on resources and natural enemies
(Wolda 1978). Even in Taiwan there can be highly
unfavorable abiotic conditions, such as a long, dry
periods or wind and heavy rain. These may inßuence
population size in current or future generations.
In the current article, we describe an island-wide
survey for F. taiwana on Taiwan to delineate the infested area requiring midge control. We studied the
seasonal abundance of F. taiwana at 3 sites in Nantou,
Taiwan, to investigate if midge abundance may be
related to meteorological factors. These data may forecast midge outbreaks and direct pretreating areas infested with midge immatures.
Materials and Methods
The distribution of F. taiwana on Taiwan was studied from September 1990 to April 1991 at 84 sites in 15
counties. Each site was surveyed by 3Ð 4 persons who
aspirated females as they landed on exposed legs. Collections were made for 20 min at each site from 1300
to 1500 hours. Females were stored in 70% alcohol and
identiÞed at the laboratory. The collection sites were
selected by the County Environmental Protection
Unit and local people who were familiar with infested
locations.
Populations of F. taiwana in the Nantou area, Taiwan, were sampled on the 8th, 18th, and 28th of each
month from January 1992 to June 1996. The 3 selected
sites, including Loyuan, Shioufeng, and Chingshui in
Nantou County, are shown in Fig. 1. Host-seeking
females of F. taiwana were aspirated from the exposed
legs of collectors at each site. Each sample consisted
of 3 replicates from sites 100 m apart. Collection was
0022-2585/00/0205Ð0209$02.00/0 䉷 2000 Entomological Society of America
206
JOURNAL OF MEDICAL ENTOMOLOGY
Vol. 37, no. 2
Fig. 1. Map of sampling sites showing the distribution of F. taiwana on Taiwan. A triangle indicates the collecting site
at Loyuan, a square shows the collecting site at Shioufen, and a circle shows the collecting site at Chinshui. Solid circles
indicate positive sites.
March 2000
CHUANG ET AL.: F. taiwana IN TAIWAN
carried out from 1300 to 1500 hours for 20 min at each
site. Females were stored in 70% alcohol and later
identiÞed and counted.
Population abundance at each site was the average
counts for the 3 replicates. Data from the 3 sites collected for 3 separated days per month for 4 yr (from
1992 to 1996) were analyzed using the SAS package
and general linear models (GLM, SAS Institute 1988)
Before statistical analysis, data were transformed by ln
(y⫹1). Means for Þgures and tables were back transformed. Monthly temperature and rainfall were obtained from Tsusan Meteorological Station in Nantou
County ⬇10 km from each site. All data obtained from
the 3 sample sites were analyzed in relation to the
meteorological data using regression analysis.
Results
Forcipomyia. taiwana was distributed over most of
Taiwan (Fig. 1). Eleven counties including Taipei,
Taoyuan, Hsinchu, Taichung, Nantou, Changhua,
Yunlin, Chiayi, Tainan, Hualien, and Yielan were infested. Among these areas, Hualien (eastern), and
Nantou (central), and Tainan (southern) were infested most heavily.
Monthly abundance of F. taiwana was investigated
in Nantou, Taiwan, from January 1992 to June 1996
(Fig. 2). The mean abundance at each site during
different years and months are presented in Table 1.
Statistical analysis indicated that there were signiÞcant differences among sites, years, and months. There
also were signiÞcant differences among sampling days
(F ⫽ 9.38; df ⫽ 2, 317; P ⬍ 0.01). The 1st sampling day
was signiÞcantly lower than the remaining 2 sampling
days. There was no signiÞcant difference between the
2nd and 3rd sampling days.
Least signiÞcant difference (LSD) tests on the
mean number of T. taiwana occurrences at Loyuan,
Shioufen, and Loyuan indicated that abundance at
Shioufen was signiÞcantly lower than at the 2 other
sites (Table 1). There was no difference between
Loyuan and Loyuan. Yearly mean numbers of F. taiwana in 1995 was signiÞcantly less than the other 3 yr.
There were no signiÞcant differences among 1992,
1993, and 1994.
There was a signiÞcant interaction between sites
and years (F ⫽ 71.61; df ⫽ 6, 317; P ⬍ 0.01), sites and
months (F ⫽ 11.3; df ⫽ 22, 317; P ⬍ 0.01), sites and
replicates (F ⫽ 57.12; df ⫽ 4, 317; P ⬍ 0.01), years
and months (F ⫽ 32.28; df ⫽ 33, 317; P ⬍ 0.01), years
and days (F ⫽ 16.43; df ⫽ 6, 317; P ⬍ 0.01), years and
replicates (F ⫽ 3.69; df ⫽ 6, 317; P ⬍ 0.01), months
and days (F ⫽ 23.94; df ⫽ 22, 317; P ⬍ 0.01), and
months and replicates (F ⫽ 3.0; df ⫽ 22, 317; P ⬍
0.01). There was also signiÞcant second-order interaction among sites, years, and months (F ⫽ 5.8;
df ⫽ 66, 317; P ⬍ 0.01), among years, months, and
days (F ⫽ 17.05; df ⫽ 66, 317; P ⬍ 0.01), and among
sites, years, months, and days (F ⫽ 3.3; df ⫽ 176, 317;
P ⬍ 0.01).
Monthly variation in population abundance, temperature, and rainfall at Loyuan, Shioufen, and Chin-
207
shui in Nantou County are presented in Fig. 2. Abundance of F. taiwana was the highest in June, July, and
August. Monthly abundance of F. taiwana was not
signiÞcantly different among June, July, and August,
among April, May, August, September, and October,
between March and November, and among January,
February and December (Table 1).
Regressions between the abundance of F. taiwana
and temperature at Loyuan (F ⫽ 20.62; df ⫽ 1, 52; P ⬍
0.01), Shioufen (F ⫽ 18.45; df ⫽ 1, 52; P ⬍ 0.01), and
Chinshui (F ⫽ 9.42; df ⫽ 1, 52; P ⬍ 0.01) in Nantou
County were signiÞcant. Regressions between the
abundance of F. taiwana and rainfall at Loyuan (F ⫽
14.91; df ⫽ 1, 52; P ⬍ 0.01), Shioufen (F ⫽ 37.47; df ⫽
1, 52; P ⬍ 0.01), and Chinshui (F ⫽ 31.41; df ⫽ 1, 52;
P ⬍ 0.01) in Nantou County also were signiÞcant.
Comparison of the slopes of regression lines by analysis of covariance indicated that they were parallel
(F ⫽ 2.02; df ⫽ 2, 150; P ⬎ 0.05; F ⫽ 0.13; df ⫽ 2, 150;
P ⬎ 0.05). Regressions between the abundance of F.
taiwana and rainfall and temperature combined over
sites were signiÞcant as illustrated in Fig. 3 and 4. A
step-up multiple regression (Y ⫽ 5.74 X1 (temperature)⫹ 0.23 X2 (rainfall) ⫺ 90.18, R2 ⫽ 0.348) indicated that temperature was the most important factor.
Discussion
F. taiwana females deposit eggs on moist substrate,
and eggs cannot survive under prolonged drying. Larvae develop in substrates where there is more or less
the constant presence of water, air, and food. Larvae
are neither strictly aquatic nor terrestrial, but they
cannot develop without moisture. Midge larvae are
distributed on the soil surfaces covered with bluegreen algae and in areas using animal manure for
fertilizer (C.C.Y., unpublished data). Soil with high
concentrations of humus around buildings and shaded
areas have the highest production of F. taiwana.
Rainfall is the main factor inßuencing the maturation of larvae (Chen et al. 1979, 1982). During the
typhoon season, heavy rains usually destroy the larval
breeding habitats in Taiwan. The populations of
midges decline after a typhoon. There were 7 typhoons (Deanna in June; Faye and Gary in July;
Helen, Janis, and Kent in August; and Ryan in September) from June to September in 1995 and subsequently populations in 1995 were signiÞcantly lower
than during the other years.
Forcipomyia. taiwana adults aggregate in hedgerows
and agricultural Þelds ⬇2 m in height (Chen et al.
1979). These midges are weak ßyers and disperse only
⬇500 m from emergence sites. Blood-sucking activities are limited locally (Chou et al. 1985). Environmental modiÞcation of the larval and adult breeding
habitat may reduce midge breeding. Clearing shaded
areas and exposing the soil to full sun will reduce the
midge population. A successful control program requires thorough knowledge of the life history and
biology of the midge.
The population abundance of F. taiwana increased
gradually from January, peaked in June or July and
208
JOURNAL OF MEDICAL ENTOMOLOGY
Vol. 37, no. 2
Fig. 2. Monthly population abundance of F. taiwana at Loyuan, Shioufen, and Chinshui in Nantou County and monthly
changes in rainfall and air temperature in the Nantou area.
March 2000
CHUANG ET AL.: F. taiwana IN TAIWAN
209
Table 1. Mean number of midges per sample at 3 sites on
Taiwan between 1992 and 1996
Sites
Year
Loyuan ⫽ 58b 1992 ⫽ 80b
Shioufen ⫽ 47a 1993 ⫽ 63b
Chinshui ⫽ 69b 1994 ⫽ 62b
1995 ⫽ 26a
F ⫽ 103.06
F ⫽ 161.14
P ⬍ 0.01
P ⬍ 0.01
Months
Jan. ⫽ 6a May ⫽ 69c Sep. ⫽ 61c
Feb. ⫽ 9a June ⫽ 139d Oct. ⫽ 52c
Mar. ⫽ 26b Jul. ⫽ 136d Nov. ⫽ 18b
Apr. ⫽ 76c Aug. ⫽ 90cd Dec. ⫽ 8a
F ⫽ 374.81
P ⬍ 0.01
Means in the same column followed by the same letter were not
signiÞcantly different by LSD test (P ⬎ 0.05).
then declined. There was signiÞcant positive correlation between the population abundance of these insects and temperature. The abundance of F. taiwana
increased gradually as temperature increased from
15⬚C to near 30⬚C, but terminated around 30⬚C. F.
taiwana apparently cannot survive temperatures of
⬎30⬚C, which may explain why the midge is not found
in southern Taiwan (Fig. 1).
The blood-feeding activity of F. taiwana females
takes place outdoors from 1000 to 1500 hours. When
the temperature falls below 20⬚C, activity decreases. It
is postulated that in cold weather, more clothes are
worn, there are fewer exposed parts of the human
body, and therefore, less chance for midge bloodfeeding. F. taiwana reject blood-meal hosts except
humans (Yeh and Chuang 1996). Few sources of human blood are probably one cause of midge population decline during cold weather.
The signiÞcant interactions between site and other
main effects indicated that site effects were not constant, but varied over time (replicates, months, and
years). The effects of yearly, monthly, and daily sampling were the same. Dramatic differences in the
abundance of midges over time at the 3 sites was
illustrated in Fig. 2 and may explain why signiÞcant
interactions were present.
Acknowledgments
We thank G. P. Huang (Department of Zoology, National
Museum of Natural Science) for providing the graphs, and
Fig. 3. Mean number of midges collected at Loyuan,
Shioufen, and Chinshui in Nantou County plotted as a function of temperature.
Fig. 4. Mean number of midges collected at Loyuan,
Shioufen, and Chinshui in Nantou County plotted as a function of rainfall.
Cheryl Robbins (National Museum of Natural Science,
Taichung, Taiwan) for critical reading of the manuscript.
Thanks are extended to the anonymous reviewers and the
editor for their critical reading of the manuscript and valuable comments. We also thank the local EPA-85-13J1-09-07
and DEP-85-05-R-006 grants for Þnancial support.
References Cited
Chen, C. S., S. J. Hsu, and J. C. Lien. 1982. Seasonal succession of a blood-sucking midge, Forcipomyia (Lasiohelae) taiwana (Shiraki) (Diptera: Ceratoponidae) in the
Hualien area. Phytopathol. Entomol. Natl. Taiwan Univ.
9: 68 Ð90 (in Chinese).
Chen, C. S., Y. N. Lin, C. L. Chung, and H. Hung. 1979.
Preliminary observation on the larval breeding sites and
adult resting places of a bloodsucking midge, Forcipomyia
(Lasiohelea) taiwana (Shiraki) (Diptera: Ceratopogonidae). Bull. Soc. Entomol. Natl. Chung-Hsing Univ.
Taiwan 14: 51Ð59.
Chou, C. C., J. C. Lien, and C. H. Wang. 1985. Medical
entomology. Nansan, Taipei (in Chinese).
Lee, T. S. 1975. Blood-sucking midges in Guandong and
Guanxi. Bull. Chinese Entomol. 18: 433Ð 436 (in Chinese).
Lien, J. C. 1989. Taxonomic and ecological studies on the
biting midges of the subgenus Lasiohelea, genus Forcipomyia from Taiwan. J. Taiwan Mus. 42: 37Ð77.
Lien, J. C. 1991. Seven new species and four new records of
Forcipomyia subgenus Lasiohelea from Taiwan (Diptera:
Ceratopogonidae). J. Taiwan Mus. 44: 83Ð116.
Shiraki, T. 1913. Investigation on general injurious insects. Taiwan Sotokufu Noji Shikenjo Tokubetsu Hokodu 8: 286Ð297.
SAS Institute. 1988. SAS/STAT userÕs guide, version 6.03 ed.
SAS Institute, Cary, NC.
Sun, W.K.C. 1961. A tentative list of Ceratopogonidae
(Diptera) recorded from Taiwan. Biol. Bull. Tunghai
Univ. (Taiwan) 6: 1Ð16.
Sun, W.K.C. 1967. Study of a biting midge, Forcipomyia (Lasiohelea) taiwana (Shiraki) (Diptera: Cerapogonidae)I.
Description of the complete life cycle of the midge reared
in the laboratory. Biol. Bull. Tunghai Univ. (Taiwan) 29:
1Ð10.
Wolda, A. 1978. Fluctuations in abundance of tropical insects. Am. Nat. 112: 1017Ð1045.
Yeh, C. C., and Y. Y. Chuang. 1996. Colonization and bionomics of Forcipomyia taiwana (Diptera: Ceratopogonidae) in
the laboratory. J. Med. Entomol. 33: 445Ð448.
Received for publication 24 August 1998; accepted 22 June
1999.
Arboviruses - DrGreene.com
Arboviruses
Related concepts:
West Nile virus, Yellow fever, Dengue fever, Colorado tick fever, St. Louis
encephalitis, Western and Eastern equine encephalitis, Japanese encephalitis,
California encephalitis, La Crosse virus
Introduction:
The West Nile virus has been in the news in recent years, but it is only one
example of the arboviruses, a group than can and does cause serious illness. The
La Crosse virus, for example, causes more damage each year than West Nile.
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What is it?
The arboviruses (arthropod-borne viruses) are a group of viruses that are spread
by mosquitoes, ticks, or sand flies. They have complex life cycles that depend on
both the arthropod and the birds or small mammals that are their hosts. Birds are
usually the preferred host.
Multimedia Library
Encephalitis in horses or mules may be the first warning sign of a brewing
epidemic in an area. Veterinarians are often the first to know.
When humans become infected, they are generally a dead-end for the virus life cycle. More than 150 different
arboviruses cause human illnesses.
Who gets it?
These viruses are common in birds and small mammals, and are accidentally spread to people who are bitten by
mosquitoes, ticks, or sand flies that have fed on these infected animals. Dengue fever and yellow fever can be
transmitted from one person to another via mosquito.
Arboviruses tend to primarily affect the young and the elderly. So far, the West Nile virus has primarily targeted the
elderly.
What are the symptoms?
In humans, the arboviruses can produce four different major sets of symptoms:
1.
2.
3.
4.
Encephalitis (or other infection of the central nervous system)
Non-specific fever, perhaps with a rash
Pain in multiple joints
Acute hemorrhagic fever (fever, generalized bleeding, and shock)
The individual viruses can also produce other symptoms, such as pain behind the eyes in dengue fever or heart
disease in Colorado tick fever.
http://www.drgreene.com/21_1028.html (1 of 7)6/25/2003 5:35:18 AM
Arboviruses - DrGreene.com
Is it contagious?
These diseases are not spread directly from person to person except by blood transfusion. Most arboviruses are not
spread from person to person even with an arthropod intermediary. Dengue and Yellow fever are exceptions.
How long does it last?
The incubation period varies from about one to 18 days following the bite (depending on the virus). The length of the
disease varies considerably.
How is it diagnosed?
These diseases may be diagnosed with tests of the blood or spinal fluid.
How is it treated?
Carefully monitoring and managing fluids, blood pressure, breathing and bleeding while the disease runs its course
often saves lives.
How can it be prevented?
The primary means of prevention is to avoid bites by dangerous species of mosquitoes, ticks, and sand flies. Different
species predominate in different geographic areas. Some, for instance, are mostly twilight feeders. Others favor the
heat of the day. Protective clothing, insect repellant, and wise choices of outings are all helpful.
Vaccines are available to prevent some arbovirus infections, such as Yellow fever and Japanese encephalitis.
Alan Greene MD FAAP
May 31, 2002
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Alleviating Eczema
Alternative to Tubes for Ear Infection Treatment
Antibiotic Dosages
Antibiotic Overuse
Antibiotics and Ear Infections
Antidepressants and Nursing
Biting
Blood Types 101: An Introduction to ABO Blood Types and the Rh System
Breast Buds
Breast Cancer -- A Story of Survival
Breast Infections
Breastfeeding with a Metabolic Disorder & Propionic Acidemia
Breath Holding Spells
Café-au-lait spots and Neurofibromatosis
Cat-Scratch Disease
Causes of Ear Infections
Chances Of Having A Second Baby With Trisomy 13
Chapped Lips
Chickenpox Vaccine
Childhood Obesity
Children and Gray Hair
Choosing Faith
Circumcision
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FS640
Fact sheet
www.rce.rutgers.edu
Greenhouse Screening for
Insect Control
Gerald M. Ghidiu, Ph.D., Specialist in Entomology &
William J. Roberts, Ph.D., Specialist in Agricultural Engineering
Greenhouses that produce vegetables or ornamentals provide an excellent environment for various
insect pests. These pests are generally very difficult
to control once they enter the greenhouse, partly
because of the physical conditions within the greenhouse, absence of natural enemies, and the lack of
insecticides registered for use in greenhouses, especially vegetable houses (refer to FS639, “Insecticides for Greenhouse Vegetables,” for labeled
insecticides). Further, once these insect pests invade
a house, they may rapidly spread to nearby,
uninfested greenhouses, being introduced on clothing,
equipment or by flying directly through an opening
into the house.
Screening on ventilation inlets and building entrances will prevent most, if not all, vegetable insect
pests from flying into the house. Selection of the
proper screen for a greenhouse depends on the size
of the insect to be excluded. Dr. J. Bethke, University
of California, Riverside, has found that the following
common insect pests of greenhouses can be excluded
using screen with the hole sizes (or smaller) shown in
Table 1.
TABLE 1.
Insect pests
leafminers
whiteflies
aphids*
flower thrips
Screen hole size
microns
inches
mesh
640
0.025
40
462
0.018
52
340
0.013
78
192
0.0075
132
* Although aphids are larger than whiteflies, finer
mesh screens may be needed because of differences in wing placement against the body.
However, screens create resistance which reduces airflow, and the smaller the hole size, the
greater the resistance. Screens placed in front of
ventilation inlets reduce the amount of air passing
through the inlet, and may prevent ventilation fans
from operating efficiently. Thus it is important to use
the proper size and mesh screen.
To determine the area of screening needed for a
specific screen mesh (hole size), follow the steps
listed below:
1. Calculate the volume of the greenhouse
(example: a 100' x 100' house with a 10' eave
height = 100,000 cubic feet). If a thermal
screen is used, multiply the calculated house
area by 7.5' eave height instead of 10'.
2. Select the mesh size to screen out the specific insect pest from Table 1 (example: 52
mesh).
3. From Table 2, determine the approach velocity (example 52 mesh = 264)
4. Divide Step 1 by Step 3 to get required area
of screen (example: 75,000 ÷ 264 = 284
square feet).
5. Divide the required area of screen calculated
in Step 4 by the house length to obtain the
screen area required per foot of building
(example: 284 ÷ 100 = 2.8 sq ft needed per
foot, or almost 3 ft2 per ft). Note that the
smaller the approach velocity figure, the
tighter the screen, and thus the greater the
area of screen required for adequate airflow.
TABLE 2.
Screen or screen size
Chicopee 32 mesh
60 mesh, stainless steel
Chicopee 52 mesh
Nylon screen, 68 mesh
Filter Fly Bar new
Woven fabric, random
Econet T
Approach velocity (ft/min)*
336
303
264
253
211
192
110
*velocities for an allowed pressure drop of 0.03" of
water.
Selecting a material with a finer screen mesh will
require a larger inlet area depending upon the approach velocities listed in Table 2. These figures
show that Econet T (approach velocity 110), which is
recommended for thrips exclusion because of the fine
mesh, allows only 1/3 the air to pass through, and thus
requires 3 times the area, as does Chicopee 32
(approach velocity 336) under the same conditions.
Screens will slowly foul and become clogged
with dirt and their resistance to airflow will increase.
The use of a manometer to measure static pressure
will help to determine when screens are becoming
clogged. Periodic cleaning of the screens will reduce
resistance drop.
Insect sticky traps placed throughout the house
(refer to FS638, “Sticky Board Traps for Greenhouses”) will trap insects present in the house.
Frequent monitoring will give an estimate of the
populations and the effectiveness of the screening.
Further information concerning screening for
insect pests of greenhouses can be obtained from the
Department of Bioresource Engineering, Cook College, Rutgers University, New Brunswick, New
Jersey, 08903.
Information in this reference appears with the understanding that no discrimination is intended and
no endorsement by RUTGERS COOPERATIVE EXTENSION is implied.
Desktop publishing by the Cook College/NJAES Office of Communications and Public Affairs
750-9402
Printed on recycled paper
RUTGERS COOPERATIVE EXTENSION
N.J. AGRICULTURAL EXPERIMENT STATION
RUTGERS, THE STATE UNIVERSITY OF NEW JERSEY
NEW BRUNSWICK
Distributed in cooperation with U.S. Department of Agriculture in furtherance of the Acts of Congress of May 8 and June 30, 1914. Cooperative Extension work in
agriculture, home economics, and 4-H. Zane R. Helsel, director of Extension. Rutgers Cooperative Extension provides information and educational services to all people
without regard to sex, race, color, national origin, disability or handicap, or age. Rutgers Cooperative Extension is an Equal Opportunity Employer.
ANTI-VIRUS AND
NO-THRIPS
“SCREEN OUT” THESE PESTICIDE HEADACHES
•
•
Skyrocketing costs
The new “Worker Protection Standard”
Regulations
•
•
Increasing concerns about Groundwater
OSHA/EPA/local chemical handling
hassles
ANTI-VIRUS AND NO-THRIPS INSECT SCREEN SELECTION CRITERIA
INSECT PEST
TO BE EXCLUDED
INSECT SIZE INCH (microns)
SCREEN
TYPE TO USE
SCREEN HOLE
SIZE - INCH (microns)
PERFORMANCE
Leafminer
0.025 (640 microns)
Anti-virus
0.0105 x 0.0322 (266 x 818 microns)
100%
Melon Aphid
0.013 (340 microns)
Anti-virus
0.0105 x 0.0322 (266 x 818 microns)
100%
Whitefly
0.018 (462 microns)
Anti-virus
0.0105 x 0.0322 (266 x 818 microns)
100%
Western Flower Thrips
0.0075 (192 microns)
No-Thrips
0.0059 x 0.0059 (150 x 150 microns)
100%
Given the increased problems and costs associated with pesticides, no modern greenhouse should be
without the proper insect barrier. Green-Tek Insect Screens, correctly installed, prevent insect
penetration, yet provide maximum possible air flow, essential for optimal crop yields.
Regardless of the cooling and ventilating system that you use, you need to consider insect screen.
Screening intake vents will produce dramatic results, but all greenhouse openings, including service
doors (which should incorporate double screened doors), should be screened for best results.
ANTI-VIRUS Insect Screen excludes Whitefly, Aphids, Leafminers and up to 80% of Western Flower Thrips
in field applications. Several years of
laboratory and field testing have
resulted in a patented screen structure
that maximizes air circulation, while
keeping pests out. Special equipment
has been developed to ensure hole size
accuracy, and a 0.24 mm diameter yarn
is used, which is 45% stronger with
greater UV resistance, compared to 0.20
mm diameter standard yarns.
ANTI-VIRUS
NO-THRIPS
INSECT SCREEN
INSECT SCREEN
NO-THRIPS Insect Screen is designed to
exclude Thrips and other pests, and is
the material of choice where Thrips
exclusion is priority.
1-800-747-6440
Tel: 608-884-9454 • Fax: 608-884-9459
www.green-tek.com
407 N. Main Street • Edgerton, WI 53534 USA
Decrease unwanted pests and
expensive pesticide usage
NATURALLY!
Insect
Screens
Our unique
computer software
helps you check
insect Screen sizing
in minutes!
Give us a call!
TECHNICAL DESCRIPTION
of high tensile-strength round
• Made
polyethylene monofilaments.
• UV stabilized.
• Transparent.
structure results in maximized air
• Unique
circulation, to enable higher yields.
SPECIFICATIONS
Construction
Opening Size
Thread Size
Weave
Weight
Shade Value
Light Transmission
Standard Width
Length
UV Resistance
• Lightweight and easy to install.
woven and tucked in selvages - even if
• Strong
mechanically punctured, the screen will
keep its strength and stability.
cleaned with power sprayers by back
• Easily
flushing.
ANTI-VIRUS
NO-THRIPS
50 x 24 mesh
0.0105" x 0.0322"
.24 mm
1/1
0.33 lbs/yd 2
20%
80%
43, 63, 78, 118, 141 inches.
Custom widths also available.
Special order 59 and 98 inches.
Orders cut to size.
Tested to equivalent of five
years field experience.
81 x 81 mesh
0.0059" x 0.0059"
.15 mm
1/1
0.216 lbs/yd2
33%
66%
39 and 78 inches
Custom widths also available.
Orders cut to size.
Tested to equivalent of three
years field experience.
INSTALLATION
1. Check that the frame, structure or wall to which the
insect screen will be fastened is as square as
possible, to eliminate twisting or shortage of fabric.
2. Metal parts should not touch the screen. In the
summer, heat accumulates in metal parts, and
might damage the plastic screen. Therefore, it is
important to cover metal parts with white water
based latex paint or white tape to protect the
screen.
3. When you install the screen, keep the screen square
and parallel to the sides of the greenhouse. This will
keep the fibers of the screen parallel. If the fibers are
not parallel to the greenhouse sides, the screen will
be shortened in length and in width.
4. When you install several screens together which
have not been stitched, you should connect the first
screen to the sides of the greenhouse. Then,
connect the second screen to the first one and to
the greenhouse sides. Continue in that way until the
entire greenhouse is covered.
Distributor
1-800-747-6440
Tel: 608-884-9454 • Fax: 608-884-9459
www.green-tek.com
407 N. Main Street • Edger ton, WI 53534 USA
Pest Data Sheet
Ralstonia solanacearum race 3 biovar 2
February 12, 2003
USDA/APHIS/PPQ
Center for Plant Health Science and Technology
Plant Epidemiology and Risk Analysis Laboratory
Raleigh, NC
Prepared by:
Andrea Lemay, Plant Pathologist
Scott Redlin, Plant Pathologist
Glenn Fowler, Entomologist
Melissa Dirani, Biologist and Technical Writer
PEST DATA SHEET
Ralstonia solanacearum Race 3 Biovar 2 (Smith) Yabuuchi et al.
TAXONOMIC POSITION
Kingdom: Proteobacteria
Class: Neisseriae
Order: Burkholderiales
Family: Burkholderiaceae
HOSTS
Primary hosts: Solanum tuberosum (potato) (CABI, 2001), Lycopersicon esculentum
(tomato) (CABI, 2001)
Other solanaceous plants: S. melongena (eggplant) (NPAG, 2001b), S. nigrum (black
nightshade) (NPAG, 2001b), S. dulcamara (bittersweet or climbing nightshade)
(PLANTS Database), and Datura stramonium (NPAG, 2001b).
Other non-solanaceous hosts include: Brassica spp. (Janse et al., 2002), Cerastium
glomeratum (Pradhanang et al., 2000), Chenopodium album (Janse et al., 2002),
Drymaria cordata (Pradhanang et al., 2000), Melampodium perfoliatum (NPAG, 2001b),
Pelargonium hortorum (geranium) (NPAG, 2001b), Polygonum capitatum (Pradhanang
et al., 2000), Portulaca oleracea (NPAG, 2001b), Stellaria media (Pradhanang et al.,
2000), Tropaeolum majus (Janse et al., 2002), Urtica dioica (PLANTS Database;
Wenneker et al., 1999).
Wild hosts: Solanaceae (CABI, 2001)
DISTRIBUTION
Worldwide:
EPPO Region: Belgium, Germany, Hungary, Netherlands, Spain, Canary Islands,
United Kingdom, England, Lebanon (CABI/EPPO, 1999)
Asia: Bangladesh, China (Fujian, Guangdong Guangxi, Hebei, Jiangsu, Taiwan,
Zhejiang), India (Himachal Pradesh, Madhya Pradesh, Maharashtra, Manipur,
Meghalaya, Tamil Nadu, Tripura, Uttar Pradesh, West Bengal), Indonesia (Java), Iran,
Japan (Kyushu), Nepal, Pakistan, Philippines, Sri Lanka (CABI/EPPO, 1999)
Africa: Burundi, Egypt, Kenya, Libya, Réunion, South Africa, Zambia (CABI/EPPO,
1999)
South America: Argentina, Bolivia, Brazil (Goias, Parana, Pernambuco, Rio Grande do
Sul, Santa Catarina, Sao Paulo), Chile, Colombia, Peru, Uruguay (CABI/EPPO, 1999)
Central America and Caribbean: Costa Rica, Guadeloupe, Mexico (CABI/EPPO,
1999)
Oceania: