Import regulations comment period.

This is for anyone interested in importing or exporting seeds or plant
stock.  Note the time limit.
>
>Dear All,
>
>This is just a reminder that the final date for public comment on the new
>"Requirements for Requests To Amend Import Regulations" Docket No. 02-132-1
>is December 27th.
>
>Please pass this along to other mailing lists.
>
>The "amending" of regulations refers to requests to add a plant to the list
>of commodities that are allowed entry into the US.
>
>This is the next stage in the implementation of "risk assessment" - if you
>enjoyed the recent phytosanitary certificate requirement, this should be of
>interest. The new regulations are intended to apply to "commodities", but
>will apply to nursery stock as well. Application to seeds should be phased
>in during the next five years.
>
>Go to:
>http://www.pestlaw.com/x/fedreg/2004/USDA-20041028A.html
>for text of the regulation.
>
>Go to:
>https://web01.aphis.usda.gov/regpublic.nsf/0/1e1016291df0b29f87256f41006acac
>1?OpenDocument
>to read comments from a nurserywoman on this.
>
>Got to:
>http://comments.regulations.gov/EXTERNAL/Comments.cfm?DocketID=04-24150&CFID
>=56963&CFTOKEN=98463295
>for how to comment.
>
>If these links don't work, just do a search on "Docket No. 02-132-1" and you
>will find it all.
>
>You have to plow through a lot of bureaucratese to get to the most alarming
>parts - these are just PART of what they will require from importers:
>
>"Description of all pests and diseases associated with the commodity
>proposed for exportation to the United States:
>
>Scientific name (including genus, species, and author names) and taxonomic
>classification of arthropods, fungi, bacteria, nematodes, virus, viroids,
>mollusks, phytoplasmas, spiroplasmas, etc., attacking the crop,
>
>Plant part attacked by each pest, pest life stages associated with each
>plant part attacked, and location of pest (in, on, or with commodity), and
>References."
>
>And further down:
>
>"We are requesting public comment as to whether some or all of this
>additional information should be required to be submitted with the
>information described above, whether some or all of the information should
>be considered 'optional,' or whether APHIS should require submission of some
>or all of the information only if we deem it necessary during the course of
>our consideration of a request."
>
>There has been some talk about making the above "optional" for nursery
>stock, but we would do well to remember how the phytosanitary certificate
>was "optional" for flowerseed... until the recent outbreak of BSE
>(bureaucratic spongiform encephalitis), or "mad bureaucrat disease" struck
>the USDA.
>
>(Hey, its just a joke! I have good friends in the USDA. Lighten up!)
>
>Although this proposed rule change is said to apply "only" to fresh fruits
>and vegetables, logs, and other "commodities", it DOES apply to "Nursery
>Stock (planted in media)", and to "Cut flowers". This will not yet affect
>the seed exchange, but will affect importation of other plant parts. This
>could easily be interpreted as applying to all plant parts, as seed is
>included in other USDA definitions of nursery stock, and unrooted cuttings
>could be considered "cut flowers", and roots, leaves, and other plant parts
>are specified in the regulations, and various purposes including propagation
>are included.
>
>Also, it should be noted that this is just the first part of the phase-in of
>this so-called "risk assessment". See:
>
>"Safeguarding recommendation E-49 recommends that APHIS "Coordinate noxious
>weed and invasive species initiatives with review of 7 CFR 319.37 and
>330.200 based on rigorous risk assessment". This recommendation was assigned
>to the Authorities Safeguarding Issue Group, and it is being addressed in a
>combined action plan for recommendation E-4 which states "Begin its
>quarantine revision process with the revision of its Fruits and Vegetables
>(Q56) and Nursery Stock (Q37) quarantines. Target completion within 5
>years". This action plan has already been submitted to the Steering
>Committee."
>
>This was four years ago.
>
>Anyone who doesn't take this seriously, should consider that regulations
>currently proposed in South Africa are specifically intended to curtail the
>import of ALL new species - only those species that can be demonstrated to
>be potential high-value new crops would be allowed - everything else is
>considered a "frivolous importattion". Rock gardening would certainly be
>considered "frivolous".
>
>With globalization there is a strong move towards international consistency
>in law - the Codex Alimentarius is one example, and European Union food laws
>another (these are currently destroying local, artisanal foods production in
>European villages).
>
>Yes, Virginia, it CAN happen here.
>
>Now, most of all this will not affect us - yet. I suspect that most of the
>information required will be waived for small shipments of nursery stock -
>to start with. There will be no sudden, sweeping implementation, but a
>gradual phase-in - the frog in the pan of heating water syndrome.
>
>But until there is an explicit recognition on the part of the USDA of the
>conservation value of the easy importation of small quantities of
>propagative material of a wide variety of plants, until there is an explicit
>exclusion of seeds and small shipments of plants, cuttings, or roots, I feel
>we should oppose such regulation.
>
>(I know, someone is sure to bring up SOD - remember that there is lots of
>somewhat dubious information floating around about it, and quite a bit of
>fuzzy thinking going on. Give it a good think-through before you raise the
>subject.)
>
>But wait, that's not all you get, there's more!
>
>"Additional information about the commodity:
>
>Common name(s) in English and in the language(s) of the exporting country,
>Cultivar, variety, or group description of the commodity, Stage of maturity
>at which crop is harvested and method of harvest, Indication of whether crop
>is grown from certified seed or nursery stock, if applicable, If grown from
>certified seed or stock, indication of the origin of the stock or seed
>(country, State), and Color photographs of plant, plant part, or plant
>product itself.
>
>Information about the area where the commodity is grown:
>
>Unique characteristics of the production area in terms of pests or diseases,
>
>Maps of the production regions, pest free areas, etc.,
>
>Length of time commodity has been grown in production area,
>
>Status of growth of production area (i.e., acreage expanding or stable), and
>
>Physical and climatological description of the growing area.
>
>Information about post-harvest transit and processing:
>
>Complete description of the post-harvest processing methods used, and
>
>Description of the movement of the commodity from field to processing to
>exporting port (e.g., method of conveyance, shipping containers, transit
>routes, especially through different pest risk areas).
>
>Shipping methods and volume of exports:
>
>Photographs of the boxes and containers used to transport the commodity, and
>
>Identification of port(s) of export and import and expected months (seasons)
>of shipment, including intermediate ports-of-call and time at intermediate
>ports-of-call, if applicable.
>
>Additional description of all pests and diseases associated with the
>commodity to be imported:
>
>Common name(s) of the pest in English or local language(s),
>
>Geographic distribution of the pest in the country, if a quarantine pest and
>follows the pathway,
>
>Period of attack (e.g., attacks young fruit beginning immediately after
>blooming) and records of pest incidence (e.g., percentage of infested plants
>or infested fruit) over time (e.g., during the different phenological stages
>of the crops and/or times of the year),
>
>Economic losses associated with pests of concern in the country, Pest
>biology or disease etiology or epidemiology, and Photocopies of literature
>cited in support of the information above.
>
>Current strategies for risk mitigation or management:
>
>Description of pre-harvest pest management practices (including target
>pests, treatments [e.g., pesticides], or other control methods) as well as
>evidence of efficacy of pest management treatments and other control
>methods,
>
>Efficacy of post-harvest processing treatments in pest control,
>
>Culling percentage and efficacy of culling in removing pests from the
>commodity, and
>
>Description of quality assurance activities, efficacy and efficiency of
>monitoring implementation.
>
>Existing documentation:
>
>Relevant pest risk analyses, environmental assessment(s), biological
>assessment(s), and economic information and analyses."
>
>NOW how much would you pay?!!
>
>Hmmm... "Photographs of the boxes and containers used to transport the
>commodity" What could be more fun?
>
>Their estimate of how much time it would take to assemble and report this
>information:
>
>"Estimate of burden: Public reporting burden for this collection of
>information is estimated to average 2 hours per response. Respondents: U.S.
>importers, foreign producers and regulatory officials."
>
>Just what ARE they smoking down there at the USDA?
>
>Now lots of the above regulation might actually make some sense - if applied
>to shiploads of raw sawlogs, or thousand-ton imports of agricultural
>commodities. But certainly not to any imports of less than a couple of
>hundred tons, or under a million dollars in value, much less small imports
>of nursery stock. These should be inspected by the USDA on arrival (at no
>charge - isn't that what we pay taxes for?).
>
>Happy holidays!
>
>David Theodoropoulos
>La Honda, California, USA
>USDA Zone 10 (most years)
>Rare (10-20 year) freezes of -7C.
>http://dtheo.org
>www.invasionbiology.org
>dtsc@rahul.net
>
Richard F. Dufresne
1216 Okeeweemee-Star Road
Star, North Carolina  27356 USA
910-428-4704
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