The International Plant Protection Convention New Standard Proposal

Submitted by Peter George on

I'm re-posting the following from Alpine L, given it's importance. There are only two posts so far, the first from Joyce Fingerut, and the second from Tony Avent. I'll post Tony's separately. I suggest that one of the moderators contact both Joyce and Tony and suggest that they post here in the future, as Alpine L is just about run its course.

"You may be interested to note - and to read - the following Draft Standard: Integrated Measures Approach for Plants for Planting in International Trade

The International Plant Protection Convention (IPPC; https://www.ippc.int/IPP/En/default.jsp)
is proposing a new Standard concerning the international movement of Plants for Planting. Their website contains the draft standard, which is now open for comment by the member countries of the IPPC.
(Go to: https://www.ippc.int/index.php?id=207803
See Draft 3, and click on the appropriate language in the Publication column;
or contact me for a pdf file)

An International Standard sets guidelines, not rules, that the signatory countries (all 173 of them) have agreed to follow when formulating their own regulations/rules governing imports and exports. While this Standard excludes seeds, it will eventually have a direct effect on the export/import of plants around the world, so many of our fellow plant society members will be affected by the resulting national regulations.

The latest thinking concerning the problems of pests associated with the movement of plants around the world is that these problems are best mitigated at the source, by the exporters (place of production), rather than caught by the importers (pest risk analyses, inspections). See page 5 for a quick summary of the underlying reasoning. Ideally, if each country based its phytosanitary standards on the same philosophy, there would be no discrepancies in the level of requirements (just the specifics of pests and types of mitigations measures).

Regulations written by any country may only pertain to "quarantine"
pests: i.e.: those with known negative economic effects, that are not already present in the importing country (or present in limited numbers, with an official control program). However, in protecting against known pests, an integrated measures approach may additionally protect against pests that are currently unknown to science or the industry.

The "Requirements" list offers factors that should be considered by each country's National Plant Protection Organization (NPPO) when proposing measures to deal with pest risk management. Factors, within production and use, are broadly ranked in order of their increasing risk level.

"General Integrated Measures" describes the overall controls that should be exercised by any place of plant production in order to be "authorized" to grow plants for export, including production, storage, movement of plants - as well as recording of all relevant information (plans, manuals, inspections, etc.).

Keep in mind that Standards are only guidelines, offering factors that
should be taken into account when proposing national regulations.
Governments will eventually draft specific rules, depending upon their
chief production crops, and their primary trading partners.
Naturally, each country, and its plant industry, would prefer to minimize its level of control on production/export (which can be
costly to initiate) and maximize the requirements for imports.
However, by international agreement, these phytosanitary requirements must not act, in lieu of tariffs, as a barrier to trade. It is hoped that, in the end, with each country monitoring and mitigating its own pest risks, all countries will benefit by seeing a reduced incidence of new pests, with their resulting negatvie economic and/or environmental impacts.

To send comments, or ask questions, please see https://www.ippc.int/index.php?id=1110520&no_cache=1&type=contactpoints&L=0
...for the contact organization for your country. The names of the officials may be somewhat out of date, but it will set you in the right direction. Comments are sent via your country representative, not directly to the IPPC.

For preliminary questions, before your contact your NPPO, I will be glad to help where I can."

Joyce Fingerut
Stonington, CT
Zone 6

Comments

Submitted by Peter George on Wed, 08/04/2010 - 09:17

(Here are Tony's comments, following my suggestion that he and Joyce post their comments here on the NARGS Forum)

Peter:

I haven't had time to figure out how that works, but feel free to post my comments there.

Joyce:

I don't have time to read the proposed regs at this time, but will offer a couple of comments on what I know of these idea.  In my plant exploration travels, I have only found about 8 countries, whose phytos are worth the paper they are printed on.  All other phytos are worthless!  This current thinking, which is more appropriately a lack thereof, assumes that all countries can issue meaningful phytos.  When you start with an incorrect assumption, it always leads to incorrect conclusions.  The idea that places of production should be inspected is also rife with problems, (i.e.
competence of inspectors for a start), but also allows no method for plant explorers to get phytos.  It's easily for bureaucrats who propose these to send off an email and ask if each county can comply with their new regulations.  Guess what, the answer is always, YES.  If we could only get the people who propose these idiotic regulations to do the "secret shopper" test, they would quickly see that most of their ideas simply don't work in the real world. 

Tony Avent
Plant Delights Nursery @
Juniper Level Botanic Garden
9241 Sauls Road
Raleigh, North Carolina  27603  USA

Submitted by Peter George on Wed, 08/04/2010 - 10:51

Tony -
I certainly understand your concerns about bringing back plants collected either in the wild - or from someone's cultivated garden. 
That will be a good point to make, and I will add it to my own comments to APHIS (the U.S.'s NPPO).

As for disparaging existing phyto-writers, that's probably not the most helpful argument (truth or validity, aside).

Thanks for your comments.

Peter -
I'm waiting for a log-in registration to post this on the NARGS Forum.  In the meantime, I hope everyone who reads this will feel free to cross post to other listservs and Forums (Fora?), since this will be an issue that eventually affects every plantsman in every country.

Joyce

Joyce Fingerut
Stonington, Connecticut
Zone 6

Submitted by IMYoung on Wed, 08/04/2010 - 14:52

Quote:

The International Plant Protection Convention (IPPC; https://www.ippc.int/IPP/En/default.jsp)
is proposing a new Standard concerning the international movement of Plants for Planting.  Their website contains the draft standard, which is now open for comment by the member countries of the IPPC.
(Go to: https://www.ippc.int/index.php?id=207803
See Draft 3, and click on the appropriate language in the Publication column;
or contact me for a pdf file)

Here is a pdf in English of the proposals : click on the link below....

104.90 KB

Submitted by alpinegarden on Wed, 08/04/2010 - 20:46

Many thanks, Maggi and Peter, for your help in spreading the word here and on SRGC's Forum.
What I am looking for are the particular concerns that growers and amateur plantsmen (in all countries) would have with this new standard.

Keep in mind that the world of commercial agriculture and horticulture requested this standard, so that countries could write balanced regulations that would protect their own crops by providing a greater measure of protection against the entry of new pests. 

Naturally, it's cheaper for each country to require offshore mitigation of pests (push the work off on the exporter).  However, if all countries were required to use a systems approach to phytosanitary cleanliness, it should be more equitable.  Of course, we know that in practice, all countries will not put rules into effect at the same level, or on the same timeline.  Some will be more restrictive (note Leslie's comments) while others will be written or enforced more loosely.  So it goes....

For some businesses/people, it may not be the standard that will be the problem, but the individual country regulations that will (sooner or later) ensue.  In that case, your best bet will be to contact your national plant protection organization, find out who will be leading the charge on the new rules, and stay in touch with that person and chat on a regular basis.  Politely and civilly, let them know of your concerns, and how the proposed rules will have a negative impact on your business or your gardening life.  My experience with APHIS, over the past nine years (and I'm sure it's true of any plant protection organization), is that they are willing to listen to concerns, answer questions, and discuss points of view.  Whether that will have any effect in the end remains to be seen.

Submitted by IMYoung on Fri, 08/06/2010 - 06:57

Here are two more comments from the SRGC thread on this subject:

Fermi de Sousa sent a link to this page to  Marcus in Tasmania who asked him to post his reply:

"Thanks - had a quick look. Will return to it later. Maybe you could post this comment from me??

It's a real worry that most of these regulatory responses are not developed in consultation with the stakeholders. Most of these decisions are made long before the people who they will directed at ever get to see them. Once taken, as I have found from personal experience, it is nigh impossible to reshape the discussion or, God Forbid, change anyone's mind. Because these decisions are taken by people who have a narrow focus they are usually not balanced by other objectives like fairness or equity and cost-effectiveness. Impacts on the nursery industry or costs/benefits to the community run a long second in these processes, unless ofcourse one belongs to a powerful lobby group and then the whole thing is inverted in favour of the protagonist.

I have found in my dealings with biosecurity agencies these 3 maxims to be true:

To an man with a hammer everything is a nail (Narrow Focus)
Biosecurity is good therefore more biosecurity is even better  (lack of balance)
We'll take the rolled gold version thanks (We dont have to pay - we actual gain)

Cheers, Marcus"

--------------------------------------------------------------------------------------

From Göte in Sweden:

The only thing that will happen is that prices on rare plants will go up and that there will be more smuggling.

Many species that have taken hold in this country in the past 150 years, came as unintentional transports with trains or ships. Some came with birds. The most devastating import - the disease that killed nearly all our native crayfish - came with ballast water from an American ship over a hundred years ago.

When there was an outbreak of foot and mouth disease in the UK some years ago, everyone who came by air from the UK regardless of whether they had visited a farm or not had to walk through a disinfecting bath. This disease is endemic in Turkey but no quarantine regulations apply to travelers from Turkey.

We know that plants and diseases are carried by natural agencies and the populating of new volcanic islands has been studied extensively.

Sometimes one wonders what we are trying to achieve. When I was very young, the black headed gull (Larus ridibundus) was unknown except in the coastal areas of Sweden. However at that time it started to spread inland and the environment pundits declared that the gulls be highly obnoxious and called them flying rats and some went out with shotguns and tried to exterminate those which tried to find food on refuse dumps.
Recently the gulls were starting to decrease in numbers and the environmental pundits declared their worry, that those irreplaceable members of the local fauna were decreasing and that they should be supported in all ways possible.

The beaver (Castor fiber) is a deadly threat to the genera Nymphaea (including the red sport in Fagertärn which is the genetic source of the red colour in the Marliac water lilies) Stratiotes, Saggitaria and some other species. However, he environmentalists declare that the beaver by its actions increases biological diversity 

I understand that the, in Sweden, most obnoxious rodent Arvicola terrestris is protected in the UK 

I have not read the paperwork in question but I agree with Marcus.

Cheers
Göte.

Submitted by alpinegarden on Fri, 08/06/2010 - 10:37

To Fermides and Gote:

Actually, the IPPC standards are written in response to requests from stakeholders.  In this case, the stakeholders are not small nurseries, non-profit plant societies, or gardeners.  The stakeholders are the member countries, who are in turn responding to their own stakeholders: large-scale agriculture, horticulture, and environmentalists.  We are affected by the unintended consequences.

But we can have an effect on the national regulations that will be written (remember, these standards are just guidelines for such rules).  We can - and should! - let our regulatory agencies know of our concerns, and be active and involved stakeholders - those are the ones who make a difference. It takes an effort, but this activity can be rewarding - personally and professionally.  Conversations with agency staff members are interesting (to both sides) and can lead to modification of existing rules, a say in proposed rules, and being consulted on future plans.
As an example: when APHIS began to enforce the requirement for phytosanitary certificates for seeds, which threatened to disrupt all our seedexes, they had no idea that there were such things as organizational seed exchanges. Once they learned about seedexes, the organizations behind them, and their careful management practices that lead to a low phytosanitary risk, they were very willing to work toward easing the phyto requirement.

The USDA-APHIS website has a page where you can join the Stakeholders Registry, to receive notifications and information on a wide variety of topics:  https://web01.aphis.usda.gov/PPQStakeWeb2.nsf/Stakeholders?OpenForm

DEFRA (in the UK) has Consultations: http://ww2.defra.gov.uk/about/consultations/
which invites comment from stakeholders on a range of proposed policies, laws, and rules. 

Europa, the gateway for the European Union, has a page where you can "Have your say on EU policies:"  http://europa.eu/take-part/consultations/index_en.htm
This page leads to several others with areas for discussions, consultations (comments), and other tools (contacts, problems, opinions).

Step up, and have your say!

Submitted by alpinegarden on Sat, 11/27/2010 - 15:52

Some of you may be interested in the official country comments that were sent to the IPPC from the U.S. representative, Julie Aliaga, APHIS-PPQ.  You're welcome to read the whole template, of course, which reflects the position that APHIS is taking and, in turn, reflects comments that she received from stakeholders.  However, take note of two particular comments, the very first paragraph and the comment under Scope.
Both comments indicate that APHIS is willing to exclude small lots of plants from future regulations that would be based upon this Standard.  The wording in those two official comments are almost word-for-word from my email to Ms. Aliaga, showing that APHIS-PPQ officials are concerned with and responsive to their stakeholders.

Go to:
http://www.aphis.usda.gov/import_export/plants/plant_exports/phyto_inter...
Click on "APHIS Comments for Draft Standards, and then on Draft: Integrated measures approach....

I hope that others have also written to their country representatives (at DEFRA, CFIA, etc.) so that their comments reflect the same thinking and the final Standard will contain language that exempts non-commercial (meaning, smaller) lots from the need for Integrated Measures.