safeguard crops, crops and forests
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Greg Rosenthal of the U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service details the importance of multiple safeguards in systems approaches – when it comes to making pests run a gauntlet to safeguard crops and forests

The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) views global agricultural trade through a plant health lens. The challenge, from this perspective, is how to move billions of dollars’ worth of agricultural products across the worlds’ oceans and continents without spreading invasive plant pests. APHIS recognises systems approaches as powerful tools to meet this challenge. A systems approach is a series of measures taken by growers, packers and shippers that, in combination, minimise pest risks prior to importation into the United States.

Systems approaches

Under a systems approach, different steps of the production chain provide opportunities to reduce risks from pests—from pre-planting, pre-harvest, during the growing season, through harvest, to the packing house, to the exporting country’s port, to the importing country’s port of entry and into domestic commerce. The idea is to apply enough measures that together ensure an appropriate level of protection.

Examples of these measures include, among many others: sterilisation of soil for pests; using only certified seeds for planting; surveying for insects; inspecting and treating crops; sanitising equipment moving between fields; harvesting before pest risks emerge; pest-proof structures; inspecting, cleaning and disinfecting commodities at packing houses; placing commodities in pest-proof packaging; conducting cold treatments in transit; inspecting commodities at the port of entry; and establishing end-use restrictions, such as human consumption versus animal consumption versus planting, flour milling only for certain grains, or juicing only for certain fruits.

Countries around the world are using and mutually recognising systems approaches as a way to facilitate safe trade. The International Plant Protection Convention (IPPC) formally adopted the concept in 2002. The IPPC is an international agreement between183 countries, including the United States. It provides the world with plant health standards and critical tools, such as systems approaches, for negotiating technically sound international trade requirements. The U.S. Plant Protection Act of 2000 defines systems approaches for APHIS.

Benefits of systems approaches

Systems approaches have many advantages. They can work when a single pest mitigation measure will not be effective or feasible. This is particularly important now that, because of human health and environmental concerns, many countries discourage the use of methyl bromide—traditionally a single and extremely effective measure. In addition, if one measure fails in a systems approach, the remaining measures provide redundancy to ensure an appropriate level of protection.

For example, U.S. imports of bell pepper from Spain are allowed under a systems approach that includes production in pest-proof greenhouses, registration and oversight by Spanish agricultural department authorities, regular greenhouse inspections and pest monitoring, pepper packing requirements and use of insect-proof covering for transit to the United States.

In addition, two APHIS programs certify exports to and allow imported nursery stock from Canada under systems approaches. These programs promote trade consistency between our two countries. APHIS also accepts imported plant cuttings grown under systems approaches from APHIS-certified foreign facilities producing these commodities.

Systems approaches can also leverage the industry’s current best practices. That means growers can address pest concerns in a way that doesn’t add burdensome requirements. Because participants across a supply chain take steps to address pest concerns before a commodity ships to the importing country, systems approaches can also facilitate the smooth entry of commodities into the importing country.

Taking systems approaches a step further

Over time, APHIS’ experts observed that many import requests for plants in growing media (PIGM) were very similar to each other. They realised this similarity offered an opportunity to streamline how they evaluate and process many of these import requests. Normally, APHIS prepares an environmental assessment (EA) unique to each country’s request for a specific plant genus in growing media, such as peat or coal cinder. The EA assesses the potential environmental consequences of the proposed importation. We also prepare a pest risk assessment (PRA) to identify the risks, and a risk mitigation document (RMD) to identify measures to help prevent the entry of pests on the plants.

For most requests, those measures—a systems approach—are identical, although we add specific measures as needed. As a result, we determined that a single programmatic EA could apply to most PIGM import requests. That would reduce the need for repetitive documentation of comparable risks. However, if the PRA and the RMD for a routine request identifies new risks for consideration, APHIS would prepare an environmental document.

And if we detect a quarantine pest in imported PIGM, we would stop importing that plant from that country until current or revised pest mitigation measures are shown to be effective.

Using a single programmatic EA would ensure continued levels of safeguarding while facilitating international trade, allowing healthier plant imports, reducing the growing time for plants to reach markets, reducing unnecessary or repetitive environmental and other documentation, and speeding port-of-entry inspections.

On 10th April, we published a draft programmatic EA in the U.S. government’s newspaper of record, the Federal Register and are accepting public comments until June 24, 2019. Once a final decision is made regarding the issues within the EA, that EA will cover all future PIGM import requests that use only the default systems approach measures. If a particular import request requires additional measures, we will prepare another environmental document that evaluates those measures. The required documentation will depend on the type and magnitude of risk from the additional measures.

The two sides of systems approaches

APHIS regularly authorises imports of fruits, vegetables, nursery stock, and other agricultural commodities under a systems approach. We also negotiate the use of systems approaches with our trading partners when they consider U.S. requests to export commodities to their markets. For example, our cherry exports to Japan must comply with a systems approach that includes, among other measures, orchard registration with APHIS, pest trap use, specific inspection and processing procedures at the packing house, carton labelling and inspection upon arrival in Japan.

Systems approaches like this one help make global trade safe, fair, and predictable. For imports and exports, they are here to stay.


Greg Rosenthal

Communications Specialist
United States Department of Agriculture (USDA)
Animal and Plant Health Inspection Service


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