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Importing Fruits & Irradiation 7


***APHIS makes reckless assumptions concerning the ability of invasive fruit flies and fungi to survive the movement of fruit from Thailand to the US. APHIS' confidence that exposure to 400 Gray of radiation will neutralize invasive pests is undermined by its own caveat that fruit destined for export to the US must be "grown in a production area that is registered with and monitore" by Thailand. Doing so, APHIS says, will reduce the number of pests in fruit and thus "maximize the effectiveness of the irradiation treatment." APHIS provides no supporting data - in the Proposed Rule or its Risk Management or Environmental Assessment documents - on the relationship between the number of pests residing in a particular fruit, and the ability of a specific irradiation level to eradicate them.
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Importation of Fresh Mangifera indica (mango) Fruit from India into the Continental United States; Risk Management (October 2006) Notification Notification...pest risks, India proposed to treat mangoes with an APHIS approved generic irradiation treatment that would mitigate pathway risks from all insect pests. All insect...
***Animal and Plant Health Inspection Service Docket No. APHIS-2006-0040 Regulatory Analysis and Development PPD, APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale, MD 20737-1238 Subject: Importation of Tropical Fruit From Thailand ? To Whom It May Concern:? The following comments are submitted for consideration in accordance with Federal Register Notice dated July 26, 2006, regarding the importation of irradiated mango, litchi, longan, rambutan, mangosteen, and pineapple from Thailand into the United States. Introduction The College of Tropical Agriculture and Human Resources (CTAHR), University of Hawaii at Manoa, is a Land Grant University with extensive expertise and experience in the control and management of pests of many tropical fruits and flowers. Unfortunately, Hawaii has had more than its share of invasive species from weeds, algae, insects, fungi, viruses, and many others. Notably among them are the fruit flies that is estimated to cost the State of Hawaii over $300 M annually in actual losses to the four species as well as avoided losses by not planting fruit fly susceptible losses. Hawaii has often been called the invasive species capital of the world. Despite Hawaii's long record of invasive species, the march of new invasive species into the state continue at a relentless pace. The proposal by the U.S. Department of Agriculture is sure to add fuel to the fire and create additional major challenges to Hawaii's small but growing exotic tropical fruit industry by increasing the introductions of pests of these tropical fruits. Purpose: The purpose of this document is to point out oversights of and problems with the Risk Analysis that was conducted. In general, the Risk Analysis focused on insect pests, which typically would be more susceptible to the irradiation treatment and thus should be of less concern of escaping the quarantine treatment than fungal and bacterial pests, which were largely ignored in the Risk Assessment. Comments The analysis of plant diseases was very superficial. There is greater risk of invasive species getting through the irradiation treatment and thus the analysis should have focused more on this group of pests. Only one fungus was analyzed for litchi, none for longan, one for mango, none for mangosteen, none for rambutan, and none for pineapple. Bacterial diseases are not even mentioned in the Risk Analysis. ? A.??????? Mango Important diseases were omitted from the Risk Analysis. The following mango diseases were not included in the Risk Analysis. Mango bacterial black spot and blossom malformation are very serious and industry-threatening diseases that must be seriously evaluated in the Risk Analysis. ?1. Mango bacterial black spot (MBBS) = bacterial canker, caused by Xanthomonas sp. pv. mangiferaeindicae (aka X. campestris pv. mangiferaeindicae).? MBBS is very difficult to control and usually becomes a limiting factor for mango industries. Although found in Florida, it is not present in Hawaii. It is present in Thailand and neighboring Malaysia. Bacterial populations on mango surfaces can average as high as 106 cfu per fruit. (Ref. Gagnevin, L. and Pruvost, O. 2001. Epidemiology and Control of Mango Bacterial Black Spot. Plant Dis. 85:928-935) E.???? Pineapple We concur with other previously submitted comments, especially those submitted by Maui Pineapple Company, concerning the paucity of the analysis of pineapple insects (4) and diseases (none) that were considered in the Risk Analysis for pineapple. Maui Pineapple Company's suggestions concerning requiring certification of pineapple growing areas are free of pineapple bacterial wilt (Erwinia chrysanthemi), and the need to develop a post entry Pest Risk Management Plan for irradiated pineapples be developed, approved, and enforced by APHIS to prevent the spread of unwanted pineapple pests from Thailand. Conclusion The Risk Analysis is grossly inadequate, focusing mainly on insects and ignoring critically important fungal and bacterial diseases. Despite knowing that diseases caused by microorganisms are less sensitive to irradiation treatment, and most likely will not be controlled by the irradiation treatment the Risk Analysis, for the most part, ignores the potential threat of the many fungal, bacterial and viral diseases that may be introduced into Hawaii. Hawaii has year-round ideal environmental conditions for microorganisms to become establish and thrive. Most of the exotic tropical fruit industry are located along the windward side of the islands that receive very high rainfall (typically 120?/year) distributed evenly throughout the year. Visual inspection will not be adequate to recognize diseased fruits since symptoms may not have developed to the stage that they are detectable by casual observation. Because the Risk Analysis is incomplete, we recommend and urge that APHIS do a thorough and complete Risk Analysis and that the threat of disease introductions be more thoroughly analyzed. ?Following this, the APHIS proposal should be allowed to be reviewed by interested parties for a period that is longer than the 60 days provided for this current proposal. ? Sincerely, Wayne T. Nishijima Associate Dean and Associate Director For Cooperative Extension ?Additional findings from another source: ?1. Four-hundred Grays is not sufficient to mitigate the risk of bacterial and fungal diseases. Therein, the Proposed Rule should include a comprehensive pest risk assessment of the plant pathogens and diseases that can move through the pathway. Visual inspection of fruit is not likely to be adequately protective of U.S. growing areas and crops in the near or long term. ? 2. Hawaii has been shipping fruit to California with a minimum absorbed dose of 400 Grays since 1998. The absorbed doses should be protective for all arthropod pests with possible exception for pupae and adult Lepidoptera which are not likely to move in the pathway for fresh fruit. ?3. The Proposed Notice of Rule Making includes a Pest Management analysis. The analysis makes reference to and the Notice includes as a condition that the national plant protection organization (NPPO) of Thailand register and monitor growing areas for fruit.? The implied understanding is that a program will be in place for the production of fruit free of disease and other quarantine pests (Pest Management analysis). Under the proposed rule, no specific obligations are imposed regarding registration and monitoring, therein, raising concern regarding the value of this condition as a mitigation measure. ?4.The Pest Management analysis makes reference to Hawaii?s experience employing irradiation as a quarantine treatment. ? The analysis is factually incorrect in the following statement: There has been no importation of irradiated pineapple from Thailand or other countries, and hence there is no record of interception of any quarantine pests from irradiated pineapple. ?Interstate movement of irradiated pineapples from HI into the mainland U.S. has been allowed since 2003. Although the pineapples were irradiated to mitigate risk from Hawaiian fruit flies only, no pest of quarantine significance has ever been intercepted from the fruit treated with 250 Gy (Uyeda 2005). Also, there is no record of interception of any quarantine pests from fruits or vegetables irradiated with 400 Gy dose, so it is safe to assume that the dose is high enough for the insect pests associated with pineapple from Thailand as well.? The pineapple in commercial production in Hawaii is the smooth Cayenne. This fruit is not a host of fruit flies present in Hawaii, therefore, the pineapple from Hawaii to the U.S. mainland has never been subject to quarantine treatment with irradiation at 250 Gy or at any other dose. The fruit moves untreated to mainland markets.??????? ? 4. Its important that the docket correctly address the potential impact of the Proposed Rule on small growers, this is particularly important to Hawaii, where small growers have worked diligently over the past 10 years to expand production of tropical fruit production and to open up new U.S. mainland markets employing the use of irradiation as a quarantine treatment. With the opening of export markets for Hawaii specialty fruit, we have seen a consistent increase in crop acreage each year (see attached report). We anticipate opportunities for crop production to improve measurably in Hawaii as growers open up new marketing opportunities with irradiation as a quarantine treatment and as more and more growing areas in the state come under fruit fly management control through the on-going and remarkably successful USDA, ARS fruit fly suppression program. Table 1 in the Notice of Proposed Rule Making presents Hawaii statistics on the tropical fruit product for the ?fresh market?. While the numbers are correct (?Statistics of Hawaii Agriculture 2004), the conclusion that this production is for the ?local market? is grossly incorrect, the bulk of the production was subject to quarantine treatment (i.e., irradiated) and distributed to U.S. mainland markets across the United States.? In light of this, the following statement is both confusing and objectionable to growers in Hawaii: ?Based on the data available to APHIS it does not appear that domestic production of litchi, longan, mango, mangosteen, pineapple, and rambutan completes with imports of these fruits. Domestic production is generally destined for the local fresh market. Thus the imports from Thailand are unlikely to substantially affect these markets. Additionally, imports from Thailand are not likely to increase the overall level of imports, it is more reasonable to assume that they would substitute for imports from other countries, given that demand for these specialty fruits is likely satiated at current levels. APHIS welcomes public comments on these potential effects.? (Emphasis added) 6. Mitigation Measures. Hawaii is a major U.S. producer of tropical fruit for U.S. mainland markets. Tropical growing conditions in Hawaii are ideal for this production, likewise, ideal for the pests that can impact this production.? For plant pathogens and diseases, a comprehensive pest risk assessment should be undertaken for all six fruit. ?The requirement that the NPPO shall register and monitor growing areas is vague and it is unclear how this condition will lead to the production of fruit free of disease and other quarantine pests (Pest Management Analysis). ?In light of serious concerns and uncertainties, at a minimum the proposed rule should specifically disallow the movement of fruit into Hawaii and other states at risk of harm to agricultural industries as a result of pest risk for which no mitigation measures are proposed.
***RE: Docket No. APHIS-2006-0040 (Importation of Fruit from Thailand) TO: Regulatory Analysis and Development PPD, APHIS, Station 3A-03.8 4700 River Road Unit 118 Riverdale, MD 20737-1238 My colleague, Dr. Carlos F. Balerdi, Multi-County Extension Agent, Miami-Dade County, Homestead, Florida and I (Dr. Jonathan H. Crane, Tropical Fruit Crop Specialist with the University of Florida, IFAS, Tropical Research and Education Center, in Homestead, Florida) have the following comments concerning the proposed USDA amendment to the fruits and vegetable regulations which would allow importation of lychee, longan, mango, mangosteen, pineapple, and rambutan into the United States from Thailand. The proposed rule is not thorough, is missing important data, and makes numerous erroneous assumptions, and inaccurate statements. Biological issues 1. The proposed APHIS rule, states that fruit would be grown only in orchards registered with the National Plant Protection Organization (NPPO) of Thailand. However, no where does the document describe how being registered with the NPPO will prevent entry of any of the quarantine pests listed in the document into the U.S. Furthermore, APHIS also does not describe or state what the consequences of finding a quarantine pest in an orchard or Thai packinghouse. 2. The fruit pests listed in the document is not incomplete. Known fruit pests that are not addressed include but are not limited to: a. Lychee pests i. Cryptophlebia carpophaga. A fruit borer of lychee. ii. Aceria litchi. A mite that attacks lychee flowers and leaves. b. Longan pests i. Longan erinose mites (Aceria longana and A. dimocarpi) attack leaves, fruit, flowers. ii. Deudorix spp. Fruit borers. c. Mango pests i. Deanolis sublimbalis, mango see borer. Furthermore, irradiation will not control the adult and pupae of the lepidoptera pests outlined in the document. Adult lepidoptera could be introduced via the holding bay in the transport ships once opened at the port of entry or pupae deposited onto soil during transport to the importer facilities. In addition, irradiation will not control ant and mite pests. 3. The APHIS proposal (and supporting documents Proposed rule for importation of litchi, longan, mango, mangosteen, rambutan, and pineapple from Thailand ? Risk management and Proposed rule for importation of litchi, longan, mango, mangosteen, rambutan, and pineapple from Thailand ? Environmental assessment) states that in addition fruit being irradiated that the fruit ?could? be inspected at the port of entry if an inspector determines that such an inspection is necessary. Inspection of the fruit should not be an option; it should have to be inspected. Presently a very low percentage of any imported agricultural product is inspected and unfortunately this has not prevented the entry of a number of devastating agricultural pests into the U.S. The recent record of APHIS-PPQ at keeping devastating pests out of the U.S. is not good e.g., citrus canker, citrus greening, Asian psyllid, pink hibiscus mealybug, Asian ambrosia beetle, Sri Lankan weevil, and fig fruit fly, just to name a few of the recent pests to invade Florida. 4. The contention that two fungal pathogens (not controlled by irradiation), Peronophythora litchii (Pythiales: Pythiaceae) on lychee and Phomopsis mangiferae (Ahmad) on mango, do not pose a threat to the lychee and mango industries of Florida, California, Hawaii, and Puerto Rico because there is no chance discarded lychee and mango fruit would ever be dumped in the production areas of those states is not true. All these states have large import companies adjacent to their tropical fruit production areas and imported fruit dumped by an importer or secondary handlers (e.g., packinghouse) in any of these states would pose a risk of establishing these diseases. Furthermore, fruit discarded by a consumer in any of the production areas in these states would pose a risk of infestation. Does USDA-APHIS really want to allow two potential new fungal pathogens into the U.S. that besides attacking lychee also attack tomato and papaya; thus jeopardizing those industries as well? 5. The APHIS proposal states that prior to harvest in Thailand, pesticides and fungicides would be applied to the fruit. No mention is made of what pesticides would be used and whether they are legally registered for use in the U.S. As you know imported fruit cannot have been sprayed with pesticides not legally registered for use on those specific crops in the U.S. In conclusion, the proposed APHIS rule has many inaccuracies and is incomplete. At a minimum, lychee, longan, mango, pineapple, and rambutan should not be allowed to be exported to Florida, California, Hawaii, and Puerto Rico from Thailand. In addition, it should be prohibited to transship these fruit from any U.S. state to these states (e.g., New Jersey to Florida). Please contact us if you have any questions. Sincerely, Jonathan H. Crane, Prof. Carlos F. Balerdi, Prof. Tropical Fruit Crop Specialist Multi-County Extension Agent cc. Rep. Mario Diaz-Balart Rep. Kendrick Meek Rep. Ileana Ros-Lehtinen Sen. Mel Martinez Sen. Bill Nelson Comm. Katy Sorenson Charles LaPradd
***To whom it concerns at USDA/APHIS Re: Docket No. APHIS-2006-0040--Importation of fruit from Thailand Dear APHIS Thank you for opening the matter of importation of fruits from Thailand into the United States to public forum. I would like to voice a strong objection to this impending policy with respect to it being implemented or enforced in the State of HAWAII. And I request that Hawaii be explicitly exempt from importation of Thai fruit. I am native of Hawaii and my concern lies with the welfare of the Hawaiian Islands and its people. I FURTHER MAINTAIN THAT WHAT IS GOOD FOR HAWAII IS GOOD FOR THE UNITED STATES...in this particular instance. I base my objections on my personal experience in both Hawaii and Thailand. I visited Thailand in May of this year (2006) and I saw the tremendous contrasts between the two tropical eco-scapes. While I found the Asian eco-scape fascinating (even charming in it own way), it was frightening to imagine how easily Hawaii's eco-scape could be transformed to look, sound and smell just like South East Asia. IT WOULD RUIN HAWAII...FOREVER. Upon this concern, I passionately urge the USDA to resend its decision to import Thai fruit to Hawaii. I submit my objections and concerns in short expansions of the these three separate themes: 1) Hawaii's extraordinary invasive and endangered species problems; 2) The idea that the USDA consider Hawaii as an ecological sanctuary and agricultural reserve...because of its unique geographical location; 3) Personal experience....My adverse physical reaction to food and water during my visit to Thailand. 1) INVASIVE and ENDANGERED SPECIES in HAWAII Naturalist -- Susan Middleton writes, "Hawaii has the unfortunate distinction of being the Endangered Species Capitol of the World." No one should be more aware than APHIS of this fact : Hawaii has the longest list of endangered species than any other state in the nation. And Hawaii's endangered species problem is directly related to its invasive species problem. Hawaii's 'gentle' flora and fauna can not compete with survival-hardened species of Asia. While irradiation of fruit process is widely acclaimed as being "highly effective" in killing bugs and microorganisms, nowhere can I find the claim that it is 100% effective--all of the time. A single pregnant bug or infectious virus or bacterium, released in Hawaii, could have a devastating outcome on the environment of this State. Taking into account the potentials for: a) ...a temporary lapse or fault in the irradiation technology or procedure; b) ...human error c) ...intentional disregard for proper procedure (i.e. terroristic intent); d) ...possible contamination after irradiation; e) ...large (and ever increasing) volumes of Asian produce over an indefinitely long-term period of time;...we can never be fully confident that 'irradiation' will keep unwanted Asian species, from being introduced to Hawaii. In fact, the probability...over a continuos period of time...almost guarantees that destructive alien species, from Asia, 'will be' introduced to Hawaii. Even if the risk of 'accidental introduction' of damaging species is very slight...ANY RISK IS TOO HIGH. And the reward is too small. (In fact, in Hawaii...which grows its own tropical fruit...there is 'no reward' whatsoever.) THE ONLY REAL WAY TO STOP HAZARDOUS SPECIES FROM INVADING HAWAII, VIA 'IMPORTED FRUIT FROM SOUTH-EAST ASIA', IS: DON'T IMPORT THE FRUIT. [For information about Hawaii's invasive species problems, see www.hear.org --"Hawaii Ecosystems at Risk Project"] 2) Establishing Hawaii as a National Reserve for Tropical Agriculture: Considering Hawaii's extremely unique geographical location, I wonder if it is not prudent for the USDA to set Hawaii aside as sort of a "safety net" in case of global agricultural disaster of tropical crops. In other words, the USDA might adapt a policy that excludes Hawaii from certain unnecessary agriculture imports; and treat the entire Island-State as a 'ecological protected zone' or "tropical agriculture-lands reserve." Suppose, for example, that a blight like Citrus Greening Disease devastates citrus crops almost everywhere in the United States. Wouldn't it be a good idea to have a reserved location that is not infected by CGD? Such an area might serve as a "seeding ground" for citrus plants--for re-planting crops in the U.S. continent. A group of 'Islands", isolated out in the middle of the Pacific Ocean, seems like an ideal place for such a "agriculture lands reserve." 3) My personal experience with food and water in Thailand. As I mentioned above, I visited Thailand in May of this year...for three weeks. I became sick to my stomach on the first day there. I was sick, with this intestinal discomfort, for the entire three weeks and even for a few days after I got home. Who can say exactly what caused it? But it seemed likely that it was food I ate...or more likely, the water associated with that food...and some 'contaminant' in that water which my body is not accustom to. (Though Thai people might be immune to whatever-it-is.) In Thailand, I traveled from the very northern border (TahTon) and went as far south as Phuket--and remained sick the entire time. So, if you think of me as your (USDA) guineapig...sent out to test the Thai water, we could conclude from this experiment: there is no part of Thailand where the water is not tainted. (...at least in terms of my physiology) So...I am skeptical about any so-called "approved areas" in terms of 'contaminant-free' water. Any fruit imported from Thailand will be washed with that contaminant-tainted water. And, while irradiation might kill the bacteria on the fruit, it does not get rid of the contaminant that taints it. I am probably in the minority--as far as American tourists who are so severely affected by Thai food and water. Though I know that I am not completely unique. I have heard similar stories to mine. Let's be conservative and say that only one in a hundred American tourists contract intestinal disorders from ingesting food (and water) in Thailand. That's not so bad...considering that 'we are the alien organism' there. On the other hand, if 'one in a hundred' American consumers get sick from eating food 'imported from Thailand'...that's highly unacceptable. Even one in a thousand would be too high. Wouldn't it? So, while I am no expert on this subject, my gut feeling says: Asian produce should stay in Asia. So those are my arguments opposing the import of fruit from Thailand....with emphasis on importing to the State of Hawaii. You will note that I have made no mention of economic challenges that these imports will create for our local farmers. That is not my immediate concern here. But I see where "they"--Hawaii's tropical fruit growers--are concerned: http://starbulletin.com/2006/07/27/news/story03.html So I feel that "we"--all of us in Hawaii--as American citizens, deserve to know exactly "Why" it is so important that we import tropical fruit from Thailand? I have scoured the USDA document [Docket No. APHIS-2006-0040] in search of the answer to that question; and the closest answer I can find is: "The national plant protection organization (NPPO) of Thailand has requested [it]." To me that is not sufficient reason, in the face of the fact that responsible American citizens request that 'you don't import those fruits'. It prompts the question: "Who does the USDA serve anyway? ...The Thai government? ...or American Citizens?" With all due respect, I will close on that note. Please reply with regards to my questions and concerns. If you decide to reconsider--and exempt Hawaii from imports of Thai...and all Asian fresh produce...I would be most grateful. Sincerely, Richard Morse
***Please do not allow fruit imports from Thailand. My father just retired from the state's Department of Agriculture and I had the opportunity to meet with several local farmers in the past. Hawaii farmers have been frustrated in their efforts to send their specialty fruits to the U.S. mainland. They understand the concerns about pests and requirements for irradiation, but now the U.S. government is considering allowing imports from Thailand? Hawaii is the 50th state of the U.S. - we have the same health and food standards as the rest of the nation. I've traveled to Bangkok for business several times and it is DIRTY. Their standards of health and cleanliness is on par with a third world country. Allowing imports of specialty fruits from Bangkok would degrade the market demand for these products and increase the threat of invasive pests to Hawaii and the mainland. If you want to test the U.S. market for specialty fruit, please work with the farmers from Hawaii first. We are U.S. citizens. Once the standards are in place after working with Hawaii farmers, then the U.S. gov't should consider imports from other countries. Thank you for your attention and consideration. Candice Kraughto
***I am Richard C. Johnson, a resident of Papaikou, Hawaii. I am President of Hawaii Tropical Fruit Growers, a Hawaii state-wide association of over 150 growers, packers and distributors of exotic tropical fruit. I am also owner-manager of Onomea Orchards a family owned and operated tropical fruit farm of 42 acres located on the Big Island of Hawaii. Our primary crops are rambutan, longan, starfruit, mangosteen and litchi. I would like to submit comments on the USDA Proposed Rule regarding importation of irradiated fruit from Thailand (Docket ID: APHIS – 2006-0040). In the text below, I have quoted sections of the Proposed Rule with my comments following each quoted section. Background: "We have not prepared a comprehensive pest risk analysis for this proposed rule, as we normally do when determining whether to allow the importation of fruits or vegetables under the regulations. When we prepare a comprehensive pest risk analysis for a commodity, one part of the analysis examines in detail the likelihood that the plant pests for which the commodity could serve as a host would be introduced into the United States via the importation of that commodity, the likelihood that those pests would become established if they were introduced, and the damage that could result from their introduction or establishment. This helps us to determine which plant pests pose a risk that makes mitigation measures beyond port-of-entry inspection necessary. However, since irradiation at the 400 gray dose is approved to neutralize all plant pests of the order Insecta, except pupae and adults of the family Lepidoptera, we did not consider it necessary to undertake a detailed analysis of the risks posed by any plant pests that fall into the category, since the risks for all these pests would be mitigated through the irradiation treatment. For the plant pests that we identified that are not approved for treatment with the 400 gray dose, we have analyzed what specific mitigations may be necessary given the risks they pose and the likelihood that these risks would be effectively mitigated by inspection." JOHNSON COMMENT: As discussed further below under “Litchi” and “Mango”, the analysis regarding the low likelihood that plant pests could be imported and established is incorrect, particularly as it applies to the State of Hawaii. Since a non-comprehensive pest risk analysis has resulted in conclusions that are incorrect and could result in foreign pests being introduced into U.S. food crops causing serious damage to an existing industry in Hawaii, I strongly urge USDA to require a complete pest risk analysis for this Proposed Rule. Litchi: "However, the 400 gray dose is not approved to treat the fungal pest, Peronophythora litchii. This pest can cause litchi fruit to drop prematurely from their trees... We believe that most litchi fruit that are infected with Peronophythora litchii would be culled prior to importation into the United States; trained harvesters, packinghouse personnel, and plant quarantine inspectors can easily detect the distinctive symptoms of the disease on fruit. Litchi that are infected with Peronophythora litchii but are not symptomatic may not be culled, but the likelihood that Peronophythora litchii would then be introduced into the United States via the few fruit that may escape detection is very low, because the spores are transmitted by water. This means that for Peronophythora litchii to be introduced into the United States via an infected litchi fruit, the fruit would have to be incompletely consumed and discarded in a place where the pest could be transmitted to a litchi production area through moving water." JOHNSON COMMENT: The conclusion that there is a very low probability of this fungus being introduced into the United States is incorrect, particularly in the case of Hawaii. Litchi trees are very common backyard trees in Hawaii. Also, many trees have been inadvertently propagated in roadside areas and other "jungle" areas. Introduction of this pest to Hawaii from infected Thai fruit is very likely for the following reasons: 1) Visual inspection for fungal infection is far from fool-proof, particularly if the infection is in the early stages. 2) The likelihood that incompletely consumed fruit would be discarded in a yard or other area with a litchi tree in Hawaii is not insignificant. Furthermore, the backyard litchi trees and litchi trees in the wild provide a likely vector for this fungus to infect the commercial litchi orchards in Hawaii. 3) The majority of the commercial litchi growing areas in Hawaii are in high rainfall areas such as the Hilo area which has an annual average rainfall of approximately 130 inches which would increase the likelihood of the spread of this fungus. The non-comprehensive pest risk assessment applied to this Proposed Rule lead to an incorrect conclusion regarding the probability of the introduction and spread of this fungus in litchi growing areas of the United States. I strongly urge USDA to require a complete pest risk analysis for this Proposed Rule. Furthermore, I strongly urge USDA to modify the rule to exclude Thai irradiated fruit from importation to the State of Hawaii. Mango: "Irradiation with a 400 gray dose is approved to treat all of the insect pests, but not the fungal plant pest Phomopsis mangiferae. We are not proposing to require any mitigation other than inspection for Phomopsis mangiferae…… However, we believe that Phomopsis mangiferae is unlikely to be introduced into the United States via the importation of mangoes for consumption. The pest is specific to mangoes and is spread only via the seed of the mango. For the pest to spread, fungal spores from the seed must be dispersed at a time when susceptible tissue is available; thus, dispersal only occurs when infected seed is used in mango production. If infected fruit is consumed and the seed is discarded as waste, the infected fruit does not serve as a pathway for introduction. Discarded fruit could create a possible source of inoculum that could provide the means for introduction, but the likelihood that infected mangoes will reach these habitats is low because (1) the host range is limited to mango; (2) the portion of the total number of mango shipments from Thailand that is expected to be transported to mango-producing areas in California, Florida, Hawaii, or Texas is small; and (3) the likelihood of fruit being discarded in mango orchards at an appropriate time is likewise very low. For these reasons, we are not proposing any measures beyond inspection to mitigate the risk associated with this plant pest." JOHNSON COMMENT: The conclusion that there is a very low probability of this fungus being introduced into the United States is incorrect, particularly in the case of Hawaii. Mango trees are very common backyard trees in Hawaii. Also, many trees have been inadvertently propagated in roadside areas and other "jungle" areas. Introduction of this pest to Hawaii from infected Thai fruit is very likely for the following reasons: 1) Visual inspection for fungal infection is far from fool-proof, particularly if the infection is in the early stages. 2) The likelihood that infected fruit being discarded in backyard compost piles or rubbish piles or adjacent to wild mango trees in Hawaii is likely and the backyard trees and trees in the wild provide a vector to the commercial mango orchards in Hawaii. The non-comprehensive pest risk assessment applied to this Proposed Rule lead to an incorrect conclusion regarding the probability of the introduction and spread of this fungus in mango growing areas of the United States. I strongly urge USDA to require a complete pest risk analysis for this Proposed Rule. Furthermore, I strongly urge USDA to modify the rule to exclude Thai irradiated fruit from importation to the State of Hawaii. Mangosteen: "APHIS has identified 11 potential quarantine pests that could be introduced into the United States via the importation of mangosteen from Thailand, all of which are insect pests. The pests are listed below, with order and family name following their scientific names in parentheses. Bactrocera carambola (Diptera: Tephritidae). Bactrocera dorsalis (Diptera: Tephritidae). Bactrocera papayae (Diptera: Tephritidae). Coccus viridis (Hemiptera/Homoptera: Coccidae). Pseudaonidia trilobitiformis (Hemiptera/Homoptera: Diaspididae). Cataenococcus hispidus (Hemiptera/Homoptera: Pseudococcidae). Dysmicoccus neobrevipes (Hemiptera/Homoptera: Pseudococcidae). Paracoccus interceptus (Hemiptera/Homoptera: Pseudococcidae). Planococcus lilacinus (Hemiptera/Homoptera: Pseudococcidae). Planococcus minor (Hemiptera/Homoptera: Pseudococcidae). Pseudococcus cryptus (Hemiptera/Homoptera: Pseudococcidae). "Irradiation with a 400 gray dose is approved as a treatment for all of these pests. JOHNSON COMMENT: The Plant Risk Assessment to allow Hawaii-grown mangosteen to be sold to the U.S. mainland has been in process with the USDA since 1998 and this PRA as well as a number of other Hawaii-grown tropical fruits has not yet been approved. The Hawaii PRAs have been in process for over 8 years without approval. This Proposed Rule is projected to be approved in one to two years . It appears that the Thai request for importation of irradiated fruit is being given much higher priority than requests from the State of Hawaii. I urge USDA to not give this request any higher priority than has been given to requests from Hawaii and to process it with the same attention and urgency that has been given to the Hawaii requests. Executive Order 12866 and Regulatory Flexibility Act: "In accordance with 5 U.S.C. 603, we have performed an initial regulatory flexibility analysis, which is set out below, regarding the effects of this proposed rule on small entities. We do not currently have all the data necessary for a comprehensive analysis of the effects of this proposed rule on small entities. Therefore, we are inviting comments concerning potential effects. In particular, we are interested in determining the degree to which imported fruits from Thailand would be expected to displace fruits imported from other countries or fruits produced domestically." JOHNSON COMMENT: Tropical fruit production is a rapidly growing portion of Hawaii's diversified agriculture initiative. Per the USDA NASS reports, tropical fruit production has been growing steadily over the last 10 years with the 2005 reported production value of $2.7m from 235 farms. With the exception of pineapple, tropical fruit farming in Hawaii is virtually 100% small family owned and operated farms. As such this is an industry of "small entities". This Proposed Rule, if approved, will have a profound effect on the many small farmers in Hawaii. I urge USDA to complete the comprehensive analysis of the effect on small entities prior to any approval of the Proposed Rule. U.S. Production and Imports "Production of longan, litchi, mango, and rambutan is a fraction of pineapple production in Hawaii and is directed to local markets." JOHNSON COMMENT: This is an incorrect statement. The vast majority of Hawaii longan and rambutan and, to a lesser degree, litchi, is sent to the U.S. mainland. On the order of 85% of Hawaii's longan and rambutan and on the order of 50% of litchi are sent to the mainland. I encourage USDA to do further research on the ultimate markets for Hawaii-grown tropical fruits in order that the impact of imports can correctly be evaluated. Effects on Small Entities "Based on the data available to APHIS, it does not appear that domestic production of litchi, longan, mango, mangosteen, pineapple, and rambutan competes with imports of these fruits. Domestic production is generally destined for the local fresh market. Thus, the imports from Thailand are unlikely to substantially affect these markets. Additionally, imports from Thailand are not likely to increase the overall level of imports. It is more reasonable to assume that they would substitute for imports from other countries, given that demand for these specialty fruits is likely satiated at current levels. APHIS welcomes public comment on these potential effects." JOHNSON COMMENT: As discussed above, Hawaii's production of longan, litchi and rambutan is generally destined for the U.S. mainland market, not local markets. Imports from Thailand will substantially affect sales of the Hawaii fruits. Hawaii has been increasing its production of these fruits year-to-year. Additional acreage is being planted every year and at present only 60% of the trees planted have reached bearing age. Hawaii has finally reached a volume which allows sales to expand from the traditional market segment for these fruits, the ethnic Asian grocery stores and produce markets on the U.S. mainland, to other market segments such as gourmet grocery stores, and, eventually to the mainstream grocery chains and produce markets on the U.S. mainland. Allowing Thai imports which are anticipated to be at a much lower price than Hawaii-grown due to the very low costs of production in Thailand, will take away much of the market that Hawaii growers have been struggling to build over the last 10 to 15 years. The U.S. mainland market is not saturated at current levels. The potential growth of consumption outside of the ethnic Asian market segment is large and should Thai producers decide to market to these segments, the levels of imports of these fruits to the U.S. could increase substantially. The economic impact of this Proposed Rule on U.S. Hawaii growers as well as on the overall level of imports should not be ignored or based on incorrect assumptions. I encourage USDA to do further research on these impacts and to accurately characterize them in the Proposed Rule.
*** not consider the use of ethylene gas on green tomatoes to ripen them. The commenter added that using ethylene gas will not increase the risk of Medfly introduction because it would involve importing green tomatoes only. Ethylene gas is not a phytosanitary measure; therefore, we would not require the use of it in our regulations. Further, green tomatoes from Costa Rica, El Salvador, Guatemala, Honduras, Nicaragua, and Panama are currently enterable into the United States and importers are free to use ethylene gas to color tomatoes if they desire.
*** Agency: EPA Document Type: SUPPORTING & RELATED MATERIALS Comments Due: Docket ID: EPA-HQ-OAR-2006-0535 Document ID: EPA-HQ-OAR-2006-0535-0012 Date Posted: Aug 4, 2006 View this Document: View as format pdf | View more Documents in this Docket Reregistration Eligibility Decision for Alachlor Notification Notification ...the enforcement action of suspension against your products. Please note that the Food Quality Protection Act of 1996 (FQPA) became effective on August 3, 1996... … Agency: EPA Document Type: SUPPORTING 7 RELATED MATERIALS Comments Due: Docket ID: EPA-HQ-OPP-2005-0050 Document ID: EPA-HQ-OPP-2005-0050-0060 Date Posted: Aug 2, 2006 View this Document: View as format pdf View more Documents in this Docket Notification Notification Agency: EPA Document Type: SUPPORTING & RELATED MATERIALS Comments Due: Docket ID: EPA-HQ-OAR-2005-0155 Document ID: EPA-HQ-OAR-2005-0155-0486 Date Posted: Jul 27, 2006 View this Document: View as format pdf | View more Documents in this Docket Importation of Fruit From Thailand Notification Notification ...and monitored by the national plant protection organization of Thailand, treated with irradiation in Thailand at a dose of 400 gray for plant pests of..
*** Importation of Litchi chinensis (litchi or lychee), Dimocarpus longan (longan), Mangifera indica (mango), Garcinia mangostana L. (mangosteen), Nephelium lappaceum L. (rambutan), and Ananas comosus (pineapple) into the United States from Thailand; Risk Management; February 28, 2006 Notification Notification ...Thailand further proposed to treat each fruit with an APHIS approved generic irradiation treatment that would mitigate all pathway risks from insect pests. Based on...
***July 17, 2006 Regulatory Analysis and Development PPD Animal and Plant Health Inspection Service Station 3A-03.8 4700 River Road, Unit 118 Riverdale, MD 20737-1238 RE: APHIS Docket Number: 2005-0106 Dear Sir or Madam: On behalf of the non-profit consumer group Food & Water Watch (formerly staff working on food and water issues at the consumer organization Public Citizen), I welcome this opportunity to comment on the proposed rule entitled "Revision of Import Regulations for Fruits and Vegetables," which was originally published in the April 27, 2006 Federal Register (71 FR 25010 - 25057). This proposed rule is designed to streamline the process under the so-called Quarantine 56 regulations. At the outset, we would like to express our concern that the mission of the Animal and Plant Health Inspection Service (APHIS) has been transformed over the past decade from one which used every precaution to prevent the introduction of foreign pests and diseases into the United States to one which enables the implementation of trade agreements that could have deleterious impacts on domestic producers. The proposed rule is the latest of several which APHIS has issued over the past several years that is designed to facilitate the opening of our domestic fruit and vegetable markets to imports. American taxpayers have been forced to foot the bill for the containment and eradication of foreign pests on our shores – with little accountability being placed on the foreign governments that export them to us. We are also concerned by the lack of responsiveness by the APHIS Freedom of Information Act (FOIA) Office to two pending requests that we have filed that have a direct bearing on the current proposed rule. On June 9, 2003 (over three years ago), Mark Worth from our staff submitted a FOIA request for all records related to submissions filed by Columbia, Thailand and any other country to use irradiation to treat fruits and vegetables for export to the United States. On January 11, 2006, Mr. Worth filed a second FOIA request for all records held by the agency from all countries interested in exporting irradiated food to the United States. We have yet to receive a response to either request. This is problematic for two reasons. First, we believe that the comment period for this proposed rule should be extended until we have received responses to these two FOIA requests and have time to evaluate the information to formulate informed comments. Second, the lack of response calls into question the ability of APHIS to provide adequate and timely information to interested parties that might be interested in filing comments under the "notice-based" process the agency is proposing in the new import regulations. With regard to the proposed rule, we have the following observations: 1) The current rule-making process is not an impediment to trade. We see no need to change the current rule-making process for imports. We believe that careful deliberation over petitions filed by foreign governments that wish to export their products to the United States should be exercised. While the Agency makes the argument that the current regulations could trigger a process that can take 18 months to three years to complete, the process does not automatically preclude trade. The process needs to be as transparent as possible – allowing for maximum opportunity for public input – and all petitions should be reviewed judiciously. 2) The proposed notice-based process is not transparent We believe that the proposed notice-based process for evaluating new petitions for imports does not afford complete transparency. The Agency should solicit as much outside input as possible before making a determination of a foreign country’s petition to export to the United States. The new process being proposed places too much power in the hands of Agency staff that will make an initial determination before it is subject to public review. The onus will be placed on the public to challenge the Agency’s determination. We are concerned that the public will not be afforded all of the information furnished to Agency staff (e.g., internal communications within the Agency and with the petitioning country) and that should additional information be solicited by public commenters, the Agency would not make it available in a timely fashion (as the above referenced FOIA requests illustrate). We question the need for the new process and urge that it be scrapped. 3) Determination of "pest-free" areas Again, we view this process as not being as transparent as it needs to be. Under the proposed rule, the Agency will make determinations without the benefit of public input, and only open the process after it has made a decision. We believe prior to making these determinations, the Agency should solicit public input and provide all relevant information that would assist the public to file informed comments. 4) Economic impacts need to be included in all rule-making for imports We are extremely disappointed that the Agency intends to drop the requirement that an analysis of economic impact on domestic producers be provided when import determinations are made. We have already experienced the decimation of the domestic garlic, asparagus and tomato industries by cheap imports, and we now see a serious challenge being mounted against our domestic apple industry. The economic impact on our domestic producers should be part of any trade agreement the United States negotiates. Foreign producers are not subject to the same environmental and phyto-sanitary restrictions under which our domestic producers operate – putting our domestic producers at a distinct competitive disadvantage. 5) Irradiation is not the answer Our organization is vehemently opposed to the use of irradiation as a phyto-sanitary measure for a number of reasons. First, we do not believe that irradiation is a safe technology. On July 17, 2000, the consumer group Public Citizen filed comments opposed to the proposed APHIS rule to permit ionizing irradiation as an approved phyto-sanitary measure for imported fruits and vegetables. In those comments, Public Citizen discussed the potential health-related problems from consuming foods that are irradiated. In fact, there is evidence to indicate that potentially carcinogenic chemicals are produced when certain fruits and vegetables are irradiated. Second, the APHIS-approved rule permitting ionizing irradiation sets up a convoluted process for products to enter the United States that have not been pre-treated, thus opening the door to the infestation from foreign pests. Third, developing countries have not been encouraged by the United States to use alternate phyto-sanitary measures to export their products to our country. Instead, they are being pushed by the United States to use this very expensive technology. Thailand, India, Columbia, Mexico and the Philippines all stand poised to build or expand irradiation capacity so that they can export fruits and vegetables to the United States. 6) Mandatory country-of-origin labeling needs to be implemented We realize that this is not an issue under the purview of APHIS, but since the Agency has embarked on a policy to expand the amount of imported fruits and vegetables entering our country, USDA needs to implement mandatory country-of-origin labeling so that American consumers can make informed choices about the food they purchase. Should you have any questions regarding our comments, please feel free to contact me at (202) 797-6550. Sincerely, Wenonah Hauter Executive Director

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