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Homeland Security and Agriculture
Last updated: September 20, 2011
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NASDA strongly supports the pest exclusion mission area known as Agricultural Quarantine Inspection (AQI) at the nation’s ports of entry that serve to protect our domestic agriculture industry from a foreign pest or disease incursion. After the events of September 11, 2001 and the anthrax incidents that followed, AQI functions were transferred from the United States Department of Agriculture (USDA) to the newly created Department of Homeland Security ("DHS") in an effort to consolidate all governmental functions that protect the nation against threats to the homeland into one agency. NASDA strongly supports the mission and efforts of DHS to prevent terrorists and terrorist weapons from entering the United States. While the prevention of terrorists and terrorist weapons from entering the United States is vital to the security of the nation, so too, is the protection of the nation's food supply, our agricultural economy, and plant resources and health. Introductions of foreign plant pests and diseases, such as Asian long-horned beetle, Emerald Ash Borer, Light Brown Apple Moth and Plum pox virus are of great concern to the U.S. agricultural economy, and to plant and animal health. The orderly flow of trade and timely inspections of perishable items are vital to agriculture and to agribusiness. The introduction of foreign or invasive plant pests remains a constant threat to nation’s agricultural crops and forests.
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Unfortunately, since the AQI transfer, pest and disease introductions have increased dramatically. It is clear that DHS’ administration of the AQI program lacks efficacy and currently there are no performance measures relative to AQI functions that DHS must meet to ensure the resources that DHS receives to protect the U.S. domestic agriculture sector are being utilized for this purpose. In addition, in order for AQI to remain effective while housed at DHS, it was essential that DHS and APHIS establish a consistent and clear communication structure that provides for problem resolution with built-in accountability in order to provide the greatest degree of risk reduction. Unfortunately, DHS’ mission is so broad that AQI is not viewed within the agency as a critical function either in terms of staffing or funding. Therefore, NASDA supports the re-assignment of the AQI mission area back to USDA APHIS given that they have the expertise to carry out a focused, coordinated and effective agricultural safeguarding effort and are statutorily charged with managing exotic pests and diseases.
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NASDA urges that increased emphasis be placed on the mission of safeguarding agriculture and strongly supports the immediate adoption of quantifiable performance measures for AQI functions to ensure the program is meeting the statutory mission for which it was created – protecting American agriculture from a foreign plant or animal pest or disease. These performance measures should consider the interdiction, control, eradication and suppression costs borne by state and local governments for foreign pests and diseases that AQI fails to interdict at the ports of entry. These costs shall be assessed to the budget of the parent department of AQI. In addition, NASDA urges DHS’ Office of Domestic Preparedness to provide specific funding opportunities to state departments of agriculture for local preparedness similar to grants provided to state departments of health.
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Pest Exclusion
Last updated: September 20, 2011
The introduction of foreign pests has cost the nation millions of dollars in control and eradication efforts and lost production. Foreign pest invasions should be recognized as a national problem, not just the problem of the state in which the pest originally entered the United States. Regardless of the entry point of the disease, it still poses a threat to the entire agriculture industry. Initiatives should be focused on pest exclusion activities including tighter security. In order to be successful, traditional APHIS pest management programs must be fully funded to meet this objective, and maintain current quarantines for federally regulated pests.
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User Fees
Last updated: September 20, 2011
APHIS should seek authority to use the Agricultural Quarantine Inspection user fees collected from the traveling public and the shipping industry for better surveillance and protection of the plant industry in the United States. Further, APHIS should seek to expand or increase the user fees charged to conduct a comprehensive pest prevention program.
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Plant Pest Survey
Last updated: September 20, 2011
Given the passage of the North American Free Trade Agreement (NAFTA) and the General Agreement on Tariffs and Trade (GATT), several states have taken initiatives to develop agreements which support the export of agricultural crops and commodities. A primary concern of importing countries in the negotiation of these agreements is the risk of introducing exotic or threatening pests. U.S. exporters face a host of phytosanitary barriers around the world resulting in millions of dollars of lost trade opportunities.
To help resolve this concern, a list of known pests associated with a crop or commodity is required by the importing country. In some cases, the crop or commodity is prohibited from export if the target pest is known to occur in the exporting state. In other situations, the importer allows entry, providing that the state can declare that a particular pest does not occur in the country of origin or growing site. Statewide pest survey programs that are supported by USDA-APHIS-PPQ through the Cooperative Agricultural Pest Survey (CAPS) can help address these phytosanitary concerns. The CAPS Program utilizes a National Agricultural Pest Information System (NAPIS) database for efficient pest management.
Proper funding for the CAPS Program should continue so that pest data can be collected and the exporting of agricultural crops and commodities can be enhanced. States should also consider conducting survey programs to complement the federal program.
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Offshore Pest Program
Last updated: September 20, 2011
In response to introductions and interceptions of the Asian gypsy moth in the early 1990s in the U.S., an offshore program in Russian Far Eastern Port Areas was initiated to exclude this and two other exotic major pests of forest and urban trees and shrubs. This program, which was initiated in 1993, has tracked the population density and distribution of three pests of Lymantria species, including the Asian gypsy moth (L. dispar), the nun moth (L. monacha), and the rosy gypsy moth (L. mathura) and implemented measures to minimize the risk of their introduction into the United States since the initiation of this monitoring program.
This cooperative project between the United States Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS), the USDA Forest Service, the Federal Forest Service of Russia, and the State Plant Quarantine Service of Russia is largely supported with funds provided by APHIS and the Forest Service. During FY 2001, APHIS and the Forest Service will jointly provide about $150,000. Most of these funds are provided by APHIS. Populations of the Asian and rosy gypsy moths typically begin to peak in the Russian Far East during the late spring and early summer. This translates into a higher risk of artificial movements of these pests on ships and cargo.
NASDA urges the U.S. Department of Interior and USDA to fund this program for as long as these pests pose a significant risk of introduction into North America. NASDA also urges USDA-APHIS and the USDA Forest Service to evaluate the risks arising from the movement of ships and cargo from other areas infested by these pests, such as Japan, Korea, and China. NASDA encourages the expansion of this program to cover other known pest threats and threats which may be identified through the timely completion of pest risk analyses in the future.
The detection, in early 2002, of live Mediterranean fruit fly larvae in Spanish Clementine citrus fruit delivered throughout the U.S. poses a serious threat to all fruit and vegetable areas. This unfortunate phytosanitary certification program failure makes it abundantly clear that proper safeguards were not adequately developed to protect our valuable agricultural resources from exotic plant pest introductions. The Spanish Clementine/medfly phytosanitary failure indicates there may be other agricultural protocols that are not adequate to protect our valuable food and fiber resources. USDA should take immediate steps to review the safeguards that are needed to assure all fruits and vegetables from any foreign country, as well as the current situation including citrus fruit from Spain are pest and disease free upon entry. The reviews should include treatment efficacy, pest surveilance, mitigation at origin, inspection at port of export, and inspection upon arrival. The expertise of NASDA as well as the expertise of the USDA-ARS, National Plant Board, and university system should be involved in the review which should be ongoing as new programs are proposed.
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Imported Wood Regulation
Last updated: September 20, 2011
Current pest risk analyses have addressed surface or shallow wood pests. However, there is concern over a potential deficiency in the current imported wood regulations with regard to railroad ties, temperate hardwood logs, wood chips, bark chips, humus, and similar materials. Experience with the currently regulated commodities to date indicates that the current regulations do not completely address the potential risks associated with these materials. Specifically, evidence that pathogenic fungi and live insects have been imported on railroad ties, that fumigation does not always control deep wood insects or fungi, and recent experiences with Asian longhorned beetle and citrus longhorned beetle demonstrate that insects that bore deep into wood still pose a serious threat. It was determined by the Oregon Department of Agriculture that live fungi, including pathogenic species, have been found in imported fumigated wood and inside fumigated bark.
NASDA urges USDA-APHIS-PPQ to conduct additional pest risk analyses and revise the wood regulations to mitigate pathways for introduction of potential deep wood pests and diseases through imported wood products.
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Quarantine 37
Last updated: September 20, 2011
Any proposed changes to CFR 319.37 commonly known as “Quarantine 37" must be based on a comprehensive biological assessment of the pest and disease introduction risk associated with the commodity and country of origin. The current request to allow additional plant species to enter the U.S. is of concern and must be subjected to a full assessment including evaluation from areas of the U.S. that are considered to be most at risk from exotic plant introductions. As Quarantine 37 has been, and remains, an important part of our first line of defense against exotic plant pests of concern to the U.S. nursery industry as well as other segments of agriculture, it must maintain its current high degree of biological integrity.