2. Phytosanitary Issues in the International Movement of Plant Products United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine Phytosanitary Issues Management Export Services April 18, 2007
Good afternoon I’m Karen Bedigian with PPQ Export Services
I want to thank AID for inviting us here today. I know we had a number of meetings last year but this will give us another opportunity to talk about the issues we each deal with and learn from each other.
Please if you have a question please feel free to stop me at any time

3. International Plant Protection Convention (IPPC)
United Nations: international treaty for cooperation in plant protection
International Standards for Phytosanitary Measures (ISPM): prevent the spread and introduction of pests of plants and plant products
All begins with International Plant Protection Convention part of Food and Agricultural Organization of UN - Much like the World Food Program is part of UN
Purpose of IPPC:
encourage international harmonization and create international standards to help ensure that phytosanitary measures were not used as unjustified barriers to trade – reduce the risk of the spread and introduction of pests of plants and plant products associated with such movements.
protect the agriculture and forestry while facilitating international trade and traffic.
While each country has their own phytosanitary requirements they must be based on the ISPMs set forth by the IPPC.
While dealing with Kenyan issues I was asked “Do they have the right to put these restrictions into place” answer is yes based on the IPPC standards and we have an obligation as a member of IPPC to meet their requirements
Phytosanitary measures are based on risk – that is why in answer to your question that food aid doesn’t have to meet the requirements – yes they do if the importing country determines this is risk

4. Obligations under IPPC
Transparent regulations
Based on science and international standards
Measures are consistent with pest risk
Least restrictive measures
Measures applied without discrimination
National Plant Protection Organization (NPPO)
Consignments must meet importing country’s phytosanitary requirements
Food Aid is not exempt
Members accept certain principles for phytosanitary measures.
Regulations must be transparent -
When Based on science and international standards = harmonization:
Restrictive measures must be applied only when made necessary by phytosanitary considerations.
Measures must be consistent with the pest risk and the least restrictive measures available.
Measures must be applied without discrimination
all countries with same phytosanitary status must be treated the same.
For a particular pest, phytosanitary measures must be same for exporting country and within the territory of the importing contracting party.
National Plant Protection Organization – each member state must establish an NPPO which will be the official government service to discharge the functions specified by the IPPC. USDA has appointed Plant Protection and Quarantine (PPQ)
Consignments will meet importing country’s phytosanitary requirements
Another question we addressed in the last year was is food aid exempt – hit key for food aid is not

5. APHIS/PPQ National Plant Protection Organization
Mission: Safeguard agriculture and natural resources from the risks associated with the entry, establishment, or spread of animal and plant pests and noxious weeds.
APHIS/PPQ - NPPO of the US for import,export issues and even domestic phytosanitary issues
Fulfillment of its safeguarding role ensures an abundant, high-quality, and varied food supply, strengthens the marketability of U.S. agriculture in domestic and international commerce, and contributes to the preservation of the global environment.
Authority: Plant Pest Act

6. Phytosanitary Issues Management (PIM)
Primary responsibility to manage, address, and help resolve technical phytosanitary trade and export issues.
IPPC International Standards for Phytosanitary Measures (ISPM)
North American Plant Protection Organization (NPPO)
US Federal Plant Pest Act
Under IPPC each member country must have a National Plant Protection Organization (NPPO) – that’s us - discharge the functions specified by the IPPC,

8. PPQ US Export Program Responsibilities
Resolve export related problems – not trade issues
Analyze and interpret foreign phytosanitary regulations
Maintain database of foreign phytosanitary regulations
Establish program policies and procedures
Provide phytosanitary certification
Responsibilities
1) Resolve export related problems – not trade issues
This is were we probably spent more of our efforts. From assisting exporters whose shipment is on hold to creating a program which would assist them in meeting a country’s requirements.
2) Analyze and interpret foreign phytosanitary regulations
We certify based on the most current information we have received from a country. While WTO members are required to notify WtO of changes this does not always happen. And for the countries that you export to there is a very good chance that the information we have is outdated or nonexistent.
Reading and interpreting regulations is not always an easy task, regardless of whether they are US regs or a foreign countries. May take many letters or visits between us and the importing country to obtain clarification
3) Maintain database of foreign phytosanitary regulations
After we have determined what the requirements are we put into database that was created for our certifying officials.
4) Establish program policies and procedures: to meet international standards – such as who is authorized to conduct phytosanitary activities leading up to issuing a PC, what products are eligible for a certificate
5) Provide phytosanitary certification
We have around 2400 certifying officials throughout the US that can provide sampling, inspections and PCs

9. PPQ US Export Program Failure to meet international standards:
Program is consistent with international standards
Failure to meet international standards:
Loss of integrity and credibility of US Export Program
More restrictive import requirements
Loss of foreign markets
Bring us before WTO
All facets of the US Export Program, including our policies and procedures, have been developed to meet our obligations under the IPPC and the ISPMs.
Policies and procedures, in addition to meeting ISPMS must also meet industry needs and importing country requirements. Sometimes this can be a challenge
Give example: ISPM have standardized PCs so that certifying officials know what information must be provided on each PC but also what information importing countries can require to be on PC. Our PCs meet the international standard AND additionally we have put a policy into place that PCs must be issued within 30 days of inspection. This policy ensures that PCs are not written for consignments that may have become infested or infected since the phytosanitary inspection.
Most crucial is the policy that we will not issue PCs for commodities that do not meet an importing country’s requirements.
When consignments do not meet requirements =
Loss of integrity and credibility of US Export Program: trading partners question the validity of our documents. This can create delays and be very costly to exporters. This can also create uncertainty for exporters.
More restrictive import requirements: if too many consignments arrive without meeting requirements. When the US received too many shipments of gladiolus from Mexico with rust disease we put more restrictive measures into place
Loss of foreign markets: for example.
Avoid Notifications of noncompliance from our trading partners

10. PPQ US Export Program Steps to Obtaining Certification
Step 1. Import Requirements/ Application for Service
Step 3. Official sampling and inspection
Step 4. Treatments
Step 5. Issuance of phytosanitary certificate (PC)
Import Requirements: don’t wait until the day you want to ship to ask for service – you may find that we can not meet the importing countries requirements or that special circumstances apply that you have not met. As with any business decision you should - Do your homework – can I ship X to Y.
Call us to find out requirements
Ask your importer what the import requirements are
Application for service
Caveat: your research should be done as close to shipping date as possible because a country’s requirements can change at any time.
Official sampling and inspection:
Treatments
Issuance of phytosanitary certificate (PC)

11. Step 1. Import Requirements
APHIS/PPQ does not regulate exports
Importing country’s requirements
Regulations
Import Permit/Official communication
US exporter’s obligated to meet phytosanitary import requirements
Food aid is not exempt
Seems to be confusion – over the past year have been asked many times why PPQ won’t issue PC. Well the answer is that under the IPPC we can’t issue PC when the consignment doesn’t meet import requirements:
APHIS/PPQ does not regulate exports – we issue PCs when your commodity meets the foreign country’s regulations.. We are here to provide a service to assist you in meeting the import requirements of a foreign country.
Import Regulations: don’t wait until the day you want to ship to ask for service – you may find that we can not meet the importing countries requirements or that special circumstances apply that you have not met. As with any business decision you should - Do your homework – can I ship X to Y.
Call us to find out requirements
Ask your importer what the import requirements are
Application for service
Caveat: your research should be done as close to shipping date as possible because a country’s requirements can change at any time.
US exporter’s obligated to meet phytosanitary import requirements and Food aid is not exempt
We’ve heard many times from exporters that “this is food aid it doesn’t have to meet the requirements.” I think the experience many of us had with Kenya last year reinforced that countries do and can regulate food aid

12. Step 1. Import Requirements
Phytosanitary certificate (PC)
Time limits: between inspection, exportation and issuance of PC
Freedom from diseases, insects and weed seeds
Packaging
Treatments
Import Permit
Transiting requirements
Here are some the most common phytosanitary requirements country’s may impose:
Phytosanitary certificate (PC)
Time between inspection, exportation and issuance of PC: for example, most countries set a time limit between the date of issuance of a PC and the date of exportation. Exporters need to be aware of this time limit – we can not enforce this but remember we may not be able to assist you if you do not meet this requirement.
For example if you ship a commodity which was originally destined to Kenya then change it to Bangladesh you will have to meet Bangladesh’s requirement that inspection can’t take place not more than 14 days before shipment or
Turkey – PC must be issued before exportation
Freedom from diseases, insects and weed seeds: depending on the pest of concern we might have to do laboratory tests or field inspections, sometimes commodity must originate from an area that is considered to be officially free of a peat – BUT we always must do a visual inspection
When a country requires area freedom for grain or grain products this can be a serious impediment to exporting because we can not meet area freedom for these commodities because of the commingling from various origins. This is complicated and we won’t go into the details here. For example for those of you that ship wheat. Karnal bunt is a disease that affects wheat grain and most countries restrict wheat from areas where this disease occurs. In the US we have a federal quarantine that regulates the movement of wheat grain into and out of the affected areas. Therefore, we can state that grain comes from an area where KB is not known to occur. Generally, though this is the only disease of grain that we can give area freedom for.
Treatments: for what pest, is there an available treatment, will it damage commodity, done at origin or at destination
Packaging: is there WPM with your shipment? If so you probably will have to have it treated according to the international standard for the treatment of wood packaging. This is also important if your commodity must be fumigated – talk about this later when I discuss treatments
Transiting requirements: do you need to meet the import requirements of country’s that you transit
Import Permit: for some country’s we can not issue the PC until you present the IP

13. Step 1. Import Requirements EXCERPT database
Another source determine an import country’s requirements is the EXCERPT database.
This is where we store all the information we have. This information is only as current as the most recent data sent to us by the importing country. Since we do not always receive a country’s regulatory changes it behooves exporters to check with the importing country. The information is not legally binding.
This is what our ACOs use
Industry can pay subscription to obtain access but I suggest calling us. It was created for our ACOs and therefore, nonACOs will lack necessary training on how to use to obtain correct answer

14. Step 1. Import Requirements
Must be phytosanitary in nature: plant health
Can not be:
Quality
Food safety
Environmental
Genetically modified organisms
Grain and grain products: can not meet disease freedom
We can only certify plant health issues
The following are not plant health issues:
Quality
Food safety
Environmental
Genetically modified organisms
Can not: Grain and grain products: can not meet disease freedom because can not take a representative sample, identity is lost– however there are exceptions like the KB – because we have a federal quarantine
If a country requires us to address any of the above we can not issue the PC and will have to negotiate a change.

15. Step 1. Import Requirements PPQ Policy
Eligibility:
Plant or plant product
Destination: international trade only
Degree of processing
Protected plant
Ability to sample and inspect
Eligibility
Plant or plant product
Destination: international trade only
Degree of processing: at this time only specific processed product are eligible for a PC
Protected plant: can be only be done at specific locations were personnel are trained to handle protected plants – would also have to meet CITES and ESA requirements
Ability to inspect: must be packaged so that we can take a representative sample. For example, if you are shipping grain loaded bulk into a container we probably can’t take a sample after the container is loaded. You will have to make arrangements with the local certifying official or FGIS to conduct the sampling and inspection

16. Step 1. Application for Service
PPQ Form 572 or Electronically - Phytosanitary Certification and Issuance and Tracking (PCIT)
US exporter with physical address in US
Inspection location
Origin: country/state/county
Country of final destination
Description of commodity-scientific name
Distinguishing marks
Port of entry
Can apply several ways:
Paper - PPQ Form 572
Electronically - Phytosanitary Certification and Issuance and Tracking
If prepaid and fill out certificate – this can serve as application
US exporter – must have physical address in US
Inspection location
Origin: country/state/county: for some commodities we may need more specific information regarding the origin.
Country of final destination: this is who we will issue the PC to and whose requirements we must meet. If the consignment will be transiting another country it is important that you tell us that – you may have to meet that country’s requirements
Description of commodity/consignment
Scientific name: exporter is responsible for this. If you can not provide we will do the best we can but if the consignment is held up we may not be able to assist
Plant part: this is important because regulations are based on the plant part and its intended use. For example you may be sending seeds but its intended use is grain. The requirements for seed will be much more restrictive due to the risk associated with planting the seeds. Most countries do not regulate seed and grain equally. Some countries though will as we found out last year with East Africa due to concerns that grain will be planted.
Weight/number of packages/pieces
Distinguishing marks
Port of entry
Date of departure

17. Step 2 Official Sampling and Inspections
Authorized personnel
Request in timely manner
Available for inspection
Representative of consignment
PC must be issued within 30 days of inspection
Authorized personnel: sometimes only PPQ can do inspections – example if large # of weed seeds – disease
Authorized personnel – we have federal and state/county ACOs. Additionally FGIS official inspectors can provide inspections for specific grains and grain products. Only authorized personnel can draw samples and conduct inspections. Exporters can not submit samples.
Request in timely manner
Available for inspection: The entire consignment should be available at one time in one place. ACOs need access to commodity. If commodity is packed in such a way that a representative sample can not be taken the consignment can not be certified. Exporter responsible for providing all labor necessary.
Representative of consignment
Packaging: can not be retail sized shipments because we would not be able to obtain a representative sample
PC must be issued within 30 days of inspection

18. FGIS Inspections
FGIS inspects for insects only, unless notified otherwise
Exporter responsible for advising FGIS of special import requirements
Special requirements must be stated on FGIS 921-2
Exporter responsible for obtaining FGIS Form “Inspection Report-Insect in Grain”
PC must be issued within 30 days of inspection
Exporter responsible for advising FGIS of any special import requirements: e.g. Kenya – peas must be split – therefore consignment must be graded as split peas
FGIS only inspect for insects, unless notified otherwise: e.g.. If country requires that shipment be free of a weed seed FGIS must be advised to inspect for this weed seed – For example Kenya requires that lentils be free of Lolium temulentum . FGIS must be advised to inspect for this weed seed. Inspectional results must be stated on FGIS documentation. If FGIS is not notified then the inspection will not be valid and will have to be reinspected.
Exporter responsible for obtaining FGIS Form “Inspection Report-Insect in Grain” – only FGIS document that PPQ can use
Special requirements must be stated on FGIS 921-2: go back to example of lentils from Kenya – the FGIS must state that
PC must be issued within 30 days of inspection
NOTE: FGIS can not treat all consignments

19. Step 3 Treatments Types of Pest mitigation
Clean consignment/conveyance
Cold treatment
Hot water dips
Heat treatment
Chemical treatments
Fumigations: methyl bromide and phosphine
Clean consignment/conveyance
Cold treatment
Hot water dips
Heat treatment
Chemical treatments
Fumigations: methyl bromide and phosphine

20. Fumigations Fumigator: authorized entity and facility
Approved treatment
PPQ must monitor
Bulk or containerized
Temperature
Gas permeable packaging
Authorized entity and facility: fumigator must be under compliance with PPQ – some concerns last year that fumigator that was approved by us was more expensive. If you know of another fumigator that would like to provide fumigation services they will have to be approved by us. This is worked out at the local level.
Approved treatment for commodity and pest of concern. Can not conduct treatments that are not legal in US
PPQ must monitor
Bulk or containerized: will affect whether fumigation can be conducted. For example: bagged commodities in a container – must have room for fans to circulate methyl bromide
Temperature: can not be conducted below 40 degrees. Below 40 degrees insects not respiring enough for gas to be efficacious
Gas permeable packaging

21. Step 4 Issuance of PC Consignment meets entry requirements
Consignment was officially inspected
Issued to NPPO of country of final destination
US exporter – must have physical address in US
PC issued within 30 days of inspection
Meets country’s time limits
Consignment must meet entry requirements
Consignment must be officially inspected
Issued to NPPO of country of final destination: country of destination must be same country where consignee is
US exporter – must have physical address in US – not a phone line that switches to an office in another country
Inspection date: PC must be issued within 30 days of inspection
Description of commodity/consignment
Distinguishing marks

22. PPQ Export User fees
Mandated by Congress to recover costs – no exceptions for user fees
Value ≥ $ $50.00
Value < $ $23.00

23. When You Have a Problem Resolve issues based on science NOT politics
Before ordering commodities determine if import requirements can be met
We are here to help – before you ship
Contact PPQ as soon as you know you have a problem
Resolve issues based on science NOT politics
Schematic:

24. PPQ US Export Program Questions? Karen Bedigian APHIS-PPQ
Senior Export Specialist
Riverdale, MD
PH: