"Proposed International Standard on Plants for Planting"

[Pascal B]

I write this from experience and want to share it just to give some insight in getting a phyto in the Netherlands, a country which you expect to have a well developed system for issueing phyto's...., I can tell you, as an individual grower it is near impossible to get one to send some plants to another country, as sad as it seems.

This year I intended to send some Arisaema to Japan in return for rare Japanese Asarum that were send to me and approached the bulb inspection bureau at Lisse. When I told them I was a hobbyist wanting to get a phyto for Japan (a country known to have some of the strongest guidelines) they had to ask permission if I could make an appointment at all! Finally they were willig to make an exception and the stuff I wanted to send was inspected, the phyto was issued but I could not include some tubers in that shipment that I received a week before from Thailand. The Thai tubers were send to me with a official phyto from Thailand and upon arrival were inspected at a fee of 100 euro again by a Dutch inspector of the same Dutch phyto organisation. But because they were not grown in my collection for a year, I could not include them and the level of inspection at Schiphol Airport was not the same as the export inspection they said. To my surprise the phyto I got only had the number of Arisaema I wanted to send on it, NOT specified to the species!. So I replaced some small bulblets with the Thai tubers and included them in the shipment.

The reason they had to make an exception for me is because the phyto buro is solely focused on the trade. Therefore officially in order to get a phyto you have to first of all register at the buro for a considerable fee each year and allow inspections once or twice a year at the place you grow the plants. For an individual hobbyist that is a nogo. When I left with my phyto and completely desillusioned I was told that they were not sure they could make an exception for me again! After hearing that I replied "so you rather have me send stuff "illegally" than provide such a service for me?". The answer was......... "we are afraid so"....!!!

So playing by the book in Holland is costly, frustrating and apparantly near impossible because all inspection buro's in NL only cater for the commmercial trade. So where does that leave me? Pushed into sending stuff without a phyto.

New regulations only can be succesfull if there is a common goal, common interpretation and most of all, a realistic approach, it can go wrong at so many levels and what Tony says is true, many countries issue a phyto that has the value of toilet paper. Why would the Dutch governement otherwise demand a new inspection when my shipment from Thailand arrives?. Because they don't trust the Thai phyto. And I can't blame them because I know how they are issued in Thailand. And you can never get that trust, Asian countries don't work like the Western countries want. So mitigating at the source thereby trusting the country of origin?! Neh...., never.

Same with the CBD and CITES, wonderfull in their goals but failing miserably because of bureaucraZy and politics. A lot of plants on the Cites lists are not theatened at all and many plants that are theatened are not on it. We think we protect the plants by not buying without a Cites document but do nothing to protect the habitat, how realistic is that? Mitigate at the source can also be applied to habitat protection. But very few countries will allow any foreign influence on their policy for nature conservation. And to read about these new regulations in Malaysia is hilarious and sad at the same time. I have done fieldwork in Malaysia several times and the number of acres of oil palm plantations is heartbreaking! But allowed by the same government! Previous prime forest which had many orchids in them, now endless rows of palm trees for oil production for all sorts of things used in the West. But yet, are we still bying soap made from that oil? Yes we are. But at the same telling people not to buy plants without a Cites document is hypocrit.

Rather accepting the fact that it can never be 100% full proof and accept the limitations and work around them for a more realistic approach, often the decision is made to regulate more and more. Upto the point that people that grow plants as a hobby have so few possibilities left to move plants around they have no other option but to do it illegally. And that is exactly the opposite of what the aim was...
Just like my experience with getting a phyto shows.


Edit: Just briefly went through the proposal, again it seems largely focused on the trade, not the hobby growers. And yet this group plays an important role in the protection of rare and endangered plants ex situ. Risk reduction by distributing rare plants among fellow growers becomes more difficult because we can never comply with these regulations.
 

[alpinegarden]

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!

[Maggi Young]

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.

I  must just point out that without people like Joyce working so hard to make representations these  concessions would not have been made and the Seed Exchanges of Societies like ours would be scuppered.

In the same way the SRGC and similar clubs are involved in making similar cases for solutions to draconian restrictions being mooted for the likes of Tasmania...... there is a lot of work to be done in such matters around the world.

[Hillview croconut]

Hi I agree one needs to be constructive in ones approach to these matters but people need to know what they are up against.

Biosecurity is a growth industry and the agencies that run them are monopolies and they tend behave like monolithic organizations behave. Add to this the fact that they are mostly funded by industry levies and you have "the tail wagging the dog" in many cases. Generally the agencies' approach is initiate these regulations behind closed doors with only large scale commercial interests present. And in many cases the decisions that are reached have more to do with international trade issues and markets than the have to do with biosecurity.

The only way to have effective input is through large-scale lobby groups, individuals or independent nursery operators have no chance on their own. I think that a major focus for the future for the Big 3 in alpine gardening should be making themselves into powerful counterveiling voices in this debate otherwise they will be regarded as irrelevant and their interests de-legitimized.

Make no mistake the future of specialist growers and nurseries is in the balance here. Increasing regulatory weight, the costs of compliance and the reluctance of biosecurity agencies to deal with anything else other than a bulk commodity business model are serious problems but first the alpine gardening community needs toet serious about getting a place at the table.

[Giles]

This is the gold standard:
http://www.icgd.reading.ac.uk/quarantine.php

[Hillview croconut]

I think that the contents of this link eloquently reiterates the points I have made.

[Giles]

I was actually trying to suggest the exact opposite.
The lightly regulated exchange of plant material between amateurs poses a severe threat.
Entire communities often depend upon the success of a few restricted crops.
Failure of a crop such as cotton, rubber, sugar, soy, maize could result in poverty, famine, political instability and mass migration.
Plant disease can change the course of human history (Think of the Irish Potato Famine).
It is impossible to ensure safety in a situation such as seed exchanges, where there is a wide diversity of plant material, in small voulmes.
It is simply incorrect to imply that seed is free of disease, or that a plants potential to act as a weed in its non native environment can be anticipated.
The current measures in place on this material are wholly inadequate, and I would support more stringent regulation, even if it were to result in seed exchanges being no longer able to send material to overseas members.

[Hillview croconut]

I tnink you are trying to compare apples with oranges. Highly manipulated genofolds being farmed in monocultures represent a far, far greater threat to biosecurity, food security, etc than any genetically diverse, essential "unimprove plant material . The vast majority of economically important pests and diseases are moved around the world through the commercial pathways than the combined efforts of all "amateurs". This is an emotive term that implies that people who dont quite have the same rights to exchange plant material. Whats need is a smarter, more nuanced approach to accomodate different levels of risk etc., you wont get that if you dont fight for it. Money and influence are big drivers in this debate not fairness or equity.

[alpinegarden]

Being well aware of seed-borne diseases, I believe that the practices in place for seed exchanges reduce such risks to their lowest level - and APHIS has agreed.  The U.S. now requires that small lots of seed enter the US under a permit and post-entry inspection (for cleanliness, as well as compliance with the list of non-enterable taxa).  In fact, at one of my first meetings with APHIS staff, I used packets of SRGC seed as examples and they were impressed with their cleanliness. This is not to say that even clean-looking seed cannot harbor pathology (e.g.: viruses), but no amount of inspection/regulation can address that, and regulators are well aware of that fact.  Seedex seeds compare very favorably with commercial seeds, grown/harvested in huge lots under conditions that actually foster the expression of latent seed-borne diseases.

APHIS (and probably other NPPOs) believes that "best management practices" are the best mitigation to lower phytosanitary risk.  I was told that the steps taken by seedexes to assure that clean seed is distributed are a good example of best management practices.

The balance to be struck with plants - perhaps the bargain to be struck with regulators - is to support the notion of regulated best management practices (arrived at through discussions/negotiations with industry stakeholders, as stated clearly in the IPPC Standard), with some allowances made for smaller nurseries and one-to-few plants from non-production sources (wild or garden origin).
Who among us would not prefer to purchase stock from a nursery held to higher standards of cleanliness?

[Lesley Cox]

The current measures in place on this material are wholly inadequate, and I would support more stringent regulation, even if it were to result in seed exchanges being no longer able to send material to overseas members.

Well thanks.

[Hillview croconut]

Yes I agree wih supporting regulated best management practices that are commensurate with critically established risk assessments and are shown to be cost-effective, and flexible enough to meet changing circumstances. And I agree that these benchmarks should be arrived at co-operatively with stakeholder and community imput. This is the real sticking point for me and I suggest Leslie Cox, we both operate within highly regulated systems where there is much emphasis on stakeholder compliance - the problem is, and I'm sure Leslie will agree with me, I dont see much in the way of willing co-operation coming from the other side. I can assure you this not from lack of trying on my behalf. I have been deeply involved in biosecurity issues over the past years and most of it has been "like swimming through treacle" and most times the agencies have relied on the power of their office rather than the strength of their arguments. As I have said before they are monopolies and they don't enjoy scrutiny and they are prone to be hijacked by sectional and political interests.

There needs to be a more open discussion about what actually constitutes effective biosecurity and a more transparent approach to establishing what best practice is and how it applies to different classes of risk. In Australia that has not happened for the specialist end of the industry. And it wont happen unless there is a concerted effort from the alpine gardening community. Can I also suggest that from the lack of general interest in this thread that wont happen soon.

[rob krejzl]

Can I also suggest that from the lack of general interest in this thread that wont happen soon.

Marcus,

I'm sure that lots of people are viewing this thread but that, like me, they're at a loss at how to make a positive contribution.

[Maggi Young]

I think you may have a good point there, Rob  :  it may be hard for folks to feel they have much to contribute to this thread but, since (as of the time of this post) 386 people have already viewed the thread, we can at least hope that some will be reading all the proposals from the links given and will be composing letters to their country representatives.

[David Nicholson]

I think you may have a good point there, Rob  :  it may be hard for folks to feel they have much to contribute to this thread but, since (as of the time of this post) 386 people have already viewed the thread, we can at least hope that some will be reading all the proposals from the links given and will be composing letters to their country representatives.

Yes, but like me 380 of them may well be struggling to understand what's going on. I'm always ready to pick up my pen and write to my MP (gives 'em something to do between compiling expenses claims!) but I like to know what I'm talking about first. What about someone who does know what they are talking about volunteering to come up with a "master" letter the less cognoscenti could just print off and sign

[Hillview croconut]

Hi Rob, you and I face different problems to most of the other good folk. But I have learnt these things and I think apply universally to this situation.

1.   Get motivated – your right to your hobby, means of making a living, way of life, etc. will be challenged (eventually), either inadvertently or deliberately and no-one other than you will be looking after your interests unless you can get taken notice of.

2.   Get informed – anticipate the challenges and get ahead of the game by understanding the issues. Use the internet, other forums, look at precedence in other countries, New Zealand and Australia have had serious biosecurity regulation for years – see what you can learn there. For one example, look at how the national standards for imports are set and organized, how they are presented and how they can be accessed by the public. Australia’s ICON database is the standard for that country.

3.   Get connected – find like minded people to test ideas with, share information and for moral support. No-one can take on the job of lobbying for a fair deal alone.

4.   Get involved – pick up an issue and take it you local member, the Minister or his office. Be persistent and courteous but don’t give in. Find support in the media, local garden clubs, gardening personalities, community organizations, etc.

It is most important that one establishes from the outset that one has a legitimate right to be heard and accommodated as far as practicable in any changes that are taking place.
It is also important to put forward one’s vision of how those rights be expressed – have some sort of plan of, if not the details, the objectives that you would like to see the regulations meet. As I mentioned before, equity and fairness, cost-effectiveness, flexibility and the capacity to test benchmarks into the future so sensible adjustments can be made. I could go on about these things for a long time but I will just make one final point: It really should be one of the primary focuses of the 3 major societies to each develop  proactive strategies that push the case for inclusion in developing new regulatory responses. As I said before an independent operator has no chance, it’s like talking into a thunderstorm, you won’t get heard. Even having your say in community consultation processes are of limited value unless they are backed up by a bit of heft, unfortunately.