"Proposed International Standard on Plants for Planting"

[Maggi Young]

Proposed International Standard on Plants for Planting :
I copy to this page the original posts from Joyce Fingerut (a former President of the  North American Rock Garden Society to Alpine L, and reproduced on the NARGS Forum with permission. Permission has been given to repost here, to give as wide an audience as possible to these in important proposals.
There are posts from Joyce, from Tony Avent and from Peter George .... I will post them here individually to make for easier reading.

[Maggi Young]

Proposed International Standard on Plants for Planting
From: Joyce Fingerut
Date:Wed, 4 Aug 2010


You may be interested to note - and to read - the following Draft Standard: Integrated Measures Approach for Plants for Planting in International Trade

The International Plant Protection Convention
(IPPC;   https://www.ippc.int/IPP/En/default.jsp)
is proposing a new Standard concerning the international movement of  
Plants for Planting.  Their website contains the draft standard, which is now open for comment by the member countries of the IPPC.
(Go to: https://www.ippc.int/index.php?id=207803
See Draft 3, and click on the appropriate language in the Publication column)

An International Standard sets guidelines, not rules, that the signatory countries (all 173 of them) have agreed to follow when formulating their own regulations/rules governing imports and exports.

While this Standard excludes seeds, it will eventually have  a direct effect on the export/import of plants around the world, so many of our fellow plant society members will be affected by the resulting national regulations.

The latest thinking concerning the problems of pests associated with the movement of plants around the world is that these problems are best mitigated at the source, by the exporters (place of production), rather than caught by the importers (pest risk analyses,inspections).  
See page 5 for a quick summary of the underlying  reasoning.  Ideally, if each country based its phytosanitary standards  on the same philosophy, there would be no discrepancies in the level  of requirements (just the specifics of pests and types of mitigation  measures).

Regulations written by any country may only pertain to "quarantine" pests: i.e.: those with known negative economic effects, that are not already present in the importing country (or present in limited numbers, with an official control program).  However, in protecting  against known pests, an integrated measures approach may additionally  protect against pests that are currently unknown to science or the industry.

The "Requirements" list offers factors that should be considered by each country's National Plant Protection Organization (NPPO) when  proposing measures to deal with pest risk management. Factors, within production and use, are broadly ranked in order of their increasing risk level.

"General Integrated Measures" describes the overall controls that should be exercised by any place of plant production in order to be "authorized" to grow plants for export, including production, storage,  movement of plants - as well as recording of all relevant information  (plans, manuals, inspections, etc.).

Keep in mind that Standards are only guidelines, offering factors that should be taken into account when proposing national regulations.  
Governments will eventually draft specific rules, depending upon their chief production crops, and their primary trading partners.  
Naturally, each country, and its plant industry, would prefer to minimize its level of control on production/export (which can be costly to initiate) and maximize the requirements for imports.  
However, by international agreement, these phytosanitary requirements  
must not act, in lieu of tariffs, as a barrier to trade. It is hoped that, in the end, with each country monitoring and mitigating its own pest risks, all countries will benefit by seeing a reduced incidence of new pests, with their resulting negatvie economic and/or environmental impacts.

To send comments, or ask questions, please see https://www.ippc.int/index.php?id=1110520&no_cache=1&type=contactpoints&L=0
...for the contact organization for your country.
The names of the officials may be somewhat out of date, but it will set you in the right direction.
 Comments are sent via your country representative,  not directly to the IPPC.

For preliminary questions, before your contact your NPPO, I will be  
glad to help where I can.(email Maggi to get Joyce's e-address)

Joyce Fingerut
Stonington, CT
Zone 6

[Maggi Young]

From: Tony Avent
Date:Wed, 4 Aug 2010
             
Joyce:

I don't have time to read the proposed regs at this time, but will offer a
couple of comments on what I know of these idea.  In my plant exploration
travels, I have only found about 8 countries, whose phytos are worth the
paper they are printed on.  All other phytos are worthless!  This current
thinking, which is more appropriately a lack thereof, assumes that all
countries can issue meaningful phytos.  When you start with an incorrect
assumption, it always leads to incorrect conclusions.  The idea that places
of production should be inspected is also rife with problems, (i.e.
competence of inspectors for a start), but also allows no method for plant
explorers to get phytos.  It's easily for bureaucrats who propose these to
send off an email and ask if each county can comply with their new
regulations.  Guess what, the answer is always, YES.  If we could only get
the people who propose these idiotic regulations to do the "secret shopper"
test, they would quickly see that most of their ideas simply don't work in
the real world.   


Tony Avent
Plant Delights Nursery @
Juniper Level Botanic Garden
9241 Sauls Road
Raleigh, North Carolina  27603  USA
Minimum Winter Temps 0-5 F
Maximum Summer Temps 95-105F
USDA Hardiness Zone 7b
email tony@plantdelights.com
website  http://www.plantdelights.com

[Maggi Young]

From: Peter George
 Date:Wed, 4 Aug 2010

Tony and Joyce,
Would it be possible for you to post this discussion on the NARGS Forum as well? It's an important and relevant topic, and we should provide it with the largest possible audience. Thanks in advance.

Peter George, Petersham, MA

[Maggi Young]

From: Tony Avent
Date:Wed, 4 Aug 2010

Peter:

I haven't had time to figure out how that works, but feel free to post my
comments there.


Tony Avent

[Maggi Young]

From: Joyce Fingerut
Date:Wed, 4 Aug 2010

Tony -
I certainly understand your concerns about bringing back plants 
collected either in the wild - or from someone's cultivated garden. 
That will be a good point to make, and I will add it to my own 
comments to APHIS (the U.S.'s NPPO).

As for disparaging existing phyto-writers, that's probably not the 
most helpful argument (truth or validity, aside).

Thanks for your comments.

Peter -
I'm waiting for a log-in registration to post this on the NARGS 
Forum. 
In the meantime, I hope everyone who reads this will feel free 
to cross post to other listservs and Forums (Fora?), since this will 
be an issue that eventually affects every plantsman in every country.

Joyce

[Maggi Young]

The consultation period of these proposals for 2010 began on 20 June and ends 30 September.

https://www.ippc.int/index.php?id=1110520&no_cache=1&type=contactpoints&L=0  will take you to a list of contacts for all countries... here is the one given for the UK:

United Kingdom [GBR] WG , IPPC official   :  Mr. Martin Ward        martin.ward@fera.gsi.gov.uk

Plant Health Policy Programme Food Environment Research Agency
10GA07
Sand Hutton
York YO41 1LZ
United Kingdom

[Maggi Young]

Here, to make life a little easier, is a pdf of the proposals, click to download.

 Plants_for_Planting_draft.pdf (104.9 kB - downloaded 77 times.)

[Lesley Cox]

In theory this could make importation easier and cheaper for New Zealanders and Australians, but I imagine both countries will ignore whatever is proposed and go their own way which is always to tighten regulations and further restrict the introduction of plant material. If seeds are to be included as well in time, that's it, so far as we're concerned. No new plant ever again.

[Lesley Cox]

Well that comment I made immediately above now seems more than a little stupid. I've had a quick look through the Draft 3 content, and it seems that the international community is intending much the same kinds of measures that NZ's ERMA (Environmental Risk Management Authority) has had in place and practice for the last 17 years. If it goes ahead much as set out, plant importation anywhere in the world will be a thing of the past. Keeping the system going in NZ at least, is massively expensive to the Govt, with a huge bureaucracy. Other countries will find the same happens to them.

And Tony is right, no country can rely fully on another country's phyto, inspectors or any measure taken at the sending out end. For this system to work, the importing country will HAVE to do all the inspections, quarantines, treatments etc. Like asking big companies to "self-regulate" their behaviour. It just doesn't happen. Someone else HAS to make the rules and oversee and enforce their implementation.

[Maggi Young]

Here is  another comment from Alpine L :

"There is another "plant move" afoot that is not dissimilar in its attempt to "regulate."  In Malaysia, the government has imposed a law that requires anyone growing any orchid species (from anyplace on earth) to supply a list of those species to the government and obtain a permit to grow them.  Further regulations require a permit to do hybridizing or propagating of these species, selling them or giving them away to friends and obtaining them from outside the country.  It even goes so far as to say that if a permit holder dies, his family has an obligation to inform the government in order to determine what happens to the orchid species."
M. R.

[Maggi Young]

And one from Joyce on the NARGS Forum:
"Many thanks, Maggi and Peter, for your help in spreading the word here and on SRGC's Forum.
What I am looking for are the particular concerns that growers and amateur plantsmen (in all countries) would have with this new standard.

Keep in mind that the world of commercial agriculture and horticulture requested this standard, so that countries could write balanced regulations that would protect their own crops by providing a greater measure of protection against the entry of new pests.

Naturally, it's cheaper for each country to require offshore mitigation of pests (push the work off on the exporter).  However, if all countries were required to use a systems approach to phytosanitary cleanliness, it should be more equitable.  Of course, we know that in practice, all countries will not put rules into effect at the same level, or on the same timeline.  Some will be more restrictive (note Leslie's comments) while others will be written or enforced more loosely.  So it goes....

For some businesses/people, it may not be the standard that will be the problem, but the individual country regulations that will (sooner or later) ensue.  In that case, your best bet will be to contact your national plant protection organization, find out who will be leading the charge on the new rules, and stay in touch with that person and chat on a regular basis.  Politely and civilly, let them know of your concerns, and how the proposed rules will have a negative impact on your business or your gardening life.  My experience with APHIS, over the past nine years (and I'm sure it's true of any plant protection organization), is that they are willing to listen to concerns, answer questions, and discuss points of view.  Whether that will have any effect in the end remains to be seen."
J.F.

[fermi de Sousa]

I sent a link to this page to my friend Marcus who asked me to post his reply:

"Thanks - had a quick look. Will return to it later. Maybe you could post this comment from me??
 
It's a real worry that most of these regulatory responses are not developed in consultation with the stakeholders. Most of these decisions are made long before the people who they will directed at ever get to see them. Once taken, as I have found from personal experience, it is nigh impossible to reshape the discussion or, God Forbid, change anyone's mind. Because these decisions are taken by people who have a narrow focus they are usually not balanced by other objectives like fairness or equity and cost-effectiveness. Impacts on the nursery industry or costs/benefits to the community run a long second in these processes, unless ofcourse one belongs to a powerful lobby group and then the whole thing is inverted in favour of the protagonist.
 
I have found in my dealings with biosecurity agencies these 3 maxims to be true:
 
To an man with a hammer everything is a nail (Narrow Focus)
Biosecurity is good therefore more biosecurity is even better  (lack of balance)
We'll take the rolled gold version thanks (We dont have to pay - we actual gain)
 
Cheers, Marcus"

[gote]

The only thing that will happen is that prices on rare plants will go up and that there will be more smuggling.

Many species that have taken hold in this country in the past 150 years, came as unintentional transports with trains or ships. Some came with birds. The most devastating import - the disease that killed nearly all our native crayfish - came with ballast water from an American ship over a hundred years ago.
 
When there was an outbreak of foot and mouth disease in the UK some years ago, everyone who came by air from the UK regardless of whether they had visited a farm or not had to walk through a disinfecting bath. This disease is endemic in Turkey but no quarantine regulations apply to travelers from Turkey.

We know that plants and diseases are carried by natural agencies and the populating of new volcanic islands has been studied extensively.

Sometimes one wonders what we are trying to achieve. When I was very young, the black headed gull (Larus ridibundus) was unknown except in the coastal areas of Sweden. However at that time it started to spread inland and the environment pundits declared that the gulls be highly obnoxious and called them flying rats and some went out with shotguns and tried to exterminate those which tried to find food on refuse dumps.
Recently the gulls were starting to decrease in numbers and the environmental pundits declared their worry, that those irreplaceable members of the local fauna were decreasing and that they should be supported in all ways possible.

The beaver (Castor fiber) is a deadly threat to the genera Nymphaea (including the red sport in Fagertärn which is the genetic source of the red colour in the Marliac water lilies) Stratiotes, Saggitaria and some other species. However, he environmentalists declare that the beaver by its actions increases biological diversity 

I understand that the, in Sweden, most obnoxious rodent Arvicola terrestris is protected in the UK 

I have not read the paperwork in question but I agree with Marcus.

Cheers
Göte.




 
     

[Maggi Young]

Folks, I am cross-posting your comments to the NARGS Forum to keep them up to date....