Scottish Rock Garden Club Forum
General Subjects => General Forum => Topic started by: Maggi Young on August 04, 2010, 09:25:37 PM
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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.
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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
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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
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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
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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
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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
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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
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Here, to make life a little easier, is a pdf of the proposals, click to download.
[attach=1]
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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. >:( >:( >:(
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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.
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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.
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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.
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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"
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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.
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Folks, I am cross-posting your comments to the NARGS Forum to keep them up to date.... :)
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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.
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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!
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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.
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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.
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This is the gold standard:
http://www.icgd.reading.ac.uk/quarantine.php
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I think that the contents of this link eloquently reiterates the points I have made.
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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.
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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.
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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?
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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.
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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.
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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.
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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.
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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 ???
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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.
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I agree with every word you say above Marcus, but like Rob and David, feel quite helpless. I as much as you, work in what has become an impossible environment for the introduction of plant material. A number of specialist nurseries have closed because new material is not permitted and gardeners and gardens suffer as a result and countless jobs have been lost. Your list of what to do about it, while absolutely on the ball, is, for many or most people, an impossibly expensive exercize in both time and money. If I were 30 years younger.....or even 10.
The great biosecurity threats in NZ now are not from introduced plants but from pests and diseases brought in on ships' decks and in containers, of machinery, especially second hand machinery, including cars, tractors industrial machines and the like, and totally inadequate inspection processes at ports of entry. This will always be the case, regardless of what requirements are put on exporting countries. In general, a "random" sample is taken of perhaps one in ten or even more. There is no question ever, of inspecting every item imported. Those exporting will never give a damn about whether they're sending bad stuff to other countries. Not their problem. It will always be our problem, to protect our biosecurity.
We also have the "political" requirements to be met. The Dept of Conservation is determined to keep out as much exotic material as possible and maintain NZ as a "natural" habitat. (It hasn't been that for 1500 years!) Then there is the Maori vote. They too, want all exotic material kept out and even removed. Ideally, from their point of view, this would extend as far as the white population, let alone immigrations of all European, African and Asian peoples. Against such strong lobbies, gardeners, nurseries, or "hobbyists" have no voice at all or if they shout loud enough, are considered to be vexatious and selfish. I do most Maori an injustice here. Most are well aware that the status quo will remain and are happy for it to do so but there is a VERY stong voice among some, wishing to turn back the clock to what they see as halcyon days of early Maori immigration (they are NOT indigenous people) before the European arrived. and our current white politicians are of the appeasing kind.
I believe your list is the right way to go for those who have reasonable restrictions or regulations at present. They may be able to save something from the devastaton to come if the proposed standards are put in place internationally. For New Zealand and probably Australia, it is far too late. For the rest of you, let our situation be a grim warning.
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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.
OK Giles.
The unregulated transports in the previous century caused pest/disease caused famines in.............. Where? Examples please!
How are you going to prevent travellers from putting seed in their pockets? Shall we all be searched naked everytime we cross a border??
Shall all private mail be steamed open in search of seed ???
Shall every bird crossing a border be shot?
I repeat: A large proportion of the pests and diseases that have been transported across borders were transported by hitchhiking on vectors that have not been subject to search or control and which in the future are not included in any planned regulations. I mean trains, ships, airplanes, machinery, (thank you Lesley) grain, etc etc. The yearly fast spread of flu is a good example.
Extended regulations only hit responsible seed exchanges and feeed burocrates and large organizations. Burocrates want more regulations so they can get more work, status and money. The organizations want monopoly on selling plants, seed etc.
As far as CITES is concerned, the regulations were written for animals and without proper discussion extended to plants in the last minutes.
An animal can usually move out from an immediate threat such as a bulldozer but cannot be propagated by cuttings grafting or division.
A plant can not move out from under the bulldozer but can be propagated vegetatively.
CITES does not prevent a farmer with a rare plant on his land to start growing this plant and exporting it. But only If he can cope with the local burocrats and pay enough for all inspection measures. In reality this is a severe hindrance. It is easier to eradicate the rare plant in order to grow a crop that he can sell without the fuzz and which he is more familiar with.
We end up with the present situation where we are allowed to put tarmac on top of the only occurance of a rare orchid in the county but are forbidden to move it into safety and even forbiden to save the seeds from the tarmac. We are also forbidden to move sterile clones of endangered species into safety (hepatica nobilis fl.pl) This means thet the regulation is a death warrant.
Cheers
Göte
PS.
Of course strict regulations would have prevented the Irish potato disaster since no potatos would had been allowed in the first place. That applies to all the listed potentially endangered crops above.
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Some of you may be interested in the official country comments that were sent to the IPPC from the U.S. representative, Julie Aliaga, APHIS-PPQ. You're welcome to read the whole template, of course, which reflects the position that APHIS is taking and, in turn, reflects comments that she received from stakeholders. However, take note of two particular comments, the very first paragraph and the comment under Scope.
Both comments indicate that APHIS is willing to exclude small lots of plants from future regulations that would be based upon this Standard. The wording in those two official comments are almost word-for-word from my email to Ms. Aliaga, showing that APHIS-PPQ officials are concerned with and responsive to their stakeholders.
Go to:
http://www.aphis.usda.gov/import_export/plants/plant_exports/phyto_international_standards.shtml
Click on "APHIS Comments for Draft Standards, and then on Draft: Integrated measures approach....
I hope that others have also written to their country representatives (at DEFRA, CFIA, etc.) so that their comments reflect the same thinking and the final Standard will contain language that exempts non-commercial (meaning, smaller) lots from the need for Integrated Measures.
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It is just this sort of helpful advice, and more besides, which has meant
that Joyce has gained the admiration and gratitude of so many American
members and the Seed Teams of the likes of SRGC and the AGS for her
assistance in clarifying USA seed import regulations and also in lobbying
for various changes to the system.
Joyce's efforts in this field are remarkable and her level of success in
preparing cogent and relevant presentations to the Authorities on these
matters have played an important part in keeping seed ordering
accessible to USA members of clubs like SRGC.
It is important that we all take heed of regulations that may be afoot is each of our countries, as Joyce says, to make sure we do all we can to keep the exchange of seed between plant enthusiasts a possiblity in time to come.
Thank you, Joyce for your continuing efforts in this field.
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I've yet to read the links from alpinegarden's post but it seems we could do with Joyce here. Please send her by airmail.
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I can assure everyone that Joyce would indeed be a welcome addition to the workforce of any club! Her dedication to NARGS is undoubted and she has been a tremendous help to the Seed exchanges of both the SRGC and AGS (and perhaps others) in the matter of understanding and implementing seed import permit regulations.
It was this unstinting help to the SRGC in such spheres that resulted in Joyce being awarded Honorary Membership of SRGC at our recent Annual General Meeting.
It is acknowledged that her help has resulted in the SRGC seed exchange being better able to advise and assist USA Members in their applications for seed from our exchange.
As you can see from her posts above, Joyce has just the determination and skills to present reasoned submissions to the various government authorities of such subjects and so you will see how richly Joyce deserved this honour.
President Liz Mills spoke at the AGM of Joyce's contribution and there was general applause for the award. Joyce Fingerut is a most valued Member of SRGC and a great example of the international cooperation that goes on between our organisations.