Editor’s Note: Since 2002 the biocontrol industry has had a more difficult time importing and moving the beneficial insects, mites, and nematodes collectively known as biocontrols. Transportation barriers were put in place — stemming from the events of 9/11 — making our efforts more challenging. Efforts to make changes so as to lessen or even remove said barriers has been handled by the ANBP (Association of Natural Bio-control Producers), of which we are a member. Lynn M. Beck, Executive Director, has provided the following update as it concerns these matters. –Ed.
Regulatory Changes and the Commercial Biocontrol Industry: An Update for 2010 from the ANBP
For the commercial biocontrol industry, and for applied biological control in general, the past eight years or so have seen a number of changes in how beneficial arthropods are imported/exported and moved around North America. Some of these regulatory changes have been stimulated by the overall tightening of security after 9/11, the increasing awareness that invasive species may travel with purposefully-introduced species, and the need to limit the potentially harmful non-target effects of introducing new classical biological control agents into the environment. All of these important issues are actively being addressed by relatively new policies in the U.S. or may soon see changes after current revision work is completed, released for public comment, and subsequently finalized by U.S. federal agencies. Because some of these regulatory processes are detailed, links to websites that include definitions and good explanations are always helpful and will be provided further below. Two of the agencies/organizations that are actively working on these regulations are the USDA, APHIS-PPQ (Animal and Plant Health Inspection Service-Plant Protection and Quarantine) and the NAPPO (North American Plant Protection Organization) Biological Control Committee.
Permitting and Shipping Issues Today
As many of you know, the USDA, APHIS-PPQ, is responsible for protecting “agriculture and natural resources from the risks associated with the entry, establishment, or spread of animal and plant pests and noxious weeds to ensure an abundant, high-quality, and varied food supply.” Among their many duties, they evaluate and issue permits for the movement of organisms entering the U.S. and moving between states. In recent years, this job has ballooned as the volume of shipments has increased, while the numbers of inspectors at any given location, has, in general, decreased. Additionally, the permit application process for bringing in new arthropods and nematodes has become more complex (more information needed), and has become more difficult with respect to evaluating release into the environment (if the organism is new to the U.S.). Complications can also occur when shipping companies need to interact with the federal inspectors to evaluate and move packages along, and when transport companies simply do not want to ship living organisms. The “permit handshake” that should take place between these points of contact does not always work smoothly and can delay or stop shipments from moving all together. To complicate matters, occasionally the U.S. Fish and Wildlife Service (USFW) gets involved when they claim a product is “wildlife” and needs a special license (and $) to continue moving to its destination.
What’s in the Works?
Both USDA, APHIS-PPQ, (hereafter referred to as “APHIS”) and the NAPPO, have been hard at work to address permitting, shipping and release issues. Let’s start with APHIS, and then discuss how NAPPO works and some of the areas it is actively addressing.
APHIS
APHIS realized, years ago, that it needed to streamline and speed up the permitting process. In 2006 they introduced the ePermit system, which reduced hard copy faxing or mailing of permit applications. The ePermit also added more organism categories to the permit application, so for the first time, one could label it as a “biological control” species versus “plant pest.” About the same time, they added bar codes to the red/white shipping labels, allowing transportation hubs access to information about the packages that might be useful if other permit papers were lost or not with the package. All very positive steps.
For the past several years, the biological control community has been anticipating changes to the APHIS regulatory rules and policies [7 Code of Federal Regulations 330.200 and 300] that will possibly affect the movement of beneficial organisms among countries and sometimes, interstate. APHIS has been revising these policies and will be issuing their resultant document for public comment sometime this year. There had not been major amendments to these policies since the 1970s, and in 2001 they had begun the process after receiving over 2000 comments. However, the events of 9/11 stopped the revision and “required a major shift” in permitting policies. So today we await the release of these proposed revisions (which has been progressing through their required steps since 2005). In general, these amendments may include the following: changes to transit permits; changes to packaging and labeling requirements; improved transparency (web-based guidance); and new and revised definitions. Among the proposed amendments that we will be watching closely are the following:
- The exemption of certain organisms from interstate movement permit requirements. [”Field populations that are native or naturalized and/or commercially available and produced from strains already established in the U.S. or have been maintained and introduced over an extended period. Organisms that are currently exempt will remain exempt.”]
- A tiered approach to formulating permit conditions for the movement and release of biocontrol organisms. There are three categories in this tier.
- Bio-A: species is present in the U.S., has wide-spread use, and was previously assessed. No permit required for interstate movement or release.
- Bio-B: Environmental assessment complete, may allow for limited environmental release, and a permit will be required for movement and release.
- Bio-C: Environmental assessment not complete. No release permitted.
Watch for the comment period when these proposed changes are published. Two public meetings will also be held, so there will be plenty of opportunity to provide feedback to APHIS. The ANBP (Association of Natural Bio-control Producers) is monitoring this closely, along with many other biocontrol groups in North America, and specifically met with APHIS and other agencies last fall to discuss the needs of the commercial biocontrol industry with those steering the process.
NAPPO
Another organization that has been helping to streamline the movement of beneficials is the NAPPO. Its mission is to “Provide a forum for public and private sectors in Canada, the United States, and Mexico to collaborate in the development of science-based standards intended to protect agricultural, forest, and other plant resources against regulated plant pests, while facilitating trade,” and to “participate in related international cooperative efforts.” Among its various panels is one dedicated to the movement and regulation of biological control organisms used in either augmentation or classical biocontrol agents intended for release into the environment with expected establishment and pest control. They also address the movement of non-Apis pollinating bees.
The NAPPO biological control panel is composed of members of regulatory agencies from all three countries as well as two industry representatives. For the past several years, it has been working on two RSPM (Regional Standards for Phytosanitary Measures) that will directly affect the movement of beneficials.
NAPPO RSPM No. 26
The NAPPO RSPM No. 26 (PDF Format) are guidelines for certification of commercial arthropod biological control agents moving into NAPPO member countries. The link provided goes directly to the this eight page RSPM and it is very easy to follow. It will provide guidelines for the development and use of a Letter of Certification to be used to “facilitate the movement of commercial arthropod biological control agents into NAPPO member countries” (Canada, Mexico, and the U.S.). While the latest panel minutes are not yet online, our ANBP Board Member, Brian Spencer (Applied Bio-nomics, Canada), is an industry representative, and reports that all three NAPPO countries have made progress on their regulations and most will be complete by this fall. In addition, NAPPO has agreed to send a letter to all commercial shipping companies expressing the importance of working together for plant protection. Panel members have been working on new packaging standards that, together with the Letter of Certification, should help shipping companies trust commercial products as safe to ship.
NAPPO RSPM No. 29
The NAPPO RSPM No. 29 (PDF Format) are guidelines for the petition for release of non-Apis pollinating insects into NAPPO countries. In the past decade, populations of native pollinating bees have declined and scientists believe some of the decline (not all) may be linked to a number of issues related to the introduction of non-native bees. Incoming non-native pollinators may have carried (and subsequently spread) additional pests and diseases, and have possibly out-competed native species causing these population declines. Therefore, the scope of this RSPM is to assist in preparing a petition for importing and release of pollinating insects in NAPPO countries. “A standardized petition for these organisms will assist reviewers and regulators in assessing the risk associated with the importation, movement, and release of pollinating insects. Apis mellifera (honeybee) is excluded…”. Follow the link to the document and you will see all the requirements being proposed to facilitate the review and safe importation of these species. Panel members report that this RSPM is close to implementation.
For More…
For more information on all of these current policies and pending changes to arthropod movement regulations, bookmark the links above and watch for updates and announcements that will be listed at those sites.
About the Author: Lynn M. LeBeck is the ANBP Executive Director. To learn more, visit the ANBP on the web at www.anbp.org.
Mike Cherim responds:
Posted: May 10th, 2010 at 7:33 am →
Thank very much for putting this together, Lynn.