What the APHIS Plant Import Rules Restructuring Means for You

Plant-Propagation-Material
Quarantine 37 covers imports of live plants and plant propagative material. Photo by Janeen Wright.

The U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) has announced it has finalized the long-awaited rule changes needed to restructure Quarantine 37.

What Is Quarantine 37?

The federal regulation covers imports of live plants and pretty much any type of plant propagative material. Taken together, these things are called “plants for planting” in plant health/phytosanitary speak, and they are distinguished from items intended for direct consumption, like fruits, vegetables, and cut flowers.

AmericanHort (ANLA, previously) has long supported a strong, science-based Quarantine 37 as the first line of defense against the introduction of invasive plant pests and diseases from other parts of the world. We want to be able to trade, but safely. When invasive pests arrive and establish here, they can bring crop loss, increased production costs, and quarantines that result in lost market access for U.S. growers, as well as damage to landscapes and ecosystems.

This Is Partly About Simplification

Under the restructuring rule, which took effect April 18, APHIS will consolidate general requirements for importing plants for planting in one place in the Code of Federal Regulations (CFR). Also, APHIS will post import restrictions for specific types of plants for planting in its Plants for Planting Manual, instead of codifying them in the CFR, and notify the public of changes through the Federal Register.

Other Changes by APHIS

APHIS will also:
• Add most currently prohibited plants to the Not Authorized Pending Pest Risk Analysis list
• Move lists of approved growing media, packing materials, and ports of entry, and other approved items to the Plants for Planting Manual
• Adopt a notice-based process for making changes to the plants for planting import restrictions that will be listed in the Plants for Planting Manual
• Add post-entry quarantine requirements to the Plants for Planting Manual
• Establish a framework for using integrated pest risk management measures

Long story short, two primary reasons for the restructure are (1) to make it easier for Agency stakeholders to find and understand rules and import requirements for plants; and, (2) to make it easier for the Agency to make future changes in the Plants for Planting Manual, after following a public notice and comment process.

But Wait, There’s More!

In a world that has us swimming in a sea of acronyms, we have a new one to learn — IPRMM (say EYE-prim). Integrated pest risk management measures, IPRMM, are coming to the forefront as a tool for addressing plant pest risk and enabling trade. Integrated measures approaches combine two or more independent pest risk management measures. Such measures, when combined in a system, may address pest risk in a way that a single measure can’t.

A good practical example of these concepts at work is the pilot certification program for plant cuttings produced in offshore facilities. That pilot, which ended March 31 and is being evaluated, combines site-specific facility design, sanitation, and pest management measures with training, recordkeeping, and traceability. Of course, an IPRMM might be more narrowly tailored to a particular plant genus from a specific country.

What’s Next

Going forward, APHIS may require IPRMM to address pest concerns associated with imports. The rule describes components of an IPRMM, including pest management plans, recordkeeping, audits, accountability and training of personnel, and traceability.

APHIS posted the updated Plants for Planting Manual on its website on April 18. AmericanHort will closely monitor the implementation process. Breeders, growers, and importers interested in following future developments should also subscribe to the APHIS Stakeholder Registry.

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