[MPWG] Fw: Greenhouse Certification Program

Wed Oct 27 12:37:48 CDT 2010

On 10-10-27 09:30 AM, Patricia_DeAngelis at fws.gov wrote:
>
> Well, the "White List" discussions this week have been interesting to
> say the least.
>
> The information below on the Canadian/US greenhouse certification
> program should better inform our understanding of this topic. Here are
> some key points:
>
>     * It's primarily about pest management - not an invasive issue.
>

The program definitely does involve invasives. The current system has a
list of excluded plants and on it are 60 terrestrial weed species and
genera. This excluded list has been in force since the beginning of the
program in 1996. There are also 15 aquatic weed species and genera on
the list. To be sure, there are also many species and genera on the
current excluded list that are vectors for pest and disease risks to crops.

The CFIA officials I spoke to confirmed to me that invasives are
definitely a part of the mix of criteria for the new list of authorized
plants.  This list has apparently been three years in the making, the
work of a committee of experts. I asked for: 1) details of the make up
of the committee; 2) the criteria by which plants are included or
rejected for the new list; and 3) a list of what plants have been
considered and rejected for the list. Apparently, the rejected plants
are quite a few. So far I have not received any details of the workings
of this committee other than what I am relating here.

It is important to understand that many plants that currently move under
this program today are not on the new list and will be prohibited if the
proposed list is implemented.  These are plants that the committee
presumably already knows have been crossing the border under the program
but decided to leave off the list. I am not talking about a handful of
plants here.

>    *
>
>
>     * This is specifically regarding exchange of nursery material
>       between the US and Canada.
>

The current proposal affects greenhouse grown plants only. Nursery (i.e.
outdoor grown) plants come under a different program, and that program
is not affected by the new list -- at least not yet.

>    *
>
>
>     * It's an EXISTING program that is being changed.
>     * The program has existed for more than a decade.
>     * The explanation and announcement from USDA are included below.
>     * NOTE that the lists are not final (i.e., the plants currently in
>       those lists may change).
>

It is true the list will change. But to what? A list that compresses the
permitted plants to something of the order of 1000 genera? This is a
world of difference from we have under the current system -- a list of
excluded plants of perhaps a couple hundred genera. More than 10,000
genera will now be excluded by virtue of not being on the list.

It is also true that the "white list" is limited to the greenhouse
certification program and that plants can continue to move under the
traditional phyto system. But -- and at least one CFIA official agreed
with me on this -- that's just because this greenhouse certification
program is "low hanging fruit" for the regulators. It is a first step. I
don't think that they will stop with just this program -- it doesn't
seem logical.  The 300 or so Canadian growers in the program mostly grow
only species that are on the list. They will be largely unaffected by
the program changes, and indeed they have a vested interest to go along
with the changes. But once this list is in place then what next? The
nursery certification program appears to be next according to one CFIA
official I spoke to. Then there is a seed certification program that
could come after that. Then who knows whether the same logic will be
applied to all plants and seeds coming from outside North America.

>
> This frame of reference should allow you to better understand and
> respond to the proposed program change. I encourage you to submit
> substantive comments directly to <michael.d.ward at aphis.usda.gov>.
>  Please be sure to share this information with others.
>
> As an aside, I am surprised and disappointed at the nature of some of
> the discussion that took place before we had the information to fully
> understand it.  The goal of this listserve is not to foment hysteria
> or deride and find fault in various sectors of the plant world, but to
> share and discussion information in a productive manner. Offensive,
> derisive, and combative discussions aimed at any of our membership are
> not acceptable.  I have a handful of people (a few of which are
> listserve members) to thank for asking good questions and helping me
> pull this information together amidst my already heavy workload this
> week.  /Thank you/.
>
> In the future, let's be more proactive and less reactive in our
> analysis of issues.

I am all for sifting out the truth from the facts. The truth is that we
going from the current system of a "black list" of prohibited plants to
a "white list" of permitted plants. I wouldn't have a problem if the
rationale for change is merely procedural, -- in search of greater
regulatory efficiency, for example. But this program profoundly changes
what is in the "permitted" basket of plants and what is in the
"prohibited" basket of plants. There is no getting away from the fact
that hundreds of thousands of species are now going to be shifted from
one basket to the other. It seems appropriate to ask why the regulators
want this profound change.

Conrad Richter

>
> Sincerely,
> Patricia
>
> Patricia S. De Angelis, Ph.D.
> Botanist - Division of Scientific Authority
> Chair - Plant Conservation Alliance - Medicinal Plant Working Group
> US Fish & Wildlife Service
> 4401 N. Fairfax Dr., Suite 110
> Arlington, VA  22203
> 703-358-1708 x1753
> FAX: 703-358-2276
>
> Promoting sustainable use and conservation of our native medicinal plants.
> <www.nps.gov/plants/medicinal>
>
> *_Greenhouse Certification Program _*
>
> *In sum: *
>
> The Canadian/US greenhouse certification program is being changed.
>  The primary change will be an approved list of plants as opposed to
> the current disapproved list.   This went out for industry comment on
> 9/17.
> *The details: *
>
> The United States Department of Agriculture Animal (USDA) and Plant
> Health Inspection Service is committed to stakeholder consultations as
> a valued aid to effective decision-making. The USDA is notifying
> United States stakeholders of planned changes to the Canada/United
> States Greenhouse Certification Program (GCP) and to solicit
> stakeholder input on the contents of an authorized plant list that
> will replace the
> list of plants currently excluded from the program.
>
> Please distribute this material among your associations and their
> members to reach the broadest cross section of traditional and
> non-traditional stakeholders. We encourage you to take the time to
> review the consultation material and advise your associations and
> their members to do the same. We ask that you, your associations and
> their members please send comments to michael.d.ward at aphis.usda.gov
>  and include the phrase "GCP comments" in the subject line of the
> email, prior to October 31, 2010.
>
> Background
>
> The Greenhouse Certification Program (GCP) is a bilateral program
> designed to facilitate the movement of low phytosanitary
> risk,greenhouse-grown plants between Canada and the United States.
> Facilities participating in the GCP implement measures to ensure that
> eligible plants are grown, stored, packed and shipped free of
> regulated pests of concern for the receiving country. In return,
> facilities in
> compliance with the GCP have increased flexibility when shipping. In
> the context of the GCP, greenhouse-grown plants are those plants
> commonly known and recognized as indoor foliage and flowering plants
> and those categorized as bedding plants intended for planting either
> indoors or outdoors.
>
> It is recognized that due to varying climatic conditions between
> Canada and the United States not all plants produced under the GCP are
> produced in traditional greenhouses. Many plants may not be able to
> survive outdoors in cooler regions of Canada and the United States but
> may establish outdoors in warmer areas of the United States.
>
> Current Status
>
> Currently, the GCP contains lists of plants that cannot be certified
> under the program. The use of 'excluded plant lists' has proven to be
> problematic in that it causes ambiguity and may lead to
> inconsistencies in its interpretation and/or application. A copy of
> the 'excluded plant list' that applies to U.S. greenhouses may be
> found in the document at this link:
> http://www.aphis.usda.gov/plant_health/acns/downloads/canadian_greenhouse.pdf
>
> Planned Change
>
> The GCP is being amended and one of the significant changes to the
> program is to replace the list of excluded plants with a list of
> plants which are approved under the program.  The use an 'authorized
> plant list' will increase program clarity and improve program
> compliance. The authorized plant list is being developed to include as
> many low phytosanitary risk greenhouse plants as possible. The list
> will include most greenhouse plants that currently move in trade
> between Canada and the United States under the GCP. The authorized
> plant list will clearly state which plants will be eligible under the
> GCP in both Canada and the United States. The same list will be used
> in both countries.
>
> The authorized plant list will include two types of plants - those
> that pose very little phytosanitary risk and those with risk
> mitigation measures that reduce their phytosanitary risk to a very low
> level. When risk mitigation measures are required, the specific
> measure(s)they will be identified in association with the specific
> plant on the authorized plant list. Examples of possible risk
> mitigation measures include requiring propagation from seed or tissue
> culture or ensuring that a particular plant is grown exclusively in
> greenhouses.
>
> In recognition of changing trade patterns and changing risk
> levels,protocols have been developed to allow for the amendment of the
> authorized plant list. Participating facilities may request additions
> to the authorized plant list. The request will undergo a joint Canada/
> United States evaluation and, if approved, the plant will be added to
> the list. If phytosanitary conditions change so that it becomes
> necessary to remove a plant from the authorized plant list, this
> decision will be conveyed to participating facilities in a timely manner.
>
> Attached you will find:
> Proposed Approved Plant List by Family
> Proposed Approved Plant List by Genus
> Protocol to Request Additions to the GCP Authorized Plant List
> Application for the Addition to the GCP Authorized Plant List
> Protocol to Remove Plants from the GCP Authorized Plant List
>
> Michael D. Ward
> Senior Accreditation Projects Manager
> USDA-APHIS-PPQ
> michael.d.ward at aphis.usda.gov
>
>
>
>
>
>
>
>
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> Any advice given on this list regarding diagnosis or treatments etc. reflects ONLY the opinion of the individual who posts the message. The information contained in posts is not intended nor implied to be a substitute for professional medical advice relative to your specific medical condition or question. All medical and other healthcare information that is discussed on this list should be carefully reviewed by the individual reader and their qualified healthcare professional. Posts do not reflect any official opinions or positions of the Plant Conservation Alliance.                                                    

-- 
\_\  RICHTERS HERBS
/ /  Goodwood, ON, L0C 1A0, Canada
\_\  Tel +1.905.640.6677  Fax +1.905.640.6641
/_/  http://www.richters.com

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