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On 10-10-27 09:30 AM, <a class="moz-txt-link-abbreviated" href="mailto:Patricia_DeAngelis@fws.gov">Patricia_DeAngelis@fws.gov</a> wrote:
<blockquote
cite="mid:OF1EA36EFD.DB469716-ON852577C9.00464F09-852577C9.004A35CD@fws.gov"
type="cite"><br>
<font face="sans-serif" size="3">Well, the "White List" discussions
this week have been interesting to say the least. </font>
<br>
<br>
<font face="sans-serif" size="3">The information below on the
Canadian/US
greenhouse certification program should better inform our understanding
of this topic. Here are some key points:</font>
<ul>
<li><font face="sans-serif" size="3">It's primarily about pest
management
- not an invasive issue.</font></li>
</ul>
</blockquote>
<br>
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. <br>
<br>
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. <br>
<br>
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. <br>
<br>
<blockquote
cite="mid:OF1EA36EFD.DB469716-ON852577C9.00464F09-852577C9.004A35CD@fws.gov"
type="cite">
<ul>
<li><br>
</li>
<li><font face="sans-serif" size="3">This is specifically regarding
exchange
of nursery material between the US and Canada.</font></li>
</ul>
</blockquote>
<br>
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.<br>
<br>
<blockquote
cite="mid:OF1EA36EFD.DB469716-ON852577C9.00464F09-852577C9.004A35CD@fws.gov"
type="cite">
<ul>
<li><br>
</li>
<li><font face="sans-serif" size="3">It's an EXISTING program that
is being
changed.</font>
</li>
<li><font face="sans-serif" size="3">The program has existed for
more than
a decade.</font>
</li>
<li><font face="sans-serif" size="3">The explanation and
announcement from
USDA are included below. </font>
</li>
<li><font face="sans-serif" size="3">NOTE that the lists are not
final (i.e.,
the plants currently in those lists may change).</font></li>
</ul>
</blockquote>
<br>
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. <br>
<br>
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.<br>
<br>
<blockquote
cite="mid:OF1EA36EFD.DB469716-ON852577C9.00464F09-852577C9.004A35CD@fws.gov"
type="cite"><br>
<font face="sans-serif" size="3">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 <</font><tt><font
size="3"><a class="moz-txt-link-abbreviated" href="mailto:michael.d.ward@aphis.usda.gov">michael.d.ward@aphis.usda.gov</a>>.
</font></tt><font face="sans-serif" size="3">Please be sure to share
this information with others. </font>
<br>
<br>
<font face="sans-serif" size="3">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. <i>Thank
you</i>. </font>
<br>
<br>
<font face="sans-serif" size="3">In the future, let's be more
proactive
and less reactive in our analysis of issues. </font>
<br>
</blockquote>
<br>
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.<br>
<br>
Conrad Richter<br>
<br>
<br>
<blockquote
cite="mid:OF1EA36EFD.DB469716-ON852577C9.00464F09-852577C9.004A35CD@fws.gov"
type="cite"><br>
<font face="sans-serif" size="3">Sincerely,</font>
<br>
<font face="sans-serif" size="3">Patricia</font>
<br>
<br>
<font face="sans-serif" size="2">Patricia S. De Angelis, Ph.D.<br>
Botanist - Division of Scientific Authority<br>
Chair - Plant Conservation Alliance - Medicinal Plant Working Group<br>
US Fish & Wildlife Service<br>
4401 N. Fairfax Dr., Suite 110<br>
Arlington, VA 22203<br>
703-358-1708 x1753<br>
FAX: 703-358-2276<br>
<br>
Promoting sustainable use and conservation of our native medicinal
plants.<br>
<<a class="moz-txt-link-abbreviated" href="http://www.nps.gov/plants/medicinal">www.nps.gov/plants/medicinal</a>></font>
<br>
<br>
<font face="sans-serif" size="4"><b><u>Greenhouse Certification
Program
</u></b></font><br>
<font face="sans-serif" size="2"><br>
</font><font face="sans-serif" size="4"><b>In sum: </b></font>
<br>
<font face="sans-serif" size="2"><br>
</font><font face="sans-serif" size="3">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.</font><font size="3"> </font>
<br>
<font face="sans-serif" size="4"><b>The details: </b></font><font
color="#800080" face="sans-serif" size="1"><br>
</font>
<br>
<tt><font size="3">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<br>
list of plants currently excluded from the program. <br>
<br>
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 <a class="moz-txt-link-abbreviated" href="mailto:michael.d.ward@aphis.usda.gov">michael.d.ward@aphis.usda.gov</a> and include the phrase "GCP
comments" in the subject line of the email, prior to October 31, 2010.
<br>
<br>
Background<br>
<br>
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<br>
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.<br>
<br>
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.<br>
<br>
Current Status <br>
<br>
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:
<a class="moz-txt-link-freetext" href="http://www.aphis.usda.gov/plant_health/acns/downloads/canadian_greenhouse.pdf">http://www.aphis.usda.gov/plant_health/acns/downloads/canadian_greenhouse.pdf</a><br>
<br>
Planned Change<br>
<br>
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. <br>
<br>
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.<br>
<br>
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.<br>
<br>
Attached you will find: <br>
Proposed Approved Plant List by Family<br>
Proposed Approved Plant List by Genus<br>
Protocol to Request Additions to the GCP Authorized Plant List<br>
Application for the Addition to the GCP Authorized Plant List<br>
Protocol to Remove Plants from the GCP Authorized Plant List</font></tt><font
size="3">
</font><font face="sans-serif" size="3"><br>
<br>
Michael D. Ward<br>
Senior Accreditation Projects Manager<br>
USDA-APHIS-PPQ<br>
<a class="moz-txt-link-abbreviated" href="mailto:michael.d.ward@aphis.usda.gov">michael.d.ward@aphis.usda.gov</a><br>
</font><font face="sans-serif" size="2"><br>
</font><font size="3"><br>
<br>
</font><font face="sans-serif" size="2"><br>
<br>
<br>
</font>
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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. </pre>
</blockquote>
<br>
<br>
<pre class="moz-signature" cols="72">--
\_\ RICHTERS HERBS
/ / Goodwood, ON, L0C 1A0, Canada
\_\ Tel +1.905.640.6677 Fax +1.905.640.6641
/_/ <a class="moz-txt-link-freetext" href="http://www.richters.com">http://www.richters.com</a></pre>
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