OFA Bulletin November/December 2012 : Page 3
November/December 2012 • Number 936 perhaps it’s time to evaluate other approaches. Inspections are just a snapshot in time and even a well trained inspector can miss a camouflaged or inactive insect or an inconspicuous pathogen in an early phase of development. With the large volume of plant material being moved (only a small percentage of which is actually inspected) and the relatively static number of inspectors and identifiers available to do the work, it is hard to argue that inspections are any more than a survey of the plant-associated organisms rather than a real method of controlling their spread. In recent years we’ve heard more discussion and seen greater interest in a process that looks to manage the risk associated with plant pests and diseases during the entire plant production process. This approach is often referred to as an integrated approach or systems approach. The idea is that there are particular points (often referred to as critical control points or contamination hazards) in the plant production process when a pest or disease can gain access to a production facility and establish. When using an integrated approach, a grower would identify the contamination hazard points and develop a method of addressing the hazard. The more contamination hazards addressed, the greater the risk is managed – providing a cumulative effect. We see a similar approach in the production, packing, and processing of food. There is no way that inspectors can evaluate all the food produced, but if the producers identify when food-borne pathogens can get into the process and address the contamination hazard points in the production and handling process, they are able to significantly reduce the risk. It’s this kind of approach that makes our food production systems the safest in the world. There is no production process, plant or otherwise, that will take the risk to zero or eliminate pests, but the idea is to reduce the risk to an acceptable level. An integrated approach is simply a more effective method for preventing the acquisition, establishment, and spread of problematic pests. There is no shortage of certification programs out there in our industry, or other industries for that matter. In the context of plant health, some of these certification programs are federally regulated – programs such as the United States. Greenhouse Certification Program (USGCP), United States Nursery Certification Program (USNCP), and the Pelargonium program, which is an APHIS-enforced program for foreign producers who want to export geranium cuttings to the U.S. APHIS and the states often have programs, typically referred to as federal domestic or state quarantine certification programs, to deal with national and regional issues like Emerald Ash Borer, Sudden Oak Death, Imported Fire Ants, and Hemlock Woolly Adelgid, to name a few. Regulated nurseries or greenhouses often enter into compliance agreements under which the producer agrees to perform certain procedures in the plant production process to mitigate risk associated with a specific pest or disease. A typical certification program includes several elements. There are things like staff training, record keeping, and the development of a pest management plan. These are areas that are carried out by the plant production operation. Then there are the auditing procedures and enforcement mechanisms that are the purview of state and federal regulators. All together they provide an enforceable understanding that agreed upon OF A Bulletin steps will be taken by the grower and, if followed, relieve the grower from certain procedures that they otherwise need to do to ship, such as a reliance on end-point inspections to receive phytosanitary certificates that are a condition for shipping. Audits rely more heavily on an evaluation of records and interviews to evaluate adherence to management plans rather than inspectors combing through an operation looking for pests on plants. Certification Programs The program being developed by the industry working group in collaboration with the National Plant Board and USDA-APHIS will include the elements listed above. Fortunately, the elements that the industry group is focusing on are largely things that the better growing operations already do – pest management plans, training, and record keeping. Most operations that ship interstate and internationally have procedures in place to prevent and respond to pest outbreaks, timeframes for scouting, and preventing standing water from gathering in propagation and production areas. Growers train employees how to perform their jobs, especially the elements that are specific to plant production. Production and distribution facilities generally record what they have received, where plants are kept, if and when treatments are applied, and where they are shipped. From a grower’s perspective, these are the primary components of a certification program. It will require more formalization and the production of a manual. However, the industry group intends to create a streamlined process for producing a manual. By working through this process and selecting the elements that pertain to your operation the manual will, essentially, self assemble. For those who are not aware of or not familiar with the pilot United States Certification Program (USNCP), it was a program developed with essentially the same elements we have discussed. However, it pertains only to certain nursery stock intended for export to Canada. In addition, the program required the development of a manual, from scratch, and enrollment was generally very complex, time-consuming, and expensive. The USNCP began as a pilot program in approximately 2006 but never expanded beyond the initial pilot nurseries largely due to the perceived additional costs and hurdles to participation. Based on the lessons learned from the USNCP, through a Farm Bill funded study carried out by the Horticultural Research Institute (the research and development branch of ANLA), the industry working group is addressing the hurdles. The idea is to lower the hurdles and increase the practical incentives for adopting the new program. The intention of the working group is to produce a program that addresses plant production no matter the growing environment, including greenhouse, screen-house, shade-house, outdoor container, and field production. Production facilities are increasingly diverse with many growers using a variety of growing environments, so a certification program should provide the flexibility to meet their needs. In addition, the program would not be based on what plants are grown. Contamination hazards are largely shared between operations despite what is being grown and how. If the contamination hazards are addressed then the pest and disease concerns are addressed. The more streamlined the operation the more Continued on page 4 3 What Will the New Plant Production Certification Program Look Like?