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Why Won’t USDA APHIS Act to Close the Wood Packaging Pathway?

CBP inspecting wood packaging; CBP photo

There is widespread agreement that the most important pathways for long-distance transport of non-native forest insects are wood packaging (crates, pallets, dunnage, etc.) and imports of live plants (which APHIS calls “plants for planting”). Sources (at end of blog): Aukema et al. 2010; Liebhold et al. 2012; Meurisse et al. 2018 and many others. See also my earlier blogs by scrolling down to the “categories” section and clicking on “wood packaging”.

According to Meurisse et al., by the middle of this decade, world maritime freight trade had reached about 10 billion metric tonnes, and air transport of cargo had reached 50 million tonnes – much of it packaged in wood.

As the world’s biggest importer, the United States receives about 27 million shipping containers each year (CBP to FT Campbell). A study carried out in 2005 – 2007 (Meissner et al. 2009) indicated that 75% of maritime shipments entering the U.S. contained wood packaging; 33% of air shipments contained wood packaging. These are significant increases over earlier estimates that put the number of containers entering the country at 25 million. An even older analysis estimated that 52% of incoming containers had wood packaging.

APHIS has recognized the pest risk associated with wood packaging for 20 years – since the Asian longhorned beetle was detected in a second city – Chicago – in 1998. APHIS and its Canadian counterpart (Canadian Food Inspection Agency) acted rapidly to adopt, first, domestic regulations governing wood packaging from China (in December 1998), then a regional standard for wood packaging, and finally to help bring about adoption of International Standard for Phytosanitary Measures (ISPM) No. 15 in 2002. A detailed description of these actions can be found in my report Fading Forests II available here.

However, as I have demonstrated often, ISPM#15 has reduced the threat – but insufficiently. Dr. Robert Haack and his coauthors (2014) found that of each thousand shipments containing wood packaging that enters the country, one harbors a quarantine pest. Applying this estimate to the current volume of incoming containers and the higher proportion containing wood packaging results in an estimate that up to 20,000 shipping containers containing infested wood packaging enter the country each year – or approximately 55 per day.

The actual approach rate might be less. There are two variables that I lack sufficient data to quantify.

First, a significant proportion of the incoming containers come from Mexico or Canada – our second and third largest trading partners. The risk of damaging pests arriving from our neighbors is less than the risk accompanying shipments from overseas – although it is not “0”. Several woodborers native to Mexico have been introduced to U.S. ecosystems and are killing trees in these new environments, e.g., goldspotted oak borer, walnut twig beetle, and soapberry borer (all described in write-ups here). It is true that these beetles were probably introduced to vulnerable parts of the U.S. in firewood rather than wood packaging. There are also reasons to be concerned about pest introductions from Canada. Threats arise from both non-native pests established in the country e.g., brown spruce longhorned beetle and European beech leaf weevil, and pests in shipments from off-shore origins that are re-packaged in Canada (Yemshanov et al. 2012 and my earlier blog from April 2017).

The second variable on which I lack data is the proportion of the 27 million containers that are transported by air, and are thus half as likely to contain wood packaging.

To account for these unknowns, I have nearly halved the number of shipping containers likely to transport pests from off-shore – so 14 million instead of 27 million. Again applying Haack’s estimate, the result is 10,500 shipping containers containing infested wood packaging entering the country every year – or approximately 29 every day.

Update with more precise data (August 24) :

Re: the two variables, I have found partial answers from a U.S. Department of Transportation website which provides data on imports of loaded chipping containers (in TEUs) for 68 ports. (For the website, go here – click on “trade statistics”, then “US Waterborne trade” (1st bullet)]

As of 2017, 22,360,941 loaded shipping containers entered the U.S. via maritime transport. Applying the estimate of 75% of these containers holding wood packaging, we find that slightly less than 17 million containers entered the country with wood packaging. Applying Robert Haack’s estimate that one in a thousand is infested with a quarantine insect, we anticipate that 17,000 of these containers were transporting a pest that threatens our country. That is 46 containers every day.

Ports which received the largest numbers of containers, according to the DoT database:

Long Beach/Los Angeles — 8.4 million containers
New York — 3.4 million containers
Savannah — 1.8
Norfolk — 1.2
Houston — 1 million containers

We need answers!

The point is, we don’t know how many pests are reaching the United States daily. Or if the current approach rate is significantly higher or lower than in the past. Despite my urging, APHIS has not undertaken a study to update Haack’s estimate – which is based on 2009 data. In the intervening nine years, several changes were made to ISPM#15 to make it more effective. The most important was restricting the size of bark remnants that may remain on the wood.

Also, we might hope that experience with implementing the standard has led to better compliance. Unfortunately, available data do not encourage belief that compliance has improved.

Customs and Border Protection (CBP) reports annually to the Continental Dialogue on Non-Native Forest Insects and Diseases on the number of import shipments with wood packaging that have been detected as not complying with ISPM#15. Over a period of eight years – Fiscal years 2010 through 2017 – CBP detected nearly 24,000 non-compliant shipments. While most (17,413) of the non-compliances were crates or pallets that lacked the required mark showing treatment in accordance with ISPM#15, in 6,388 cases the wood packaging actually harbored a pest in a regulated taxonomic group. This works out to about 800 infested shipments detected each year.

By comparing Dr. Haack’s estimate with the CBP data, I estimate that Customs is detecting and halting the importation of four to eight percent of the shipments that actually contain pest-infested wood. Since CBP inspects only about two percent of incoming shipments, this detection rate demonstrates the value of CBP’s program to target likely violators – and deserves praise. But it is obviously too low a “catch” rate to provide an adequate level of protection for our forests.

Indeed, using the older, lower estimates of both numbers of shipping containers and the proportion that contain wood packaging, Leung et al. 2014 concluded that continuing to implement ISPM#15 at the efficacy level described by Haack et al. would result in a tripling of the number of non-native wood-boring insects introduced into the U.S. by 2050.

CBP inspector views Cerambycid larvae found in wood packaging that bears ISPM#15 stamp

Closer examination of the data raises more troubling questions. On average, 97% of the 6,388 shipments containing infested wood pieces detected by CBP were found in wood that bore the ISPM#15 stamp indicating that it had been treated. The proportion of infested shipments bearing the stamp has not changed over the past eight years. This is alarming and we need to understand the reason. Does this finding indicate widespread fraud? I understand that most inspectors believe this is the cause. Other possible explanations are accidental misapplication of the treatments or the treatments simply not working as expected. APHIS researchers have found that larvae from wood subjected to methyl bromide fumigation were more likely to survive to adulthood than those intercepted in wood that had been heat treated (Nadel et al. 2016). Does this indicate that methyl bromide fumigation is less effective? What effort is APHIS making to determine which of these explanations is correct?

Certain countries have a long-standing record of non-compliance with ISPM#15. APHIS’ database of pest interceptions on wood packaging over the period Fiscal Year 2011 to FY 2016 contains 2,547 records of insect detections from dozens of countries. The countries of origin with the highest numbers of shipments detected to have pests present were Mexico, China, Italy, and Costa Rica. These numbers reflect in part the huge volumes of goods imported from both Mexico and China. But China and Italy stand out for their poor performance. (The U.S. does not regulate – or inspect! – wood packaging from Canada; see blog here.)

Meissner et al. say that as of a decade ago, Chinese shipments were only half as likely to be enclosed in wood packaging as are shipments from other exporters. Yet shipments from China still rank second in the number of non-compliant shipments; they make up 11% of all interceptions. In part, the data reflect inspection priorities: due to the great damage caused by Asian insects to North American trees and the past record of poor compliance, CBP targets shipments from China for more intense scrutiny. Still, the high number of detections reflects continuing non-compliance by Chinese exporters. And remember – the U.S. and Canada began requiring treatment of wood packaging from China at the end of 1998 – nearly 20 years ago! [Feb 17 blog]

shipment of decorative stone with wood packaging

We don’t import a lot of goods from Italy – but Italian shipments of decorative stone and tile have always been plagued by high levels of pests in accompanying wood packaging. Indeed, more pests have been found in wood supporting tiles and stone than any other type of commodity in 24 of the 25 years preceding 2014 (Haack et al. 2014).

What is APHIS doing to pressure these countries to improve their compliance? As I blogged in October, link the Bureau of Customs and Border Protection began imposing a financial penalty on first-time violators in November 2017. Since interception data do not provide an adequate measure of the pest approach rate (see Haack et al 2014 for an explanation), APHIS should commission an analysis of Agriculture Quarantine Inspection Monitoring data to determine the pest approach rate before and after the CBP action in order to determine whether the more aggressive enforcement has led to reductions in non-compliant shipments at the border.

What Can Be Done to Slow or Eliminate this Pathway?

I reiterate my call for holding foreign suppliers responsible for complying with ISPM#15. One approach is to penalize violators. Now that the Bureau of Customs and Border Protection has toughened its enforcement, the U.S. Department of Agriculture should drop its decade-old policy of allowing importers to accumulate five (detected) violations in a calendar year before applying the civil penalties authorized by the Plant Protection Act.

Another step APHIS should take would be to prohibit use of packaging made from solid wood (boards, 4 x 4s, etc.) by foreign suppliers which have a record of repeated violations over the 12 years that ISPM#15 has been in effect – or the 19 + years for exporters from Hong Kong & mainland China. Officials should allow continued imports from those same suppliers as long as they are contained in other types of packaging materials, including plastic, metals, fiberboards …

SOURCES

Aukema, J.E., D.G. McCullough, B. Von Holle, A.M. Liebhold, K. Britton, & S.J. Frankel. 2010. Historical Accumulation of Nonindigenous Forest Pests in the Continental United States. Bioscience. December 2010 / Vol. 60 No. 11

Haack, R. A., K. O. Britton, E. G. Brockerhoff, J. F. Cavey, L. J. Garrett, M. Kimberley, F. Lowenstein, A. Nuding, L. J. Olson, J. Turner, and K. N. Vasilaky. 2014. Effectiveness of the international phytosanitary standard ISPM no. 15 on reducing wood borer infestation rates in wood packaging material entering the United States. Plos One 9:e96611.

Hulme, P.E. 2009. Trade, transport and trouble: Managing invasive species pathways in an era of globalization. Journal of Applied Ecology 46:10-18

Jung, T. et al. 2015 “Widespread Phytophthora infestations in European nurseries put forest, semi-natural and horticultural ecosystems at high risk of Phytophthora disease” Forest Pathology. November 2015; available from Resource Gate

Klapwijk, M.J., A.J. M. Hopkins, L. Eriksson, M. Pettersson, M. Schroeder, A. Lindelo¨w, J. Ro¨nnberg, E.C.H. Keskitalo, M. Kenis. 2016. Reducing the risk of invasive forest pests and pathogens: Combining legislation, targeted management and public awareness. Ambio 2016, 45(Suppl. 2):S223–S234 DOI 10.1007/s13280-015-0748-3

Koch, F.H., D. Yemshanov, M. Colunga-Garcia, R.D. Magarey, W.D. Smith. 2011. Potential establishment of alien-invasive forest insect species in the United States: where and how many? Biol Invasions (2011) 13:969–985

Leung, B., M.R. Springborn, J.A. Turner, E.G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. The Ecological Society of America. Frontiers of Ecology.org

Levinson, M. The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger Princeton University Press 2008

Liebhold, A.M., E.G. Brockerhoff, L.J. Garrett, J.L. Parke, and K.O. Britton. 2012. Live Plant Imports: the Major Pathway for Forest Insect and Pathogen Invasions of the US. www.frontiersinecology.org

Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory

Meurisse, N. D. Rassaati, B.P. Hurley, E.G. Brockerhoff, R.A. Haack. 2018. Common Pathways by which NIS forest insects move internationally and domestically. Journal of Pest Science. https://doi.org/10.1007/s10340-018-0990-0

Nadel, H., S. Myers, J. Molongoski, Y. Wu, S. Linafelter, A. Ray, S. Krishnankutty, A. 2016. Identificantion of Port Interceptions in Wood Packaging Material Cumulative Progress Report, April 2012 – August 2016

Sikes, B.A., J.L. Bufford, P.E. Hulme, J.A. Cooper, P.R. Johnston, R.P. Duncan. 2018. Import volumes and biosecurity interventions shape the arrival rate of fungal pathogens. http://journals.plos.org/plosbiology/article?id=10.1371/journal.pbio.2006025

Yemshanov, D., F.H. Koch, M. Ducey, K. Koehler. 2012. Trade-associated pathways of alien forest insect entries in Canada. Biol Invasions (2012) 14:797–812

Posted by Faith Campbell

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New science reveals that threats remain from Bd, the infamous frog and toad-killing pathogen

California red-legged frog

courtesy of the U.S. Fish and Wildlife Service

In my last blog, I addressed how the United States Fish and Wildlife Service (FWS) has neglected to undertake the plan that it announced in early 2016 to finalize and improve its weak “interim” regulation aimed at preventing the salamander disease “Bsal” (Batrachochytrium salamandrivorans) from infecting salamanders in the still-unexposed United States. While Canada, the European Union and the United Kingdom have all taken very strong measures this year to block salamander imports that are not “Bsal free,” our country is stuck on a much weaker approach that I described as “Swiss cheese”.

Further compounding my concern about FWS’s inaction is new science about Bsal’s older devastating cousin, “Bd” (Batrachochytrium dendrobatidis), the separate fungus epidemic that has extirpated huge numbers of frogs and toads worldwide, driving several species extinct. Within the last year, the FWS has secretly withdrawn its consideration of a formal petition to regulate Bd filed with the Secretary of the Interior (in charge of the FWS) by Defenders of Wildlife in 2009. The Petition set out a plan to block the ongoing risk to native frogs and toads that the Bd pathogen posed then – and still poses. See description and documents under “Chytrid Fungus – September 16, 2010” here. The petition requested the FWS to create a “Clean Trade” program for shipments of imports, keeping them out of the country unless accompanied by certification that they are “Bd free” – whether by quarantine, testing or other reliable certification approach.

The new key paper, published last month in Science, is a sweeping study that finally answers the two questions that bedevilled amphibian experts since Bd’s first identification back in the mid-1990s: where did it come from and how was it spread around the world? O’Hanlon et al.’s study, “Recent Asian origin of chytrid fungi causing global amphibian declines,” here, [one must have an account to read the article] was extremely complex (there were 59 co-authors!). They discovered that Bd originated in salamanders in Asia, likely on the Korean Peninsula, and was spread via trade in live frogs and toads (pets, specialty foods and perhaps other uses). Genetic analysis of the numerous Bd strains showed there is still potential for more strains to mix, for new hybrids to emerge and for still more virulent outbreaks of the disease to occur. The article states: “… further sampling across this region is urgently needed because the substantial global trade in Asian amphibians presents a risk of seeding future outbreak lineages.” One lead co-author, Professor Matthew Fisher of Imperial College London, told the BBC:

“Until the ongoing trade in infected amphibians is halted, we will continue to put our irreplaceable global amphibian biodiversity recklessly at risk.”

Also notable is University of Maryland Professor Karen Lips’ concise commentary on it here [one must have an account to read the article]. Dr. Lips links the lessons of Bd and Bsal, pointing out the obvious: regulators need to learn the tragic lessons of Bd and take steps to keep out Bsal now – and not wait until after the fact of an outbreak.

Perhaps it was understandable before the O’Hanlon et al. paper that the FWS never responded to the Defenders of Wildlife Bd petition seeking trade restrictions because Bd was already so widespread within the United States then (unlike Bsal) and Bd’s origins and genetics were so confusing. It was not entirely clear that regulating further amphibian imports would have actually improved our level of Bd protection. But, O’Hanlon et al. changes that –– we now know enough to justify much stricter regulation to prevent more imports of Bd-infected frogs and toads and to block the potential for more virulent outbreaks here.

In short, FWS action on that 2009 Defenders of Wildlife petition is called for now. (Disclaimer: I wrote and filed that petition when I was Director of International Conservation at Defenders.) However, in a remarkably unfortunate use of its administrative powers, the FWS internally determined in March of 2017 to just altogether stop considering it. Rather than communicating back to Defenders that it is granting or denying its petition the FWS now states that it has “Withdrawn” consideration of any regulatory action, here.

This move by FWS plainly is part of the Trump Administration’s broad de-regulatory agenda. But, the FWS made no decision other than to put it on hold and Defenders of Wildlife did not withdraw it, so as a legal matter the nine-year old Petition is still pending. The FWS can and should take it up again and grant it. But, Defenders likely will have to push hard in order for that to happen.

The scientific community working on both Bd and Bsal has produced authoritative, painstaking studies on which the FWS and others can rely in regulating. And the community has made clear calls to stop the ongoing trade in many scores of species of amphibians around the world with no quarantines or health certificates, which is “business as usual” now. If the amphibian trade continues in the future it needs to be Clean Trade or we will suffer further consequences. It is up to us in the conservation community to convert the scientists’ calls into regulatory reality.

Posted by Peter Jenkins

Study finds “targetted” phytosanitary measures are effective in reducing introductions of plant pests

Figure 2 from the article:

The number of new pathogens discovered each year on 131 focal host plant species in New Zealand (closed circles) and the mean annual rate of pathogen arrival estimated from the model (solid blue line), with shading showing the 95% credible interval.

Benjamin A. Sikes and several coauthors (article available here; open access!) find that targetted biosecurity programs can reduce the establishment of nonnative pathogens even while global trade and travel continue to increase.

The study relies on data from New Zealand because that country has more than 150 years of data on phytosanitary policies and pathogen introductions. Do other countries have data that would support a comparative study in order to test the authors’ conclusions more generally?

The study is unusual in analyzing introductions of a variety of forms of pathogens (fungi, oomycetes, and plasmodiophorids) rather than invertebrates. Pathogens pose significant plant health risks but are notoriously difficult to detect. The study used data on plant-pathogen associations recorded in New Zealand between 1847 and 2012. It focused on hosts in four primary production sectors: crops (46 species, including wheat, tomatoes, and onions); fruit trees (30 species, including grapes, apples, and kiwifruit); commercial forestry (42 species, including pines and eucalypts); and pastures (13 species of forage grasses and legumes). In total, 466 pathogen species for which the first New Zealand record was on one of these 131 host plants were included in the study. The pathogens were assumed to have arrived on imports seeds or fresh fruits of plants in the same family as the 131 hosts in the various production sectors.

After calculating each pathogen’s probable date of introduction, the authors compared those dates to contemporaneous levels of imports and incoming international travellers. Sikes et al. applied statistical techniques to adjust their data to the fact that detection of pathogens is particularly sensitive to variation in survey effort.

Findings:

The annual arrival rate of new fungal pathogens increased exponentially from 1880 to ~1980 in parallel with increasing import trade volumes. Subsequently rates stabilized despite continued rapid growth in not only imports but also in arrivals of international passengers.
However, there were significant differences among the four primary production sectors.

Arrival rates for pathogens associated with crops declined beginning in the 1970s but slightly earlier for those associated with pasture species. These declines occurred despite increasing import volumes.
Arrival rates of pathogens that attack forestry tree species continued to increase after 1960.
Arrival rates for pathogens that attack fruit tree species remained steady while import volumes rose steadily

Sikes et al. attribute these contrasting trends between production sectors to differences in New Zealand’s biosecurity efforts. They record when phytosanitary restrictions targetting the four sectors were adopted and link those changes to reductions in numbers of pathogens detected a decade or so later. They conclude that targetted biosecurity can slow pathogen arrival and establishment despite increasing trade and international movement of people.

Regarding the contrasting situation of the forestry and fruit tree sectors, Sikes et al. note that while phytosanitary inspections of timber imports was initiated in 1949, it focussed primarily on invertebrate pests. In addition, surveys for pathogens on fruit tree and forestry species were less robust than in the cases of crop and pasture species, and the peak survey effort occurred several decades later – in 1980 for fruit trees, 2000 for forestry species.

Furthermore, pathogens of forestry and fruit tree species can be introduced on types of imports other than seeds and fresh fruits, including soil and live plant material (e.g., rootstock) and untreated wood products.

Sikes et al. say there is no evidence of slowed pathogen arrival rates resulting from imposition of post-entry quarantine to live plant material beginning in the 1990s. I find this very troubling. Post-entry quarantine is a high-cost strategy. Still, several plant pathologists have advocated adoption of this strategy because they believed it would be sufficiently more effective in preventing introductions of – especially! – pathogens as to be worthwhile. Do others have data with which to add to our understanding of this disturbing phenomenon?

The authors suggest that introductions of tree-attacking pathogens on rising imports of wood packaging might have swamped decreases in introductions via other vectors. They consider that implementation of International Standard for Phytosanitary Measures (ISPM) No. 15 in 2002 means it is too early to see its impact in detection data. As I have blogged several times, implementation of ISPM#15 by the United States, at least, has reduced presence of detected pests – primarily insects – by 52%. Little is known about the presence of pathogens on wood packaging – according to some experts, inspectors rarely even look for pathogens. So I think the authors’ suggestion might not fully explain the continuing introduction of pathogens that attack tree species used in plantation forestry in New Zealand.

Prof. Michael Wingfield of South Africa has written numerous articles on the spread of pathogens that attack Eucalyptus on seeds imported to establish plantations in various countries; one such article is available here. This seems a more likely explanation to me.

The study’s analysis demonstrated that the overall rate of non-native fungal pathogen establishment in New Zealand was more strongly linked to changes in import trade volume than to changes in numbers of international passengers arriving on the islands. Although Sikes et al. don’t explicitly raise the question, they note that New Zealand has put considerable effort into screening incoming people – which appears from these data to have a smaller payoff than imposing phytosanitary controls on imports.

Recent declines in surveys mean the authors must estimate current pathogen arrival rates. The data gaps exacerbate the inevitable uncertainty associated with the time lag between when an introduction occurs and when it is detected. They estimate that an average of 5.9 new species of fungal pathogens per year have established on the focal host plant species since 2000. They estimate further that 55 species of pathogens are present in New Zealand but have not yet been detected there.

I am quite troubled by the reported decline in New Zealand’s postborder pathogen survey efforts since about 2000. This appears very unwise given that the risk of new introductions of pathogens that attack fruit and forestry trees continues – or even rises! Indeed, scientists associated with the forestry industry note the risk to Douglas-fir and Monterrey (Radiata) pine plantations from the pitch canker fungus Fusarium circinatum – which could be introduced on imported seeds, nursery stock, and even wood chips. Radiata pine makes up 92% of softwoods planted – and exotic softwoods constitute 97% of the plantation forestry industry.

Furthermore, non-native pathogens threaten New Zealand’s unique forest ecosystems. Since this study focused on non-native plant hosts, it does not address the risk to native forest species. However, the threat is real: Kauri trees – the dominant canopy species in some native forest types – is suffering from a dieback caused by an introduced Phythopthora. Also, two other pathogens threaten the many trees and shrubs in the Myrtaceae family found in New Zealand – Puccinia rust (which is established in Australia but not New Zealand) or the Ceratocystis fungi causing rapid ohia death – both threaten native forests in Hawai`i, as discussed in a recent blog.

Posted by Faith Campbell

APHIS Nursery Stock Regulations (Q-37) – Modernization Finally Completed!

citrus longhorned beetle – entered country several times in imported bonzai plants

After about 20 years, APHIS has finalized important changes to the regulations which govern imports of living plants (what they call “plants for planting”; the regulation is sometimes called “the Quarantine 37” rule). The new regulation takes effect on April, 18, 2018.

I congratulate APHIS on this important achievement!

[Twenty years is a long time – so changes happen. When APHIS released its Advance Notice of Proposed Rulemaking (ANPR) in December 2004 and its proposed rule in April 2013, I was employed by The Nature Conservancy and submitted comments for that organization. I will refer to those earlier comments in this blog. However, I now represent the Center for Invasive Species Prevention, so my comments here on the final regulations reflect the position of CISP, not the Conservancy.]

APHIS’ 2004 ANPR came after years of preparation. Then, more than eight years passed until the formal proposal was published on April 25, 2013. Comments were accepted from the public until January 30, 2014. During this nine-month period, 17 entities commented, including producers’ organizations, state departments of agriculture, a foreign phytosanitary agency (The Netherlands), private citizens, and The Nature Conservancy. [You can view the ANPR and proposal, comments on these documents, and APHIS’ response here — although you need to click on “Restructuring of Regulations on the Importation of Plants for Planting” and then “Open Docket Folder” to pursue the older documents.]

In the beginning, APHIS had a few goals it hoped to achieve: to allow the agency to respond more quickly to new pest threats, to apply practices that are more effective at detecting pests than visual inspection at points of import, and to shift much of the burden of preventing pest introductions from the importer and APHIS to the exporter.

Progress has been made toward some of these goals outside this rule-making. APHIS instituted a process to temporarily prohibit importation of plants deemed to pose an identifiable risk until a pest risk assessment has been completed (the NAPPRA process). APHIS has further enhanced its ability to act quickly when a pest risk is perceived by relying increasingly on “Federal Orders”.

At the same time, APHIS participated actively in efforts by international phytosanitary professionals to adopt new “standards.” These define a new approach to ensure that plants in international trade are (nearly) pest-free. Both the North American Plant Protection Organization’s regional standard (RSPM#24) and the International Plant Protection Organization’s global standard (ISPM#36) envision a system under which countries would no longer rely primarily on inspections at ports-of-entry. Instead, they would negotiate with the supplier or exporting country to develop programs to certify that growers’ pest management programs are effective. Both standards detailed: 1) how the place of production might manage pest risk and ensure traceability of plants; 2) how the importing and exporting countries might collaborate to administer the program; 3) how audits (including site visits) would ensure the program’s efficacy; and 4) what actions various parties might take in cases of noncompliance.

It was hoped that these international standards would lead to widespread adoption of “integrated pest management programs” composed of similar requirements – similar to the impact of ISPM#15 for wood packaging. However, living plants are more complex pest vectors than the wooden boards of crates and pallets, so each country was expected to negotiate its own specific programs – something not encouraged for wood packaging.

APHIS’ decades-long effort to amend its regulations is warranted because of the high risk of non-native insects and – especially – pathogens being introduced via international trade in living plants. U.S. examples include white pine blister rust, chestnut blight, dogwood anthracnose, and sudden oak death (all described briefly here )

dogwood anthracnose

According to Liebhold et al. 2012 (full reference at end of blog), 12% of incoming plant shipments in 2009 were infested by a quarantine pest. This is an approach rate that is 100 times greater than the 0.1% rate documented for wood packaging (Haack et al. 2014). I have discussed the living plant introductory pathway and efforts up to 2014 to get it under control in my report, Fading Forests III.

Shortcomings of the Final Q 37 Rule

So – how well does this final rule meet APHIS’ objectives?

First, will it shift much of the burden of preventing new pest introductions from the importer and APHIS to the exporter, while ensuring the system’s efficacy? In my view, on behalf of CISP, it falls short.

The new rule sets up a process under which APHIS might require that some types of imported plants be produced and shipped under specified conditions intended to reduce pest risk. However, non-American entities have little incentive to protect America’s natural and agricultural resources and from invasive species. So any new process needs severe penalties for violators.

We have seen how widespread and persistent compliance failures are for wood packaging under ISPM#15. http://nivemnic.us/wood-packaging-again-11-years-after-ispm15-problems-persist/ For this reason, I (on behalf of the Conservancy) had suggested that APHIS formally adopt a specific goal of “no new introductions”. I recognized that this goal was unachievable per se, but suggested that it should stand as a challenge and be the basis for adopting stringent restrictions on plant imports. I suggested limiting plant imports to those either a) produced under integrated pest management measures systems (verified by third-party certification) or b) plants brought into facilities operating under post-entry quarantine conditions — and following other best management practices that had been developed and supervised by independent, scientifically-based bodies.

In my current view, APHIS’ regulation falls far short of either this goal of shifting burdens or setting a truly stringent requirement. In fact, APHIS has explicitly backed away from its own original goals and procedures.

The new regulation does authorize APHIS to choose to set up import programs under which the exporting country agrees to produce plants for the U.S. market under a system of integrated pest risk management measures (IPRMM) approved by APHIS. In accordance with the international standards, the programs established under this new power will address how the place of production will manage pest risk and ensure traceability of plants; how APHIS and the exporting country will administer the program; how plant brokers will ensure plants remain pest-free while in their custody; how audits will be performed to ensure program efficacy; and what actions various parties will take in cases of noncompliance.

How efficacious this new approach will be in preventing new introductions will depend on how aggressive APHIS is in both choosing the plant taxa and places of-origin to be managed under such IPRMM programs and in negotiating the specific terms of the program with the exporting country.

It is discouraging that APHIS has ratcheted down how frequently it expects to rely on the IPRMM approach. In the explanatory material accompanying the final regulation, APHIS clarifies that did not intend that IPRMM would be used for all imports of living plants. The IPRMM framework is described as only one of several means to achieve the goal of preventing introduction of quarantine pests. APHIS will choose the “least restrictive measures” needed to prevent introduction of quarantine pests. To clarify its position, APHIS changed the introductory text to indicate that IPRMM will be applied when such measures are necessary to mitigate risk – that is, “when the pest risk associated with the importation of a type of plants for planting can only be addressed through use of integrated measures.” [Emphases added]

The final rule is also discouraging in some of its specifics.

Whereas the draft regulation specified steps that places of production must take to ensure traceability of the plants they produce, in the final regulation the traceability elements specified in each IPRMM agreement will depend on the nature of the quarantine pests to be managed. Again, APHIS seeks to ensure that its requirements are not unnecessarily restrictive.
Although the international standard had specified severe penalties when a grower or broker violated the terms of the IPRMM agreement, APHIS proposed to base the regulatory responses to program failures on existing bilateral agreements with the exporting country. Despite the Conservancy’s plea that APHIS follow ISPM#36 in adopting more specific and severe penalties, APHIS has not done so. The one bright spot is that APHIS may verify the efficacy of any remedial measures imposed by the phytosanitary agency of the exporting country to correct problems at the non-compliant place of production. [Emphasis added]
APHIS is relaxing the detailed requirements for state post-entry quarantine agreements – despite the Conservancy’s concern that such agreements’ provisions could be influenced by political pressure and other nonscientific factors.

Two Improvements

I am pleased that APHIS has retained requirements applied to plant brokers, despite one commenter’s objections. Brokers handling international shipments of plants grown under an IPRMM program must both handle the plants themselves in ways that prevent infestation during shipment and maintain the integrity of documentation certifying the origin of the plants. A weakness, in my current view, is that APHIS will allow brokers to mix consignments of plants from more than one producer operating under the IPRMM program. APHIS does warn that if non-compliant (infested) plants are detected at import, all the producers whose plants were in the shipment would be subject to destruction, treatment, or re-export.

A major improvement under the new regulation is that APHIS will now operate under streamlined procedures when it wishes to amend the requirements for importing particular plants (whether a taxon, a “type”, or a country of origin). Until now, APHIS has been able to make such changes only through the cumbersome rulemaking process, Instead, APHIS will now issue a public notice, accept public comments, and then specify the new requirements through amendment of the “Plants for Planting Manual” [ https://www.aphis.usda.gov/import_export/plants/Manuals/ports/downloads/plants_for_planting.pdf ] APHIS estimates that such changes can be finalized four months faster under the new procedure.

A Final Caveat

Finally, APHIS needs to be able to measure what effect the new procedures have on preventing pest introductions. Such measurement depends on a statistically sound monitoring scheme. APHIS has stated in some documents that the current Agriculture Quarantine Inspection Monitoring (AQIM) system doesn’t serve this purpose. APHIS needs to develop a valid monitoring program.

References

Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (2014) Effectiveness of the International Phytosanitary Standard ISPM No. 15 on Reducing Wood Borer Infestation Rates in Wood Packaging Material Entering the United States. PLoS ONE 9(5): e96611. doi:10.1371/journal.pone.0096611

Posted by Faith Campbell

New study evaluates “candidate pool” from which invasive species might come

Campanula latifolia – one of the species detected as an “emerging” invasive species in the database relied upon by the authors of the study

The authors of a new study note that officials managing invasive species programs rely largely on knowledge of a species’ previous invasion history to predict its level of threat in the geographic area under their responsibility. This approach does not work with the many introduced species that have no history of a previous detected invasion. Hanno Seebens and 49 coauthors – including tree-pest experts Eckehard G. Brockerhoff, Marc Kenis, Andrew M. Liebhold, and Alain Roques — have sought to figure out how great a handicap that lack of data is. See “Global rise in emerging alien species results from increased accessibility of new source.” The study is available for $10 here. Figures, tables, and references are available without charge.

The study used a database of 45,984 first records of establishment of 16,019 species belonging to the following major taxonomic groups: vascular plants, mammals, birds, fishes, insects, crustaceans, mollusks, and other invertebrates.

Last year, many of the same scientists, relying on the same database, found that the rate of new introductions of alien species has risen rapidly since about 1800 – and shows no sign of slowing down. The adoption of national and international biosecurity measures during the 20th century have slowed introductions – but they are not sufficiently effective, especially regarding those plants and animals that are introduced primarily accidentally as stowaways on transport vectors or contaminants of commodities (e.g., algae, insects, crustaceans, mollusks and other invertebrates). The 2017 study found a strong correlation between these “accidental” alien species’ spread and the market value of goods imported into the region of interest. For that study, go here. I blogged about the findings on 1 March 2017 – here.

In the new 2018 article, the scientists found that even after many centuries of invasions the rate of emerging alien species is still high. Across all taxonomic groups, one out of four detections during 2000 – 2005 was of a species that had not been previously recorded anywhere as alien. Detections of “new” or “emerging” aliens is occurring at an even higher rate for some taxonomic groups. But new detections of insects fit the average – every fourth detection during 2000 – 2005 was of a species not previously recorded outside its native range.

The authors conclude that the continuing high proportion of “emerging” alien species is best explained by the interplay of 1) the incorporation into the pool of potential alien species of species native to regions formerly not accessible to traders; 2) increases in introduction rates due to higher import volumes; and 3) probably rising establishment rates as a consequence of land degradation that facilitates establishment in recipient regions. This process compensates for the decrease of new invaders from historically important source regions – from which potentially invasive species have presumably already taken advantage of pathways and been recorded as introduced somewhere.

emerald ash borer Agrilus planipennis – one of the species in the database of “emerging” invasive species

The number of insect species in the database candidate species pool is 20,611 species – an admittedly small fraction of all insects (for example, there are more than 350,000 beetle species worldwide). Twenty-four percent of these insect species have already been established somewhere outside their native ranges. However, the authors note that data gaps – which are larger for some taxonomic groups and geographic regions – mean that the number of actual “first” introductions is probably larger than records indicate, and consequently the estimated size of the candidate species pools may also be higher. Indeed, the paper does not attempt to estimate the actual size of the invasive species “pool” for insects.

The authors analyzed the importance of eight factors – temperature, relative humidity, import values, three land-use categories, number of botanical gardens, and human population size – in explaining the continued high number of “emerging” invaders detected in recent years. While these factors were explanatory for some taxonomic groups, they had a very low predictive value for insects.

For vascular plants, every third record of an introduction in 2000 – 2005 was of an “emerging” alien species. Interestingly, the number of botanical gardens in a country was a significant predictor for emerging alien vascular plants. However, as the authors of the article point out, reliance on this factor ignores the probable importance of other contributors such as the number of species planted in the receiving country; similarities between source and receiving environments; and introductions by acclimatization societies, European explorers or settlers, and plant hunters.

Acer ginnala –one of the species detected as an “emerging” invasive species in the database; photo by J. Weisenhorn, University of Minnesota extension

In any case, lots of previously undetected alien species are detected each year. In this database, 58% of the species had a single record; 86% of all species have no more than two first records in countries on the same continent. The large number of species with only one or two records led the authors to conclude that most species will not spread widely. I question that conclusion because species often require some time to spread to new locations – either local or distant. The authors do admit that they are unable to determine which species have a high potential for spread.

ash trees at the St. Louis arch – before arrival of emerald ash borer

The continued high rate of introduction of new species leads the authors to estimate that between 1% and 16% of all species on Earth – depending on the taxonomic group – qualify as potential invasive alien species. The authors did not attempt to estimate the true candidate pool or percentage of invasive species for insects. For vascular plants, the authors estimated the candidate pool at 47,000 species (out of a total of 368,000 species on Earth), or 13%.

Like its predecessor, this study’s importance arises from its broad perspective – covering the entire globe and a wide range of taxonomic groups. Its major conclusion that invasions will continue on a large scale serves as a warning to all stakeholders. These include officials charged with protecting agriculture and the broader economy, or the natural environment; conservationists; and those engaged in the economic activities that promote invasion.

However, the authors found that the data did not support more specific advice. First, as noted above, they were unable to determine which of the “emerging” invasive species in all taxonomic groups have a high potential to spread.

For those of us focused on invasive species that threaten native plants, data gaps limit the predictive value of the study the most. The database is too scant even to estimate the invasive species “pool” of potential insect pests. Plant pathogens are not included in the analysis.

Posted by Faith Campbell and Phyllis Windle

What Is USDA Waiting For?

As I wrote in my blog in October, the Department of Homeland Security Bureau of Customs and Border Protection (CBP) has reversed a previous policy and now has the option to impose a financial penalty on importers when any of their shipments does not comply with the international standard for wood packaging (International Standard for Phytosanitary Measure Number 15 – or ISPM#15). The penalties are assessed under Custom’s authority per Title 19 United States Code (USC) § 1595a(b) or 19 USC § 1592.

The Department of Agriculture has its own legal authority to penalize shippers whose wood packaging violates regulations implementing ISPM#15. However, USDA not taken the equivalent step of using its own authority to crack down on violators. Why not?

APHIS’ legal authority stems from the Plant Protection Act of 2000 [7 U.S.C. §7701, et seq. (2000)] (The text is posted here)

This law provides broad authority to APHIS to penalize non-compliant importers, using both civil and criminal penalties. Under Section 7734 (b):

“Any person that violates this chapter … may, after notice and opportunity for a hearing on the record, be assessed a civil penalty by the Secretary…” The penalty can vary from $50,000 to $1 million, depending on whether the importer is an individual or a corporation; the number of violations adjudicated in the proceeding; the gravity of the violation; and the importer’s ability to pay. Civil penalties can be assessed regardless of whether the violation was intentional (in the language of the statute, “willful”).

Under Section 7734(a), the Department may seek criminal penalties in cases when the importer “knowingly” violated the law and its implementing regulations. Criminal penalties include both fines and imprisonment. To apply a criminal penalty, USDA must convict the importer in a trial – prove the violation beyond a reasonable doubt.

It is puzzling that USDA has not acted on this authority.

As we all know, the biological diversity of America’s forests’ is severely threatened by wood-borers that can enter the country in wood packaging. Tree mortality caused by non-native pests has been estimated to cost municipalities $1.7 billion per year (Aukema et al. 2011). For discussions of introduced pests’ impacts, see the sources listed at the end of this blog.

Nearly 12 years after APHIS adopted regulations implementing the formal International Standard for wood packaging, significant numbers of shipments that do not comply with the regulations continue to arrive. In the fiscal year that ended on September 30, Customs detected 2,000 shipments in which the wood packaging did not bear the mark certifying that the wood had been treated in accordance with ISPM#15. In nearly 900 additional shipments, CBP detected damaging pests in the wood packaging. (For more detail on this issue, see my blog from last February.) link. So, the need to improve compliance is manifest. Imposing a financial penalty strikes me as an available and useful strategy to achieve that improvement.

The new CBP policy is a much-needed step. Now USDA should reinforce that action by implementing its own enforcement powers. The USDA’s Office of General Counsel and APHIS should be asked what is preventing implementation and what can be done to move this forward. Effective action to interdict forest pests requires strong enforcement by both CBP and USDA. Right now, it looks like the Department of Homeland Security cares about U.S. forests more than the Department of Agriculture.

SOURCES

Aukema, J.E., B. Leung, K. Kovacs, C. Chivers, K. O. Britton, J. Englin, S.J. Frankel, R. G. Haight, T. P. Holmes, A. Liebhold, D.G. McCullough, B. Von Holle.^. 2011. Economic Impacts of Non-Native Forest Insects in the Continental United States PLoS One September 2011 (Volume 6 Issue 9)

Background on forest pest damages:

Campbell and Schlarbaum, Fading Forest reports http://treeimprovement.utk.edu/FadingForests.htm

Lovett, G.M., M. Weiss, A.M. Liebhold, T.P. Holmes, B. Leung, K.F. Lambert, D.A. Orwig , F.T. Campbell, J. Rosenthal, D.G. McCullough, R. Wildova, M.P. Ayres, C.D. Canham, D.R. Foster, S.L. LaDeau, and T. Weldy. 2016. Nonnative forest insects and pathogens in the United States: Impacts and policy options. Ecological Applications, 0(0), 2016, pp. 1–19. DOI 10.1890/15-1176.1 Recommendations available at www.caryinstitute.org/tree-smart-trade

Posted by Faith Campbell

New “Plant Pest” Boss Soon to Take Office

Gregory Ibach

Gregory Ibach has been appointed USDA Under Secretary of Agriculture for Marketing and Regulatory Programs. He will supervise APHIS.

Mr. Ibach has strong ties to mainstream agriculture. A fourth-generation farmer (cow-calf and rowcrops), he has served as Nebraska’s Commissioner – or Deputy – of Agriculture under three governors – since 1999. His academic background is animal science and agricultural economics.

Mr. Ibach’s nomination was supported by 60 organizations, including the Farm Bureau, National Cattlemen’s Beef Association, and National Corn Growers.

The Senate Committee on Agriculture, Nutrition & Forestry held a very friendly hearing on Mr. Ibach’s appointment on October 5, 2017 2017 (video posted at the Committee website) During the hearing – which was shortened by the need to attend to other Senate business – Senators’ attention focused on the farm conservation programs managed by the other nominee at the hearing (William Northey, nominee for Undersecretary for Farm and Foreign Agricultural Services). In response to several questions about marketing programs, Mr. Ibach said he needed to learn more about an issue.

In his formal testimony, Mr. Ibach noted the breadth of responsibilities under the jurisdiction of the Under Secretary for Marketing and Regulatory Programs and promised to find a balance between the two duties: representing and promoting the interests of farmers and ranchers; and overseeing some of the entities that regulate them. (Written testimony posted on Committee website — link above.)

“If confirmed, I will help the Secretary achieve his goals through ensuring sensible and effective regulations, responding to our customers in a timely and straight forward manner, focusing on plant and animal health program effectiveness, and fostering safe innovation that is farmer, consumer and environmentally sound.”

I summarize key points of the hearing below.

Committee Chairman Pat Roberts (R-KS) noted that foreign animal disease threats – such as avian influenza – have threatened agricultural production and asked what Mr. Ibach’s priorities would be for safeguarding animal health. Mr. Ibach said he takes very seriously APHIS’ responsibilities to keep diseases and pests out of the country and to control those that enter. He promised to learn about every program.

Ranking Democrat Debbie Stabenow (D-MI) asked Mr. Ibach about budgetary pressures. He responded by saying he would commit to doing the best job possible with available funds and to pursue efficiencies.

Amy Klobuchar (D-MN) was also concerned about disease threats to Minnesota’s large-scale turkey and hog producers.

John Hoeven (R-ND) pressed Mr. Ibach to find a solution to blackbirds as a threat to agriculture. Mr. Ibach said they are a problem in Nebraska, too. He promised to seek a “balanced” approach that preserved wildlife “when appropriate” while protecting farmers from destruction and disease threats.

Senator Leahy (D-VT) submitted questions pertinent to our concerns about tree-killing pests. Noting that Mr. Ibach had spoken about the pest threat to farmers, ranchers, and producers but had made no mention of the forest pests, Senator Leahy asked:

What familiarity do you have with APHIS’ work to keep out invasive forests pests that threaten our nation’s forests and the rural jobs and economy those forests support?

Mr. Ibach replied: I am familiar with the work that APHIS does in partnership with states to keep out and eradicate forest pests. In fact, in Nebraska, we have been working closely with APHIS prior to and since Emerald Ash Borer was found in the state for the first-time last year. These pests can absolutely devastate our forests, and if confirmed, I would work to make sure that APHIS’ pest programs, including those to protect the green mountains of Vermont, are effective.

Can you tell me how many wood and tree pests APHIS inspectors find every year, which theoretically should not have made it to our shores if importers were using the best available processes and phytosanitary practices to keep American agriculture and natural resources safe? And do you commit to looking into this issue and finding ways to safeguard both American agriculture and our natural resources?

Mr. Ibach replied: I do not have that data, but commit to learning more and working every day to protect American agriculture and natural resources if confirmed.

Senator Roberts said that the Committee would act soon to approve the nominations of Gregory Ibach and William Northey.

The Under Secretary for Marketing and Regulatory Programs sets the tone for APHIS’ efforts. This person can prompt aggressive protection efforts … or block such efforts by opposition or indifference. Let’s hope that Mr. Ibach plays the former role!

Posted by Faith Campbell

Penalties for Importers Who Violate Wood Packaging Rules!

CBP inspection of wood packaging; CBP photo

On September 25, the DHS Bureau of Customs and Border Protection (CBP) announced that beginning on November 1, the agency would no longer eschew penalizing importers of non-compliant wood packaging until that importer had accumulated five such interceptions in the course of a year.

Beginning November 1, “responsible parties with a documented WPM violation may be issued a penalty under Title 19 United States Code (USC) § 1595a(b) or under 19 USC § 1592.”

As readers of this blog might remember, I have frequently fulminated against the “five strikes” policy. The United States began full implementation of the international standard governing treatment of wood packaging (ISPM#15) 11 and ½ years ago. The U.S. and Canada began requiring China to treat its wood packaging nearly 18 years ago. Nevertheless, numerous shipments containing wood packaging that does not comply with the regulations continue to arrive at our borders – and to bring pests. As of February, only about 30 import shipments (out of nearly 21,000 shipments found to be in violation of ISPM#15 requirements) have received a financial penalty.

shipments of stone or tile are frequently supported by non-compliant wood packaging; photo (c) the Queen by right of Canada (CFIA)

In a blog I posted in February I described the continuing detections of pests in wood packaging. In summary, during Fiscal Years 2010 through 2016, CBP detected nearly 5,000 shipments of wood packaging that harbored a pest in a regulated taxonomic group. The APHIS interception database for the period FYs 2011 – 2016 contained 2,547 records for insect detections on wood packaging. The insects belonged to more than 20 families. A quarter were in the Cerambycid family; 11% were Buprestids. In a study of insect larvae removed from incoming wood packaging from the period April 2012 through August 2016, APHIS scientists evaluated 1,068 insects from 786 separate interceptions of non-compliant wood packaging. The wood packaging in all three datasets came from dozens of countries.

(Remember, the U.S. and Canada do not apply ISPM#15 to wood packaging moving between the two countries. Neither country inspects wood packaging from the other country at even the low rate of inspection applied to wood packaging coming from other countries – so we don’t know how many quarantine pests are moving in this high-volume trade.)

The Bureau of Customs’ action has partially fulfilled one of two recommendations that I made in the February blog. I applaud CBP’s action. However, neither CBP or APHIS has yet prohibited importers with records of repeat violations from using wood packaging – my second recommendation.

Note that the CBP decision applies Customs regulations; USDA has apparently not changed its policy of allowing importers to accumulate five (detected) violations in a calendar year before applying the civil penalties provided by the Plant Protection Act. Why?

Posted by Faith Campbell

Worldwide Study Confirms ISPM#15 is not Protecting Forests – What Do We Do Now About Pests in Wood Packaging?

You know that the continuing pest risk associated with imports of wood packaging is among my biggest concerns. See, for example, fact sheets here and blogs here and here.

A new book about the family Cerambycidae (edited by Wang 2017; reference at end of blog) confirms that longhorned beetles continue to be introduced to many countries via this pathway, more than a decade after widespread implementation of the international standard governing wood packaging (ISPM#15). Furthermore, data from several countries confirm that China continues to fall short … but that problems are more widespread.

The Wang book finds that 16 outbreaks of the Asian longhorned beetle (ALB) were detected between 2012 and 2015.

Unless otherwise noted, the information provided here comes largely from the book’s chapter on biosecurity coauthored by Dominic Eyre and Robert A. Haack (see link below). Opinions stated are mine, unless specified otherwise.

In some cases – which I will note – further details are from my earlier posts.

While I think the risk of introduction of highly damaging pests via the wood packaging pathway is well documented in Wang (2017) and other publications, no one can truly quantify this risk because of shortcomings in countries’ data. Available data come primarily from countries’ records of pest “interceptions” – usually at points of entry. However, interception data are inadequate to conclusively establish the lack of a threat for a particular trade or to provide a fair comparison of the relative threat of particular trades. Most interception databases have the following shortcomings (Eyre and Haack are summarizing points made by a third scientist – Lee Humble – in an earlier article):

(1) interception databases are not based on random sampling, which is necessary to measure the “approach” or “infestation” rate;

(2) inspections which find no pests are not recorded, so we cannot know what proportion of incoming shipments are infested;

(3) once inspectors have discovered a quarantine pest in a shipment, the consignments may be destroyed without further inspection, and thus other exotic organisms can be missed;

(4) only a small percentage of individual shipments are inspected; and

(5) organisms often are not identified to species due to difficulty of identifying larvae.

Furthermore,

(1) trade volumes and sources can change rapidly;

(2) the number of consignments inspected varies from year to year in response to national and regional plant health and wider government priorities;

(3) the method and intensity of quarantine inspections can vary within and among countries and as well as over time; and

(4) different proportions of consignments from different trades can be inspected, reflecting the perceived quarantine risks of each trade.

Still, scientists try to analyze the available data because propagule pressure may be the most important factor in determining whether an exotic pest becomes established.

What have they found?

Data from both the United States and Europe document that problems of non-compliance continue in recent years – more than a decade after adoption of ISPM#15.

United States:

Since APHIS interception records began being computerized in 1985, Cerambycidae have been among the most frequently intercepted insect families associated with wood products and packaging. The top five countries for infested shipments during the period 1984 – 2008 were China, Italy, Mexico, Turkey and Spain. A country’s rank is linked in part to import volumes – which are very high for China, Canada, and Mexico. Because the U.S. inspects very limited quantities of wood packaging from Canada, its absence from the top five may be misleading [discussed in my blog from February, here.

Another factor explaining these countries’ rankings is the continued – in fact increasing! – presence of pests in wood packaging accompanying imports of tile and quarry products (e.g., marble, slate). Many of these imports are from Italy, Spain, and Mexico. Interceptions on these imports increased significantly from the mid-1990s to 2008. The increase in these interceptions is most alarming because it shows USDA leaders have not yet taken effective action to curtail this risk, despite its being evident since record-keeping began.

Over the period Fiscal Years 2010 through 2016, the U.S. Bureau of Customs and Border Protection has detected nearly 5,000 consignments in which cases the wood packaging harbored a pest in a regulated taxonomic group. APHIS experts identified 2,500 insects taken from wood packaging during this period; a quarter were Cerambycids. A second APHIS analysis of a subset of the wood packaging-associated insects found examples from 39 countries, including 212 shipments from Europe; 130 shipments from Asia; and 341 shipments from the Americas – almost exclusively Mexico. [These detections are discussed in my blog from February, here.

Europe has had a similar experience.

Interception records included in EUROPHYT show 306 Cerambycidae interceptions on wood packaging over the period 1998 – 2013. The number of interceptions recorded in 2012 and 2013 are double those of all previous years. Each year, the majority are on wood packaging from China.
Most interceptions of ALB (distinct from detections of establishments) have occurred after the shipment cleared border inspection procedures, e.g., in warehouses.
As with the U.S., while the majority of non-compliant shipments are from China, the problem is worldwide: Europe has also found various species of longhorned beetles in wood packaging from various European countries (inside and outside the European Union), other Asian countries, Africa, Australasia, and the Americas.
Austria inspected 451 consignments of stone imports received April 1, 2013 – April 14, 2014. Forty-four consignments (9.8%) were found to be out of compliance with ISPM#15. Live Cerambycidae were found in 38 consignments (8%), including ALB. This finding confirms the widespread awareness that stone imports rank high for non-compliant wood packaging.

Regulatory Authorities’ Response (or lack thereof)

Europe

Since March 31, 2013, the European Union has required inspection of 90% of consignments of slate, marble, and granite and 15% of consignments of two other categories of stone imports.

CBP agriculture specialists in Laredo, Texas, examine a wooden pallet for signs of insect infestation. [Note presence of an apparent ISPM stamp on the side of the pallet] Photo by Rick Pauza

United States

As noted by Haack et al. (2014) (reference below), as of 2009, approximately 13,000 containers harboring pests probably enter the U.S. each year. That is 35 potential pest arrivals each day. [This issue is also discussed in the fact sheet and blogs here and here.
The United States has not specified an obligatory inspection rate for such high-risk imports as stone and tile. Instead, it relies on Customs and Border Protection to target import shipments suspected of being out of compliance based on past performance of importers, suppliers, and types of imports.
Several relevant issues are discussed in the blog in February 2017 (second blog linked to above). First, I noted that the U.S. Department of Homeland Security Bureau of Customs and Border Protection – over the seven-year period Fiscal Years 2010 through 2016 – has detected nearly 5,000 cases of wood packaging harboring a pest in a regulated taxonomic group. Comparing the estimate by Haack et al. 2014 with the CBP data indicates that Customs is detecting about 6% of all pest-infested shipments.
Furthermore, about 26% of infested wood pieces detected by CBP were found in wood that was marked as having been treated according to ISPM#15 requirements. What does this mean? Fraud? Accidental misapplication of the treatments? Or are the treatments less effective than hoped? What are USDA and other responsible agencies doing to clarify the causes?
CBP staff reported that only about 30 import shipments (out of nearly 21,000 shipments found to be in violation of ISPM#15 requirements) have received a financial penalty. How can USDA and Customs officials justify this failure to enforce the regulations?

What Can Be Done to Close Down the Wood Packaging Pathway

I suggest that our goal should be to hold foreign suppliers responsible for complying with ISPM#15. One approach is to penalize violators. APHIS and Customs might

Prohibit imports in packaging made from solid wood (boards, 4 x 4s, etc.) from foreign suppliers which have a record of repeated violations over the 11 years ISPM#15 has been in effect (17 years for exporters from Hong Kong & mainland China). Officials should allow continued imports from those same suppliers as long as they are contained in other types of packaging materials, including plastic, metals, or fiberboards.
Fine an importer for each new shipment found to be out of compliance with ISPM#15 in cases when the foreign supplier of that shipment has a record of repeated violations.

There would need to be a severe penalty to deter foreign suppliers from simply changing their names or taking other steps to escape being associated with their violation record.

At the same time, the agencies should work with non-governmental organizations and importers to promote creation of an industry certification program that would recognize and reward importers who have voluntarily undertaken actions aimed at voluntarily exceeding ISPM#15 requirements so as to provide a higher level of protection against invasive species that would otherwise potentially be introduced into the United States.

What You Can Do

Tell your member of Congress and Senators that you are worried that our trees are still being put at risk by insects arriving in wood packaging. Ask them to urge the USDA Secretary Sonny Perdue to take the actions outlined above in order to curtail introductions of additional tree-killing pests.
Talk to your friends and neighbors about the threat to our trees. Ask them to join you in communicating these concerns to their Congressional representatives and Senators.
Write letters to the editors of your local newspaper or TV news station.

Use your knowledge about pests threatening trees in your state or locality in your communications!

Other Introduction Pathways for Cerambycids

tree removals in Tukwilla, WA to eradicate citrus longhorned beetle; photo by Washington State Department of Agriculture

Plants for planting

Other studies have confirmed that importation of living plants (called by regulators “plants for planting”) is a high-risk pathway for introducing tree-killing pests. See the Eyre and Haack chapter for a summary.

This is as true for highly damaging Cerambycids as for other types of plant pests. One of the most damaging is the citrus longhorned beetle (CLB) (Anoplophora chinensis). CLB [https://www.dontmovefirewood.org/invasive-species/] poses an even greater threat to North American forests than ALB – it has a wider host range and climate-matching models show that it could establish across most of the United States. CLB were detected in a nursery in Tukwilla, Washington, in 2001; the pest was eradicated. Nine CLB outbreaks have been detected in Europe; three are considered eradicated (Eyre & Haack 2017).

Eyre and Haack (2017) report that in Europe of the 455 Cerambycidae intercepted over the period 1998 – 2013, 54 were on imported in living plants. These included probably 49 citrus longhorned beetle (CLB). Most were detected primarily on maple nursery stock that originated China (32), with smaller numbers from other countries, including Netherlands (8), and Italy (where CLB has been established).

New Zealand has intercepted 74 CLB on plants for planting over the 28 year period 1980 – 2008. One third of this total was intercepted in 2008.

Authorities’ Responses (or lack thereof)

Europe

Since 2012, the European Union has required that 10% of CLB host plants imported into the European Union should be destructively sampled (that is, dissected to see whether insects are present internally).
This requirement supplements a broader requirement that plants for planting be treated as a high risk commodity. Member states are required to inspect all incoming P4P consignments. This requirement is, however, undermined by much more lenient requirements regarding movement of plants among EU member states – some genera are not regulated … others are controlled by Plant Passports – an industry-led scheme. [For more on this issue, see my blog from October 2016 here.

United States

APHIS issued a Federal order tightly restricting imports of CLB hosts from Europe in 2013 – four years after a CLB outbreak was detected in a part of the Netherlands which is a center for the production of hardy ornamental nursery stock for European and probably American markets.
APHIS proposed to revise its overall plant importation regulations (the “Q-37 regulations) to rely more on integrated management by the exporting nurseries in contrast to port inspections. This rulemaking has stalled. [See my blog about this here.]

Finished Wood Products

While no country is keeping comprehensive records, finished wood products have transported longhorned beetles. Eyre and Haack (2017) concluded that upholstered furniture presents one of the highest risk among the finished wood products – partly because imports are rising rapidly, partly because insect-damaged wood can be hidden under the upholstery. New Zealand found that some Asian manufacturers place good quality wood on visible surfaces and poor quality timber (insect damaged and bark covered) in internal sections. Officials inspected 49 couches and found that 30 had wood with bark, 19 had insect contaminants, and 32 had visible insect damage. Fungal samples were isolated from 11 of the couches. They found 4 longhorned beetles.

References

Wang, Q. (Ed.). 2017. Cerambycidae of the world: biology and pest management. Boca Raton, FL: CRC Press

The chapter on biosecurity is available here: http://treesearch.fs.fed.us/pubs/54552

A chapter on Cerambycid impacts in urban and rural forests is available here: http://treesearch.fs.fed.us/pubs/54543

Posted by Faith Campbell

Invasive “hot spot” study confirms vulnerable places, causes of introductions

removing Miconia from Hawaiian forest; courtesy of the Nature Conservancy of Hawai`i

A recent article by Wayne Dawson and 24 coauthors (see reference at the end of this blog) provides the first-ever global analysis of established alien species. They studied the diversity of established alien species belonging go eight taxonomic groups – amphibians, ants, birds, freshwater fish, mammals, reptiles, spiders and vascular plants – across 609 regions (186 islands or archipelagos, and 423 mainland regions).

The analysis found that the highest numbers of established alien species in these taxonomic groups were in the Hawaiian Islands, New Zealand’s North Island and the Lesser Sunda Islands of Indonesia. The Hawaiian Islands have high numbers of invasive species in all of the eight groups studied. In New Zealand, the highest numbers were invasive plants and introduced mammals that prey on the native birds.

Florida is the top hotspot among mainland regions. Florida is followed by the California coast and northern Australia.

Burmese python in the Florida Everglades; photo by U.S. Fish & Wildlife Service

Patterns

Invasive species hotspots were found mainly on islands and in coastal regions of mainland areas. The lead author, Dr. Wayne Dawson, a researcher at Durham University’s Department of Biosciences, suggested that the greater invasive species richness in coastal regions probably results from higher rates of species introductions to port areas compared to interior regions.

Island regions have, on average, higher cross-taxon invasive species richness. This cross-taxon richness on islands tends to be higher for those islands further from continental landmasses. The authors suggest that such oceanic islands might be more likely to import large quantities of goods from foreign sources than islands close to continents, thus experiencing higher propagule pressure.

Associations

Regions with greater wealth (measured as per capita GNP), human population density, and area have higher established alien richness. These effects were strongest on islands. The authors suggest that wealth and human population density might correlate with higher numbers of species being brought to the region through trade and transport.

On mainlands, cooler regions have higher richness. I think this might reflect history – centuries of colonial powers importing plants and animals. However, colonial powers also introduced species to tropical regions. In contrast, on islands warmer and wetter regions have higher richness of invasive species.

Drivers

The authors conclude that cumulative numbers of invasive species at a particular location are driven to a greater extent by differences in area and propagule pressure than by climate. The model that best explains cross-taxon invasive species richness combines per capita GDP, population density and sampling effort. Other important factors are area of the region, mean annual precipitation, and whether a region is on a mainland or island(s).

The study results show that, per unit increase in area, per capita GDP, and population density, invasive species richness increases at a faster rate on islands than on mainlands. This might be confirmation of the longstanding belief that islands are more readily invaded than mainlands, although the authors caution that a rigorous test of this explanation would require data on failed introductions.

The authors call for additional research to understand whether these effects arise because more species are introduced to hotspot regions, or because human disturbance in these regions makes it easier for the newcomers to find vacant spaces and opportunities to thrive.

I think it would be helpful to compare the findings on invasive species richness in specific regions to data on historic patterns of trade and colonization to strengthen our understanding of the importance of propagule pressure in determining invasion patterns.

Increasing Confirmation of Significance and Breadth of Invasive Species Threat

The Dawson et al. study is the latest in a series of analyses of global or regional patterns in invasive species. I have blogged previously about several of these:

Bradshaw et al. 2016 concluded that invasive insects alone cause at least $77 billion in damage every year, a figure they described as a “gross underestimate”.
A study by Hanno Seebens and 44 coauthors showed that the rate of new introductions of alien species has risen rapidly since about 1800 – and shows no sign of slowing down. Adoption of national and international biosecurity measures have been only partially effective, failing to slow deliberate introductions of vascular plant species, birds, and reptiles, and accidentally introduced invertebrates and pathogens. Like Dawson et al, Seebens et al. found a strong correlation between the spread of bioinvaders introduced primarily accidentally as stowaways on transport vectors or contaminants of commodities (e.g., algae, insects, crustaceans, molluscs and other invertebrates) and the market value of goods imported into the region of interest.
Liebhold et al. 2016(see reference below) studied insect assemblages in 20 regions around the world. They found that an insect taxon’s ability to take advantage of particular invasion pathways better explained the insect’s invasion history than the insects’ life-history traits. (The latter affect the insect’s ability to establish in a new ecosystem.)
Maartje J. Klapwijk and several colleagues note that growing trade in living plants and wood products has brought a rise in non-native tree pests becoming established in Europe. The number of alien invertebrate species has increased two-fold since 1950; the number of fungal species has increased four-fold since 1900.
Jung et al. (2015) studied the presence of Phytophthora pathogens in nurseries in Europe. They found 59 putatively alien Phytophthora taxa in the nurseries. Two-thirds were unknown to science before 1990. None had been intercepted at European ports of entry when they were introduced. Nor have strict quarantine regulations halted spread of the quarantine organism ramorum.
A report by The World Conservation Union (IUCN) on World Heritage sites globally found that invasive species were second to poaching as a threat to the sites’ natural values. Of 229 natural World Heritage sites examined, 104 were affected by invasive species. Island sites – especially in the tropics – were most heavily impacted.
Another report by IUCN found that invasive species were the second most common cause of species extinctions – especially for vertebrates.

Conclusions

These studies demonstrate that

Invasive species have become a significant threat to biological diversity and ecosystem services around the world – one that continues to grow.
The recent spate of studies originating in Europe probably reflects recent recognition of the continent’s vulnerability – as seen, inter alia, in the proliferation of tree-killing Phytophthoras.
Human movement of species – propagule pressure – whether deliberately or due to inadequate efforts to manage trade-related pathways – explain the bulk of “successful” introductions.
Economic activity drives introductions, so areas at highest immediate risk are urban areas and other centers receiving high volumes of imports and visitors. Among troubling trends in the future is rapid global urbanization – along with rising economic interdependency.
Efforts to curb these movements – at the national, regional, and international levels – have failed so far to counter the threat posed by invasive species of nearly all taxonomic groups.

In my view, the requirements that phytosanitary measures “balance” pest prevention against trade facilitation results in half measures being applied – and half measures achieve halfway results. For example, the U.S. does not require that packaging be made from materials that cannot transport tree-killing pests. The USDA has moved far too slowly to limit imports of plant taxa that pose a risk of either being invasive themselves or of transporting pests known to be damaging.

Conservationists should focus on building political pressure to strengthen regulations and other programs intended to curtail this movement. No other approach will succeed.

Sources

Bradshaw, C.J.A. et al. Massive yet grossly underestimated global costs of invasive insects. Nat. Commun. 7, 12986 doi: 10.1038/ncomms12986 (2016). (Open access)

Dawson, W., D. Moser, M. van Kleunen, H. Kreft, J. Perg, P. Pyšek, P. Weigelt, M. Winter, B. Lenzner, T.M. Blackburn, E.E. Dyer, P. Cassey, S.L. Scrivens, E.P. Economo, B. Guénard, C. Capinha, H. Seebens, P. García-Díaz, W. Nentwig, E. García-Berthou, C. Casal, N.E. Mandrak, P. Fuller, C. Meyer and F. Ess. 2017. Global hotspots and correlates of IAS richness across taxon groups. Nature Ecology and Evolution Vol. 1, Article 0186. DOI: 10.1038/s41559-017-0186 | www.nature.com/natecolevol

Jung,T., L. Orlikowski, B. Henricot, P. Abad-Campos, A.G. Aday, O. Aguin Casa, J. Bakonyi, S.O. Cacciola, T. Cech, D. Chavarriaga, T. Corcobado, A. Cravador, T. Decourcelle, G. Denton, S. Diamandis, H.T. Doggmus-Lehtijarvi, A. Franceschini, B. Ginetti, M. Glavendekic, J. Hantula, G. Hartmann, M. Herrero, D. Ivic, M. Horta Jung, A. Lilja, N. Keca, V. Kramarets, A. Lyubenova, H. Machado, G. Magnano di San Lio, P.J. Mansilla Vazquez, B. Marais, I. Matsiakh, I. Milenkovic, S. Moricca, Z.A. Nagy, J. Nechwatal, C. Olsson, T. Oszako, A. Pane, E.J. Paplomatas, C. Pintos Varela, S. Prospero, C. Rial Martinez, D. Rigling, C. Robin, A. Rytkonen, M.E. Sanchez, B. Scanu, A. Schlenzig, J. Schumacher, S. Slavov, A. Solla, E. Sousa, J. Stenlid, V. Talgø, Z. Tomic, P. Tsopelas, A. Vannini, A.M. Vettraino, M. Wenneker, S. Woodward and A. Perez-Sierra. 2015. Widespread Phytophthora infestations in European nurseries put forest, semi-natural and horticultural ecosystems at high risk of Phytophthora disease. Forest Pathology.

Klapwijk, M.J., A.J.M. Hopkins, L. Eriksson, M. Pettersson, M. Schroeder, A. Lindelo¨w, J. Ro¨nnberg, E.C.H. Keskitalo, M. Kenis. 2016. Reducing the risk of invasive forest pests and pathogens: Combining legislation, targeted management and public awareness. Ambio 2016, 45(Suppl. 2):S223–S234 DOI 10.1007/s13280-015-0748-3 [http://www.nature.com/articles/ncomms14435 ]

Liebhold, A.M., T. Yamanaka, A. Roques, S. Augustin, S.L. Chown, E.G. Brockerhoff, P. Pysek. 2016. Global compositional variation among native and nonindigenous regional insect assemblages emphasizes the importance of pathways. Biological Invasions (2016) 18:893–905

Seebens, H. et al., 2017. No saturation in the accumulation of alien species worldwide. Nature Communications. January 2017. [http://www.nature.com/articles/ncomms14435 ]

Posted by Faith Campbell