**Florida Department of Agriculture & Consumer
Services**![](media/image1.png){width="1.4993055555555554in"
height="1.6666666666666667in"}

**CHARLES H. BRONSON, Commissioner**

**Please Respond to:**

**Division of Plant Industry**

**P.O. Box 147100/1911 Southwest 34^th^ Street**

**Gainesville, Florida 32614-7100**

**Telephone: (352) 372-3505/Facsimile: (352) 955-2300**

May 26, 2005

Regulatory Analysis and Development

USDA, PPD, APHIS, Station 3C71

4700 River Road, Unit 118

Riverdale, Maryland 20737-1238

**RE: Federal Register Docket No. 03-048-1**

**Importation of Fruits and Vegetables**

Reference is made to the proposal to amend the fruits and vegetables
regulations to list a number of fruits and vegetables from certain parts
of the world as eligible, under specified conditions, for importation
into the United States.

The Florida Department of Agriculture and Consumer Services would like
to take this opportunity to formally offer the following comments
regarding this proposal:

*Fruits and Vegetables Eligible for Entry Under Permit*

The nematologists of the Florida Department of Agriculture and Consumer
Services are concerned about the importation of edible root crops from
Mexico and China. The risk of introducing the potato pathotype of the
false root-knot nematode (N*acobbus aberrans*) with Swiss chard from
Mexico was previously discussed in our response to the Federal Register
Docket No. 02-106-1, Importation of Fruits and Vegetables dated February
2, 2004.

Furthermore, we are also concerned about the risks associated with the
importation of ginger roots from China. Ginger is an excellent host of
the burrowing nematode (*Radopholus similis*) and root-knot nematodes
(*Meloidogyne spp.*). Root-knot nematode species that attack citrus are
present in China. These species (e.g. *Meloidogyne citri)* do not occur
in the United States. These nematodes can enter the United States with
ginger roots.

We are aware that these edible root crops have been imported for many
years into the United States. However, the fact that these root crops
have been introduced for many years does not justify a complete
confidence in this trade policy. Unfortunately, the detection of an
exotic nematode plant pest is more difficult to detect than that of an
arthropod.

The damage caused by an introduced nematode plant pest becomes
noticeable after many years (5-10) from the entry of the nematode pest.

We would recommend that APHIS conduct a complete risk analysis relative
to the introduction of these nematodes with edible root crops from
Mexico and China.

*Grapefruit, Sweet Oranges, and Tangerines from Mexico*

We are very concerned about the proposal to allow grapefruit (*Citrus
paradise*), sweet oranges (*Citrus sinensis)*, and tangerines (*Citrus
reticulate)* from areas of Mexico where certain fruit flies occur to be
imported into the United States without treatment under certain
conditions, which would be set forth in a new section of 319.56-2nn.

Under this proposal the growers who would conduct the trapping would be
required to be monitored under an APHIS-approved quality control
program. Based on the failure of a similar program established for
Spanish Clementine growers, we are adamantly in opposition to this
proposal. At the very least, we would recommend that a fruit cutting
component be included to check for fruit fly larva. This would serve as
a back-up to field trapping.

*Papaya From Brazil and Nicaragua*

Both Mediterranean fruit fly (*Ceratitis capitata*) and South American
fruit fly, (*Anastrepha fraterculus*) are widespread in Brazil, and
known to attack papaya. The Mediterranean fruit fly is also widespread
in Nicaragua. Before we can endorse this proposal to allow papaya from
Brazil and Nicaragua to be imported into the United States, we would
like the opportunity to review the ten (10) conditions under which fruit
will be acceptable as uninfested.

*Fruit Fly-Free Areas in Argentina*

Current regulations refer to Medfly free areas that have been
established for certain areas in southern Argentina. However, we must
ask the questions: Are these same areas also free of the South American
fruit fly (*Anastrepha fraterculus)*? If this has not been verified, we
recommend that his proposal be removed from the proposed rule amendment.

As always, we certainly welcome the opportunity to offer comments on the
proposed amendments to the regulations governing the importation of
fruits and vegetables into the United States.

Sincerely,

**CHARLES H. BRONSON**\
**COMMISSIONER OF AGRICULTURE**

Richard D. Gaskalla

Division Director

RDG/rc