Risk Management Proposal:   
Proposed amendment to the IHS  155.02.05 : Seeds for sowing and 
requirements for the importation of Pisum seeds for sowing.  
 
FOR PUBLIC CONSULTATION  
 
 
 
 
 
 
 
13th February  2017   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Plant Imports  
Plants, Food & Environment  
Ministry for Primary Industries  
Pastoral House  
25 The Terrace  
PO Box 2526  
Wellington 6140  
New Zealand  
 
Tel: +64 4 894 0100  
Fax: +64 4 894 0662  
 
Email: plantimports@mpi.govt.nz   
i Contents  Page 
 
Submissions  2 
Official Information Act 1982  2 
Purpose  3 
Scope  3 
Part 1: Background  3 
Commodity description  4 
Trade    4 
Current IHS requirements  4 
Part 2: Context  4 
Domestic   4 
International setting  5 
Part 3: Risk Assessment  5 
Source information  5 
Summary of Risk  5 
Part 4: Risk Management  7 
Treatments and efficacy  7 
Part 5: Feasibility & Practicality of Measures  9 
Part 6: Proposed amendments to the current IHS: Seeds for sowing  10 
References  12 
APPENDIX 1  13  
 
Submissions  
The Ministry for Primary Industries (MPI) invites comment s from interested parties on the proposed  changes to the 
format of the Import Health Standard 155.02.05: Seeds for Sowing , and measures for the importation of Pisum  seeds for 
sowing , supported by this Risk Management Proposal .  
 
An IHS “specifies requiremen ts to be met for the effective management of risks associated with importing risk goods, 
including risks arising because importing the goods involves or might involve an incidentally imported new organism” 
(section 22(1) Biosecurity Act 1993).  
 
 
The follo wing points may be of assistance in preparing comments:  
 Wherever possible, comments should be specific to a particular change in IHS requirements or a question 
asked in this document (referencing section numbers or commodity names as applicable).  
 Where p ossible, reasons, data and supporting published references to support comments are requested.  
 The use of examples to illustrate particular points is encouraged.   
 
MPI therefore seeks comment on the proposed changes to the format of the Import Health Standard 155.02.05: Seeds 
for Sowing, and requirements for the importation of Pisum  seeds for sowing. Submitters may also like to comment 
separately on other aspects of the IHS and MPI will respond to these in due course.  
 
MPI encourages respondents to forward comments electronically. Please include the following in your submission:  
 The title of the consultation document in the subject line of your email;  
 Your name and  title (if applicable);  
 Your organisation’s name (if applicable); and  
 Your address.  
 
Send submissions to: plantimports@mpi.govt.nz . 
However, should you wish to forward submissions in writing, please send th em to the following address to arrive by close 
of business on 13th March 2017.  
Plant Imports  
Plants, Food & Environment  
Ministry for Primary Industries  
PO Box 2526  
Wellington 6140  
New Zealand  
 
Submissions received by the closure date will be considered during the development of the final IHS. Submissions 
received after the closure date may be held on file for consideration when the issued IHS is next revised/ reviewed.  
 
Official Information Act 1982  
Please note that your submission is public information  and it is MPI policy to publish submissions and the review of 
submissions on the MPI website. Submissions may also be the subject of requests for information under the Official 
Information Act 1982 (OIA).  
 
The OIA specifies that information is to be made available to requesters unless there are sufficient grounds for 
withholding it, as set out in the OIA. Submitters may wish to indicate grounds for withholding specific information 
contained in their submissi on, such as the information is commercially sensitive or they wish personal information to be 
withheld.  
 
Any decision to withhold information requested under the OIA is reviewable by the Ombudsman.  
 2 
 
3 Purpose  
1. The purpose of this document is to:  
 Clarify the proposed changes to the format of the Import Health Standard 155.02.05: Seeds for Sowing . 
 Summarise the known  biosecurity risks  of the entry of an unwanted organism ( Bruchus pisorum  – pea seed 
weevil ) associated with the importation of Pisum  seeds  from all approved countries . 
 Summarise how the proposed measure can effectively manage risk . 
 Establish the feasibility  and practicality of implement ing the proposed measures . 
 Seek stakeholder feedback on the proposed phytosanitary measures   
Scope  
2. This RMP provi des information and the process used to assess the proposed additional option  to the  phytosanitary  
measures for Pisum  seed  to manage B. pisorum . 
 
3. MPI is reviewing all standards and guidance documents so that the legal requirements are clear and that 
information is consistently presented and easy to understand. As part of this review process MPI has reviewed and 
proposes to migrate all approved seed treatments to the technical standard MPI-STD-ABTRT Approved Biosecurity 
Treatment . Therefore, all MPI approved treatments for the seeds for sowing pathway will be centralized in one 
standard for clarity and ease of use. MPI is seeking feedback on the proposed changes  
 
4. The draft amendment to the IHS is the subject of consultation under section 23(3) of the Biosecurity Act (1993). 
This RMP provides information to support the consultation on the IHS amendment but is not itself the subject of 
consultation.  However, the Ministry for Primary Industries ( MPI) will accept comments and suggestions on the RMP 
in order to improve future IHS consultations.  
 
Part 1: Background  
5. The pea weevil ( Bruchus pisorum  (Linnaeus, 1758) [Coleoptera: Bruchidae] ) is a recently de tected  pest of pea 
(Pisum ) plants  in New Zealand.  
6. Bruchus pisorum  is a regulated pest in Import Health Standard 155.02.05: Seeds for Sowing  and an unwanted 
organism.  Pea weevils have been found in a number of Wairarapa commercial pea growing and storage properties . 
A biosecurity  response has been initiated and there is a two year ban on growing green peas (including sugar snap 
and snow peas) in the region. New Zealand’s pest free area status has been changed as a result of this detection.  
7. The pest is now considered present in New Zealand and subject to official control ( as per  ISPM 8: Determination of 
pest status in an area ).  To support official control : 
 the pest continues to be a regulated quarantine pest for New Zealand  
 the pest is contained and being eradicat ed in the detection area (Wairarapa) through movement controls and 
a ban on host production  
 MPI has imposed  mandatory phytosanitary measures for imported Pisum  seed including a mandatory on -
arrival methyl bromide fumigation directed by the Chief Te chnical Officer (CTO).  
8. B. pisorum  is found in many regions around the world where pea seeds are grown either for sowing or 
consumption . It can spread through infested seeds and h eavy infestation often reduce s the pea seed to shells if 
intervention is not taken (Ministry for Primary Industries, 2016).  The pest complete s its lifecycle after spending the 
latter part of its life in the seed. This pest has only one generation per year (monovoltine).  
9. The adult weevil will emerge from its p upation stage and exit the seed in search of autumn and winter hibernation 
sites. Alternatively, it can remain in the seed and await sowing, emerging from the seed when soil moisture levels 
increase. Heat and vibration may cause the weevil to prematurely e xit the seed.   4 10. Up to 70 percent of the weight loss of infested peas occurs in the two months after harvest because pea weevil 
larvae continue feeding during this period. This weight loss can be significantly reduced by fumigating the crop 
immediately follow ing harvest. Fumigation also ensures seed does not contain live beetles at sowing in the next 
season , if these seed lots are not exposed to pea weevil  after the treatment . 
Commodity description  
11. The following species of pea seed are eligible for import into New Zealand under the Import Health Standard 
155.02.05: Seeds for Sowing : 
 Pisum abyssinicum  
 Pisum elatius  
 Pisum fulvum  
 Pisum sativum  
 
12. Pisum  seeds for sowing can only be imported from of the following approved  countries: Austral ia, Austria, Belgium, 
Canada, Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Luxembourg, the 
Netherlands, Portugal, Spain, Sweden, Taiwan, United Kingdom and United States of America.   
Trade  
13. New Zealand produced 66,500  tonne of peas in 2015, earning approximately $27 million in domestic sales and 
$84.8 million in exports including $51.5 million from frozen peas (Fresh Facts, 2015). It is estimated that 
international demand for processed peas is growing at 12% every five  years. Since pea weevil only feeds on peas, 
revenue earned from pea sales would be directly affected due to reduced yields. The impact of pea production in 
New Zealand on the GDP according to NZIER is estimated to be of $112 million dollars.  
14. One of New Ze aland’s top export destination for peas is Australia, where exports have exceeded $32m. Further 
earnings of this crop w ere $34m from exports to countries in North America and Asia (Fresh Facts, 2015).  
Current IHS requirements  
15. The phytosanitary requirement s listed in the IHS for pea seed weevil and approved fungicide treatment are as 
follow:  
Testing on arrival in New Zealand  
For lots of pea seed over 2kg, a small sample of pea seeds (approx. 100 grams per lot) will be taken and soaked 
with water on arrival to verify that the seed is free from any regulated pests (e.g. pea weevil larvae).  
Guidance  
Small samples of pea seed (< 2kg) for research purposes do not require the soak test but still require dry 
inspection.  
Approved Treatments  
The Pisum  seeds must be treated with one of the following combinations:  
a) Metalaxyl -M at 0.35g a.i per kg of seed, Fludioxonil at 0.1g a.i per kg of seed and Cymoxanil 0.2g a.i per kg of 
seed;  
b) Fosetyl aluminium at 1.53g a.i per kg of seed, Thiram at 0.5g a.i pe r kg of seed and Thiabendazole at 0.37g a.i 
per kg of seed  2 
 
5 Border Procedures  for Pisum seeds (prior to the emergency measures)  
16. Previously, w here insect infested Pisum  seed lot was  detected following the pea seed test , one of the following 
treatments coded as SST1 of the MPI-STD-ABTRT Approved Biosecurity Treatment were  applied to mitigate the 
risk of entry of a regulated pest:  
 
Fumigant  Rate  Temperature  Duration  
Methyl bromide  16 g/m3  
24 g/m3  20 +C  
10-19C 24 hrs  
 
Phosphine  2 g/m3  10 -15C 
16 – 20C 
21 – 25C 
26C + (max 35C)  7 days  
6 days  
5 days  
4 days  
Emergency measures  
17. The current prescribed seven day phosphine treatment rate was been reviewed and may be insufficient to control 
pea weevil based on scientific literature . A CTO Direction under section 30A (4) of the Biosecurity Act was issued 
on 28 July 2016 requiring fumigation of all lots of Pisum seeds arriving into New Zealand for this sowing season. 
MPI specified that the fumigant methyl bromide (MeBr) should be used a t the specifications listed in SST1 of MPI-
STD-ABTRT Approved Biosecurity Treatment (http://www.mpi.govt.nz/document -vault/1555 ) at an MPI -approved 
facility until such a time as MPI reviewed the phosphine treatment . . 
18. The CTO direction was put in place as a provisional  measure until assessment of the most appropriate measure  to 
apply to all Pisum  seed lots imported into New Zealand  was determined . 
Part 2: Context  
Domestic   
19. The New Zealand biosecur ity system is regulated through the Biosecurity Act 1993. Section 22 of the Act describes 
the meaning of an IHS , and requires  that the IHS  specifies requirements to be met for the effective management of 
risks associated with importing risk goods (includin g plants and plant products) into New Zealand.  
20. MPI is the government authority responsible for the effective management of risks associated with the importation 
of risk goods into New Zealand (Part 3, Biosecurity Act 1993).  
21. MPI engages with interested part ies and/or affected New Zealand stakeholders when major amendments are made 
to an  IHS.  
22. MPI follows MPI guidance for decision makers  and procedures for the amendment of an IHS  and consultation.  
 
International setting  
23. Where possible, phytosanitary measures  are aligned with international standards, guidelines, and 
recommendations as per New Zealand’s obligations under Article 3.1 of the WTO Agreement on the Application of 
Sanitary and Phytosanitary Measures (SPS Agreement), WTO 1995  and section 23(4)(c) of t he Biosecurity Act 
1993 .  
24. The SPS Agreement states that phytosanitary measures must not discriminate unfairly between countries or 
between imported or domestically produced goods, and where there is a choice of phytosanitary measures to 
reduce risk to an a cceptable level, WTO members must select the least trade restrictive measure.   6 Part 3: Risk Assessment  
Source information  
25. In the development of this RMP  the following information was used to identify appropriate measures to manage the 
entry and establishme nt of Bruchus pisorum  into New Zealand:  
 Relevant literature and database searches  
 Stakeholders feedback  prior to the development of this RMP  
 MPI pest i nterception records  
Summary of Risk  
26. Bruchus pisorum  is a regulated pest on imported pea seed because : 
 it is present in many seed  exporting countr ies and absent from New Zealand  in the South Island  and under 
official control  in the North Island , and  
 it is likely to be present on the pathway if the risk is unmitigated, or  
 it is known to be associated with the commodity, and  
 its hosts include species which are present in New Zealand, and  
 it is climatically able to establish in New Zealand, and/or  
 it is likely to cause high economic impacts to New Zealand.  
Entry  
27. In this Risk Management Proposal, Bruchus pisorum  is considered to have entered New Zealand if viable larvae or 
adult s are present in the host seeds at a  low infestation level after biosecurity clearance. It is known that infestation 
levels below 0.1% are still capable of deliver ing a founder popu lation of pea weevil , especially in larger 
consignments (D. Voice, pers. comm. 2017).  
28. Bruchus pisorum  is widespread in Europe, Asia, North Africa; North, Central, and South America; and 
southwestern Australia  (Berim, 2008) . Many of the Pisum  seeds that Ne w Zealand imports come from countries 
that have Bruchus pisorum  e.g. Australia . Therefore, there is potential for this regulated pest to enter New Zealand.  
29. In the last three sowing seasons MPI has intercepted nine consignments of peas containing regulated insects , 
including pea weevil . All these seed consignments were send for treatment (fumigation) at the importers choice . 
These reports provide clear evidence that Bruchus pisorum  can be imported in commercial seed production 
systems , and if infested seeds are not detected at the border pests could enter New Zealand unless lots have been 
fumigated.  
Exposure  
30. The exposure assessment is made on the basis that Bruchus pisorum  has already entered New Zealand on seeds 
of Pisum  species .  Bruchus pisorum  is considered to be ‘exposed’ to a host plant if the infested  seed with either a 
larvae or an adult  is sown in close proximity to non -infested host plants . The adult weevil will emerge from its 
pupation stage and exit the seed in search of autumn and winter hibernation sites. Alternatively, it can remain in the 
seed and await sowing, emerging from the seed when soil moisture levels increase. Heat and vibration may cause 
the weevil to prematurely exit the seed. Suitable hosts of B. pisorum  are present in New Zealand and therefore t he 
likelihood of exposure to hosts  in New Zealand is considered high.  
Establishment  and spread  
31. The assessment of establishment of Bruchus pisorum  via Pisum  seeds is made on the basis that the regulated pest 
has been exposed to a new host plant in New Zealand. Therefore, the pest has successfully formed a population in 
New Zealand. The likelihood of Bruchus pisorum  establishing in the New Zealand environment (beyond one 
season) is considered to be high. There is a climate match index with New Zealand of above 0.8 and 0.9 for areas 
of Europe and SW Australia where the pea weevil has expanded its distribution (Phillips et al. 2016).  2 
 
7 32. The adults primarily overwinter within peas in storage, but also in the fie ld and many other sheltered spots. The 
adults can use 2 strategies for survival, exit the seed after feeding and pupation is completed or the adult can stay 
await within the seed  (D. Voice, pers. comm. 2017) . Completion of the entire life cycle is dependen t on the pea 
species ( Pisum sativum ). The pea weevil adult emerges from overwintering sites as temperatures rise and is 
known to fly at least 5 km attracted by flowering pea crops, feeding on flowers (pollen, nectar and sometimes 
petals)  (Armstrong, 2005 ; MPI, 2016 ).Therefore, the likelihood of Bruchus pisorum  spreading in New Zealand 
beyond the initially infected area is considered to be moderate to high if that initial area is either a commercial 
property or a home garden.  
Economic consequences  
33. The potential economic consequences are considered to be high.  Pisum species are susceptible hosts of Bruchus 
pisorum  and different cultivars of Pisum are grown commercially in New Zealand .Therefore there is potential for 
there to be economic consequences if Bruchus pisorum  establish ed in New Zealand.  
34. An infestation caused by this insect can result in  serious economic losses, in part  as a result of loss of seed 
contents consumed by the pest but also  because  pea weevil -damaged seed will have  lower germination rates 
reducing considerably the price per unit (Plantwise webpage, 2017 ).  
35. Yield loss caused by Bruchus pisorum  has been recorded from diverse geographic regions, i n Australia 11 -72% 
(Horne and Bailey, 1991); in Spain 12 -26% (Marzo et al.  1997) and in USA up to 64% (Pesho et al., 1977).  
36. Direct impact of pea weevil establishing in N ew Zealand  (particularly the South Island) would be reduction of yield 
by consumption of the seed by the insect or by increasing the number of seeds split during  threshing. Yield loss 
has been recorded to be as much as  15% during  heavy infestations. During harvest , when the seeds have 13% 
seed moisture content , the pea weevil larvae are normally found to be  immature and have by then only completed 
20 to 30% of the ir feeding. Therefore, at least  70 to 80% of the seed damage has yet to be done  (Armstrong, 
2005) .  
37. Economic impacts will likely continue in subsequent years if the same Pisum  crop is planted in the same field, 
because the new crop will likely become infe sted with the regulated pest  via transmission from the infested  seed in 
the field  and/or adults from overwintered sites . The growing cost s would increase because of the addition al 
application of insecticides to manage the insects in the field and in some ca ses fumigation of seed post -harvest . 
Maximum Residue Limit ( MRL ) levels may also be an issue for some importing countries especially for marrowfat 
peas and the Asian market (D . Voice, 2017 pers. comm.)  
38. Fumigation at this time, straight after harvest, preve nts further seed weight (yield) loss. The re is nil tolerance  in the 
human consumption pea market for live or dead pea weevil . The same level of tolerance is also present in the 
stock feed and seeds for sowing market. The damage caused by the insect in the seeds (circular cavities ) are not 
visually acceptable for human consumption , while it also directly affect seed sprouting percentages  (Armstrong, 
2005) .  
 
Part 4: Risk Management  
Pea soak test  
39. The requirement for pea soak test has been removed from the Import Health Standard 155.02.05: Seeds for 
Sowing  and replaced with a mandatory fumigation under the CTO Direction under section 30A (4) of the Biosecurity 
Act issued on the 28th July 2016 .  
40. It is known that infestation levels within a pea seed lot is not  expected to be uniform in its distribution and that 
infestation levels lower than 0.1% are still capable to deliver a founder population of Bruchus pisorum , especially in 
larger consignments (D. Voice, pers. comm. 2017)   8 41. Pea soak test on arrival, performe d at a higher rate of 3152 seeds (approx. 700g) based on the Poisson 
distribution, as per  ISPM 31: Methodologies for Sampling of Consignments  does provide  95% confidence of 
detecting pea weevil at levels of 0.1% infestation.   
42. This information does not support the re instate ment  of the pea soak test  for Pisum seeds , even at higher sampling 
rates;  as the only phytosanitary measure for Bruchus pisorum  in the Import Health Standard 155.02.05: Seeds for 
Sowing . The pea soak test does not provide a sufficient  level of confidence that a consignment is free of B. 
pisorum . 
Treatment and efficacy  
43. Fumigation is one of the most effective methods to control storage insects, but it is effective only when seeds are 
fumigated at an efficacious dose and time for the temp erature and moisture content.  
44. This control strategy (fumigation) plays a major role in insect pest elimination in stored products.  Fumigants have 
the ability to penetrate the insect body through the spiracles advancing  via the trachea and tracheoles . The toxic 
gas completely fills an area with the purpose to suffocate or poison the pests within  (Shadia, 2011) .  
45. After examining scientific literature it was determined that t he current prescribed seven day phosphine treatment 
rate may be insufficient to contr ol pea weevil. Phosphine treatment of imported infested seed was suspended in 
July 2016.  
46.  To maintain its area freedom Tasmania and parts of New South Wales requires that all Pisum seeds imported into 
the area are phosphine fumigated prior to delivery. The  fumigation period is of 10 days.  
47. At present fumigation is managed by a Chief Technical Officer Direction to MPI inspectors for on -arrival treatment 
of Pisum consignments and it is now proposed that an effective offshore fumigation measure is included in the 
Pisum schedule of the seed for sowing standard.  
48. The important fumigants used to manage pests associated with seed are:  
 methyl bromide  
 aluminium phosphide  
 ethyl formate  
 hydrogen cyanide  
49. Methyl bromide treatment is currently mandatory for  imported Pisum  seed.  However, aluminium phosphide  (also 
known as phosphine ) is considered one of the best fumigants  for seeds as deleterious effect on seed quality  has 
not been reported although  it requires a longer fumigation time . 
Phosphine  
50. It is proposed to reinstate phosphine as a n alternative fumigant option in the technical standard MPI-STD-ABTRT 
Approved Biosecurity Treatment (http://www.mpi.govt.nz/document -vault/1555 ). Fumigation with either Methyl 
Bromide or phosphine is proposed as a mandatory requirement for all Pisum seeds imported into New Zealand. 
Phosphine has a broad spectrum activity against many invertebrates and has been registered for disinfestation of 
stored products and post -harvest application for many years (EPPO, 2012 ). The proposed rate and exposure rate 
for the treatment are as follow:  
Phosphine  2 g/m3 10 -15ºC 
16 – 20ºC 
21 – 25ºC 
26ºC + (max 35C)  14 days 
13 days 
12 days 
11 days  
 The proposed ph osphine schedule provides an appropriate level of protection to manage all life stages of B. 
pisorum  from countries where the pest could infest Pisum  seed for sowing.  The efficacy of the phosphine 
fumigation at 2g/m3 is dependent on insect life stage, trea tment duration  and temperature.  
Life stages  2 
 
9 i. Some life stages of insects are more tolerant to phosphine that others . Eggs and pupae are normally 
more tolerant to the gas and adults succumb more easily  (FAO 1989).  Reynolds et al 1967 described  
that this tolerance could  at least be partially overcome by the development of the different life stages  
that occurred in the insects during the relatively long exposure periods  to the fumigant .  
The author described, based on an experiment with another co mmon grain storage pest, Sitophilus 
granaries  (grain weevil), that  all pre -adult stages, some of which are quite tolerant to the fumigant, may 
reach a susceptible stage of development during long periods of exposure to phosphine (e.g. 10-day 
duration) ,  leading to complete mortality  of the insect  (Reynolds et al. 1967).  
Treatment duration  and Temperature  
ii. The d uration or exposure time is an important factor for efficacy of phosphine against pea weevil . 
iii. A dose of 2g/m3 for 7 days at 10 -15 ºC (the current approved rate in MPI - STD-ABTRT Approved 
Biosecurity Treatment s) is considered insufficient  to kill pea weevil  (Waterford & Winks 1994).  
Waterford & Winks (1994) tested two field strains of B. pisorum  and exposed to phosphine fumigation 
at two constant concentrations of 120µg/L and 240 µg/L and one decaying concentration at 1.5 g/m3 
at 25ºC and 15ºC for periods of 5,10, 14 and 21 days. The best results were achieved when using 1.5 
g/m3 concentration at  both temperatures 25 ºC and 15 ºC. No weevils at the larvae, pupae and adult 
stages were found alive in samples taken from the treatments at 14 and 21 days of exposure to 
phosphine fumigation  (Waterford & Winks 1994).  It is expect ed that most pea weevil a rriving in 
imported seed to be at the pupal or adult stage unless the see d is exported straight after harvesting  
(Dave Voice, pers. comms. 2017).  
iv. The EPPO standard PM 10/21 (1) states that the duration of the fumigation with phosphine must  be 
performed long enough to allow for an almost complete reaction between  the phosphine products with 
moisture present in the commodity  so that little or no non -reacted phosphine products remain. The 
longer the fumigation time when using phosphine is, the more effectiv e the fumigatio n. (EPPO, 2012) . 
v. The work of Williams and Whittle (1994) support the results of Waterford & Winks (1994). The authors 
stated that pea weevil in stored peas can be controlled using a single dose of phosphine applied at the 
rate of 1.5 g/m3 at  a minimum exposure time of 21 days at storage temperature between 20 -30 ºC 
(Williams and Whittle, 1994).  
vi. Relative temperature, humidity, commodity moisture levels and gas -tightness of the building/container 
will influence the effectiveness of the treatmen t (EPPO, 2012) .  
vii. The toxicity of the fumigant will decrease if the temperature of the container fa lls below 10  ºC (FAO, 
1989).  
Packaging  
viii. The permeability of packaging films presents a significant barrier to effective fumigation of imported 
goods with fumigants with PVC and HDPE presenting a greater barrier to effective fumigation than 
LDPE. Multilayer packing in different packaging materials (e.g. a cardboard box with a LDPE internal 
liner and shrink -wrapped with PVC) of some imported products compound s the problem of effective 
gas distribution  (Bycroft et al 2008) . 
ix. Fumigation of Pisum  seed packed within sealed impermeable packages or with plastic liners (such as 
the one tonne bags), plastic wrappings such as cellophane, films, shrink wrap, and papers t hat are 
waxed, laminated, or waterproofed are not readily permeable by methyl bromide and other fumigants 
and must therefore be perforated, removed, or opened (slashed) before fumigation.  
Part 5: Feasibility & Practicality of Measures  
51. The New Zealand pea s eed industr ies would benefit from the measures implemented to mitigate the risk of 
importing infested pea seeds into New Zealand.  
52. The mandatory application of either a phosphine or methyl bromide fumigation treatment as proposed in point 54  is 
operationally feasible and effectively manages the risk posed by B. pisorum  for the following reason s: 
 The treatment s are efficacious.  
i. Methyl bromide and phosphine  are two of the most common chemical fumigants for stored -product 
protection worldwide.   10 ii. Methyl bromide is an effective , broad spectrum  and versatile fumigant. It can penetrate quickly and deeply 
into sorptive materials at normal atmospheric pressure , while dissipate rapidly and make possible the safe 
handling of bulk commodities  (FAO, 1989) . Regardless, a s a signatory to the Montreal Protocol, New 
Zealand is urged to phase out using methyl bromide where possible due to its negative effects on the ozone 
layer even though quarantine use is exempt under the Protocol.  
iii. Phosphine leaves minimal resi dues, and is acceptable to most markets , while being effective against insects 
in most types of grain.  Phosphine has a broad spectrum activity against many invertebrates and has been 
registered for disinfestation of stored products and post -harvest applica tion for many years  (FAO, 1989). 
Evidence from Waterford & Winks (1994), Williams and Whittle (1994) and EPPO, 2012  supports a longer 
exposure time for the application of phosphine as a fumigant to control Bruchus pisorum . 
 The treatment can be applied with  existing methodology  
i. No change is proposed to the dosage (g/m3) and temperature for both fumigants, only to the exposure time  
for phosphine . Phosphine is a slow acting fumigant when in comparison with methyl bromide, not 
responding readily to the increase  in concentration, but exposure time. It is expected that current MPI 
approved treatment facilities will be able to carry out the proposed treatments without further issues.  
ii. Phosphine and methyl bromide have been tested successfully on a range of commodit ies including seeds 
as a post -harvest treatment.  
iii. Maintaining adequate gas tightness, to minimize losses, during the fumigation period is important.  
 The treatment maintains seed quality.  
i. There is considerable evidence that phosphine in insecticidal treatments does not, under normal 
conditions, affect the germination of seeds  (FAO, 1989) . 
ii. Sorption studies of phosphine by Williams & Whittle (1994) showed that field peas do not sorb excessive  
amounts of phosphine, and the desorption  experiments demonstrated that the sorbed phosphine is readily 
desorbed leaving no detectable phosphine residue in the peas.   2 
 
11 Part 6: Proposed amendments to the current IHS: Seeds for sowing  
Measures for Bruchus pi sorum  
53. The proposed requirements for Bruchus pisorum  in the Pisum schedule are : 
 All lots of pea seed imported into New Zealand are required to be fumigated according to the specifications 
listed in MPI -STD-ABTRT Approved Biosecurity Treatment ( http://www.mpi.govt.nz/document -vault/1555 ) 
 The fumigation treatment is required to be completed offshore prior to export, or on arrival in New Zealand.  
 Pre-export fumigation  for each seed lot must be endorse d by the NPPO on the phytosanitary certificate, 
where the fumigant used, dosage, temperature and time must be clearly stated, or if done on arrival in New 
Zealand, must be completed in an MPI -approved facility.  
 
54. The proposed mandatory fumigation options for Bruchus pisorum  listed in MPI -STD-ABTRT Approved Biosecurity 
Treatment ( http://www.mpi.govt.nz/document -vault/1555 ) are: 
 
Fumigant  Rate  Temperature  Duration  
Methyl bromide  16 g/m3 
24 g/ m3 20 +ºC 
10-19ºC 24 hrs  
 
Phosphine  2 g/m3 10 -15ºC 
16 – 20ºC 
21 – 25ºC 
26ºC + (max 35C)  14 days 
13 days 
12 days 
11 days  
 
55. The revised schedule for Pisum seeds can be found in APPENDIX 1.  
56. MPI welcomes comments on the  proposed measures.  
Format change s 
57. The IHS has been revised and all approved treatments listed will migrate into the technical standard  MPI-STD-
ABTRT Approved Biosecurity Treatment  [http://www.mpi.govt.nz/document -vault/1555 ] to improve layout , to 
centralize all approved treatments for seeds for sowing in one standard, to clarify the overall approved treatments, 
and to facilitate reviews and updates .  
58. Stakeholders and NPPOs will be re quired to refer to the treatment  standard to obtain information on the approved 
treatments required for imported seed , prior to phytosanitary certification .  
59. The removal of the approved treatments from the Import Health Standard 155.02.05: Seeds for Sowing  to the 
technical standard  MPI-STD-ABTRT Approved Biosecurity Treatment  [http://www.mpi.govt.nz/document -
vault/1555 ] will facilitate  periodic reviews  of fungicide s and other treatments  to ensure the best practice options are 
used to manage pests. Listing the treatments in  MPI-STD-ABTRT  allows the treatments to be updated more quickly 
than through the IHS process.  
60. The technical standard MPI-STD-ABTRT can be updated following  targeted con sultation with the industry and a 
decision document signed by the Chief Technical Officer. Since the last IHS review of chemicals , a number of new, 
more efficacious formulations  have been released into the market, while other s have been removed  from the 
market , although they are still listed in the IHS .  
61. MPI welcomes comments on the proposed changes .  12 References  
1. Armstrong, E. (2005). Managing Pea Weevil. Retrieved January 19, 2017, from 
http://www.dpi.nsw.gov.au/__data/assets/pdf_file/0020/157034/pulse -point -04.pdf  
 
2. Berim, M. N. ( All Russian Institute of Plant Protection , St. Peterburg -Pushkin , Russia). 2008. Bruchus pisorum. 
In A. N. Afonin,  S. L. Greene, N.  I. Dzyubenko, A.  N. Frolov (eds.). 2008. Interactive Agricultural Ecological 
Atlas of Russia and Neighboring Countries. Economic Plants and their Diseases, Pests and Weeds [Online]. 
Availa ble at : http://www.agroatlas.ru/en/content/pests/Bruchus_pisorum/  
 
3. Biosecurity Act 1993. http://www.legislation.govt.nz/act/public/1993/0095/latest/whole.html#DLM314623   
 
4. Bycroft et al. Methyl bromide penetration of plastics. MAF Operational Research 2008.  
 
5. FAO 1984. Manual of fumigation for insect control. EJ Bond, FAO Plant Producti on and Protection Paper 54.  
 
6. Fresh Facts. (2015, June 30). Retrieved January 19, 2017, from http://www.freshfacts.co.nz/files/freshfacts -
2015.pdf  
 
7. European and Mediterranean Plant Protection Organization (EPPO) (2012), Phosphine fumigation of stored 
products to control stored product insects in general. EPPO Bull, 42: 498 –500. doi:10.1111/epp.2622  
 
8. Gamiel et al. Permeability of Plastic Films to Methy l Bromide: A Comparative Laboratory Study.  Pestic. Sci. 
1998, 53, 141 -148. 
 
9. Marzo, F., Aguirre, A., Castiella, M. V. and Alonso, R. 1997. Fertilization effects of phosphorus and sulfur on 
chemical composition of seeds of Pisum sativum L. and relative infes tation by Bruchus pisorum. L. J. Agric. 
Food. Chem. 45, 1829 —1833.  
10. Ministry for Primary Industries. 2016. Look out for Pea Weevil, viewed 19 January 2017, 
http://www .hortnz.co.nz/assets/Uploads/Pea -weevil -fact-sheet -20.5.2016.pdf  
 
11. MPI 2017. Approved Biosecurity Treatments, MPI -STD-ABTRT  https://mpi.govt.nz/document -vault/1555  
 
12. MPI 155.02.05 Import Health Standard (IHS): Seeds for sowing  http://www.mpi.govt.nz/document -vault/1151  
 
13. Official Information Act 1982. http://www.legislation.govt.nz/default.aspx  
 
14. Pea weevil (Bruchus pisorum). (n.d.). Retrieved January 18, 2017, from 
http://www.plantwise.org/KnowledgeBank/Datasheet.aspx?dsid=99 07 
 
15. Pesho, G. R., Muehlbauer, F. J. and Harberts, W. H. 1977. Resistance of pea introductions to the pea weevil. J. 
Econ. Entomol. 70, 30 —33. 
 
16. Phillips, C. B.; Kean, J. K.; Vink , C. J. (In prep) A climate match analysis between New Zealand and the rest of 
the world. http://www.arcgis.com/home/webmap/viewer.html?webmap=e7e1c77123d c4b8fb336c1a825207f1f  
 
17. Reynolds, E.M., Robinson, J.M. & Howells, C. The effect on Sitophilus 1967 granarius (L.) of exposure to low 
concentrations of phopshine. J. Stored Prod. Res., 2 : 177 - 186.  
 
18. Shadia E. Abd El -Aziz, 2011. Control Strategies of Store d Product Pests.  Journal of Entomology, 8: 101 -122. 
 
19. Waterford, C. J. and Winks, R. G. (1994) Response of the pea weevil Bruchus pisorum (L.) to phosphine. In 
Highley, E.; Wright, E.J.; Banks, H.J.; Champ, B.R. (Eds.), Stored Product Protection, Proceedings of the 6th 
International Working Conference on Stored -Product Protection, 17 -23 April 1994, Canberra, Australia. CAB 
International, Wallingford, United Kingdom. (ISBN 0851989322)   
 
20. Williams, P. and Whittle, C. P. (1994) Phosphine fumigation of stored field peas for insect control. In Highley, 
E.; Wright, E.J.; Banks, H.J.; Champ, B.R. (Eds.), Stored Product Protection, Proceedings of the 6th 2 
 
13 International Working Conference on Stored -Product Protection, 17 -23 April 1994, Canberra, Australia. CAB  
International, Wallingford, United Kingdom. (ISBN 0851989322)  
 
21. WTO 1995. Agreement on Sanitary and Phytosanitary Measures . Geneva: World Trade Organisation.  
   14 APPENDIX 1 - Proposed schedule for Pisum seeds for sowing  
2.60 Pisum  
 
The following proposed requirements only apply to species in the Plant Biosecurity Index listed under Import 
Specifications for Seed - see 155.02.05 under Pisum .  
 
Countries: Australia, Austria, Belgium, Canada, Czech Republic, Denmark, Finland, France, Germany, Greece, 
Hungary,  Ireland, Italy, Luxembourg, the Netherlands, Portugal, Spain, Sweden, Taiwan, United Kingdom and 
United States of America.  
 
Quarantine pests: Refer to “Pest List for Pisum ”.  
 
Import permit: Not Required  
 
2.60.1 Phytosanitary certificate - Additional de clarations  
(1) In addition to the certifying statement in Part 1.5.2 of this import health standard, if satisfied that the pre -
shipment activities have been undertaken, the exporting country NPPO must confirm this by recording the 
treatments applied in th e disinfestation and/or disinfection treatment section, and by providing the following 
additional declarations to the phytosanitary certificate:  
 
a) “The Pisum seeds have been:  
i) sourced from a ‘pest free area’ free from Broad bean mottle virus, Broad b ean stain virus, Clover yellow mosaic 
virus, Pea early -browning virus, Pea enation mosaic virus, Peanut mottle virus, Peanut stunt virus .  
 
OR  
ii) sourced from a ‘pest free place of production’ free from Broad bean mottle virus, Broad bean stain virus, Cl over 
yellow mosaic virus, Pea early -browning virus, Pea enation mosaic virus, Peanut mottle virus, Peanut stunt virus ”;  
 
AND  
b) “The Pisum seeds have been:  
i) sourced from a ‘pest free area’ free from Cladosporium cladosporioides f. sp. pisicola”;  
 
OR  
ii) “treated with one of the fungicide combinations in MPI approved treatments (refer to MPI-STD-ABTRT Approved 
Biosecurity Treatment )”.  
 
2.60.2 Fumigation   
(1) All lots of pea seed imported into New Zealand are required to be fumigated according to the specifications 
listed in MPI-STD-ABTRT Approved Biosecurity Treatment  (http://www.mpi.govt.nz/document -vault/1555 ) 
(2) The fumigation treatment  is required to be completed offshore prior to export, or on arrival in New Zealand.  
(3) Pre -export treatment  for each seed lot must be endorsed by the NPPO on the phytosanitary certificate, where 
the fumigant  used , dosage, temperature and time must be cl early stated, or if done on arrival in New Zealand, must 
be completed by an MPI -approved facility.  
 
2.60.3 Approved Fungicide Treatments  
(1) All lots of pea seed imported into New Zealand are required to be treated  according to the specifications listed 
in MPI-STD-ABTRT Approved Biosecurity Treatment  (http://www.mpi.govt.nz/document -vault/1555 ) 
(2) The treatment  is required to be completed offshore prior to export, or on arrival in New Zealand.  2 
 
15 (3) Pre -export treatment  for each seed lot must be endorsed by the NPPO on the phytosanitary certificate, where 
the fungicide  used  and application  rate must be clearly stated, or if done on arrival in New Zealand, must be 
completed by an MPI -approved facili ty.