United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Interstate Movement of Leaves of Allium spp. from Hawaii

Into the Continental United States

Risk Management Document

October 30, 2013

Plant Health Programs (PHP)

Regulations, Permits and Manuals (RPM)

Contact Person: David Lamb
3

Introduction

The United States Department of Agriculture’s Animal and Plant Health Inspection Service 

(USDA-APHIS) has received a request from the Hawaii Department of Agriculture (HDOA) to 

allow interstate movement of commercially produced leaves of Allium spp. (Liliaceae) for 

consumption into the continental United States. Since the interstate movement of leaves of 

Allium spp. from Hawaii is currently not authorized by United States regulations 7CFR § 318.13, 

a pathway-initiated pest risk assessment (PRA) was prepared by APHIS’s Plant Protection and 

Quarantine (PPQ) to identify the unmitigated pest risks associated with the interstate movement 

of leaves of Allium spp. from Hawaii (USDA, 2013). 

The risk assessment identified the following quarantine pests as having a high unmitigated risk 

potential:

Scirtothrips dorsalis Hood (Thysanoptera: Thripidae)

The risk assessment identified the following quarantine pests as having a medium unmitigated 

risk potential:

Acrolepiopsis sapporensis (Matsumura) (Lepidoptera: Acrolepiidae)

Spodoptera litura (Fabricius) (Lepidoptera: Noctuidae)

The PRA identified these pests as candidates for risk management and rated them Medium or 

High for probability of introduction. Low rated pests normally only require standard port of 

entry inspection as a mitigation. Pests rated Medium and High for probability of introduction 

that have been identified in the PRA as candidates for risk management may require mitigations 

beyond standard port of entry inspection based on the biology of the pests. This document 

outlines the phytosanitary measures that APHIS will require if the proposed interstate movement

of leaves of Allium spp. from Hawaii is approved. 

The proposed movement of fresh leaves of Allium spp. from Hawaii, if approved, would be 

regulated by amendment to existing fruit and vegetable domestic movement regulations (7 CFR 

§318.13). Pest risk management is the process of identifying ways to react to a perceived risk, 

evaluating the efficacy of these actions, and identifying the most appropriate options (IPPC, 

2004). This document outlines phytosanitary measures and provides evidence of their efficacy in

preventing the introduction of quarantine pests. 

Risk Management Measures

All measures listed below must be included for fresh leaves of Allium spp. shipped to the 

mainland:

1. Commercial Consignments only. Only commercially produced consignments of leaves of 

Allium spp. may be shipped interstate to the continental United States.
4

2. Inspection. A biometric sample of leaves of Allium spp. must be inspected by APHIS 

following any post-harvest processing. A biometric sample will be inspected for quarantine 

pests. If quarantine pests are found, the entire consignment will be prohibited from 

movement into the continental United States unless it is treated with an approved quarantine 

treatment monitored by APHIS. 

Efficacy of Risk Management Measures

Requiring that Allium sp. leaves be moved interstate from Hawaii only as commercial 

consignments will mean that standard commercial practices will remove most pests from the 

pathway. Standard commercial practices often include cultural, chemical, or mechanical means 

(e.g., field sanitation, pre-harvest application of pesticides, resistant cultivars) to eliminate pests 

from fields or prevent pest infestation. Sanitation, such as removing and discarding infested or 

damaged produce and pesticide applications, are essential components of good agricultural 

practices, and are mainstays of commercial production (e.g., Kirk et al., 2001). Commercial 

consignments must be marketable to the consumer to be profitable and that means that visible 

pests infestations are routinely culled during harvest and packing.

Acrolepiopsis sapporensis has not been intercepted on any commodity, including Allium sp., 

from Hawaii. However APHIS has 16 records of Acrolepiopsis assectella interceptions on 

Allium sp., all in passenger baggage from Hawaii. The PRA indicated that Acrolepiopsis 

assectella is not known to be present in Hawaii (USDA, 2013). “While we found many 

references indicating that A. assectella (Zeller) (Lepidoptera: Acrolepiidae) is established in 

Hawaii (e.g., Fullaway and Krauss, 1945: Mau and Lee, 1995), these are misidentifications of A. 

sapporensis (Gaedike, 1997). Acrolepiopsis assectella is not known to be present in Hawaii and 

therefore we did not list it below.” The 16 APHIS interception records of Acrolepiopsis 

assectella are presumed to be Acrolepiopsis sapporensis. Acrolepiopsis sapporensis is a leaf 

mining Lepidoptera with a host range restricted to Allium species. The larvae feed within the 

interior of the Allium leaf leaving a conspicuously visible mine. 

Since 1984, Scirtothrips dorsalis and Spodoptera litura have never been intercepted in Allium sp. 

from Hawaii. Scirtothrips dorsalis is a polyphagous species with many host plants. APHIS/CBP 

intercepts this pest occasionally on cut flowers, herbs, peppers and other commodities, in 29 

years there have been 57 interceptions in commercial cargo. It has been intercepted twice from 

Hawaii, once on Basil and once on Oncidium orchids. Inspections for thrips usually involve 

shaking or striking the commodity against a hard surface so that thrips are dislodged. These 

inspections are effective at finding thrips (DAFF, 2013). Spodoptera litura is a Noctuid moth 

with a wide range of host plants. The eggs are laid in a mass on the host plant. The larvae cause 

large amounts of damage to the host; by the time the larvae mature to 5th instar they are very

large and conspicuous. The egg masses and the larval damage are readily visible on inspection. 

Spodoptera litura has not been intercepted by APHIS on Allium sp. from Hawaii.

Inspections are effective in detecting thrips, leaf miners and caterpillars on Allium sp. leaves. 

Inspection ensures that various stages of any pest that are present will be detected; this is 
5

particularly effective against those pests whose later life stages are larger and more readily 

detected (Cavey, 2003; Borror et al., 1989).

Summary

Requiring that Allium sp. be moved interstate only as commercial consignments will mean that 

commercial practices will remove most pests from the pathway. Inspections are effective against 

thrips, leaf miners and caterpillars on Allium sp. APHIS finds that the mitigations described here 

will result in the effective removal of the pests of concern from the pathway identified by the 

pest risk analysis for the interstate movement of fresh Allium sp. leaves from Hawaii into the 

continental United States. 

Author

Walter Gould, Senior Risk Manager

APHIS-PPQ

References

AQAS. 2013. Agricultural Quarantine Activity System Pest Interception Database. USDAAPHIS-PPQ. Last accessed Oct. 2013.

Borror, D. J., Triplehorn, C. A. and N. F. Johnson. 1989. Introduction to the study of insects, 6 

ed. Harcourt Brace Jovanovich College Publishers, TX.

Cavey, J.F. 2003. Managing introduction of invasive plant pests in the United States. pages 350 

– 361 in Invasive species. Vectors and management strategies. G.M. Ruiz and J.T. Carlton 

eds. Island Press. Wash. D.C.

DAFF. 2013. Queensland Government, Dept. of Agriculture, Fisheries and Forestry (DAFF). 

Inspection of fruits and vegetables for melon thrips. State of Queensland (Australia), 

Dept. of Agriculture, Fisheries and Forestry. ICA-WI-03. 14pp.

http://domesticquarantine.org.au/wordpress/wp-content/uploads/178-ica-wi-03-20_07-01-13.pdf

Fullaway, D. T., and N. L. H. Krauss. 1945. Common Insects of Hawaii. Tongg Publishing 

Company, Honolulu, Hawaii. 228 pp.

Gaedike, R. (1997) Acrolepiidae. Fascicle 55 in Lepidopterorum Catalogus. Edited by J. 

Heppner. Association for Tropical Lepidoptera, Scientific Publishers, Gainesville, FL.

Kirk, K., Bessin, R., Hartman, J., O’Leary, J. and Strang, J. 2001. Total quality assurance: apple 

production: best management practices. Kentucky Coop. Ext. Serv. ID-137.
6

IPPC. 2004. Pest risk analysis for quarantine pests, including analysis of environmental risks 

and living modified organisms. International Standards for Phytosanitary Measures No. 

11. Rome: Secretariat of the International Plant Protection Convention, United Nations 

Food and Agriculture Organization.

Mau, R. F. L., and S. G. Lee. 1995. Crop Knowledge Master: Acrolepiopsis assectella. 

University of Hawaii, Honolulu, Hawaii. Last accessed October 29, 2013, 

http://www.extento.hawaii.edu/kbase/crop/type/acrolepi.htm.

USDA. 2000. Guidelines for Pathway-Initiated Pest Risk Assessments, Version 5.02. USDAAPHIS, PPQ; http://oars.aphis.usda.gov/ppq/pra/commodity/cpraguide.pdf

USDA. 2013. Importation of Leaves of Allium spp. from Hawaii into the Continental United 

States. A Qualitative, Pathway-Initiated Pest Risk Assessment USDA-APHIS-PPQ 

Center for Plant Health Science and Technology - Plant Epidemiology and Risk Analysis 

Laboratory. 39 pp.