United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine



## Commodity Import Evaluation Document (CIED)



## Expansion of areas allowed to i mport Fresh Commercial

Avocado Fruit (

Persea americana Mill. var. ‘Hass’) from

Mexico into the Continental United States

, Hawaii, and

Puerto Rico

Count r y of Origin : Mexico 

### Date of Request : 10/20 1 0

Commodity c ommon name and Scientific name : avocado ( Persea americana

Mill. var. ‘Hass’)

________________________________________________________________________

Introduction:

Hass avocados have been approved for entry into the United States from Mexico under (7 CFR §

319.56

- 30 ) since 1997, alth ough importation was initially restricted to part of the United States

to limit pest risk (USDA, 1996)

. A supplemental Pest Risk Assessment (PRA) for Mexican

‘Hass’ avocados was prepared by APHIS to support the subsequent expansion of market access

to all 50 states (USDA, 2004). The CFR was also amended in 2009 to remove requirements for

trapping for Anastrepha species fruit flies based on scientific publications and operational

evidence that showed Anastrepha spp. fruit flies would not follow the p athway of Hass avocados

from Mexico (USDA, 2009)

. T he requirement to safeguard harvested avocado fruit from fruit

flies was retained. The current market access for ‘Hass’ avocadoes from Mexico is ONLY from

the Mexican state of Michoacan (municipalities: Acuitizio, Apatzingan, Ario, Cotija de la Paz,

Erongaricuaro, Hidalgo, Irimbo, Los Reyes, Madero, Nuevo Parangaricutiro, Paracuaro, Periban,

Salvador Escalante, Tacambaro, Tangamandapio, Tancitaro, Taretan, Tingambato, Tinguindin,

Tocumbo, Turicato, and Tu xpan) ( 7 CFR § 319.56

- 30 , 2011 ; APHIS, 2013 ). APHIS has

prepared a revised PRA for Mexico avocadoes in response to a request from Mexico to expand2

the current export region to allow entry of Hass avocados from all of Mexico into the continental

United States, Hawaii, and Puerto Rico (USDA, 2014).

The current systems approach used for exporti ng Hass avocados from Michoacan, Mexico to the

United States specifically mitigates the following avocado pests : Conotrachelu s aguacatae

, C.

perseae

, Copturus aguacatae

, Heilipus lauri ( Coleoptera: Curculionidae )

, and Stenoma catenifer

( Lepidoptera: Oecophoridae ) ( 7 CFR § 319.56

- 30, 201 4 ).

The 2004 PRA was updated by APHIS to determine if any significant avocado pests are present

in areas of Mexico outside of Michoacan (USDA, 2004; 2014)

. The PRA reported the following

pests of quarantine concern:

Type Pest Classification Pest Scientific Name Actionable pest for:

CONUS HI PR

Arthropods Coleoptera: Curculionidae Conotrachelus aguacatae   

Conotrachelus perseae   

Conotrachelus serpentinus  

Copturus aguacatae   

Heilipus lauri   

Hemiptera: Coccidae Philephedra lutea 

Hemiptera: Pseudococcidae Maconellicoccus hirsutus   

Paracoccus marginatus   

Lepidoptera: Oecophoridae Stenoma catenifer   

Lepidoptera: Tortricidae Cryptaspasma perseana   

Thysanoptera:

Phlaeothripidae Pseudophilothrips perseae   

Thysanoptera: Thripidae Scirtothrips aceri  

Scirtothrips perseae 

Thrips palmi   

Fungi a nd

Chromistans Phytophthora citricola 

Phytophthora heveae  

Sphaceloma perseae 

Viroids Avocado sunblotch viroid  

The PRA (USDA, 2014) considered the current systems approach mitigations in the CFR as a

baseline which addresses the risk for Conotrachelus aguacatae

, C. perseae

, Copturus aguacatae

, Heilipus lauri ( Coleoptera: Curculionidae )

, and Stenoma catenifer ( Lepidoptera: Oecophoridae )

. The PRA (USDA, 2014) concluded that expanding the exporting region from Michoacan to all

of Mexico is not likely to alter the effectiveness of the mitigations and t hat given similar biology

and impacts to the pests currently listed in the CFR 319

- 56.30

, they therefore gave

Conotrachelus serpentinus ( Coleoptera: Curculionidae ) and Cryptaspasma perseana

( Lepidoptera: Tortricidae ) Negligible risk ratings. T he current mitigations described in the CFR3

for Hass avocados from Michoacan will mitigate risk from Conotrachelus serpentinus

( Coleoptera: Curculionidae ) and Cryptaspasma perseana ( Lepidoptera: Tortricidae ) that may be

present on Hass avocados from other parts of Mexico as well as Conotrachelus serpentinus (for

Hawaii and Puerto Rico)

, Cryptaspasma perse ana (for Continental United States, Hawaii, and

Puerto Rico)

, Phytophthora citricola (for Puerto Rico)

, and Phytophthora hevea (for Hawaii and

Puerto Rico)

, included in the systems approach for inspection, cutting and culling

. The PRA

rated the fungal pla nt pathogens Phytophthora citricola and P. heveae (Oomycetes: Pythiales) as

Negligible because infected fruits are highly likely to be removed from the pathway by the post

harvest practices of in spection, cutting, and culling.

The PRA determined that o f several pests selected for further analysis

, the following were are

not candidates for risk management, because no endangered area exists within the continental

United States, Hawaii, and Puerto Rico: Paracoccus marginatus (Hemiptera: Pseudococcidae),

Phil ephedra lutea (Hemiptera: Coccidae), and Thrips palmi (Thysanoptera: Thripidae).

The 2014 PRA determined that the following pests are candidates for risk management, because

they met the threshold to likely cause unacceptable consequences of introduction

, and they

received an overall likelihood of introduction risk rating above Negligible:

Arthropods

Maconellicoccus hirsutus (Green) Hemiptera: Pseudococcidae Medium

Pseudophilothrips perseae (Watson) Thysanoptera: Phlaeothripidae Medium

Scirtothrips aceri (Moulton) Thysanoptera: Thripidae Low

Scirtothrips perseae Nakahara Thysanoptera: Thripidae Low

Fungi

Sphaceloma perseae Jenkins Ascomycetes: Myriangiales Low

Viroid

Avocado sunblotch viroid Low



### Pest Interceptions:

APHIS has intercepted actionable pests from commercial consigments of avocados from Mexico

only three times since 1997 (AQAS, 2014) : Phyllachora gratissima Rehm (Phyllachoraceae)

– two interceptions in 2002

, Apis mellifera (Linnaeus) (Apidae)

– one interception (2013) . The

PRA (USDA, 2014) listed Phyllachora gratissima as present only on leaves and not on the

pathway of the avocado fruit. Honey bees ( Apis mellifera ) are considered actionable by APHIS

unless they enter under permit that provides for freedom of honey bees pathogens and parasites.

They would not be normally associated with avocado fruit, but might ‘hitchhike’ with

consigments

.

None of the pests ( Tephr itid fruit flies , fruit or stem weevils

, the fruit boring moth , mealybugs,

thrips or plant pathogens) listed in the Mexico avocado PRA s (USDA, 199 6 ; 2004 ; 2014 ) as

following the pathway of fresh avocadoes have ever been intercepted in commercial consigment s

of avocados since Mexico gained market access in 1997 (AQAS, 2014)

.4

Current Mitigations :

APHIS requires that certain conditions be maintained to minimize risks associated with the

importation of avocadoes from Mexico into the continental United States. These conditions are

listed in § 319.56

- 30 and include the following :

§ 319.56

– 30 Hass Avocados from Michoacan, Mexico

. Fresh Hass variety avocados ( Persea americana ) may be imported from Michoacan, Mexico,

into the United States in accordance with the requirements of § 319.56

– 3 of this subpart, and

only under the following conditions:

(a) Shipping restrictions.

(1) The avocados may be imported in commercial consignments only;

(2) Shipping restrictions. The avocados may be imported into and distributed in all States and in

Puerto Rico, but not in any U.S. Territory.

(b) Trust fund agreement. The avocados may be imported only if the Mexican avocado industry

association representing Mexican avocado growers, packers, and exporters has e ntered into

a trust fund agreement with APHIS for that shipping season in accordance with § 319.56

– 6.

(c) Safeguards in Mexico. The avocados must have been grown in the Mexican State of

Michoacan in an orchard located in a municipality that meets the requi rements of paragraph

(c)(1) of this section. The orchard in which the avocados are grown must meet the requirements

of paragraph (c)(2) of this section. The avocados must be packed for export to the United States

in a packinghouse that meets the requiremen ts of paragraph (c)(3) of this section. The Mexican

national plant protection organization (NPPO) must provide an annual work plan to APHIS

that details the activities that the Mexican NPPO will, subject to APHIS’ approval of the work

p lan, carry out to meet the requirements of this section; APHIS will be directly involved with

the Mexican NPPO in the monitoring and supervision of those activities. The personnel

conducting the trapping and pest surveys must be hired, trained, and supervised by the Mexican

NPPO or by the Michoacan State delegate of the Mexican NPPO.

(1) Municipality requirements.

(i) The municipality must be listed as an approved municipality in the bilateral work plan

provided to APHIS by the Mexican NPPO.

(ii) The municipality must be surveyed at least semiannually (once during the wet season and

once during the dry season) and found to be free from the large avocado seed weevil Heilipus

lauri , the avocado seed moth Stenoma catenifer , and the small avocado seed weevils

Conotrachelus agu acatae and C. perseae

. (iii) Trapping must be conducted in the municipality for Mediterranean fruit fly (Medfly)

(Ceratitis capitata) at the rate of 1 trap per 1 to 4 square miles. Any findings of Medfly must be

reported to APHIS.

(2) Orchard and grower requirements.

The orchard and the grower must be registered with the Mexican NPPO’s avocado export

program and must be listed as an approved orchard or an approved grower in the annual work

plan provided to APHIS by the Mexican NPPO. The operations of the orchard must meet the

following conditions:

(i) The orchard and all contiguous orchards and properties must be surveyed semiannually and

found to be free from the avocado stem weevil Copturus aguacatae.5

(ii) Avocado fruit that has fallen from the trees mus t be removed from the orchard at least once

every 7 days and may not be included in field boxes of fruit to be packed for export.

(iii) Dead branches on avocado trees in the orchard must be pruned and removed from the

orchard.

(iv) Harvested avocados must be placed in field boxes or containers of field boxes that are

marked to show the official registration number of the orchard. The avocados must be moved

from the orchard to the packinghouse within 3 hours of harvest or they must be protected from

fruit fl y infestation until moved.

(v) The avocados must be protected from fruit fly infestation during their movement from the

orchard to the packinghouse and must be accompanied by a field record indicating that the

avocados originated from a certified orchard.

(3) Packinghouse requirements

. The packinghouse must be registered with the Mexican NPPO’s avocado export program and

must be listed as an approved packinghouse in the annual work plan provided to APHIS by the

Mexican NPPO. The operations of the packinghouse must meet the following conditions:

(i) During the time the packinghouse is used to prepare avocados for export to the United States,

the packinghouse may accept fruit only from orchards certified by the Mexican NPPO for

participation in the a vocado export program.

(ii) All openings to the outside must be covered by screening with openings of not more than 1.6

mm or by some other barrier that prevents insects from entering the packinghouse.

(iii) The packinghouse must have double doors at the e ntrance to the facility and at the interior

entrance to the area where the avocados are packed.

(iv) Prior to the culling process, a biometric sample, at a rate determined by APHIS, of avocados

per consignment must be selected, cut, and inspected by the Mexican NPPO or its approved

designee and found free from pests.

(v) The identity of the avocados must be maintained from field boxes or containers to the

containers in which they will be shipped so the avocados can be traced back to the orchard in

which they were grown if pests are found at the packinghouse or the port of first arrival in the

United States.

(vi) Prior to being packed for shipping, each avocado fruit must be cleaned of all stems, leaves,

and other portions of plants and labeled with a sticker that bears the official registration

number of the packinghouse.

(vii) The avocados must be packed in clean, new boxes or bulk shipping bins, or in clean plastic

reusable crates. The boxes, bins, or crates must be clearly marked with the identity of the grower,

packinghouse, and exporter. The boxes, bins, or crates must be covered with a lid, insect

- proof

mesh, or other material to protect the avocados from fruit

- fly infestation prior to leaving the

packinghouse. Those safeguards must be intact at the time the consignment arrives in the United

States.

(viii) The packed avocados must be placed in a refrigerated truck or refrigerated container and

remain in that truck or container while in transit through Mexico to the port of export for

consignments shipped by air or sea or the port of first arrival in the United States for

consignments shipped by land. Prior to leaving the packinghouse, the truck or container must be

secured by the Mexican NPPO with a seal that will be broken when the truck or conta iner is

opened. The seal may be broken and a new seal applied by the Mexican NPPO if the truck

or container stops at another approved packinghouse for additional avocados meeting the

requirements of this section to be placed in the truck or container. The seal on the refrigerated6

truck or refrigerated container must be intact at the time the truck or container reaches the port of

export in Mexico or the port of first arrival in the United States.

(ix) Any avocados that have not been packed or loaded into a refrigerated truck or refrigerated

container by the end of the workday must be kept in the screened packing area.

(d) Certification. All consignments of avocados must be accompanied by a phytosanitary

certificate issued by the Mexican NPPO with an additio nal declaration certifying that the

conditions specified in this section have been met.

(e) Pest detection. If any of the avocado pests Heilipus lauri

, Conotrachelus aguacatae

, C.

perseae

, Copturus aguacatae , or Stenoma catenifer are detected during the se miannual pest

surveys in a packinghouse, certified orchard or areas outside of certified orchards, or other

monitoring or inspection activity in the municipality, the Mexican NPPO must immediately

initiate an investigation and take measures to isolate and eradicate the pests. The Mexican NPPO

must also provide APHIS with information regarding the circumstances of the infestation and

the pest risk mitigation measures taken. Orchards affected by the pest detection will lose their

export certification immediately, and avocado exports from that orchard will be suspended

until APHIS and the Mexican NPPO agree that the pest eradication measures taken have been

effective.

(f) Inspection. The avocados are subject to inspection by an inspector at the port of first arrival,

at any stops in the United States en route to an approved State, and upon arrival at the terminal

market in the approved States. At the port of first arrival, an inspector will sample and cut

avocados from each consignment to detect pest in festation.

(g) Repackaging. If any avocados are removed from their original shipping boxes, crates, or bulk

shipping bins and repackaged, the stickers required by paragraph (c)(3)(vi) of this section may

not be removed or obscured and the new packaging mus t be clearly marked with all the

information required by paragraph (c)(3)(vii) of this section.

Addition of new pests to systems approach and changes to the CFR :

The systems approach as it is currently written in 7 CFR § 319.56

- 30 is changing to allow

addition of new export areas in Mexico that meet the requirements of the systems approach

.

It is pro posed to change the section title and first sentence in the CFR § 319.56

– 30 removing the

word Michoacan to allow Hass avocadoes from all growing areas in Mexico to be exported to

the continental United States , Hawaii and Puerto Rico if the areas meet the conditions of the

systems approach for Mexico avocadoes

.

The quarantine pest s list ed in the CFR will be removed, the pest list will be maintained in the bi

lateral work plan. The p ests Crypta s pasma perseana and Conotrachelu s serpentinus must be

added to the lists of pests surveyed for and the consequences of pest detections in the bilateral

workplan.

(ii) The municipality must be surveyed at least semiannually (once during the wet season

and once during the dry season) and found to be free from avocado pests listed in the

bilateral workplan

. (i) The orchard and all contiguous orchards and properties must be surveyed7

semiannually and found to be free from avocado pests listed the bilateral workplan

.

(e) Pest detection. If any of the avocado pests listed in the bilateral workplan are detected

during the semiannual pest surveys in a packinghouse, certified orchard or areas outside

of certified orchards

, or other monitoring or inspection activity in the municipality, the

Mexican NPPO must immediately initiate an investigation and take measures to isolate

and eradicate the pests.

The Inspection (f) clause in the CFR will be amended to remove the requirement for cutting at

the port of first arrival to allow for operational flexibility. This is justified based on the lack of

interceptions of program pests from 1997 to 2014 in fruit sampled in Mexico and at port of entry.

Avocadoes will still be sam pled for pests in the field and at the packinghouse in Mexico.

(f) Inspection. The avocados are subject to inspection by an inspector at the port of first

arrival, at any stops in the United States en route to an approved State, and upon arrival at

the te rminal market in the approved States. At the port of first arrival, an inspector may

sample and cut avocados from each consignment to detect pest infestation.

All other conditions of the mitigations in § 319.56

– 30 must be met for avocadoes from Mexico

to be exported to the United States

, Hawaii and Puerto Rico

.

The following pests we re rated either low or medium and therefore require only the port of entry

inspection to prevent them from following the pathway of fresh avocadoes from Mexico.

Maconellicoccus hirsutus (Green) Hemiptera: Pseudococcidae Medium

Pseudophilothrips perseae (Watson) Thysanoptera: Phlaeothripidae Medium

Scirtothrips aceri (Moulton) Thysanoptera: Thripidae Low

Scirtothrips perseae Nakahara Thysanoptera: Thripidae Low

Fungi

Sphaceloma perseae Jenkins Ascomycetes: Myriangiales Low

Viroid

Avocado sunblotch viroid Low

Other mitigations that will remove these pests from the pathway include packinghouse culling,

commercial consignments and NPPO inspection. Thrips and mealybugs are surface pests that

can be culled or detected by inspection. Commercially produced fruit ar e grown and packed to

meet quality levels that allow them to be marketed for sale. Commercially produced fruit are

less likely than other fruit to have pests or other phytosanitary issues. Interceptions of pests in

commercial fruit versus passenger bagga ge indicate that non

- commercially produced fruit has a

much higher risk of carrying pests (AQAS, 201 4 ). Inspection is considered effective at finding

external feeding pests or accidental hitchhikers and excluding infested consigment from entering

commerce (Cavey, 2003; Wittenberg & Cock, 2001). The PRA concluded that, based on the

biology of the pests, Conotrachelus serpentinus and Cryptaspasma perseana will be mitigated

by the existing systems approach (Gilligan et al., 2011). The systems approach requi rements for

surveys to prove pest free places of production, and the extensive culling and inspections

required will mitigate these pests as they have the other weevils and Stenoma catenifer

.8

Disease symptoms for inspections and culling: Sphaceloma perseae causes raised corky lesions

on the fruit ( Menge & Ploetz, 2003 ). S phaceloma perseae is a pathogen of young tissues and

fruit become resistant once they are half grown ( Menge & Ploetz, 2003 ; Mossler & Crane,

2012 ); therefore, it is likely symptoms will be evident on fruit and subject to culling. The

Avocado sunblotch viroid typically c au ses abnormal tree growth; red, yellow, pink or white

streaks on young branches; leaves may become bleached in appearance and fruit may develop

white, yellow, or red blotches/depressions ( Dodds et al. , 2006 ; Menge & Ploetz, 2003 ).

Symptomatic avocado fruit are highly likely to be culled, but symptomless fruit would go

undetected.

Summary:

The pests of quarantine significance that may follow the pathway of avocadoes from Mexico

incl ude the or i ginal pests from early PRAs (USDA, 1996 ; 2004 ) and several additional pests

identified in the revised PRA (USDA, 2014)

. Since 2004, approximately 181,000 consigments

totaling over 3.2 million metric tons of Hass avocadoes from Mexico have been imported into

the United States (QPAS, 2014)

. None of the pests ( Tephritid fruit flies , fruit or stem weevils,

the fruit boring mot h , mealybugs, thrips or plant pathogens) listed in the Mexico avocado PRAs

(USDA, 1996; 2004; 2014) as following the pathway of fresh avocadoes have ever been

intercepted in commercial consigmenbts of avocados since Mexico was granted market access in

1997 (AQAS, 2014)

. APHIS has intercepted actionable pests with commercial consigments of

avocados from Mexico only three times since 1997 (AQAS, 2014): Phyllachora gratissima

Rehm (Phyllachoraceae)

– two interceptions in 2002, Apis mellifera (Linnaeus) (Apidae)

– one

interception (2013). Honey bees ( Apis mellifera ) are considered actionable by APHIS unless

they enter under permit that provides for freedom of honey bees pathogens and parasites. They

would not be normally associated with avoc ado fruit, but might ‘hitchhike’ with consigments

.

The current required mitigations include systems approach for all pests, with pest survey s and a

pest control program in country that is subject to APHIS approval and oversight . The lack of

interceptions of any of the pests listed as following the pathway of Mexico avocadoes in the

PRA s indicates that the mitigations are sufficient to exclude quarantine pests from the pat hway.

Author s :

Walter P. Gould , Ph.D.

Senior Risk Manager

- Entomology

Regulations, Permits and Manuals

Jose R. Hernandez, Ph.D.

Senior Risk Manager

– Plant Pathology

Regulations, Permits and Manuals

References cited:9

AQAS

- PestID. 201 4

. Agricultural Quarantine Activity System Pest Interception Database.

USDA

- APHIS

- PPQ. Last access May . 201 4

.

Cavey

, J

. F

. 2003

. Mitigating introductions of invasive plant pests in the United States. In: Ruiz

, G

. M

. and Carlton

, J

. T

. (eds) Invasive Species, Vectors and Management Strategies, pp 350

– 361.

Island Press, Washington, D.C. USA. 518 pp

.

Dodds, J. A., D. Matthews, M. L. Arpaia, and G. W. Witney. 2006. AvoResearch: Recognizing

Avocado Sunblotch Disease. California Avocado Commission.

http://www.californiaavocadogrowers.com/assets/Uploads/Growers

Site/IndustryIssuesAndNews/Pests

- and

- Diseases/AvoResearch

- Sunblotch.pdf . (Archived at

PERAL).

Gilligan, T.M., J.W. Brown and M.S. Hoddle. 2011. A new avocado pest in Central America

(Lepidoptera: Tortricidae) with a key to Lepidoptera larvae threatening avocados in California

. Zootaxa 3137: 31

– 45

.

Menge, J. A., and R. C. Ploetz. 2003. Diseases of Avocado. Pages 35

- 71 In Diseases of Tropical

Fruit Crops. CABI Publishing.

Mossler, M. A., and J. H. Crane. 2012. Florida Crop/Pest Management Profile: Avocado .

Publication #CIR 1271. Pesticide Information Office, Horticultural Sciences Department, Florida

Cooperative Extension Service, Institute of Food and Agricultural Sciences, University of

Florida, http://edis.ifas.ufl.edu/pi048

.

USDA. 1996. Importation of Avocado Fruit ( Persea americana ) from Mexico

. Supplemental

Pest Risk Assessmen t: Addendum I: Estimates for the Likelihood of Pest Outbreaks Based on the

Draft Final Rule

. Animal and Plant Health Inspection Service (APHIS)

, Plant Protection and

Quarantine (PPQ)

, Biological Assessment and Taxonomic Support (BATS)

, Riverdale, MD. 9

p p.

USDA. 2004. Importation of Avocado Fruit (Persea americana Mill. var. ‘Hass’) from Mexico.

A Risk Assessment. November 19, 2004. United States Department of Agriculture, Animal and

Plant Health Inspection Service, Plant Protection and Quarantine, Center for Plant Health

Science and Technology. Raleigh, NC. 138 pp.

USDA. 2009. Movement of Hass Avocados From Areas Where Mexican Fruit Fly or

Sapote Fruit Fly Exist . Final Rule. Federal Register Tuesday June 30, 2009, p. 31154

- 31160.

USDA

. 2013. Fruits and Vegetables Import Requirements (FAVIR) Database. United States

Department of Agriculture, Animal and Plant Health Inspection Service (APHIS).

https://epermits .aphis.usda.gov/manual/index.cfm?ACTION=pubHome

.10

USDA. 2014. Importation of Fresh Fruit of Avocado (Persea americana Mill. var. ‘Hass’) from

Mexico into the Continental United States, Hawaii, and Puerto Rico

. A Qualitative, Pathway

Initiated Pest Risk A ssessment

. United States Department of Agriculture, Animal and Plant

Health Inspection Service, Plant Protection and Quarantine, Center for Plant Health Science and

Technology. Raleigh, NC. 1 19 pp.

Wittenberg, R. . and M.J.W. Cock

. (2001). Invasive a lien species: T oolkit of best prevention

and management practices. Wallingford,Oxon:CABInternational.

http://www.issg.org/pdf/publications/GISP/Guidelines_Toolkits_BestPractice/Wittenberg&Cock

_2001_EN.pdf11

Recommendations



### Conditions for i m p o rtation of Mexico Avocadoes into the United States from

all parts of Mexico :

APHIS will require t he following conditions for the importation of Mexico avocadoes in order to

prevent the introduction or dissemination of plant pests into the United States : All other

conditions of the mitigations in § 319.56

– 30 must be met for avocadoes from Mexico to be

exported to the United States except that section (c) will be changed from listing specific

growing areas in Mexico to allow avocadoes from all growing areas in Mexico to be exported

to the continental United States , Hawaii and Puerto Rico if the conditions of the sy stems

approach are met

. Additional pests identified in the PRA (USDA, 2014) will be added to

requirements of the systems approach in the bilateral workplan . The pests include:

Arthropods that are pests for Hawaii and Puerto Rico

Conotrachelus serpentinus (Klug) ( Coleoptera: Curculionidae )

Arthropod pests for Continental United States, Hawaii, and Puerto Rico

Cryptaspasma perseana Gilligan & Brown (Lepidoptera: Tortricidae)

Fung us pests for Puerto Rico

Phytophthora citricola Sawada (Oomy cetes: Pythiales)

Fung us pests for Hawaii and Puerto Rico

Phytophthora hevea e A.W. Thompson ( Oomycetes: Pythiales )

Fungus pest for Hawaii

Sphaceloma perseae Jenkins ( Ascomycetes: Myriangiales )

Viroid pest for Hawaii and Puerto Rico

Avocado sunblotch viroid

________________________________________________________________________



### _X_ APPROVED

___ DISAPPROVED

Walter P. Gould & José R. Hernández 10 June 201 4

Signature (name) Date