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<body><p><b>Final Rule:  Cold Treatment Regulations 
</b></p>
<p><b>Analysis in Support of Certification that the Rule will not have a Significant             Economic Impact on a Substantial Number of Small Entities</b></p>
<p><b>Docket No. APHIS-2006-0050</b></p>
<p><b>July 2010</b></p>
<p><b>Policy Analysis & Development
</b></p>
<p><b>Policy & Program Development
</b></p>
<p><b>Animal & Plant Health Inspection Service
</b></p>
<p><b>U.S. Department of Agriculture</b>
</p>
<p><b>Cold Treatment Regulations:  Analysis in Support of Certification that the Rule will not have a Significant Economic Impact on a Substantial Number of Small Entities</b></p>
<p><b>Docket No. APHIS-2006-0050 
</b></p>
<p>
This analysis examines the impact on U.S. small entities of a final rule following an interim rule that sets forth certain phytosanitary treatment amendments for fruit imports.  The amendments include new requirements for cold treatment enclosures and procedures, including precooling.  Currently, 26 fruits and nuts are required to be cold treated to be eligible for import into the United States:  apple, apricots, avocado, cape gooseberry, cherry, ethrog, grapes, grapefruit, kiwi, lemon, loquat, lychee, nectarine, oranges, ortanique, peach, pear, persimmon, plum, plumcot, pomegranate, quince, sand pear, tangerine, mandarin, and clementine.
 
</p>
<p>
Stakeholders and industry representatives have raised concerns about the presence of hot spots in large, tightly packed fruit shipments undergoing in-transit cold treatment.  Research and industry experience has established that fruit undergoing cold treatment can remain warmer than the target treatment temperature for several days due to natural fruit respiration.  If infested fruit is contained within a pallet group, natural respiration of the larval pests may also significantly raise temperatures in the shipment and reduce treatment effectiveness.  
</p>
<p>
Precooling of fruit prior to cold treatment has been shown to be effective in preventing the emergence of hot spots within shipments of fruit.
  This rule imposes more stringent requirements for precooling fruit prior to cold treatment.  In addition, it requires the use of measures approved by the Animal and Plant Health Inspection Service as adequate to ensure the security and integrity of cold treatment temperature data, adds requirements to increase the effectiveness of cold treatment conducted in vessel holds and treatment enclosures, and provides for officials authorized by APHIS to conduct audits of the cold treatment process.  </p>
<p>
The Regulatory Flexibility Act requires agencies to evaluate the potential effects of their proposed and final rules on small businesses, small organizations, and small governmental jurisdictions.  Section 604 of the Act requires an agency to prepare a final regulatory flexibility analysis (FRFA) that describes the expected impact of the rule on small entities and the steps the agency has taken to minimize significant economic impacts on small entities.  In place of the FRFA, the head of the agency may certify that a rule will not have a significant economic impact on a substantial number of small entities.  This analysis provides the factual basis for certification of this rule.
</p>
<p>
This analysis examines the possible effects on U.S. small entities of the new cold treatment regulations.  As background, we provide a brief overview of U.S. fruit production and trade.  This is followed by a comparison of the costs of precooling to the value of the fruit imports.  We then describe the expected impact on small entities.
</p>
<p><u>U.S. Fruit Production and Trade
</u></p>
<p>
From 2003 to 2007, the United States produced an annual average of about 
9 million metric tons (MT) of the fruits mentioned above, valued at over $5.6 billion.  Most U.S. production of fresh citrus occurs in California and Florida.  Non-citrus fruit production takes place in many States, with Washington being the main producer of apples.
  
</p>
<p class="default_Text">Foreign markets are increasingly important for U.S. fruit producers, accounting for approximately 27 percent of 2007 fresh fruit sales.  As shown in table 1, the United States is a net exporter of fresh fruits, exporting an average of about 2.2 million MT valued at $2.2 billion (2003-2007) and importing about 1.4 million MT valued at $1.8 billion (2003-2007).
  Ten countries (Argentina, Australia, Brazil, Canada, Chile, Italy, Mexico, New Zealand, South Africa, and Spain) supplied 95 percent of U.S. fresh fruit imports.
   
</p>
<p>Table 1.—<u>U.S. fruit production, consumption, exports and imports, 2003-2007</u></p>
<table><tbody><tr>	<td><p>Year</p>
</td>	<td><p>Production (in 1,000 metric tons)</p>
</td>	<td><p>Consumption (in 1,000 metric tons)</p>
</td>	<td><p>Exports (in 1,000 metric tons)</p>
</td>	<td><p>Imports (in  1,000 metric tons)</p>
</td></tr>
<tr>	<td><p>2003</p>
</td>	<td><p>9,311</p>
</td>	<td><p>8,231</p>
</td>	<td><p>2,316</p>
</td>	<td><p>1,236</p>
</td></tr>
<tr>	<td><p>2004</p>
</td>	<td><p>9,032</p>
</td>	<td><p>8,045</p>
</td>	<td><p>2,180</p>
</td>	<td><p>1,193</p>
</td></tr>
<tr>	<td><p>2005</p>
</td>	<td><p>9,119</p>
</td>	<td><p>8,213</p>
</td>	<td><p>2,291</p>
</td>	<td><p>1,385</p>
</td></tr>
<tr>	<td><p>2006</p>
</td>	<td><p>8,420</p>
</td>	<td><p>7,593</p>
</td>	<td><p>2,178</p>
</td>	<td><p>1,351</p>
</td></tr>
<tr>	<td><p>2007</p>
</td>	<td><p>8,904</p>
</td>	<td><p>8,444</p>
</td>	<td><p>2,133</p>
</td>	<td><p>1,673</p>
</td></tr>
<tr>	<td><p>5-Year Average (2003-2007)</p>
</td>	<td><p>8,957</p>
</td>	<td><p>8,104</p>
</td>	<td><p>2,220</p>
</td>	<td><p>1,367
</p>
<p></p>
</td></tr>
</tbody></table>
<p>Sources:  Production, consumption, export, and import data are from USDA/NASS, Citrus Fruit 2008 Summary, September 2008; Non-citrus Fruits and Nuts: 2008 Preliminary Summary, January 2009.  Export and import data are from Global Trade Information Services, Inc., Country Edition, April 2009.  </p>
<p>Note:  Production, export, and import quantities are summations for apples, apricots, avocados, blueberries, cherries, grapes, grapefruits, kiwifruits, lemons, oranges, peaches and nectarines, pears, plums, and tangerines.  Consumption is calculated as 
production + imports - exports.  </p>
<p>
As shown in table 1, U.S. fresh fruit production has declined slightly in recent years.  Production totaled 9.3 million MT in 2003 and declined to 8.9 million MT in 2007, an annual decline of about 0.9 percent.  Consumption increased over this same period from 8.2 million MT to 8.4 million MT, and U.S. imports increased from 1.2 million MT to 1.7 million MT.  Imports represented 17 percent of consumption.  
</p>
<p><u>Economic Impact of the New Cold Treatment Regulations </u></p>
<p class="plain_Text">The new cold treatment regulations require that fruit intended for in-transit cold treatment must first undergo precooling until the temperature of the entire shipment reaches the highest allowable temperature in the treatment schedule under which the fruit will be treated. 

In-transit treatment enclosures such as ship holds and containers may not be used for precooling unless an official authorized by APHIS approves the loading of the fruit in the enclosure as adequate to allow for fruit pulp temperatures to be taken manually prior to beginning treatment.  Although in-transit precooling is an available option, precooling in a refrigerated warehouse or similar approved facility is considerably more 
cost-effective.  On-board precooling requires prolonged shipment times of a day or more while the fruit is being precooled to the required temperature, resulting in higher shipping costs.</p>
<p class="plain_Text">In theory, any increase in treatment costs resulting from the new precooling regulations could reduce the quantity of fresh fruit supplied by exporters to the United States and increase the price, adversely affecting U.S. consumers of imported fresh fruit.  In addition, U.S. fresh fruit producers who compete with the foreign suppliers could benefit.  However, the price effects attributable to the new cold treatment regulations are expected to be negligible, and impacts for U.S. producers and consumers insignificant.  </p>
<p>For the 10 countries that account for 95 percent of U.S. fresh fruit imports, less than 10 percent of their exports in 2007 were to the United States.
  These countries are major suppliers of fresh fruit worldwide, accounting for over 55 percent of 2007 world exports of the various fruits included in table 1.
  Since the U.S. market represents a relatively small share of these countries’ total fresh fruit exports, prices and supplies are not expected to be much affected by any increase in treatment costs.
  Many of these major fruit-exporting countries already have refrigerated warehouses and similar facilities available for precooling.  
</p>
<p class="plain_Text">Of the countries that supply the remaining five percent of U.S. fresh fruit imports, 28 of them shipped fruits that combined totaled only a little over 1.5 bulk shipments (12,000 MT).  Because most of these countries send very small shipments of fresh fruit, it may not be economical for them to construct refrigerated warehouses for precooling.  Based on U.S. construction costs, a medium-sized refrigerated warehouse (between 60,000 and 100,000 square feet) may cost between $7 million and $10 million.
</p>
<p class="plain_Text">Exporters of fresh fruit to the United States, particularly those located in major exporting countries, are more likely to acquire needed space in existing refrigerated warehouses.  The cost of renting precooling space in refrigerated facilities is not expected to be significant.    </p>
<p class="plain_Text">
In table 2, we compare precooling costs to the value of the fruit imported, and show that precooling is relatively inexpensive.  These precooling costs are borne regardless of whether the treatment takes place on land or on a vessel.  We base our calculations on cold treatment costs reported in an analysis concerning Spanish clementine imports.
  
</p>
<p class="plain_Text">Table 2.—<u>U.S. fruit imports and pre-cooling treatment costs as a percentage of the value of imports</u> 
</p>
<table><tbody><tr>	<td><p></p>
</td>	<td><p>U.S. imports</p>
</td>	<td><p>Exports by the 10 major fruit exporting countries to the United States</p>
</td>	<td><p>World exports by all countries</p>
</td>	<td><p>Cost of treatment</p>
<p>(in dollars)</p>
</td>	<td><p>Cost of treatment as a percentage of the value of U.S. imports</p>
</td></tr>
<tr>	<td><p></p>
</td>	<td><p></p>
</td>	<td><p></p>
</td>	<td><p></p>
</td>	<td><p>One </p>
<p>day</p>
</td>	<td><p>Three days</p>
</td>	<td><p>One </p>
<p>day</p>
</td>	<td><p>Three days</p>
</td></tr>
<tr>	<td><p></p>
</td>	<td><p>A (in thousands of dollars)</p>
</td>	<td><p>B (MT)</p>
</td>	<td><p>C (MT)</p>
</td>	<td><p>D (MT)</p>
</td>	<td><p>E</p>
</td>	<td><p>F</p>
</td>	<td><p>G</p>
</td>	<td><p>H</p>
</td></tr>
<tr>	<td><p>Apples</p>
</td>	<td><p>144,493</p>
</td>	<td><p>176,005</p>
</td>	<td><p>2,639,019</p>
</td>	<td><p>7,116,322</p>
</td>	<td><p>109,522</p>
</td>	<td><p>328,566</p>
</td>	<td><p>0.076%</p>
</td>	<td><p>0.227%</p>
</td></tr>
<tr>	<td><p>Apricots</p>
</td>	<td><p>4,315</p>
</td>	<td><p>1,969</p>
</td>	<td><p>90,797</p>
</td>	<td><p>195,572</p>
</td>	<td><p>1,225</p>
</td>	<td><p>3,675</p>
</td>	<td><p>0.028%</p>
</td>	<td><p>0.085%</p>
</td></tr>
<tr>	<td><p>Avocados</p>
</td>	<td><p>290,171</p>
</td>	<td><p>218,440</p>
</td>	<td><p>561,122</p>
</td>	<td><p>664,635</p>
</td>	<td><p>135,928</p>
</td>	<td><p>407,783</p>
</td>	<td><p>0.047%</p>
</td>	<td><p>0.141%</p>
</td></tr>
<tr>	<td><p>Blueberries</p>
</td>	<td><p>114,454</p>
</td>	<td><p>23,681</p>
</td>	<td><p>91,543</p>
</td>	<td><p>154,286</p>
</td>	<td><p>14,480</p>
</td>	<td><p>43,439</p>
</td>	<td><p>0.013%</p>
</td>	<td><p>0.038%</p>
</td></tr>
<tr>	<td><p>Cherries</p>
</td>	<td><p>30,670</p>
</td>	<td><p>9,846</p>
</td>	<td><p>55,330</p>
</td>	<td><p>249,930</p>
</td>	<td><p>6,236</p>
</td>	<td><p>18,709</p>
</td>	<td><p>0.020%</p>
</td>	<td><p>0.061%</p>
</td></tr>
<tr>	<td><p>Grapes</p>
</td>	<td><p>847,144</p>
</td>	<td><p>567,850</p>
</td>	<td><p>1,999,329</p>
</td>	<td><p>3,322,321</p>
</td>	<td><p>353,354</p>
</td>	<td><p>1,060,061</p>
</td>	<td><p>0.042%</p>
</td>	<td><p>0.125%</p>
</td></tr>
<tr>	<td><p>Grapefruit</p>
</td>	<td><p>1,990</p>
</td>	<td><p>17,624</p>
</td>	<td><p>351,524</p>
</td>	<td><p>1,136,818</p>
</td>	<td><p>10,967</p>
</td>	<td><p>32,900</p>
</td>	<td><p>0.551%</p>
</td>	<td><p>1.653%</p>
</td></tr>
<tr>	<td><p>Kiwi</p>
</td>	<td><p>39,778</p>
</td>	<td><p>40,952</p>
</td>	<td><p>251,437</p>
</td>	<td><p>1,058,286</p>
</td>	<td><p>25,483</p>
</td>	<td><p>76,449</p>
</td>	<td><p>0.064%</p>
</td>	<td><p>0.192%</p>
</td></tr>
<tr>	<td><p>Lemons</p>
</td>	<td><p>21,760</p>
</td>	<td><p>45,189</p>
</td>	<td><p>1,549,540</p>
</td>	<td><p>2,188,628</p>
</td>	<td><p>28,120</p>
</td>	<td><p>84,359</p>
</td>	<td><p>0.129%</p>
</td>	<td><p>0.388%</p>
</td></tr>
<tr>	<td><p>Oranges</p>
</td>	<td><p>75,855</p>
</td>	<td><p>75,354</p>
</td>	<td><p>3,257,648</p>
</td>	<td><p>4,306,934</p>
</td>	<td><p>47,020</p>
</td>	<td><p>141,061</p>
</td>	<td><p>0.062%</p>
</td>	<td><p>0.186%</p>
</td></tr>
<tr>	<td><p>Peaches and Nectarines</p>
</td>	<td><p>60,372</p>
</td>	<td><p>66,271</p>
</td>	<td><p>1,046,685</p>
</td>	<td><p>1,342,126</p>
</td>	<td><p>41,238</p>
</td>	<td><p>123,715</p>
</td>	<td><p>0.068%</p>
</td>	<td><p>0.205%</p>
</td></tr>
<tr>	<td><p>Pears and Quinces</p>
</td>	<td><p>92,025</p>
</td>	<td><p>85,372</p>
</td>	<td><p>1,036,235</p>
</td>	<td><p>2,419,269</p>
</td>	<td><p>53,124</p>
</td>	<td><p>159,372</p>
</td>	<td><p>0.058%</p>
</td>	<td><p>0.173%</p>
</td></tr>
<tr>	<td><p>Plums</p>
</td>	<td><p>36,969</p>
</td>	<td><p>34,386</p>
</td>	<td><p>296,365</p>
</td>	<td><p>468,291</p>
</td>	<td><p>21,397</p>
</td>	<td><p>64,192</p>
</td>	<td><p>0.058%</p>
</td>	<td><p>0.174%</p>
</td></tr>
<tr>	<td><p>Tangerines</p>
</td>	<td><p>1,398,15</p>
</td>	<td><p>98,091</p>
</td>	<td><p>2,023,084</p>
</td>	<td><p>3,066,053</p>
</td>	<td><p>61,039</p>
</td>	<td><p>183,116</p>
</td>	<td><p>0.044%</p>
</td>	<td><p>0.131%</p>
</td></tr>
<tr>	<td><p></p>
</td>	<td><p>1,899,811</p>
</td>	<td><p>1,461,030</p>
</td>	<td><p>15,249,658</p>
</td>	<td><p>27,531,836</p>
</td>	<td><p>909,149</p>
</td>	<td><p>2,727,448</p>
</td>	<td><p>0.048%</p>
</td>	<td><p>0.144%</p>
</td></tr>
</tbody></table>
<p>Note: Import values and quantities in columns A and B are five-year averages (2003-2007); world export quantities in column D are for 2007; E=(B*2,204.6*$0.56/1,984), the cost of one day treatment;  F=(B*2,204.6*$1.68/1,984), the cost of three days treatment; G = (E/[A*1,000])*100; H = (F/[A*1,000])*100; 2,204.6 is the weight, in pounds of a metric ton, 1,984 pounds is the assumed weight of a pallet, and  $0.56 and $1.68 are the costs of pre-cooling a pallet for one and three days, respectively.
</p>
<p>In table 2, the import values and quantities in columns A and B, respectively, are five-year averages (2003-2007).  Column C quantities are global exports by the top 10 suppliers of these commodities and Column D shows global exports of these fruits by all countries.  Columns E and F are precooling costs, calculated as described in the note to the table.  Column E shows the one-day treatment cost and Column F, the three-day treatment cost.  Columns G and H show the significance of these costs relative to import values.  Only in the case of grapefruit is the three-day treatment cost greater than one percent of the value of the fruit; grapefruit had the smallest import value of the listed fruit, averaging $2 million per year.  </p>
<p>Overall, the costs of precooling totaled less than 0.15 percent of the value of the fruit imports, assuming a three-day precooling period throughout.  In many cases, the shipment will reach the required precooling temperature in less time.  In dollar terms, these precooling costs totaled less than $3 million per year.  These costs are a fraction of potential losses that may result, for example, from Medfly infestations.  A Medfly infestation that occurred in California during 1980–1982, according to public comments received on the proposed rule for Spanish clementines, cost $100 million to eradicate and $100 million in lost export revenues.
  
</p>
<p><u>Potentially Affected Entities and Expected Impact of the Rule 
</u></p>
<p>The Small Business Administration (SBA) has established guidelines for determining which firms are to be considered small under the Regulatory Flexibility Act.  U.S. entities that may be affected include producers of Medfly host crops (many of which are categorized within the following North American Industry Classification System subsectors: NAICS 111310 Orange Groves, NAICS 111320 Citrus (except Orange) Groves, NAICS 111331 Apple Orchards, NAICS 111332 Grape Vineyards, NAICS 111334 Berry (except Strawberry) Farming, NAICS 111335 Tree Nut Farming, NAICS 111336 Fruit and Tree Nut Combination Farming, and NAICS Other Non-citrus Fruit Farming), Fruit and Vegetables Merchant Wholesalers (NAICS 422480), Supermarkets and other Grocery Stores (NAICS 445110), and Fruit and Vegetable Markets (NAICS 445230).  The vast majority of the businesses that comprise these industries are small entities. 
</p>
<p class="plain_Text">The Small Business Administration (SBA) classifies fruit fly host crop operations as small entities if their annual receipts are not more than $750,000.
  According to the 2007 Census of Agriculture, there were over 127,895 operations engaged in the production of citrus and non-citrus fruits.  Over 98 percent of these entities were designated as small entities.  The SBA classifies fresh fruit and vegetable merchant wholesalers (NAICS code 422480) as small if they employ 100 or fewer employees.  According to the 2002 Economic Census, there were 4,644 of these entities, with 484 (or 10.4 percent) of them considered to be large.
  SBA classifies supermarkets and other grocery stores as small entities if their annual receipts are not more than $23 million. There were 56,577 supermarkets and other groceries in 2002.  Of these, only 3477 or 6.1 percent are considered to be large.  Fruit and vegetable markets (NAICS code 445230) are considered small if their annual sales are less than $6.5 million.
  In 2002, the most recent year for which data are available, there were 2,257 fruit and vegetable markets.
  Approximately 96 percent of these are considered to be small entities under the SBA’s standards.
</p>
<p> 
The rule has no mandatory reporting, recordkeeping, or other compliance requirements.  U.S. entities that may be affected by the rule voluntarily engage in trade transactions.  Any reporting or other requirements will be those normally associated with the regular transactions involved in doing business.
</p>
<p>
Clearly, a majority of the entities that comprise these U.S. industries are small, but any impacts on these industries due to the new cold treatment regulations will be insignificant.  The rule will not have a significant economic impact on a substantial number of small entities.  
</p>
<p><u>Summary
</u></p>
<p class="plain_Text">It is unlikely that U.S. entities will be directly affected by the new cold treatment requirements; compliance will be the responsibility of the exporting entity.  Any reporting or recordkeeping requirements for U.S. entities will be those normally associated with importing fruit from abroad.
</p>
<p class="plain_Text">In theory, if foreign exporters do experience a cost increase because of this amendment, the quantity of fruit supplied may decrease.  This decrease could result in an increase in the price of fruit, costing U.S. consumers and benefiting U.S. producers and suppliers.  However, any additional costs because of this amendment will represent only a small fraction of the price of the fruit.
</p>
<p class="plain_Text">The number of U.S. industries that could be potentially affected by this amendment are small, and any impacts on these industries due to these changes in the cold treatment regulations will be insignificant.  Under these circumstances, the Administrator of the Animal and Plant Health Inspection Service has determined that this action will not have a significant economic impact on a substantial number of small entities.</p>
<p>� USDA/APHIS/PPQ, Risk Management Document (http:// � HYPERLINK "http://www.nabcblues.org/legislative/Uruguay%20pest%20risk%20analysis.pdf" ��www.nabcblues.org/legislative/Uruguay%20pest%20risk%20analysis.pdf�). As some of these commodities are crosses between others (for example, ortanique is a cross between sweet orange and tangerine; plumcot a cross between plum and apricot, etc.) and are less significant in terms of volume, the focus of the analysis is limited to selected commodities.
</p>
<p>� Pre-cooling of fruit also provides commercial benefits.  Various research shows that prompt pre-cooling of fruits and vegetables immediately after harvesting maintains the quality of fresh fruit for a longer period of time (inhibits growth of decay-causing microorganisms, reduces respiratory activities, lessens moisture loss and leads to longer shelf life).  The suggested length of time varies from commodity to commodity. Michael T. Talbot and Khe V. Chau, Pre-cooling Strawberries, Publication #CIR942 (� HYPERLINK "http://eds.ifas.ufl.edu/AE136" ��http://eds.ifas.ufl.edu/AE136�); and Mahesh Aswaney, Forced-Air Pre-cooling of Fruits and Vegetables, Air Conditioning and Refrigeration Journal, January-March 2007.  (� HYPERLINK "http://www.chipl.com/pdf/AHRAE_Journal_Article.pdf" ��www.chipl.com/pdf/AHRAE_Journal_Article.pdf�). 
</p>
<p>� USDA/NASS, Citrus Fruit 2008 Summary, September 2008; Non-citrus Fruits and Nuts:  2008 Preliminary Summary, January 2009.
</p>
<p>� Although the United States is a net aggregate exporter of the above fresh fruits, it is a net importer of grapes, blueberries, kiwi fruit, and tangerines (including clementine and mandarin).
</p>
<p>� Global Trade Information Services, Inc., the Global Trade Atlas, Country Edition, April 2009.  (http.www.gtis.com/gta/).
</p>
<p>� Calculated by dividing U.S. imports from the 10 countries by their exports worldwide (see table 2):  1,461,030 MT / 15,249,658 MT = 9.6 percent. 
</p>
<p>� Calculated by dividing world exports by the 10 countries by total world exports (see table 2):  15,249,658 MT / 27,531,836 MT = 55.4 percent.  
</p>
<p>� Global Trade Information Services, Inc., the Global Trade Atlas, Country Edition, April 2009.  (http.www.gtis.com/gta/).
</p>
<p>� The Port of Corpus Christi completed in July 2000 a new 99,520 square foot refrigerated warehouse at a total cost of $9.2 million (about $92.5 per sq. ft. ($9,200,000/99,520)) for importing and exporting fruits, vegetables, meats, and other commodities (� HYPERLINK "http://www.portofcorpuschristi.com/pdfs/Channels8-99.pdf;" ��http://www.portofcorpuschristi.com/pdfs/Channels8-99.pdf�).  As another example, the Port of Wilmington, Delaware, completed construction of a new 60,000 square feet refrigerated warehouse at a total cost of $7.5 million (about $125/sq. ft. ($7,500,000/60,000)). The facility will be used primarily for fresh fruit.  
</p>
<p>(� HYPERLINK "http://www.drba.net/press/releases/files/20040615drbarowanuniversity.pdf" ��http://www.drba.net/press/releases/files/20040615drbarowanuniversity.pdf�).
</p>
<p>� We use 1,984 pounds as the weight of one pallet.  Source:  USDA/APHIS/PPD/PAD, Amending Import Rules for Clementines from Spain:  Final Regulatory Impact Analysis, October 2002.
</p>
<p>
</p>
<p>� USDA/APHIS/PPD/PAD, Amending Import Rules for Clementines from Spain:  Final Regulatory Impact Analysis, October 2002. 
</p>
<p>� SBA, Small business Size Standards matched to North American Industry Classification System 2002, Effective January 2006 (www.sba.gov/size/sizetable2002.html).
</p>
<p>�The 2007 Wholesale Trade/Establishment and Firm Size data release date is November 2010.
</p>
<p>� The 2007 Retail Trade/Establishment and Firm Size data release date is October 2010.
</p>
<p>� U.S. Census Bureau, 2002 Economic Census Geographic Area Series:  Manufacturing and Wholesale Trade, Revised January 2006 (www.census.gov/econ/census02/ guide/geosumm.htm).  
</p>
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