# Importation of Bananas ( **Musa** spp.) from the Philippines into the
Continental
United States

Environmental Assessment, July 2012 United States Department of Agriculture

Marketing and Regulatory Programs

Animal and

Plant Health Inspection
Service

# Importation of Bananas ( **Musa** spp.) from the Philippines into the
Continental United States

Environmental Assessment

J uly 2012

Agency Contact:

Meredith Jones Regulations, Permits and Manuals Regulatory Compliance and Coordination
Plant Protection and Quarantine Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road, Unit 1 56

Riverdale , MD 20737

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## Table of Contents

I. Need for the Proposed Action

..................................................... 1

II. Alternatives

.................................................................................. 2

A. No Action

............................................................................... 2

B. Systems Approach

................................................................ . 2

III. Environmental Effects

................................................................ . 6

A. No Action

............................................................................... 6

B. Systems Approach

................................................................ . 6

IV. Other Environmental Considerations

......................................... 11

A. Endangered Species Act

...................................................... 11

B. Executive Order 12114

........................................................ 1 2

V. Listing of Agencies and Persons Consulted

.............................. 13

VI. References

................................................................................ 14

Appendix 1

. Response to comments

......................................... 171 

## I. Need for th e Proposed Action

Under the Plant Protection Act, the United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service ( APHIS ) has authority to prohibit or restrict the importation and interstate movement of organisms, plant pests, or noxious weeds that may injure or cause disease in plants. The regulations in "Subpart— Fruits and Vegetables" (7 Code of Federal Regulations (CFR) § 319.56–1 through

319.56–50 ) prohibit or restrict the importation of fruits and vegetables into

the Un ited States from certain parts of the world to prevent the introduction and dissemination of plant pests that are new to or not widely

distributed within the United States.

The National Plant Protection Organization ( NPPO ) of the Philippines has

requeste d that the United States a mend its regulations to allow fresh, hard

green bananas to be imported into the United States

. Historically, bananas have been imported from Central and South America where they are considered a lower risk commodity . Bananas hav e also been imported

into the continental United States from Hawaii . Approval of bananas from the Philippines would represent the first importation of this commodity

from Asia.

To determine the potential pest risks inherent in allowing banana import ati on from the Philippines, and to determine mitigations which might be effective in combat ing the pest risk, APHIS analyzed the Philippine proposal and prepared a pest risk assessment (USDA

– APHIS

, 2009 ) and a risk management analysis ( USDA

– APHIS , 2010). APH IS incorporated pest interception data, information from the NPPO of the Philippines, and peer- reviewed scientific literature into the pest risk analysis ( USDA

– APHIS , 2009 ) and the risk management analysis ( USDA

– APHIS , 2010 ).

Based on the pest risk analys is and the risk management analysis , APHIS is proposing that, as a condition of entry, bananas from the Philippines would have to be produced, packed, and transported in accordance with a systems approach designed to mitigate the potential risks associated with the importation. Such an approach has been utilized for importing

bananas from Hawaii

, as well as from other countries. The systems approach is considered to be an appropriate safeguard to ensure that consignments of bananas from the Philippines wo uld have a low likelihood of containing fruit with the potential to cause the introduction of a plant pest into the United States.2 

## II. Alternatives

After completi on of the pest risk analysis and the risk management analysis for bananas from the Philippines, APHIS designed a systems approach that includes multiple independent phyto sanitary risk reduction measures designed to mitigate the risk of the 14 pests of concern. These mitigations include monitoring, inspections, and chemical treatments.

APHI S is evaluating the environmental impacts of t wo alternatives: (1) no action alternative; and (2) a systems approach for all 1 4 pests (the preferred alternative).



### A. No Action

Under the no action alternative, the United States would continue to prohibi t the importation of bananas from the Philippines. However, in compliance with international trade regulations and agreements, the United States is required to consider the import request of the Philippines

to determine whether such imports can be made safely using the phytosanitary methods approved for comparable commodities. APHIS has determined that the United States may import bananas from the Philippines , under certain conditions, without increasing the risk of introduction of quarantine pests ( USDA

– APHIS , 2009; USDA

– APHIS, 2010). The no action alternative, therefore, will not satisfy the need for the proposed rule

. This alternative does

, however, serve as a baseline for comparison.



### B. Systems Approach

The preferred alternative would allow importation into the continental

United States of commercial ly produced bananas from the Philippines, subject to specific mitigation measures. Banana species to be imported

include Musa acuminata cultivars and M. acuminata x M. balbisiana hybrids. Th is alter native is based upon an integrated systems approach incorporat ing current production standards and practices in the Philippines , as well as specific pest -mitigation measures designed by

APHIS to prevent the introduction of the identified quarantine pest s.

APHIS’ pest risk assessment identified 14 pests of quarantine significance associated with the importation of bananas from the Philippines. These quarantine insects include

—

• t hree fruit flies (Diptera: Tephritidae):

o Bactrocera musae (Tryon),

o Bactrocer a occipitalis (Bezzi) , and

o Bactrocera philippinensis Drew and Hancock ;3 • one long horned beetle (Coleoptera: Cerambycidae):

o Sybra alternans Wiedemann ;

• t wo soft scales (Hemiptera: Coccidae):

o Ceroplastes rubens Maskell, and

o Coccus viridis (Green);

• e ight mealy bugs (Hemiptera: Pseudococcidae):

o Dysmicoccus neobrevipes Beardsley

,

o Geococcus coffeae Green

,

o Maconellicoccus hirsutus (Green)

,

o Planococcus lilacinus (Cockerell)

,

o Planococcus minor (Maskell)

,

o Pseudococcus cryptus Hempel

,

o Rastrococcus invadens Williams , and

o Rastrococcus spinosus (Robinson) (USDA–APHIS, 2009).

The risk management analysis outline s a systems approach to mitigate the pests of concern , and provides details about how the systems approach is designed to prevent any of the identified quaran tine pests from entering

the United States with the importation of fresh, hard, green bana nas from the Philippines (USDA–APHIS, 2010).

The systems approach mandates

—

Registered places of production. Bananas must be grown in places of production that a re registered with the NPPO of the Philippines. Registration of production sites will allow trace back to the production site if pest problems are found on fruit shipped to the United States. Problem production sites can then be removed from the program u ntil further mitigation measures have been taken to reduce pest populations.

Traceability. Harvested bananas must be placed in field cartons or containers that are marked to show the official registration number of the production site. The place of production where the bananas were grown must remain identifiable when the fruit leaves the place of production, at the packinghouse, and throughout the export process. Fruit presented for inspection at the United States port of entry must be identified in the shipping documents accompanying each lot of fruit specify ing the production site or sites in which the fruit was produced, and the packing house or houses in which the fruit was processed. This identification must

be maintained until the fruit is release d for entry into the United States.

Place of production pest management program including covering bananas with insecticide impregnated bags . Each place of production must follow a pest management program specified by the NPPO of the Philippines to reduce populations of quarantine pests. This includes applying pesticides to reduce pest populations and bagging bananas after4 flower drop with plastic bags impregnated with chlorpyrifos. If at any time during the growing period when the bag is covering the fruit, the bag falls off or is torn so that fruit flies can enter, that fruit is no longer eligible for export to the United States.

Fruit fly population monitoring and management for l ow prevalence production sites. Several species of Bactrocera th at may attack bananas

, including Bactrocera musae, B. occipitalis, and B. philippinensis, are present in the Philippines. Bananas, and especially green bananas, are generally considered to be poor hosts to most species of fruit flies; however, B. musae is recorded as attacking green bananas. Low prevalence will be used as part of a systems approach to mitigate risk from

Bactrocera species fruit flies. Procedures for the establishment and maintenance of areas of low pest prevalence must comply with

intern ational standards (NAPPO, 2003; IPPC, 2005). Beginning at least 3 months before harvest and continuing through the completion of harvest, trapping in the places of banana production for Bactrocera fruit fly species must be conducted with at least 1 trap p er 0.2 square kilometers ( km 2 ) by the NPPO of the Philippines. APHIS -approved traps baited with APHISapproved baits must be used and serviced at least once every 2 weeks. If

more than 2.0 fruit flies per trap per day are trapped, insecticide treated baits (or bait stations) must be applied in the affected place of production in order for it to remain eligible to export bananas. The NPPO of the Philippines maintains records of fruit fly detections for each trap, updates the records each time the traps are checked, and makes the records available to APHIS inspectors upon request.

Bananas harvested hard green (no color break or yellow visible). The bananas must be harvested at a mature green state. None of the bananas harvested for export may be at or past color break (turning yellow). Damaged fruit must not be harvested for export.

Safeguarding. Bananas must be safeguarded from exposure to fruit flies and other injurious pests from harvest to export.

Packinghouses. Packing houses must prevent the entry of pests (pest exclusionary packinghouses) with double-door entry and other measures designed to exclude fruit flies and other pests of quarantine concern. The packinghouse operations for export of bananas must be monitored by the

NPPO of the Phili ppines. Bananas intended for United States ’ markets must be properly segregated and labeled from bananas intended for other

markets.

Post

- harvest processing. After harvest, all damaged or diseased fruits must be culled at the packinghouse. Fruit will be washed with a high pressure water spray, dehanded (separating clusters of bananas (hands)5 from the larger bunch), and washed with soap and water. Fruit for export must be packed into new, clean boxes, crates, or other packing materials.

NPPO Inspecti on. Fruit must be inspected in the Philippines at an

APHIS -approved inspection site under the direction of inspectors from the NPPO of the Philippines following any post-harvest processing. A sample of boxes from each consignment must be selected. The f ruit from these boxes must be visually inspected for quarantine pests. A portion of the fruit being inspected must be cut to detect internally feeding quarantine

pests.

Phytosanitary certificate. Each consignment of fruit must be accompanied by a phyt osanitary certificate issued by the NPPO of the Philippines that contains an additional declaration stating that the bananas in the consignment were grown, packed, and inspected in accordance with the systems approach described in the CFR.

Port of Entry I nspection. Fruit must b e inspected at the first

United States port of entry by Customs and Border Protection inspectors from the Department of Homeland Security. A sample of boxes from each consignment will be inspected for quarantine pests . If signific ant interceptions of quarantine pests occur, APHIS may ask the NPPO of the Philippines to suspend those production sites pending the result of an investigation at which time those production sites may either be removed from the program or required to take remedial measures.

APHIS proposes to amend the regulations under Subpart – Fruits and Vegetables (7 CFR § 319.56–1 through 319.56–47) to allow the importation of bananas from the Philippines under a verifiable systems approach which includes the following requirements—

• Insecticide -impregnated bags applied to bunches of fruit to prevent
insect infestation;

• Fruit fly population monitoring;

• Fruit fly trapping and potential insecticide treated bait application;

• Importation of hard green bananas with no dam age;

• Safeguarding bananas from exposure to fruit flies from harvest through all handling and transport until export;

• Post -harvest processing requirements for culling, cleaning, and packing of fruit;

• Packinghouses must prevent the entry of insect pests;

• Fr uit will be inspected in the Philippines at an APHIS -approved site by or under the direction of inspectors from the NPPO of the Philippines;

• Fruit cutting of a sample will be cut to detect internally feeding quarantine pests;6 • Each consignment of fruit will be accompanied by a phytosanitary certificate issued by the NPPO of the Philippines;

• Port of Entry inspection; and

• Places of production of bananas to be imported into the United States must be registered with the NPPO of the Philippines.



## III

. Environm ental Effects

A. No Action

Under the no action alternative, fresh, hard, green bananas from the Philippines would not be allowed entry into the United States. There would be no environmental consequences, including cumulative impacts,

in prohibiting th e entry of bananas from the Philippines into the

United States because there would be no requirements for treating the fruit, and pests associated with bananas could not be introduced via this pathway.



### B. Systems Approach

Under the p referred a lternative

, importation of commercially produced

bananas from the Philippines would be allowed into the United States under certain mitigations

. APHIS has concluded that commercial shipments of Philippine bananas may safely be imported into the

continental Unit ed States without the risk of introducing pests using the combination of mitigations included in the systems approach ( USDA

– APHIS , 2010), as described in the section on alternative actions.

The preferred alternative would allow for the importation of ba nanas from the Philippines into the continental Un ited States while continuing to provide protection against the introduction of quarantine pests.

Noncommercial consignments of bananas from the Philippines would continue to be denied entry in to the United States. The proposed conditions of entry are designed solely to protect the United States from quarantine pests that might follow the pathway of imported bananas from the Philippines.

Operational procedures

, such as i nspection, survey, and harvest prac tices have limited, if any, environmental impacts in the United States and,

therefore , are not discussed further in this document. However, c hemical treatments have the potential to manifest environmental impacts , and will

be discussed below in detail

.7 The proposed systems approach mandates application of a pest management program including pesticide-impregnated bags to eliminate quarantine pests from bananas. These bags reduce the number of quarantine pests that may follow the pathway of bananas (USDA

– APHIS, 2010). The use of p esticide -impregnated bags are industry standard practices in Central and South America production of bananas (Matlock and de la Cruz, 2003; Polidoro et al., 2008; Simmonds, 1966). Currently, the primary ex porters of bananas t o the United States are Guatemala, Ecuador, and Costa Rica (U.S. Department of Commer ce as cited by

USDA –ERS, 2010). These three countries already utilize chlorpyrifos

impregnated bags (Polidoro, et al., 2008, Smith, A., 2000, WRM, 2004). In fact, c hlorp yrifos is one of the most commonly used pesticides in worldwide banana production (Wilson and Otsuki, 2004).

Chlorpyrifos-impregnated bags are the industry standard practice for the Philippines (BPI, 2005). According to the NPPO of the Philippines, chlorpy rifos -impregnated polyethylene bags are used to cover the fruit bunches after bunch spray to prevent mealybug, scale, and fruit fly insect

infestation on the fruit. Additional chlorpyrifos-impregnated polyethylene material (in a form of "strip" or "square") is installed on the fruit as additional control against insect pests when needed.

Potential environmental effects from imported insecticide

- treated bananas include human health risks to individuals exposed to the treated bananas.

Ind ividuals tha t would be exposed may include U.S. consumers that would eat imported bananas , and U.S. workers that may regularly handle the imported bananas.

Human H ealth E ffects

Chlorpyrifos is an organophophate (OP) pesticide. OPs are a group of related pesticides that are widely used because they are relatively inexpensive, are broad spectrum (can usually be used on several crops to control a variety of insects), and insects have not developed a resistance to them. Exposure to OPs are known to cause quick (acute) and long- term (chronic) effects in humans and wildlife (EPA, 1999).

Potential h uman exposure in the United States to chlopyrifos- treated

bananas from the Philippines would primarily be limited to oral and dermal exposure. The U.S. Environmental Protection Agency (EPA) indicates that chlorpyrifos is modera tely toxic following acute oral and dermal exposures. Exposure can cause cholinesterase inhibition in humans, which means the chemical can overstimulate the nervous system causing nausea, dizziness, c onfusion and, at very high exposures (such as major spills), respiratory paralysis and death (EPA, 2002). Inhibition of cholinesterase is the most sensitive effect in all animal species evaluated, regardless of the route or duration of exposure (EPA, 2000 ). Chlorpyrifos 1. Chlorpyrifos

Impregnated Bags8 and its primary metabolite, 3,5,6- trichloro -2-pyridinol (TCP), were found to be readily excreted in urine , and it has been concluded that the compounds do not have a significant potential to accumulate ( as cited in NTP, 1992 ).

In order to attempt to protect individuals from chemical residues, t he EPA

sets limits on the maximum amount of a pesticide residue that may legally be present in or on raw agricultural commodities in the U nited S tates

. These limits are called “tolerances

. ” EPA bas es t olerances on the potential risks of the residues to human health. The chlorpyrifos tolerance set by the EPA for bananas is 0.1 parts per million (ppm) and 0.01 ppm for banana pulp (40 CFR 180.342 ).

In residue studies conducted in 2007 by the USDA–A gricultural Marketing Service, 744 samples of imported bananas were collected throughout the United States and tested for pesticide residues, including chlorpyrifos (USDA–ARS, 2008). Chl orpyrifos resid ues were found on only 3 of the 744 samples, and no tolerances for chlorpyrifos or any other pesticide were exceeded on any banana sample (USDA –ARS, 2008).

While the study above did not test bananas imported from the Philippine s, APHIS expects that chlorpyrifos residues on Philippine bananas would similarly be under the EPA tolerance level. The imported bananas included in the above study were subject to a systems approach similar to the approach that would be required of the Philippine s. Since the Philippine s would be applying chlorpyrifos in a manner similar to which the way it is applied in other countries, APHIS does not anticipate an

increase in chlorpyrifos residues.

The Food and Agriculture Organization of the United Nations (FAO) cites

an unpublished Dow Chemical study that specifically tested chlorpyrifos

residues in/on bananas in the Philippines (Ling, 1986 as cited in FAO, 2001). In 1983 in the Philippines, bananas were covered weekly with chlorpyrifos-impregnated bags. After post-harvest intervals of 10, 11, and 12 weeks, whole bananas, banana pulp, and banana peels were tested for chlorpyrifos residues. Whole bananas (pulp and peels) tested contained a range of 0.02 to 0.13 mg/kg (0.02 to 0.13 ppm) residues of chlorpyrifos; banana pulp tested contained a range of 0.01 to 0.07 mg/kg (0.01 to 0.07 ppm) ; and

, banana peels tested contained a range of < 0.01 to 0.19 mg/kg (< 0.01 to 0.19 ppm).

While the upper limit of chlorpyrifos residues in whole bananas and banana pulp from the Dow study were above the tolerance levels set by

EPA , APHIS has been unable to locate and review the unpublished report

to ensure that the treatment methods used in 1983 are similar to the methods that would be used under the proposed s ystems approach. APHIS anticipates that different treatment methods were utiliz ed as9 bananas coming from other countries currently treating with chlorpyrifos impregnated bags are within allowable residue limits.

Should any imported bananas contain residues that would exceed the tolerance level established by EPA (p er section 402(a) (2)(B) and of the Federal Food, Drug, and Cosmetic Act (FFDCA)), i t is the responsibility

of FDA to ensure that the bananas are subject to enforcement action (for

more on this see: http://www.fda.gov/iceci/compliancemanuals/compliancepolicyguidancem anual/ucm123236.htm)

. Therefore, although APHIS does not anticipate a tolerance issue, if bananas from the Philippines contain chlorpyrifos residue above the established tolerance, the bananas would be subject to enforcement action by FDA.

I nsecticide

- treate d bait sprays will be used in places of production when

fruit flies are detected at a level greater than 2 flies per trap per day. Bait

treatments are typically broadcast into the environment, targeted to the

area around the affected banana plantation. The bait contains a protein

that attracts fruit flies . The protein is mixed with a toxicant that kills any fruit flies that are attrac t ed to the bait. The toxicants commonly used in

insecticide

- treated bait for control of Med iterranean fruit fly are malat hion or spinosad. However, other ingredients may be used in the Philippines

.

Malathion is a broad-spectrum organophophate. It is used in aerial and ground bait spray appl ications to control fruit flies , and has very slight to

moderate toxicity to birds and mammals . It is of low phototoxicity to most plants. Terrestrial and aquatic invertebrates are at risk th roughout the treatment area because of high exposures and toxicity. Toxicity to

terrestrial invertebrates varies from moderate to severe

. The toxicity of malathion bait spray on honey bees is high. Malathion is considered slightly to very highly toxic to fish , and highly toxic to the aquatic life stages of amphibians, while its toxicity to aquatic invertebrates ranges

from moderately toxic to very highly toxic. Risk to nontarget organisms varies according to the size of the area treated and whether it is applied aerially or by ground. Targeted and ground applications of bait spray generally present lower risk s to birds, mammals

, and aquatic spec ies ( USDA –A PHIS , 2001).

Spinosad has low toxicity and risk to nontarget birds and mammals, however, is considered highly toxic to honey bees. Toxicity to other nontarget terrestrial invertebrates is varied

, and the toxicity to honey bees

decreases once a pplication residues have dried. Toxicity to fish is considered moderate while toxicity to aquatic invertebrates ranges from slightly toxic to highly toxic, depending on the test species. Aquatic

insects , such as mosquito larvae, are several times more se nsitive than aquatic crustaceans

, such as cladocerans (EPA, 1997 ; Thompson et al., 2000; Bond et al.

, 2004). 2. Insecticide

Treated Bait10 When using insecticide

- treated baits , the bananas are never in contact with

the treated bait . Therefore, regardless of the chemical used, bait

treatments would not cause human health risks to individuals in the

United States consuming the bananas or to the U.S. workers that may

handle the bananas

.

Under the systems approach alternative, mitigation measures are designed to prevent the introduction and dissemination of plant pests into or through

the continental United States as a result of the movement of bananas from the Philippines into the continental United States. In addition, residue

levels of chlorpyrifos on imported bananas have not bee n found to exceed tolerance levels established by EPA

.

NEPA requires that agencies analyze whether their action is related to other actions with individually insignificant but cumulatively significant impacts (40 CFR § 1508.27(b)(7)). NEPA regulations s tipulate that the analysis of the cumulative effects include “ . . .the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions” (40 CFR § 1508.7). Each individual action may not, of itself, have a significant effect; however, “[c]umulative impacts can result from individually minor but collectively significant actions taking place over a period of time” (40 CFR § 1508.7).

For the purposes of this analys is, one must consider the cumulative effects of the mitigation measures as well as any past or reasonably foreseeable

future actions that could increase the risk of introduction and establishment of quarantine plant pests as a result of the importation of

bananas into the continental United States. According to the risk management document ( USDA

– APHIS, 2010 ), the mitigations for the preferred alternative provide a highly effective level of phytosanitary protection. Therefore, the preferred alternative is not expected to increase any cumulative risks. In the future, additional countries may submit

requests t o the Unite d States to export bananas to the United States. Similarly, mitigations for any future proposals would be designed to remove the risks of introducing plant pests from importing these commodities; however, this would be analyzed in future environmental

documents.

An increase in cumulative impacts to human health in the United States are not expected from the preferred alternative as neither new chemical treatments nor an increase in chemical treatments are expected to occur as a result of the proposed systems approach. As previously discussed, with

the use of insect

- treated baits, bananas are never in contact with the pesticide. Regardless of the chemical used, bait treatments used in the Philippines would not cause human health risks to individuals in the

United States consuming the bananas or to the U.S. workers that may 3. Su mmary

4. Cumulative Impacts11 handle the bananas. Therefore, there would be no significant cumula tive

effect from bait treatments.

Regarding the use of chlorpyrifos- impregnated bags, cumulative impacts

to human health in the United States are also not expected . As previously mentioned, the primary ex porters of bananas to the United States are Guat emala, Ecuador, and Costa Rica (U.S. Departme nt of Commerce as cited by USDA–ERS, 2010). All three countries currently treat bananas

with chlorpyrifos -impregnated bags (Polidoro, et al., 2008, Smith, A., 2000, WRM, 2004). Chlorpyrifos is one of the most commonly used pesticides in worldwide banana production ( Wilson and Otsuki, 2004). Therefore, b ananas entering the United States from the Philippines under the proposed systems approach should not increase exposure of consumers or workers handling the ban anas to chlorpyrifos.



## IV

. Other Environmental Considerations

This analysis is being prepared in compliance with the National Environmental Policy Act of 1969 (NEPA). The APHIS NEPA implementing procedures require, to the fullest extent possible, the integration of all Federal environmental laws and E xecutive orders with the analysis o f environmental impacts (7 CFR § 372.7). Of the numerous

environmental review laws , Executive orders, and departmental or agency directives, this section focuses on two th at have possible relevance concerning potential plant, animal, or human health impacts under the

p referred a lternative

.


### A. Endangered Species Act

Section 7 of the Endangered Species Act and its implementing regulations require Federal agencies to consul t with the U.S. Fish and Wildlife Service (FWS) and/or the National Marine Fisheries Service to ensure their actions are not likely to jeopardize the continued existence of endangered or threatened species or result in the destruction or adverse modificati on of critical habitat. APHIS has considered the potential effects on endangered and threatened species and their habitats from the importation of bananas

from the Philippines into the continental United States . Based upon the integrated systems approach and additional mitigation measures required by the proposed rule, the prog ram has determined that the importation of

commercial ly produced hard, green bananas from the Philippines into the

continental United States would have no effect on any endangered or threatened species or their critical habitats.12 

### B. Executive Order 12114

Executive Order (EO) 12114, “Environmental Effects Abroad of Major Federal Actions,” was reviewed in evaluat ing the potential environmental impact to the Philippines of adopting the proposed systems approach.

This EO furthers the purpose of NEPA with respect to the environment outside the United States, its territories , and its possessions. Some objectives of this EO are to “provide information for use by decisionmakers, to hei ghten awareness of and interest in environmental concerns and, as appropriate, to facilitate environmental cooperation with foreign nations.” Potential effects to nations affected by implementation of the p referred alternative and to the global environmen t are to be

considered.

The chemical treatments required under the proposed systems approach

would take place in the Philippines before export. Implementation of the systems approach is not expected to have a significant effect on Philippine plants, ani mals, humans, or environment and, therefore, no circumstances that will trigger the need for special environmental review are involved in implementing the proposed systems approach.

The two chemical treatments that are mandated under this alternative are chlorpyrifos-impregnated bags and insectic ide- treated baits , if necessary.

The Philippines is already regularly using the chemical treatments that would be required under the proposed systems approach, therefore, no environmental effects are anticipate d. The Philippines’ Department of Agriculture 2010 pamphlet for farmers indicates that when three hands (10 or more bananas growing together) are visible , they should be sprayed with appropriate insecticides and fungicides to prevent thrips, other insects that may damage the fruits , and fungal diseases. Farmers are also told to bag the banana bunches when the last hand has emerged to protect the bananas from pests, as well as hasten maturity. Herbicides and

disinfectants are suggested in certain instance s (PHDA, 2010).

Insec tici de- tr e ated bait s are not specific to fruit flies and can attract and kill many nontarget insects. Also, there is the potential for indirect risk to wild mammals and birds from the loss of available invertebrate prey that

would oc cur after treatment. Risks from these types of effects are reduced for those birds and mammals that can forage outside of the treatment area ; recovery of most invertebrate populations that will occur within the banana plantation after treatment will ensur e that any impacts to mammals

and birds are short- term in nature. In addition, bait insecticide treatments would be localized and would only occur on those banana plantations that

exceed two fruit flies per trap per day, limiting impact to non target species

.13 

## V. Listing of Agencies and Persons
Consulted

U.S. Department of Agriculture Animal and Plant Health Inspection Service Policy and Program Development

Environmental and Risk Analysis Services, Unit 149 Riverdale, MD 20737

U.S. Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine Regulations, Permits and Manuals Regulatory Compliance and Coordination, Unit 156 Riverdale, MD 20737

U.S. Department of Agriculture Animal and Plant Health Inspe ction Service Plant Protection and Quarantine Phytosanitary Issues Management, Unit 140 Riverdale, MD 2073714 

## VI

. References

Bond, J.G., Marina, C.F., and Williams, T., 2004. The naturally derived insecticide spinosad is highly toxic to Aedes and Anopheles mosquito larvae. Medical and Veterinary Entomology. 18:50–56.

BPI —See Bureau of Plant Industry Bureau of Plant Industry

Bureau of Plant Industry Bureau of Plant Industry, 2005. Importation Of Banana ( Musa acuminata Cultivars and Hybrids) as Commercial Shipments of Fresh Mature Hard Green Fruit from the Philippines to Continental United States. A Qualitative, Pathway

- Initiated Risk Assessment for a Commodity. Republic of the Philippines Department of Agriculture Bureau of Plant Industry. 92 pp.

EPA —See U.S. Environmental Protection Agency

FAO —S ee Food and Agriculture Organization of the United Nations

Food and Agriculture Organization of the United Nations, 200 1. Pesticide

residues in food - 2000 evaluations. Part I - Residues. FAO Plant Production and Protection Paper, 165, 2001.

IPPC —S ee International Plant Protection Convention

International Plant Protection Convention , 2005. Requirements for the establishment of areas of low pest prevalence. ISPM No. 22. 10 pp.

Matlock , R.B. , and de la Cruz, R., 2003. Ants as indicators of pesticide impacts in banana. Environmental Entomology. 32: 816–829.

NAPPO —S ee North American Plant Protection Organization

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2004.17 Appendix 1. Response to comments

A comment was submitted by the Florida Department of Agriculture and Consumer Services’ Department of Plant Industry (FDACS DPI) on the proposed rule. FDACS DPI does not agree with the entry of fresh bananas from the Philippines into Florida because of the potential risk in importing three species of fruit flies ( Bactrocera musae

, B. occipitalis, and B. philippinensis ). Introduction of these fruit fly species would impact Florida’s agricultural crops.

Response: Of the three fruit fly species, APHIS only considers one species, B. musae , to pose a risk of infesting commercially produced Philippine bananas. There is no scientific evidence that the other two species will attack green bananas and will be ex ported to the United States from the Philippines. W hile it has been recorded that B. musae has been found on green bananas , there is no evidence that green bananas are a common or preferred host.

APHIS considers the mitigations against pe sts on bananas from the Philippines

, as described in the preferred alternative of this environmental

assessment , to be robust . There are multiple layers of safeguards, any one of which is sufficient to mitigate the risk posed by the fruit flies B. musae

, B. occipitalis , and B. philippinensis . These mitigations are based on those currently used in Central and South America for export of ban anas to the United States that have been effective in preventing fruit flies from entering into the United States. APHIS interception records going back to

1983 indicate that there have been no interceptions of fruit flies in commercially produced bananas from Central and South America. Two additional mitigations (fruit fly trapping and population control) were added specifically for the Philippines bananas program to address fruit fly

risk.