Importation of Bananas

(Musa spp.) from the 

Philippines into the 

Continental 

United States

Environmental Assessment,

April 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

April 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 156

Riverdale, MD 20737

__________________________________________________________

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__________________________________________________________

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must be registered by appropriate State and/or Federal agencies before they 

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__________________________________________________________

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

V. Listing of Agencies and Persons Consulted .............................. 13

VI. References ................................................................................ 14
1

I. Need for the 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 United 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 

requested that the United States amend 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 have 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

importation from the Philippines, and to determine mitigations which 

might be effective in combating 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). APHIS 

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 analysis 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 would 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 completion of the pest risk analysis and the risk management 

analysis for bananas from the Philippines, APHIS designed a systems 

approach that includes multiple independent phytosanitary risk reduction 

measures designed to mitigate the risk of the 14 pests of concern. These 

mitigations include monitoring, inspections, and chemical treatments. 

APHIS is evaluating the environmental impacts of two alternatives: (1) no 

action alternative; and (2) a systems approach for all 14 pests (the 

preferred alternative).

A. No Action

Under the no action alternative, the United States would continue to 

prohibit 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 commercially 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. This alternative is based upon an integrated systems approach 

incorporating 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 pests. 

APHIS’ pest risk assessment identified 14 pests of quarantine significance 

associated with the importation of bananas from the Philippines. These 

quarantine insects include—

• three fruit flies (Diptera: Tephritidae):

o Bactrocera musae (Tryon),

o Bactrocera occipitalis (Bezzi), and

o Bactrocera philippinensis Drew and Hancock;
3

• one long horned beetle (Coleoptera: Cerambycidae):

o Sybra alternans Wiedemann;

• two soft scales (Hemiptera: Coccidae):

o Ceroplastes rubens Maskell, and

o Coccus viridis (Green);

• eight mealybugs (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 outlines 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 quarantine pests from entering 

the United States with the importation of fresh, hard, green bananas from 

the Philippines (USDA–APHIS, 2010). 

The systems approach mandates—

Registered places of production. Bananas must be grown in places of 

production that are 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 until 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 specifying 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 released 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 after 
4

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 low prevalence 

production sites. Several species of Bactrocera that 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 

international 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 per 0.2 square kilometers (km2

) 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 Philippines. 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 Inspection. 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 fruit 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 phytosanitary 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 Inspection. Fruit must be 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 significant 

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 damage;

• 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; 

• Fruit 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. Environmental 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 the 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 preferred alternative, 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 United 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 bananas from 

the Philippines into the continental United 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 into 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 inspection, survey, and harvest practices 

have limited, if any, environmental impacts in the United States and,

therefore, are not discussed further in this document. However, chemical 

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 pesticide-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 exporters of bananas to the United States are Guatemala, 

Ecuador, and Costa Rica (U.S. Department of Commerce as cited by

USDA–ERS, 2010). These three countries already utilize chlorpyrifosimpregnated bags (Polidoro, et al., 2008, Smith, A., 2000, WRM, 2004). 

In fact, chlorpyrifos 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, 

chlorpyrifos-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. 

Individuals that 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 Health Effects

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 human 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 moderately 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, confusion 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. ChlorpyrifosImpregnated 

Bags
8

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, the EPA 

sets limits on the maximum amount of a pesticide residue that may legally 

be present in or on raw agricultural commodities in the United States. 

These limits are called “tolerances.” EPA bases tolerances 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–Agricultural 

Marketing Service, 744 samples of imported bananas were collected 

throughout the United States and tested for pesticide residues, including 

chlorpyrifos (USDA–ARS, 2008). Chlorpyrifos residues 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 Philippines,

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 Philippines. Since the

Philippines 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 systems approach. 

APHIS anticipates that different treatment methods were utilized as
9

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 (per section 402(a)(2)(B) and of the 

Federal Food, Drug, and Cosmetic Act (FFDCA)), it 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. 

Insecticide-treated 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 attracted to the bait. The toxicants commonly used in 

insecticide-treated bait for control of Mediterranean fruit fly are malathion 

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 applications 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 throughout 

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 risks to birds, mammals, and aquatic species

(USDA–APHIS, 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 application 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 sensitive than 

aquatic crustaceans, such as cladocerans (EPA, 1997; Thompson et al.,

2000; Bond et al., 2004). 

2. InsecticideTreated Bait 
10

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 been 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 stipulate 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 analysis, 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 to the United 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. Summary

4. Cumulative 

Impacts
11

handle the bananas. Therefore, there would be no significant cumulative 

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 exporters of bananas to the United States are 

Guatemala, Ecuador, and Costa Rica (U.S. Department 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, bananas entering the United States from the Philippines under 

the proposed systems approach should not increase exposure of consumers 

or workers handling the bananas 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 Executive orders with 

the analysis of environmental impacts (7 CFR § 372.7). Of the numerous 

environmental review laws, Executive orders, and departmental or agency 

directives, this section focuses on two that have possible relevance 

concerning potential plant, animal, or human health impacts under the 

preferred alternative.

A. Endangered Species Act

Section 7 of the Endangered Species Act and its implementing regulations 

require Federal agencies to consult 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 modification 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 program has determined that the importation of 

commercially 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 evaluating 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 heighten 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 preferred alternative and to the global environment 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, animals, 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 insecticide-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 anticipated. 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 instances (PHDA, 2010).

Insecticide-treated baits 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 occur 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 ensure 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 nontarget 

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 Inspection Service 

Plant Protection and Quarantine 

Phytosanitary Issues Management, Unit 140 

Riverdale, MD 20737 
14

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—See Food and Agriculture Organization of the United Nations

Food and Agriculture Organization of the United Nations, 2001. Pesticide 

residues in food - 2000 evaluations. Part I - Residues. FAO Plant 

Production and Protection Paper, 165, 2001. 

IPPC—See 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—See North American Plant Protection Organization

National Toxicology Program, 1992. Executive summary of safety and 

toxicity information: Chlorpyrifos. February 5, 1992

North American Plant Protection Organization, 2003. Guidelines for the 

establishment, maintenance and verification of areas of low pest 

prevalence for insects. RSPM No. 20, Ottawa, Ontario, Canada. 16 pp.

NTP—See National Toxicology Program

PHDA—See Philippine Department of Agriculture

Philippine Department of Agriculture, 2010. Banana. [Online]. 

Available: www.da.gov.ph/tips/banana.pdf [2011, Mar. 30].
15

Polidoro, B.A., Dahlquist, R.M., Castillo, L.E., Morra, M.J., E. 

Somarriba, E., and Bosque-Pérez, N.A., 2008. Pesticide application 

practices, pest knowledge, and cost-benefits of plantain production in the 

Bribri Cabécar Indigenous Territories, Costa Rica. Environmental 

Research. 108: 98–106. 

Simmonds, N.E., 1966. Bananas. 2nd edition. Longman, London. 512 pp.

Smith, A., 2000. Pesticides News. No. 48, page 9. June 2000.

Thompson, G.D., Dutton, R., and Sparks, T.C., 2000. Spinosad––a case 

study: an example from a natural products discovery programme. Pest 

Mgt. Sci. 56: 696–702.

USDA–APHIS—See U.S. Department of Agriculture, Animal and Plant 

Health Inspection Service

USDA–ERS—See U.S. Department of Agriculture, Economic Research 

Service

USDA–AMS—See U.S. Department of Agriculture, Agriculture 

Marketing Service

U.S. Department of Agriculture, Agricultural Marketing Service, 2008. 

Pesticide data program annual summary, calendar year 2007. [Online]. 

Available: 

http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5074

338 [2011, June 8].

U.S. Department of Agriculture, Animal and Plant Health Inspection 

Service, 2009. Importation of banana, Musa spp., as fresh, hard green 

fruit from the Philippines to the continental United States: A qualitative 

pathway-initiated risk assessment—July 21, 2009. U.S. Department of 

Agriculture, Animal and Plant Health Inspection Service, Plant 

Epidemiology and Risk Analysis Laboratory, Raleigh, NC.

U.S. Department of Agriculture, Animal and Plant Health Inspection 

Service, 2010. Risk management document: Importation of banana, Musa

spp., as fresh, hard green fruit from the Philippines to the continental 

United States. November 16, 2010. Riverdale, MD.

U.S. Department of Agriculture, Animal and Plant Health Inspection 

Service. 2001. Fruit fly cooperative control program, final environmental 

impact statement—2001. [Online]. Available: 

http://www.aphis.usda.gov/plant_health/ea/downloads/fffeis.pdf [2008, 

April 14].
16

U.S. Department of Agriculture, Economic Research Service, 2010. Fruit 

and tree nuts outlook. May 28, 2010. [Online]. Available: 

http://www.ers.usda.gov/publications/fts/2010/May05/FTS342.pdf [2011, 

Mar. 28].

U.S. Environmental Protection Agency, 2002. Chlorpyrifos facts. 

[Online]. Available: 

http://www.epa.gov/oppsrrd1/REDs/factsheets/chlorpyrifos_fs.htm 

[2002, February].

U.S. Environmental Protection Agency, 2000. Office of Pesticide 

Programs. Human health risk assessment: Chlorpyrifos. [Online]. 

Available: 

http://www.epa.gov/scipoly/sap/meetings/2008/september/hed_ra.pdf

[2000, June].

U.S. Environmental Protection Agency, 1999. Organophosphate 

pesticides in food – A primer on reassessment of residue limits. [Online]. 

Available: 

http://psych.umb.edu/faculty/adams/fall2005/US%20EPA%20-

%20Organophosphate%20Pesticides.htm [1999, May].

U.S. Environmental Protection Agency, 1997. Office of Pesticide 

Programs, 1997. Spinosad: Fact sheet for use on cotton. 10 pp.

Wilson, J.S., and Otsuki, T., 2004. To spray or not to spray: Pesticides, 

banana exports, and food safety. Food Policy. 29: 131–146.

World Rainforest Movement, 2004. Forest destruction for export: Banana 

plantations in Latin America. WRM Bulletin. Issue No. 85, August, 

2004.