# 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 Prog rams

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 1 56
Riverdal e, 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

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

V. Listing of Age ncies and Persons Consulted

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

VI. References

................................ ................................ ................ 141 

## I. Need for the Proposed Action

Under the Plant Protection Act, the United States Department of Agriculture (USD A), 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.

T he National Plant Protection Organization ( NPPO ) of the Philippines has requested that the United States a mend its regulations to allow fresh, hard

green bananas to be imported in to 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 import ation from the Philippines , and to determine mitigations which might be effective in combat ing the pes t risk, APHIS analyzed the Philippine proposal and prepared a pest risk assessment (USDA

– APHIS

, 200 9 ) and a risk management analysis ( USDA

– APHIS

, 2010 ). APHIS incorporated pest interception data, information from the NPPO of the Philippines, and peer

- revi ewed scientific literature into the pest risk analysis ( USDA

– APHIS , 200 9 ) and the risk management analysis ( USDA

– APHIS , 20 10 ).

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 we ll 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 pla nt pest into the United States.2 

## II. Alternatives

After completi o n 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 red uction 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 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 n o a ction 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 tha t the United States may import bananas from the Philippines

, under certain conditions

, without increasing the risk of introduction of quarantine pests ( USDA

– APHIS , 200 9 ; USDA

– APHIS,
2010 ). The n o a ction alternative, therefore, will not satisfy the need fo r 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

,
s ubject to specific mitigation measures. Banana species to be imported
include Musa acuminata cultivars and M. acuminata x M. balbisiana hybrids. Th is alternative 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 i mportation of bananas from the Philippines. These quarantine insects include

—

• t hree fruit flies (Diptera: Tephritidae):

o Bactrocera musae (Tryon)

,

o Bactrocera occipitalis (Bezzi)

, and

o Bactrocera philippinensis Drew and Hancock ;3 • o ne long horned beetle (Cole optera: Cerambycidae):

o Sybra alternans Wiedemann ;

• t wo soft scales (Hemiptera: Coccidae):

o Ceroplastes rubens Maskell, and

o Coccus viridis (Green);

• e ight mealybugs (Hemiptera: Pseudococcidae):

o Dysmicoccus neobrevipes Beardsley

,

o Geococcus coffeae Green

,

o M aconellicoccus hirsutus (Green)

,

o Planococcus lilacinus (Cockerell)

,

o Planococcus minor (Maskell)

,

o Pseudococcus cryptus Hempel

,

o Rastrococcus invadens Williams

, and

o Rastrococcus spinosus (Robinson) (USDA

– A PHIS, 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 quarantine 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 are registered with the NPPO of the Philippines. Registration of production sites will allow trace b ack 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. Harves ted 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 pro duction, 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 ac companying 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 released for entry into the United States.

Place of production pest management program including cov ering 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 population s 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 eligi ble for export to the United States.

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

, including Bactrocera musae, B. occipitalis, and B. philippinensis

, are
prese nt 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 contin uing 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 ( km 2 ) by the NPPO of the Philippines. APHIS

- approved traps baited with AP HIS

approved 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 h ard 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 designe d to exclude fruit flies and other pests of quarantine concern. The packinghouse operations for export of bananas must be monitored b y the NPPO of the Philippines. Bananas intended for United States ’ markets must be properly segregated and labeled from b ananas 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 th e 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 dire ction 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 bein g 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 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 significant interceptions of quarantine pests occur, APHIS may ask the NPPO of the Philippines to suspend t hose 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 all ow 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 infes tation;

• 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 transp ort 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 ins pectors 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 t he 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 requiremen ts 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
banan a s from the Philippines would be allowed into the U nited 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 th e 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 Un ited States while continuing to provide protectio n 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

qu arantine pests that might follow the pathway of imported bananas from the Philippines.

Operational procedures

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

, therefore

, are not disc ussed 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 pestic ide

- 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,

t he primary ex porters of bananas to 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 hlorpyrifos is one of the most commonly used pesticides in worldwide banana production ( Wilson and Otsuk i, 2004 ).

C hlorpyrifos

- impregnated bags are the industry standard practice for the Philippines (BPI, 2005). According to the NPPO of the Philippines,

c hlorpy rifos

- impregnated polyethylene bags are used to cover the fruit bunches after bunch spray to pr event mealybug, scale

, and fruit fly insect
infestation on the fruit. Additional c hlorpyrifos

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

Potenti al environmental effects from imported insecticide

- treated bananas
include human health risk s to individuals exposed to the treated bananas.
Ind ividuals that would be exposed may include U.S. consumers that would eat imported bananas

, and U.S. workers tha t 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 u sed 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 e xposures. 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. Chlorpyrifos

Impregnated Bags8 and its primary metabolite, 3,5,6

- trichloro

- 2

- pyridinol (TCP) , were found
to be re adily 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 o f a pesticide residue that may legally be present in or on raw agricu ltural commodities in the U nited S tates

. These limits are called “tolerances

. ” EPA bases t olerances on the potential risks of the residues to human health. The chlorpyrifos tolerance

s et 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). Chl orpyrifos resid u es 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 expect s that chlorpyrifos residues on Philippine bananas would similarly be under the EPA tolerance level. The imported bananas
included in the above stud y were subjec t to a systems approach similar to the approach that w ould 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)

. I n 198 3 in the Philippines, bananas were covered weekly with chlorpyrifo s

- 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 p pm )

.

While t he 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 us ed in 1983 are similar to the methods that would be used under the proposed s ystems approach. APHIS anticipates that different treatment methods were utilized 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 th e Philippines contain chlorpyrifos residue above the established tolerance, the bananas would be subject to enforcement action by FDA.

I nsecticide

- 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 ki lls any fruit flies that are attrac t ed to the bait

. T he toxicant s commonly used in
insecticide

- treated bait for control of Med iterranean 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 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 r oughout 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 hig hly 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 w hether it is applied aerially or by ground

. Targeted and ground applications of bait spray generally present lower risk s to birds, mammals

, and aquatic species ( 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 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; Bon d 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 bana nas 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 t he 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 whethe r 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 wh ich 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 reas onably 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

requ ests 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 futur e 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 o f 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 t o individuals in the
United States consuming the bananas or to the U.S. workers that may 3. Summary

4. Cumulative Impacts11 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, t he primary ex porters of bananas to the United States are Guatemala, 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)

. C hlorpyrifos is one of the most commonly used pesticides in worldwide banana production ( Wilson and Otsuki, 2004 ). Therefore, b ana nas 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 E xecutive orders with the analysis o f environmental impacts (7 CFR § 372.7). Of the numerous
environmental review laws

, E xecutive 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

p r eferred a lternative

. 

### 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 ens ure 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 sp ecies 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 i mportation 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) 12 114 , “ 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 E O furthers the purpose of NEPA with respect to the environme nt outside the United States, its territories

, and its possessions. Some objective s 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 enviro nmental cooperation with foreign nations.” Potential effects to nations affected by implementation
of the p referred a lternative and to the global environment are to be
considered.

The chemical treatments required under the proposed systems approach
woul d 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 specia l 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 a lready 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)

.

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

- term in nature. In addition, bait insecticide tr eatments 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 P lant 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 Regulatio ns, 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
Riverdal e, MD 2073714 

## VI

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