UNIFORM INTER-DEPARTMENTAL 

PROCEDURES FOR CLEARING AND 

CONTROLLING SHIPMENTS AT POE

by

Stephen Bullington

Acting Domestic Diagnostic Coordinator

USDA APHIS PPQ

(PPQ and CBP coordination and what 

does CBP do when a pest is found)
KEEP IN MIND

1. Even though specific actions that follow may take 

place away from the port, they are all integral to 

clearing and controlling shipments there

2. These actions involve coordinating a variety of 

actors—CBP, PPQ Port Operations, the SEL, NIS, and 

occasionally CPHST

3. Taken as a whole, these actions are preemptive—

cargo infested with exotic pests is never allowed to 

enter commerce

4. This described routine is uniform—it is followed by 

80+ Area Identifiers at over 327 official ports and 16 

Plant Inspection Stations
WITH CBP

1. Cargo inspected by CBP

2. If potential pest found, CBP puts hold on cargo

3. Potential pest specimen submitted to PPQ Area 

(Port) Identifier
WITH AREA IDENTIFIER

1. Area Identifier issues 309 for specimen in Pest 

ID; this 309 contains all of the relevant 

information for the interception—date, number 

of specimens and life stages of the potential 

pest, country of origin, inspected host, etc.

2. Then puts most unambiguous name on 

specimen he/she can--ideally a species name
WITH AREA IDENTIFIER

1. If ID is to species and he/she has authority for 

that species, that ID is final

2. In Pest ID each taxon (family, genus, or species) 

name is considered as either “Reportable” or 

“Non-Reportable”
“PEST” STATUS--1

1. NON-REPORTABLE—This means that we can 

release the hold on the cargo and let it enter 

commerce, as the organism is either NOT a pest, 

or is a pest that is native or already established

Remember, PPQ is tasked with keeping out 

exotic pests, i.e. those that are not found here—

we have no legal mandate to insure that 

commodities are free of native or established 

pests
“PEST” STATUS--2

1. REPORTABLE—This means we need to look 

closer at the specimen and the situation in 

which it was intercepted, before we can arrive at 

a quarantine decision

For a Reportable taxon two quarantine decisions 

are possible:

1. ACTION—Mitigation of some type is mandatory

2. NO ACTION—the shipment is treated as if the 

interception was Non-Reportable
WITH AREA IDENTIFIER

1. If Area Identifier has authority for an ID, they 

then decide course of action and update 309 

with it. Options for “Action” include:

 Treatment

 Destruction

 Return

 FRSMP Pest

2. If ID is to family or genus, or identifier does not 

have authority for that species, it is 

preliminary, and the specimen is submitted to 

appropriate National Specialist for a final ID. In 

other words, the 309 becomes an “Urgent”
A WORD ON PRIORITY

(and some other terms)

1. URGENT—cargo on hold awaiting ID; turnaround time within 24 hours

2. PROMPT—important for some other reason; 

turn-around time a few weeks

3. ROUTINE—can ID at leisure

4. DIGITAL—special Urgent where photos are sent 

instead of specimen
WITH NATIONAL SPECIALIST

1. National Specialists located at several places: at 

SEL (Entomology) in either Beltsville or at the 

Smithsonian, or with NIS in Beltsville 

(Entomology, Botany, Mycology), or with NIS in 

Philadelphia (Malacology)

2. National Specialist identifies specimen

3. Adds ID to 309 record in Pest ID Database
AT NIS HEADQUARTERS

1. Updated Urgent 309s automatically sent to NIS; we get 

50-100/day

2. NIS personnel decide course of action and then note that 

on 309

 Treatment

 Destruction

 Return

 FRSMP Pest

 Release

3. NIS notifies Area Identifier of selected action by FAX
WITH CBP AGAIN

1. Area Identifier notifies CBP of final ID and NIS 

recommendation

2. CBP complies with recommendation

3. EAN issued if cargo not released
SUMMARY

• Inspections are ALWAYS responsibility of CBP

• In some cases both Final ID of potential pest and 

Quarantine Decision are responsibility of PPQ Area 

Identifier

• In other cases Final ID responsibility of National 

Identifier and Quarantine Decision are responsibility 

of NIS

• Compliance with and implementation of Quarantine 

Decision are ALWAYS responsibility of CBP
QUESTIONS?