1 **United States Department of Agriculture Animal and Plant Health Inspection Service**  **Plant Protection and Quarantine**



## Importation of Chipilin ( **Crotalaria longirostrata Hook and**  **Arn.) from Guatemala**  **into the Continental United States**

**Risk Ma nagem**  **ent Document**
**January 1**  **8, 201 2** 

**Plant Health Programs (PHP) Regulations, Permits and Manuals (RPM)**  **Contact Person: Claudia Ferguson** 2

**Introduction**
In response to a request for market access to import fresh leaves of chipilin ( Crotalaria lo ngirostrata Hook and Arn.) from El Salvador in to the c ontinental United States , the United States Department of Agriculture (USDA)’s Animal and Plant Health Inspection Service (APHI S) prepared a pest risk assessment (PRA) as per the Guidelines for Pathway

-Initiated Pest Risk Assessment

s (USDA, 2000)
. Subsequently , Guatemala submitted a request for market access in 2011. The original PRA assessed the risk for all species of Crotalaria in the chipilin
growing region near El Salvador, which includes Costa Ri ca, Guatemala, Honduras , Nicaragua, and Southern Mexico. The PRA included pests distributed in the entire Crotalaria spp. growing regio n, which added pests known to occur in Costa Rica , Guatemala, Honduras, Nicaragua, and S outhern Mexico to those in El Sa lvador. Th e pest risk assessment Importation of Fresh Leaves of Chipilin, Crotalaria longirostrata

, from El Salvador into the Continental United States (USDA, 2010 ) found two quarantine pests of concern that could follow the pathway of fresh leaves: Phak

opsora meibomiae (Arthur) Arthur, is rated with a high pest risk potential, and Uromyces crotalariae (Arthur) J.W. Baxter, is rated with a medium pest risk potential. **Standard Industry Practices** The information on standard industry practices was provi ded by MAG (Ministerio de Agricultura y Ganadería), El Salvador ; they are considered simple and standards practices. The product is harvested by hand, then it is sorted (culled) for quality and pest s problems , washed in a weak bleach solution, air dried , and bundled in portions weighing about 250 grams; finally the leaves are place d in plastic bags for shipping (MAG, 2005)
. **Risk Management Measures** The following risk management measures must be followed for chipilin from Guatemala to be imported into th e United States:

 Chipilin leaves must be imported as commercial consignments only
.
 Each consignment of chipilin must be accompanied by a phy tosanitary certificate (PC) issued by the National Plant Protection Organization (NPPO ) of Guatemala , with an addi tional declaration (AD) stating: Chipilin in this consignment has been inspected and found free of Phakopsora meibomiae and Uromyces crotalariae
.
 Each consignment is subject to inspection upon arrival at the port of entry to the United States.3

**Evidence for the Effective Removal of Pest of Concern from the Pathway**  B y restricting the importation of chipilin to commercial consignments only , we will ensure that appropriate sanitation , pest management, culling and packing practices are in place to prevent the introduction of Phakopsora meibomiae and Uromyces crotalariae
. As part of the process of commercially picking, processing and packaging, chipilin that is damaged or where pests or diseases are present, will be culled. The NPPO will inspect the chipil in to be exported to issue the PC with AD which certifies the product is free of Phakopsora meibomiae and Uromyces crotalariae
. In spection ensures that various stages of any pest or disease that are present will be detected; rust signs and sy mptoms are co nspicuous enough to be found and culled during inspections (Cummins and Hiratsuka, 1983). Inaddition, the chipilin will be subject to inspection for pests at the port of entry to the United States by

officers of Customs and Border Protection (CBP). The PC with the AD will alert CBP inspectors to look for the quarantine pests of concern. I nspection is an effective method for detecting pests and is a primary method of preventing quarantine pests from entering the United States ( Cav ey , 2003; Wittenberg an d Cock, 2001)
. **Conclusion** Phakopsora meibomiae and Uromyces crotalariae were identified as following the pathway of fresh leaves of chipilin. APHI S believes that the phy tosanitary measures proposed in this document will result in the effective remova l of the quarantine pests associated with the importation of fresh leaves of chipilin from Guatemala into the continental United States. In spection is considered effective at finding external feeding pests and excluding infested shipments from entering co mmerce (Cavey , 2003; Wittenberg and Cock, 2001 ); also, rust signs and sy mptoms are conspicuous enough to be found and culled during inspections. The phy tosanitary certificate with the additional declaration stating freedom of both rust quarantine pests requires the Guatemala NPPO to conduct an inspection and also raises the awareness of the pests listed in the AD of those requirements for our port of entry inspection.
**Authors** José R. Hernández Senior Risk Manager Walter P. Gould Senior Risk Manager4

**References:** Cavey , J.F. 2003. Mitigating introduction of invasive plant pests: the APHI S
- PPQ Mission. From: Chapter 13, pp. 350
- 361 in Ruiz, G.M and J.T. Carlton. 2003. I nvasive species: vectors and management strategies. I sland Press, Washingt on, D.C. 518p. Cummins , G. B., and Y. Hiratsuka. 1983. Il lustrated genera of rust fungi. American Phy topathological Society , St. Paul, MN. MAG, 2005. In forme técnico sobre el cultivo del Chipilin ( Crotalaria longirostrata ). Ministerio de Agricultura y Ganadería (MAG). Personal communication to Centro de Excelencia Fitsanitaria. 2005. USDA. 2000. Guidelines for Pathway
- In itiated Pest Risk Assessments, Version 5.02. USDA
APHI S, PPQ
. Permits and Risk Assessment
. Commodity Risk Analy sis Branch . 3 0 pp. USDA. 2010
. Im portation of Fresh L eaves of Chipilin, Crotalaria longirostrata , from El Salvador into the Continental United States. Qualitative , Pathway
- In itiated Pest Risk Assessment. USDA, APHI S, CPHST, PERAL , Raleigh, NC. 25 pp. Wittenberg , R. and M.J.W. Cock. 2001. I nvasive Alien Species: A toolkit of best prevention and management practices. CABI publishing, CAB I nternational, Wallingford, Oxon, UK. 228 pp.