United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Risk Management Document

Importation of Fresh Commercial Avocado (Persea americana

P. Mill.) Fruit from Peru into the Continental United States

July 9, 2009

Plant Health Programs (PHP)

Regulations, Permits and Manuals (RPM)

Contact Person: Alex Belano
Rev. 7 July 9, 2009 3

Introduction

The National Plant Protection Organization (NPPO) of Peru, Servicio Nacional de Sanidad 

Agraria (SENASA), submitted a market access request in 2000 to the United States Department 

of Agriculture’s Animal and Plant Health Inspection Service (USDA-APHIS) to export fresh

fruit of avocado (Persea americana P. Mill.) of the variety “Hass” to the continental United 

States (USDA, 2008a). Currently, importation of fresh avocado fruit from Peru by the United 

States is not authorized by 7 CFR §319.56. A pathway-initiated pest risk assessment was 

prepared by APHIS Plant Protection and Quarantine (PPQ) to identify the unmitigated pest risks

associated with importation of fresh Hass avocado fruit from Peru (USDA, 2008a).

The risk assessment identified the following quarantine pests (two species of fruit fly and a fruitboring moth) as having a high unmitigated risk potential:

Anastrepha fraterculus (Wiedemann) (Diptera: Tephritidae)

Ceratitis capitata (Wiedemann) (Diptera: Tephritidae)

Stenoma catenifer Walsingham (Lepidoptera: Oecophoridae)

The risk assessment identified the following pests (one soft scale and one mealybug) as having a 

medium unmitigated risk potential.

Coccus viridis (Green) (Hemiptera: Coccidae)

Ferrisia malvastra (McDaniel) (Hemiptera: Pseudococcidae)

The risk assessment identified the Potato Tuber Spindle viroid as having a high unmitigated risk 

potential; however, an additional analysis for the Likelihood of Establishment of the pathogen 

entering on avocados for consumption estimated the probability to be Low (Appendix 2, USDA, 

2008a) therefore, no mitigation measures are required against potato spindle tuber viroid.

APHIS-PPQ pest risk assessment guidelines (USDA, 2000) suggest that, for quarantine pests 

given an overall high or medium risk potential rating, phytosanitary measures beyond standard 

port-of-entry inspection are recommended to mitigate pest risk. Quarantine pests estimated to 

present a low risk typically will not require specific mitigative measures; the port-of-entry 

inspection, to which all imported commodities are subject, can be expected to provide sufficient

phytosanitary security.

The proposed importation of fresh avocado fruit from Peru, if approved, would be regulated by 

amendment to existing fruit and vegetable import regulations (7 CFR §319.56). Pest risk 

management is the process of identifying ways to react to a perceived risk, evaluating the 

efficacy of these actions, and identifying the most appropriate options (IPPC, 2004). This 

document outlines phytosanitary measures and provides evidence of their efficacy in preventing

the introduction of quarantine pests. The appropriate level of protection may be achieved through 

the application of a single phytosanitary measure, such as establishment of pest-free places of 

production or a quarantine treatment, or a combination of measures in a systems approach. 

Standard industry practices for Peruvian avocados include that the fruit is subjected to postharvest treatments, such as “cleaning from dirt and dust and washing” (USDA, 2008a). These 
Rev. 7 July 9, 2009 4

practices mitigate risks from surface pests such as Coccus viridis and Ferrisa malvastra. 

Risk Management Measures - Systems Approach for Peruvian avocados

The importation of avocados from Peru will only be permitted when they are grown and 

processed under a systems approach including the following risk management measures. 

Mitigation measures for all pests:

Monitoring and Oversight

The NPPO of Peru must provide a workplan to APHIS that details the activities that the NPPO of 

Peru will, subject to APHIS’ approval of the workplan, carry out to meet the requirements of the 

systems approach. APHIS will be directly involved with SENASA in monitoring and auditing 

implementation of the systems approach. 

The NPPO of Peru must visit and inspect registered places of production monthly, starting at 

least two months before harvest and continuing until the end of the shipping season, to verify 

that the growers are complying with the requirements of the systems approach. 

In addition to conducting inspections at the packinghouses, the NPPO of Peru must monitor 

packinghouse operations to verify that the packinghouses are complying with the requirements of 

the systems approach.

 

If the NPPO of Peru finds that a place of production or packinghouse is not complying with the 

requirements of the systems approach, no fruit from the place of production or packinghouse will 

be eligible for export to the United States until APHIS and the NPPO of Peru conduct an 

investigation and appropriate remedial actions have been implemented. 

The NPPO of Peru must review and maintain all forms and documents related to export program 

activities in places of production and packinghouses for at least 1 year and, as requested, provide 

them to APHIS for review. 

Requirements for places of Production

Registered places of production. Avocados must be grown in places of production that are 

registered with the NPPO of Peru. The NPPO of Peru will visit and inspect the production sites 

monthly, starting two months before harvest, and continue until the end of the shipping season. 

The personnel conducting the trapping and pest surveys must be hired, trained, and supervised by 

the NPPO of Peru. The NPPO of Peru will certify that each place of production has effective 

fruit fly trapping programs and follows pest control guidelines, when necessary, to reduce 

regulated pest populations. APHIS may monitor the production sites if necessary. 

Grove sanitation. Avocado fruit that has fallen from the trees must be removed from the 

production site at least once every seven days, starting two month before harvest and continuing 

through the end of the harvest, and may not be included in field containers of fruit to be packed 
Rev. 7 July 9, 2009 5

for export. Removal of fallen fruit removes pests from the places of production.

Traceability. Harvested avocados 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 avocados were grown must remain identifiable when the fruit leaves the grove, at the 

packinghouse, and throughout the export process. The fruit must be moved to the packinghouse 

within three hours of harvest or must be protected from fruit fly infestation until moved.

Packinghouse Requirements. 

Avocados must be packed within 24 hours of harvest in an insect-exclusionary packinghouse. 

The packinghouse must be registered with the NPPO of Peru. All openings to the outside of the 

packinghouse must be covered by screening with openings of not more than 1.6 mm or by some 

other barrier that prevents pests from entering. The packinghouse must have double doors at the 

entrance to the facility and at the interior entrance to the area where the avocados are packed. 

The fruit must be safeguarded by an insect-proof screen or plastic tarpaulin while in transit to the 

packinghouse and while awaiting packing. Fruit must be packed in insect-proof cartons or 

containers, or covered with insect-proof mesh or a plastic tarpaulin for transport to the United 

States. These safeguards must remain intact until arrival in the United States. During the time the 

packinghouse is in use for exporting avocado fruit to the United States, the packinghouse may 

only accept fruit from registered, approved production sites based on this systems approach.

Phytosanitary Inspection. 

A biometric sample of avocado fruit from each place of production must be inspected in Peru by 

the NPPO of Peru following any post-harvest processing. A biometric sample at a rate to be 

determined by APHIS will be visually inspected for all quarantine pests including Coccus viridis

and Ferrisia malvastra, and a portion of the fruit will be cut open to detect internal pests, such as 

fruit flies and Stenoma catenifer. 

Fruit presented for inspection at the port of entry to the United States must be identified in the 

shipping documents accompanying each lot of fruit to specify the production site or sites, in 

which the fruit was produced, and the packing shed or sheds, in which the fruit was processed. 

This identification must be maintained until the fruit is released for entry into the United States.

A biometric sample will be visually inspected for quarantine pests, and a portion of the fruit will 

be cut open to detect any internal pests, such as fruit flies and Stenoma catenifer.

Phytosanitary Certificate. Each consignment of fruit must be accompanied by a phytosanitary 

certificate issued by NPPO of Peru and providing an additional declaration stating that the fruit 

in the consignment has been produced in accordance with systems approach requirements for 

Peru avocados and is free of quarantine pests.

Mitigation measures specific for certain pests:

Pest free places of production for Stenoma catenifer
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Avocados to be exported to the United States must be grown in pest free places of production for 

Stenoma catenifer. Establishment and maintenance of pest-free places of production must be in 

accordance with international standards (e.g., IPPC, 1996, 1999; NAPPO, 2004). APHIS must 

approve the survey protocol used to determine and maintain pest free status, as well as protocols 

for actions to be performed upon detection of a pest. The NPPO of Peru has established a survey 

program for Stenoma catenifer. APHIS has reviewed this data and determined that the 

production sites where avocados are grown qualify as pest free places of production. Pest free 

places of production are subject to audit by APHIS to verify their status.

To maintain their status as pest free places of production, departamentos (25 regional 

subdivisions of Peru) in which avocados for export to the United States are grown must be 

surveyed by the NPPO at least once no more than two months prior to the harvest season 

(March-August) and found to be free from infestation by Stenoma catenifer. Surveys will include 

representative areas from all parts of each registered place of production. All fruit must be either 

from the upper half of each tree or from the ground, and will be cut and examined for the 

presence of eggs and larvae of S. catenifer in the pulp or seed, and eggs in the pedicel. A 

biometric sample of fruit, the number to be agreed upon by APHIS and the NPPO, must be cut 

for each place of production,

Detection of one or more Stenoma catenifer during an annual survey or during any other 

monitoring or inspection activity will result in immediate suspension of the affected orchard 

from the export program until appropriate measures to reestablish pest freedom, agreed upon by 

the NPPO of Peru and APHIS, have been taken. These measures may include further delimiting 

surveys, appropriate pesticide treatments, and removal of infested host material. The NPPO of 

Peru keeps records of Stenoma catenifer detections for each place of production, updates the 

records each time the places of production are surveyed, and makes the records available to 

APHIS inspectors upon request. The records must be maintained for at least 1 year after the 

harvest.

Mitigation measures for Anastrepha fraterculus: Avocados for export can originate from pest 

free places of production or places of low pest prevalence (ALPP).

Anastrepha fraterculus Option 1: Pest Free Areas

Establishment and maintenance of pest-free areas must be in accordance with international 

standards (e.g., IPPC, 1996, 1999; NAPPO, 2004). APHIS must approve the survey protocol 

used to determine and maintain pest free area status, as well as protocols for actions to be 

performed upon detection of a pest. Pest free areas are subject to audit by APHIS to verify their 

status.

Anastrepha fraterculus Option 2: Low prevalence 

The only records of this fruit fly species as infesting avocados are unverified references in old 

literature (Ovruski et al 2003; White and Elson-Harris, 1992). Hass avocados are known to be 

poor hosts to several species of Anastrepha (Aluja et al., 2004). Low prevalence will be used as 

part of a systems approach to mitigate risk from this fruit fly.
Rev. 7 July 9, 2009 7

Procedures for the establishment and maintenance of areas of low pest prevalence must comply 

with international standards (NAPPO, 2003; IPPC, 2005).

Beginning at least 1 year before harvest begins and continuing through the completion of 

harvest, trapping in the places of avocado production for Anastrepha fraterculus must be 

conducted with at least 1 trap per 0.2 km2. APHIS-approved traps baited with APHIS-approved 

baits must be used and serviced at least once every 2 weeks. If more than 0.7 FTD (number of 

fruit flies per trap per day) of this fruit fly is trapped, pesticide bait treatments must be applied in 

the affected place of production in order for the place of production to remain eligible to export 

avocados. The NPPO keeps 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. 

The records must be maintained for at least 1 year.

Mitigation measures for Ceratitis capitata: Avocados for export can originate from pest free

areas or be treated with an APHIS approved quarantine treatment.

Ceratitis capitata Option 1: Pest Free Areas

Establishment and maintenance of pest-free areas must be in accordance with international 

standards (e.g., IPPC, 1996, 1999; NAPPO, 2004). APHIS must approve the survey protocol 

used to determine and maintain pest free area status, as well as protocols for actions to be 

performed upon detection of a pest. Pest free areas are subject to audit by APHIS to verify their 

status.

Ceratitis capitata Option 2: Quarantine Treatments

Methyl bromide fumigation (Schedule T101-c-1), cold treatment (Schedule T107-a), and methyl 

bromide fumigation followed by cold treatment (Schedules T108-a1, a2, a3) are all approved for 

disinfesting avocado of C. capitata (USDA, 2008b). Exposure to methyl bromide may result in 

injury to the fruit, and should be monitored carefully. Under the combined fumigation and cold 

treatment, methyl bromide concentration and periods of fruit exposure to the gas are reduced, 

potentially lowering the risk of fruit damage. All treatments must be applied according to 

specifications in the APHIS-PPQ Treatment Manual (USDA, 2008b), and must be conducted in 

facilities registered with the NPPO of Peru and with oversight by APHIS personnel.

Consequences if certain pests are found in shipments:

If Coccus viridis or Ferrisa malvastra are found in a shipment, that lot of fruit may not be 

exported. If a single Ceratitis capitata immature stage is found in a shipment from a pest free 

place of production, this will result in immediate suspension of the affected place of production

from the export program until the source of the infestation is identified and the infestation is 

eradicated. If a single Ceratitis capitata larva is found in a shipment from a pest free place of 

production (either by the NPPO in Peru or at the United States port of entry), the fruit may be 

imported into the United States only if it is treated with an approved quarantine treatment 

monitored by APHIS.
Rev. 7 July 9, 2009 8

If a single Anastrepha fraterculus fruit fly larva or Stenoma catenifer larva is found during 

inspection by the NPPO or at the port of entry, the entire lot of fruit will be prohibited from 

export, and the place of production producing that fruit will be suspended from the export 

program until appropriate measures, agreed upon by the NPPO of Peru and APHIS, have been 

taken. If these pests are detected at a United States port of entry the fruit must be destroyed or 

re-exported.

Efficacy of Risk Management Measures

Establishment of pest-free places of production obviates the need for post-harvest commodity 

treatments to achieve phytosanitary security (IPPC, 1996, 1999). Pest free areas have been used 

successfully to prevent infestation by Ceratitis capitata of fruits in Argentina, Australia, Belize, 

Brazil, Chile, Ecuador, Guatemala, Mexico, Peru, and Venezuela. Pest free places of production

have been used successfully to prevent infestation by Stenoma catenifer of Hass avocados in 

Michoacan, Mexico.

Each of the quarantine treatments noted above provides probit-9-level security for Medfly (e.g., 

Aegerter & Folwell, 2001; Powell, 2003), and satisfies the appropriate level of phytosanitary 

protection for the United States against the risk of introduction of the Medfly (USDA, 2008b).

Peru avocados produced under this systems approach will also be subject to inspection by 

Department of Homeland Security Customs and Border Protection (CBP) at the U.S. ports-ofentry. Infested fruit will be rejected, and traceback will be done by APHIS and the NPPO of 

Peru to identify and correct problems including removal of the packinghouse or area of 

production from the export program. A systems approach can provide an alternative to single 

measures to meet the appropriate level of phytosanitary protection, or can be developed to 

provide phytosanitary protection in situations, in which no single measure is available (IPPC, 

2002). Hass avocados from Mexico have been produced and exported to the United States under 

a systems approach for Stenoma catenifer, seed and stem weevils and fruit flies for over eight 

years with no interceptions of program pests (Bedigian, 2004; USDA, 2007).

Grove sanitation removes pests from production sites (Grove et al. 1999; Pena et al. 1998) and 

culling removes damaged and infested fruit at the packing house. As part of a systems approach 

these measures are effective at lowering pest populations. 

Summary

There are several risk management measures available for the high-risk pests identified above 

that will permit the importation of avocado from Peru while satisfying the appropriate level of 

phytosanitary protection for the United States (Table 1). By themselves, pest-free places of 

avocado production, as well as quarantine treatments provide the level of phytosanitary security 

required by the United States. A systems approach, employing a combination of measures acting 

independently, if properly implemented, also mitigates risk and provides an acceptable level of 

phytosanitary protection.
Rev. 7 July 9, 2009 9

Table 1. Summary of risk management options for avocado, Persea americana, from Peru.

Measure Pest Efficacy

Requirements for places 

of production include the 

following measures: 

Registered places of 

production, grove 

sanitation, traceability 

requirements.

Packinghouse 

requirements and 

industry practices of 

culling damaged fruit and 

cleaning and washing 

fruit

All, but must be used in 

conjunction with other 

measures as part of a 

systems approach

As part of a systems approach these 

measures are effective at lowering pest 

populations. Grove sanitation 

removes pests from production sites 

(Grove et al. 1999; Pena et al. 1998) 

and traceback prevents problem 

production sites from exporting fruit

(USDA 2008a). Preventing pest from 

entering the packinghouse prevents 

postharvest pest infestations. 

Removal of any damaged or diseased 

fruit reduces the risk that pests will be 

exported to the United States.

Phytosanitary inspection All, but must be used in 

conjunction with Pestfree places of production, 

Treatments, or Areas of 

low pest prevalence for 

fruit flies and Stenoma 

catenifer.

Inspection ensures that various stages 

of any pest that are present will be 

detected; this is particularly effective 

against those pests whose later life 

stages are larger and more readily 

detected (Borror et al. 1989).

Regular inspections are recognized as 

part of a balanced pest management 

program (Kahn and Mathur 1999).

Phytosanitary certificate All, but must be used in 

conjunction with Pestfree places of production, 

Treatments, or Areas of 

low pest prevalence for 

fruit flies and Stenoma 

catenifer.

The phytosanitary certificate requires 

the NPPO of Peru to inspect the 

avocados for quarantine pests. 

Pest-free areas Ceratitis capitata, 

Anastrepha fraterculus,

Satisfies requirements for appropriate 

level of protection (IPPC, 1996, 1999; 

USDA, 2006)

Pest-free places of 

production

Stenoma catenifer Satisfies requirements for appropriate 

level of protection (IPPC, 1996, 1999; 

USDA, 2006)

Treatment - Methyl 

bromide fumigation 

(T101-c-1)

Ceratitis capitata Satisfies requirements for appropriate 

level of protection (USDA, 2008b)

Treatment - Cold 

treatment (T107-a)

Ceratitis capitata Satisfies requirements for appropriate 

level of protection (USDA, 2008b)
Rev. 7 July 9, 2009 10

Measure Pest Efficacy

Treatment - Methyl 

bromide fumigation plus 

refrigeration (T108-a1, 

a2, a3)

Ceratitis capitata Satisfies requirements for appropriate 

level of protection (USDA, 2008b)

Areas of low pest 

prevalence

Anastrepha fraterculus Can provide phytosanitary security, as 

demonstrated by earlier import 

programs employing systems 

approaches, such as tomato (7 CFR 

§319.56-28), and clementine, 

mandarin, and tangerine (7 CFR 

§319.56-38) from Chile
Rev. 7 July 9, 2009 11

Authors

T.W. Culliney, Entomologist, 

APHIS-PPQ, CPHST, PERAL

Walter Gould, Senior Risk Manager

APHIS-PPQ

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