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

Ju ly 9

, 200 9

Plant Health Programs (PHP) Regulations, Permits and Manuals (RPM)

Contact Person: Alex BelanoRev. 7 Ju ly 9 , 2009 3 Introduction

The National Plant Protection Organization (NPPO) of Peru, Servic io 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 Uni ted 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 (U SDA, 2008a).

The risk assessment identified the following quarantine pests (t wo species of fruit fly and a fruit

boring moth) as having a high unmitigated risk potential:

Anastrepha fraterculus (Wiedemann) (Diptera: Tephritidae) Ceratitis capitata (Wiede mann) (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: C occidae)

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 patho gen entering on avocados for consumption estimated the probability to be Low (Appendix 2, USDA, 2008a) therefore, no mitigation measures are required against p otato 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 im ported commodities are subject, can be expected to provide sufficient phytosanitary security.

The proposed importation of fresh avocado fruit from Peru , if approved, would be regu lated 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, e valuating the efficacy of these actions, and identifying the most appropriate opti ons (IPPC, 2004)

. This document outlines phytosanitary measures and provides evidence of their efficacy in prevent ing

the int roduction of quarantine pests. The appropriate level of protection may be achieved through the application of a single phytosanitar y 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 post

harvest treatme nts, such as “cleaning from dirt and dust and washing ” (USDA, 2008a). TheseRev. 7 Ju ly 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 m easures for all pests:

Monitoring and Oversight

The NPPO of Peru must provide a workpla n 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 implementatio n 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 t he 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.

I f 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 N PPO 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 Per u will certify that each place of production has effective fruit fly trapping programs and follow s pest control guidelines, when necessary, to reduce regulated pest populations. APHIS may monitor the production sites if necessary.

Grove sanitation . Avo cado 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 p ackedRev. 7 Ju ly 9 , 2009 5 for export. Removal of fallen fruit removes pest s 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 p lace 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 protect ed from fruit fly infestation until moved.

Packinghouse Requirements.

Avocados must be packed within 24 hours of harvest in a n 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 ar ea where the avocados are packed. The fruit must be safeguarded by a n 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 ins ect

- 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 p ost

- 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 pr oduced

, 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 S tenoma catenifer

.

Phytosanitary Certificate

. Each consignment of fruit must be accompanied by a phyt osanitary certificate issued by NPPO of Peru and providing an additio nal 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 m easures specific for certain pests:

Pest free places of production for Stenoma cateniferRev. 7 Ju ly 9 , 2009 6 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 standar ds (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 fo r 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 mainta in 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 wi ll 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 w ill result in immediate suspension of the affected orchard from the export program until appropriate measures to reestablish pest freedom , agree d 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 ke e p s records of Stenoma catenifer detections for each place of production , update s the

records each time the places of production are surveyed , and ma kes the records available to APHIS inspectors upon request. The records must be maintained for at least 1 year after the

harvest

.

Mitigation measures for Ana strepha 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 accordanc e with international

standar ds (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

- Har ris, 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 fl y

.Rev. 7 Ju ly 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 Anas trepha fraterculus must be conducted with at least 1 trap per 0.2 km 2

. 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 th i s frui t fl y 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 ea ch 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

standar ds (e.g., IPPC, 1996, 1999; NAPPO, 2004). APHIS must a pprove 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 (Schedule s T108

- a 1, 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 lowe ring 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.

Conseque nces if certain p ests 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 Ju ly 9 , 2009 8 I f a single Anastrepha fra terculus fruit fly larva or S tenoma 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

p rogram 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

E stablishment 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 S t enoma cat enifer of Hass avocados in Michoacan, Mexico.

Each of the quarantine treatm ents 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

- of

entry. 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 pro tection, 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 caten ifer , 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 a nd 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 Ju ly 9 , 2009 9 Table 1. Summary of risk man agement 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 a nd 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. G rove 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 infestatio ns. 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 Pest

f ree places of production

, Treatments, or Areas of

l ow p est p revalenc e 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. 19 89). 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 Pest

f ree place s of production

, Treatments, or Areas of

l ow p est p revalence 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 pr otection (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 Satisfi es requirements for appropriate level of protection (USDA, 200 8b )

Treatment

- Cold treatment (T107

- a) Ceratitis capitata Satisfies requirements for appropriate level of protection (USDA, 200 8b )Rev. 7 Ju ly 9 , 2009 10 Measure Pest Efficacy

Treatment

- Methyl bromide fumigation plus refrigeration (T1 08

- a 1, a2, a3 ) Ceratitis capitata Satisfies requirements for appropriate level of protection (USDA, 200 8b )

Areas of l ow p est

p revalence Anastrepha fraterculus Can provide phytosanitary security, as demonstrated by earlier import programs employing system s approaches, such as tomato (7 CFR §319.56

- 2 8 ), and clementine, mandarin, and tangerine (7 CFR §319.56

- 38 ) from ChileRev. 7 Ju ly 9 , 2009 11 Authors

T.W. Culliney, Entomologist,

APHIS

- PPQ, CPHST, PERAL

Walter Gould, Senior Risk Manager

APHIS

- PPQ

References

Aegerter, A. F. and R.J. Folwell. 2001. Selected alternatives to methyl bromide in the postharvest and quarantine treatment of almonds and walnuts: an economic perspective. Journal of Food Processing and Preservation 25(6): 389

- 410

.

Aluja, M., F. Diaz

- Fleischer and J. Arredondo. 2004. Nonhost status of commercial Persea

Americana ‘Hass’ to Anastrepha ludens

, Anastrepha obliqua

, Anastrepha serpentina and Anastrepha striata (Diptera: Tephritidae) in Mexico. J. Econ. Entomol. 97: 293

- 309.

Bedigian, K. 2004. Mexican a vocado import program. Federal Register 69(229): 69748

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Borror, D. J., Triplehorn, C. A. and N. F. Johnson. 1989. Introduction to the study of insects, 6 ed. Harcourt Brace Jovanovich College Publishers, TX.

Grove, T., W.P. Steyn and M.S. De Be er. 1999. The false codling moth, Cryptophlebia

leucotreta (Meyrick) ( Lepidoptera: Tortricidae) on avocado

– a literature review. South

African Avocado Growers’ Association Yearbook. 22: 31

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IPPC. 1996 . Requirements for the establishment of pest fre e areas. International Standards for Phytosanitary Measures No. 4. Rome: Secretariat of the International Plant Protection Convention, United Nations Food and Agriculture Organization.

IPPC. 1999. Requirements for the establishment of pest free places of production and pest free production sites. International Standards for Phytosanitary Measures No. 10. Rome: Secretariat of the International Plant Protection Convention, United Nations Food and Agriculture Organization.

IPPC. 2002 . The use of integrated m easures in a systems approach for pest risk management. International Standards for Phytosanitary Measures No. 14. Rome: Secretariat of the International Plant Protection Convention, United Nations Food and Agriculture Organization.

IPPC. 2004. Pest risk analysis for quarantine pests, including analysis of environmental risks and living modified organisms. International Standards for Phytosanitary Measures No. 11. Rome: Secretariat of the International Plant Protection Convention, United Nations Food and

A griculture Organization.Rev. 7 Ju ly 9 , 2009 12 IPPC. 2005. Requirements for the establishment of areas of low pest prevalence. International Standards for Phytosanitary Measures No. 22. Rome: Secretariat of the International Plant Protection Convention, United Nations Food and Agriculture Organization.

Kahn and Mathur. 1999. Containment facilities and safeguards for exotic plant pathogens and pests. APS Press, St. Paul MN. 213pp.

NAPPO. 2003. Guidelines for the establishment, maintenance and verification of areas of low

p est prevalence for insects. NAPPO Regional Standards for Phytosanitary Measures No. 20. Ottawa: Secretariat of the North American Plant Protection Organization.

NAPPO. 2004. Guidelines for the establishment, maintenance and verification of fruit fly pest free areas in North America. NAPPO Regional Standards for Phytosanitary Measures No. 17. Ottawa: Secretariat of the North American Plant Protection Organization.

Ovruski, S., P. Schliserman, and M. Aluja. 2003. Native and introduced host plants of

Anast repha fraterculus and Ceratitis capitata (Diptera: Tephritidae) in Northwestern Argentina. J. Econ. Entomol. 96: 1108

- 1118.

Pena, J.E., A.I. Mohyuddin and M. Wysoki. 1998. A review of the pest management system in mango agroecosystems. Phytoparasitic a 26: 1

- 20.

Powell, M.R. 2003. Modeling the response of the Mediterranean fruit fly (Diptera: Te phritidae) to cold treatment. Journal of Economic Entomology 96(2): 300

- 310.

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- Initiated Pest Risk Assessments, Version 5.02. USDA

APHIS, PPQ; http://oars.aphis.usda.gov/ppq/pra/commodity/cpraguide.pdf

USDA. 2005. Work plan for the Exportation of Hass Avocados from Mexico to the United States

of America. United States Department of Agriculture, Animal and Plant Health Inspection

Service

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USDA. 2006. Areas approved by APHIS as free of specified pests. Document No. APHIS

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- 0106

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- 2005

- 0106 ); http://www.regulations.gov/fdmspublic/component/main

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Continental United States . A Pathway

- initiated Commodity Risk Analysis . United States Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Raleigh, NC. 89 pp.Rev. 7 Ju ly 9 , 2009 13 USDA. 2008b. Treatment Manual. USDA

- APHIS

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White, I.M. and M. M. Elson

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