# Importation of Fresh Baby Kiwi ( **Actinidia arguta**  ), Fig ( **Ficus**
**carica** ), and Pomegranate ( **Punica granatum**  ) Fruits from
Chile into the
Continental

United States

Environmental Assessment

December 2009 United States Department of Agriculture

Marketing and Regulatory Programs

Animal and

Plant Health Inspection
Service

# Importation of Fresh Baby Kiwi ( **Actinidia arguta** ), Fig ( **Ficus carica** ), and Pomegranate ( **Punica granatum** ) Fruits from Chile
into the Continenta l
United States

Environmental Assessment

December 2009

Agency Contact s : Claudia Ferguson, Regulatory Policy Specialist David Lamb, Import Specialist Regulations, Permits and Manuals Plant Protection and Quarantine

Animal and Plant Health Inspection Service
U.S

. Department of Agriculture 4700 River Road, Unit 133 Riverdale, MD 20737

________________________________________________________________ The U.S

. Department of Agriculture (USDA) prohibits discrimination in all its program s and activities on the basis of race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, and marital or family

status

. (Not all prohibited bases apply to all programs.) Persons with disabilities who requir e alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720

– 2600 (voice and TDD).

To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326

–W, Whitten Building, 1400 Independence Avenue, SW, Washington, DC 20250

– 9410 or call (202) 720

– 5964 (voice and TDD)

. USDA is an equal opportunity provider and employer.

## Table of Contents

I. Need for the Proposed Action

................................ .................. 1

II. Alternatives

................................ ................................ ............... 3
A. No Action

................................ ................................ ............. 3
B. Preferred Alternative

................................ ........................... 3

III. Environmental Impacts of the No Action and the Proposed Action

................................ ................................ ....... 4
A. No Action

................................ ................................ ............. 4
B. Preferred Alternative

................................ ........................... 4 C. Cumulative Impacts

................................ ............................. 6

IV. Other Environmental Considerations

................................ ...... 7

A. Endangered Species Act

................................ ..................... 8
B. Other Considerations

................................ .......................... 8

V. Listing of Agencies and Persons Consulted

........................ 10

VI. Literature Cited

................................ ................................ ........ 111 

## I

. Need for the Proposed Action

The regulations in “Subpart

- Fruits and Vegetables” (7 Code of Federal Regulations ( CFR ) §§ 31 9.56 ) 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

. Currentl y, the regulations do not provide for the importation of fresh baby kiwi ( Actinidia arguta ), fig ( Ficus carica ), and pomegranate ( Punica granatum ) fruits from the Republic of Chile.

The U

. S

. Department of Agriculture (USDA) , Animal and Plant He alth Inspec tion Service (APHIS), is charged with protecting America’s agricultural and natural resources from foreign pests. APHIS is proposing to permit

, under certain conditions

, the importation of fresh baby kiwi, fig, and pomegranate fruits from Chile into the continental United States . (For the purposes of this document, the term “continental United States” denotes the 48 contiguous States and Alaska.) This action is in response to a request from Ser vicio Agrícola y Ganadero, the national plant protection o rg anizatio n (NPPO) of Chile, to allow the importation of these

three commodities into the United States.

APHIS has prepared two pest risk assessments and two risk management documents to determine which quarantine pests 1

1 A quarantine pest is defined by the International Plant Protection Convention as “ a pest of potential economic importance to the area endangered thereby and not yet present there, or present but not widely distributed and being officially controlled ” (I PPC, 2009). pose a risk and which risk mitigatio ns will allow for the safe importation of fresh baby kiwi, fig

, and pomegranate fruits into the continental United States from Chile (APHIS, 2008

, 2009a

, 2009b

, 2009c). Pest risk assessment has identified Brevipalpus chilensis Baker ( B. chilensis ), o r, t he Chilean false spider mite, to be a pest of concern for baby kiwi, fig

, and pomegranate fruits (APHIS, 2008 and 2009a ). Ceratitis capitata ( C. capitata ), or Mediterranean fruit fly, was determined to be a pest of concern for figs and pomegranates, but not for baby kiwi s (APHIS, 2008 and 2009a ). Both pests are of quarantine significance.

However, for C

. capitata the entire Republic of Chile has recently shown

that it meets the requirements listed under 7 CFR § 319.56

– 5 for pest

- free

areas . Therefore, APHIS is preparing a notice seeking public comment on

its intent to recognize all of Chile as being free of C

. capitata (APHIS, 2009d). It is anticipated that the notice will appear shortly. Following the

60

- day public comment period, APHIS will evaluate any comments received and make a final determination of pest

- free

- area status for Chile (APHIS, 2009d ). Until that process is completed, APHIS will continue to

consider C

. capitata as a quarantine pest in Chile and wil l require fig and2 pomegranate fruits imported from Chile to have phytosanitary certification

with a n additional declaration tha t the fruit comes from an area found free

of C. capitata

.

Given a production area is free of C

. capitata , the only quarantine pest likely to follow the pathway of imported baby kiwi, fig, and pomegranate

fruits from Chile is B. chilensis (APHIS, 2009e). The risk management documents identify phytosanitary measures whose application is expected

to minimize or eliminate the risk from B. chilensis (APHIS, 2009b and

2009 c). Plant species in the continental United States that could be damaged by the introduct ion of B. chilensis include domesticated wine grapes and table grapes, and two threatened and endangered species, Ribes

echinellum and Prunus geniculata (APHIS, 2008 and 2009a). Mitigations to preclude such damage will be required.

Baby kiwi is a frui ting vine native to Northeastern Asia. Baby kiwi ( A. arguta) is a different species from the kiwis generally see n in U.S. supermarket s ( A. deliciosa )

. In the United States, baby kiwi is occasionally considered by some people to be a weed, but is not unde r official control, so it is not considered to be a quarantined species. Baby

kiwi is under cultivation in a number of residential and commercial agricultural areas of the United States, and is known to have escaped or naturalized in Maine, Massachusetts, and Ohio.

The fig tree is of the mulberry family and is native to Southwestern Asia. It is commercially produced in at least 14 States in the United States. The majority of fig production occurs in California and several S outhern

States ; California produced 98 percent of the total crop in 2006 ( APHIS, 2009a).

The pomegranate grows on a small tree or shrub and is one of the world’s oldest known edible fruits. Most of the U.S. commercial production of pomegranates occurs in South

- Central California

. Pomegranates have a potentially longer storage life than figs and

, under the proper conditions

, may be maintained for about 2 months postharvest (APHIS, 2009a).

This environmental assessment (EA) has been prepared, consistent with

APHIS’ National Environmental Policy A ct implementing procedures (7 CFR § 372), for the purpose of evaluating how implementation of the

a lternative s described in the following section may affect t he quality of the

human environment. 2

2 The term “human environment” is “interpreted comprehensively to includ e the natural and physical environment and the relationship of people with that environment” ( 40 CFR § 1508.14 )

. This EA will be used to help determi ne whether or not to prepare an environmental impact statement which entails a more comprehensive study of the alternatives

. An environmental impact3 statement must be prepared if implementation of the proposed action may significantly affect the quality o f the human environment

.

Written comments are welcome and should be sent to the contact person

identified in the Federal Register notice making this document available to the public, by or before the established comment due date.



## II

. Alternatives

Th is EA analyzes potential environmental consequences of a proposal to

authorize the importation of baby kiwi, fig, and pomegranate fruits from

Chile into the continental United States

. Two alternatives are considered

in this EA: (1) no change in the current import requirements , which do

not permit the importation of these three commodities from Chile into the

continental United States (the “no action” alternative)

, and (2) change the import requirements to allow the importation of the three commodities

from Chile into the continental United States under certain conditions (the “preferred” alternative).



### A. No Action

The no action alternative would leave APHIS’ fruit and veg etable import requirements unchanged. Fresh b aby kiwi, fig, and pomegranate fruits

from Chile would continue to be prohibited from importation into the

United States . This prohibition, however, would mean that the United States is not in compliance with international trade agreements.



### B. Preferred Alternative

T h e preferred alternative would amend APHIS’ fruit and vegeta ble import requirements which would allow the importation of commercial consignment s 3

Because of the identified pest risk potential, APHIS has determined that further risk mitigation will be necessary in addition to making the fruit consignments subject to port of entry inspection (APHIS, 2009b and 2009c). APHIS is proposing, under the pre ferred alternative, required methyl bromide fumigation, in combination with a declaration that the

fruit comes from an area found free of C. capitata , as well as APHIS inspection (APHIS, 2008, 2009a, 2009, and 2009c). The methyl bromide of baby kiwi, fig, and pomegranate fruits from Chile into

the continental United States.

3 A c ommercial consignment is defin ed as a “ lot of fruits or vegetables that an inspector identifies as having been imported for sale and distribution. Such identification will be based on a variety of indicators, including, but not limited to: Quantity of produce, type of packaging, identification of grower or packinghouse on the packaging, and documents consigning the fruits or vegetables to a

wholesaler or retailer ” ( 7 CFR § 319.56

- 2 )

.4 treatment prescrib ed for the three commodities is known to be effective against B

. chilensis , the quarantine pest of concern

.

APHIS is proposing to allow the importation of fresh baby kiwi, fig, and

pomegranate fruit s from Chile into the continental U nited S tates under the following conditions:

**•** An APHIS inspector will prescribe necessary safeguards for unloading, handling, and transportation of the fruits preparatory to fumigation.

**•** Baby kiwi, fig, and pomegranate fruits intended for the United States are to be exported in commercial consignments.

**•** Consignments of fresh baby kiwi, fig, and pomegranate fruits must be fumigated with methyl bromide according to APHIS treatment

schedule T101

- i

- 2

- 1 (for B. chilensis ) either in Chile or at the first port of arrival in the United St ates.

**•** An APHIS inspector will monitor the fumigation.

**•** Commercial consignments of figs and pomegranates must be accompanied by a phytosanitary certificate with an additional

declaration that the fruit comes from an area found free of

Mediterranean fruit fly.

**•** Fruit shipments not in compliance with the prescribed safeguards and required treatment will not be allowed entry into the United

States.



## III

. Environmental Impacts of the No Action and the Proposed Action

A. No Action

Current regulations do not allow the entry of fresh baby kiwi, fig, and pomegranate fruits from Chile into the United States

. Under the no action alternative, these three commodities from Chile would continue to be prohibited from entering the United Stat es

. There would be no potential environmental consequence of continuing the status quo.



### B. Preferred Alternative

Under the preferred alternative

, APHIS fruit and vegetable import requirements would be amended to allow the importation of commercial consignment s of fresh baby kiwi, fig, and pomegranate fruits from Chile

into the continental United States following fumigation of each shipment with methyl bromide. The efficacy and environmental concerns regarding

the methyl bromide treat ment are discussed below.5 Methyl bromide fumigation would occur prior to exporting fresh baby kiwi, fig, and pomegranate fruits from Chile or would be done at a n APHIS

- designated fumigation center at the U .S. port of entry. Implementation of the Federal Register notice will require that the fruit be fumigated. Fumigations must meet the conditions as out lined in table 1,

which shows the treatment schedule for T101

- i

- 2

- 1.

The amount of methyl bromide needed to treat one shipping container is equal to the rate of application times the container’s volume. A standard container is assumed to be 40 feet long, 9 feet wide, and 15 feet tall, resulting in a volume of 5,400 cubic feet. Assuming the maximum application rate shown in table 1of 4 lbs/1000 cubic feet , then 21.6 lbs of methyl bromide would be used per container. If no sorption to the container or the commodity occurred, up to 21.6 lbs of methyl bromide could potentially be released to the atmosphere. Perishable commodities such as fresh fruit, howeve r, undergo some sorption, with off

- gassing of

85 to 98 percent of the methyl bromide applied (UNEP, 2007).

Table 1. Treatment Schedule for T101

- i

- 2

- 1.

Temperature (°F) Me thyl Br omide Dosage Rate (lb/1000 cubic feet) Exposure Period* (minimum hours)

80 or above 1.5 2 .5

70

– 79 2 2 .5

60

– 69 2.5 2 .5

50

– 59 3 2 .5

40

– 49 4 2 .5

* Exposure duration is for treatment conducted in a n enclosed facility or chamber

. If conducted under a tarpaulin ; the minimum is 3 hours. Sources: APHIS, 2009e and 7 CFR § 305.6

.

APHIS has estimated the maximum usage of methyl bromide fumigation that could occur annually as a result of implementing the preferred alternative. Baby kiwi may be shipped to the continental United States at various times during the y ear, while fig and pomegranate fruits are likely to be shipped during the off

- season in the United States. Fewer than ten

40

- foot containers of baby kiwi are expected to be shipped to the

United States each year (APHIS, 2008). Somewhere between 1 and

100 containers of fig or pomegranate fruits are expected annually

, resulting in a total projected maximum of 110 shipping containers requiring methyl bromide fumigation.

Therefore, APHIS has determined that the maximum amount of methyl bromide likely to be used annually, under the preferred alternative, is equal to the maximum number of containers (110) multiplied by the maximum amount of methyl bromide needed to treat each container (21.6 lbs)

— a total of 2,376 lbs. The maximum amount of metric tons (MT) o f methyl bromide that may potentially be released to the6 atmosphere is calculated as the product of the number of containers (110), the number of pounds of methyl bromide used per container (21.6), and the fraction (98 percent) of methyl bromide not sorbed by the container or commodity. The amount is then converted to metric tons by multiplying the resulting number by the product of 0.45359237 kg/lb and

1 MT/1,000kg, to yield a total of 1.0561807553 MT, or, less than 1.1 MT

per year.

APHIS

- approved m ethyl bromide fumigation is conducted in enclosed

chambers or under tarpaulins , thus limiting the potential exposure of nontarget animals, including humans, and the environment

. Occupational workers are at the most risk of methyl bromide exposure; however,

a dherence to label safety measures and guidelines should ensure there are no adverse effects on persons exposed occupationally

. Additionally, based on the effectiveness of methyl bromide to eliminate the presence of live plant pests, the importation of com mercial consignments of baby kiwi, fig, and pomegranate fruits from Chile into the continental United States is not expected to increase the risk to nontarget animals or the environment from either of the two quarantine pests of concern

.

It is possible th at even commercial consignments of nonsymptomatic fruit

may undergo inspection without B

. chilensis and C

. capitata being

detected . However, the potential risk to U.S. agriculture and natural

resources from undetected B

. chilensis is expected to be negligible under

the prescribed use of methyl bromide fumigation on fresh Chilean baby kiwi, fig, and pomegranate fruits intended for export to the continental United States (APHIS, 2009b and 2009c). Historical evidence of successful imports of grapes and citrus from Chile to the United States

indicates that the T101

- i

- 2

- 1 treatment is effective against B

. chilensis (APHIS, 2009c and 2009e). The additional requirements of C

. capitata

free production areas for figs and pomegranates, phytosanitary

certifica tion, and APHIS inspection are designed to supplement the expected efficacy of the fumigation treatment in order to prevent the two quarantine pests from entering the United States (APHIS, 2009c).



### C

. Cumulative Impacts

NEPA requires that agencies analyze whether 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 incl ude “the impact on the en vironment

which 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 effec t; 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 , one7 must consider the cumulative effects of the mitigation measures as well as any past or reasonably foreseeable future actions that could increase the risk of introduction and establishment of quarantine plant pests as a result of the importation of fresh baby kiwi, fig, and pomegranate fruits into the

continent al United States

.

According to both risk management documents (APHIS, 2009b and 2009c) , the mitigations for the preferred alternative provide a highly

effective level of phytosanitary protection

. Although other countries may submit requests to the Uni ted States to bring in fresh baby kiwi, fig, or pomegranate fruits , each of these requests would be considered under

separate regulatory actions. Thus, any risk presented by future proposals is not expected to have cumulatively significant impacts on the human

envir onment because the mitigations established by the preferred

alternative are designed to remove the pest risk of importing these

commodities

.

The use of methyl bromide fumigation can lead to cumulative impacts

when added to its use on other commodities. The rate of h uman production and usage of methyl bromide worldwide is being studied as a potential factor in global ozone depletion. Reporting of overall methyl bromide usage globally is still inconsistent and incomplete. APHIS prefers to o verestimate potential methyl bromide usage

.

Under the preferred alternative, the maximum amount of methyl bromide that potentially could be released to the atmosphere totals less than 1.1 MT per year. To put this total in perspective, an aggregate proj ection of all methyl bromide estimates for compliance with the international phytosanitary standards for wood packaging material in international trade ranges from 3,191 to 9,628 MT per year. The quantities of methyl

bromide needed to treat commercial con signments of baby kiwi, fig and

pomegranate fruits are not substantial

, and fall within the negligible treatment levels anticipated from previous cumulative analys e s (APHIS, 2003 and 2007). In addition, the ongoing reduction in global methyl bromide usage (down more than 27,000 MT from 1996 to 2005 as a result of domestic and international phase

- out efforts) offsets all levels of methyl bromide fumigation expected to result from implementation of the change in import requirements (APHIS, 2007). Therefore, no significant cumulative impact on human health or the environment is expected through implementation of the preferred alternative.



## IV

. Other Environmental Considerations

The APHIS

– NEPA implementing procedures require, to the fullest extent possible, the integration of Federal environmental laws and executive orders with the analysis of environmental impacts (7 CFR § 372.7)

. Of8 the numerous environmental review laws and executive orders, this

document considers those that have potential association to plant, animal, or human health impacts deriving from implementation of the preferred

alternative

.



### A

. Endangered Species Act

Section 7 of t h e Endangered Species Act (ESA) and its implementing regulations require Federal agencies to consult with the U.S . Fish and

Wildlife Service and/or the National Marine Fisheries Service to ensure that 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 of allowing importation of shipments of the three Chilean

commodities on e ndangered and threatened species and their habitats.

The risk management documents conclude that the prescribed combination

of m itigations will result in the effective removal of the pests of concern associated with the importation of fresh baby kiwi, fig, and pomegranate fruits from Chile (APHIS, 2009b and 2009c)

. The fumigation treatments

are to be conducted within contained fac ilities that are designed to prevent methyl bromide exposure to nontarget organisms and the environment. Therefore, importation of commercial consignments of the three

commodities from Chile into the continental United States, under the preferred alternati ve, is expected to have no effect on threatened or endangered species or their habitats.



### B

. Other Considerations

Certain executive order s , such as Executive Order 13045 , “ Protection of Children from Environmental Health Risks and Safety Risks, ” Executive

Order 12898 , “ Federal Actions to address Environmental Justice in Minority Populations and Low

- income Populations, ” Executive Order

12114

, “ Environmental Effects Abroad of Major Federal Actions, ” a nd departmental or agency directives call for sp ecial environmental reviews

in certain circumstances

.

No circumstances that would trigger the need for special environmental reviews are involved in implementing the preferred alternative considered

in this document

. No disproportionate adverse effect s are anticipated to any minority, low

- income population or particular sub group o f the U.S

. population . So long as appropriate safety procedures and protocols in the methyl bromide treatment program are implemented and followed

, there

will be no effect a broad based on implementation of the preferred

alternative

.9 Fresh baby kiwi exports from Chile to the continental United States are expected to be limited in size and frequency, yielding between 150,000 and 300,000 kilograms or, fewer than ten 40

- foot cargo shi pping containers annually (APHIS, 2008). Fig and pomegranate total exports to

the continental United States are estimated to total between 1 and

100 containers annually, holding approximately 29 tons of cargo per

40

- foot container (APHIS, 2009a).

Fig and pomegranate fruits are cultivated at different seasons in the Northern and Southern Hemispheres. Chile intends to export fresh fig and pomegranate fruits to the continental United States during the months of the year when there is no major product ion by the United States and other Northern Hemisphere nations (APHIS, 2009a). Even if the projected maximum importation of fresh baby kiwi, fig, and pomegranate fruits occurs (110 containers), no adverse economic or human health impacts are expected to r esult from the implementation of the preferred alternative.10 

## V

. Listing of Agencies and Persons
Consulted

U.S. Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine Regulations, Permits, and Manuals 4700 River Road, Unit 33 Riverdale, MD 20737

U.S. Department of Agriculture Animal and Plant Health Inspection Service Policy and Program Development Environmental Risk and Analysis Services 4700 River Road, Unit 149 Riverdale, MD 20737

U.S. Department of Agriculture Animal and Plant Health Inspection Service Policy and Program Development Regulatory Analysis and Development 4700 River Road, Unit 118 Riverdale, MD 2073711 

## VI

. Literature Cited

APHIS

— See U.S

. Department of Agriculture, Animal and Plant Health Inspection Service

IPPC

— See International Plant Protection Convention

International Plant Protection Convention, 2009. International Standards for Phytosanitary Measures. ISPM No.5

– glossary of phytosanitary terms. [Online.] Available: https://www.ippc.int/servlet/CDSServlet?status=ND0xMzM5OS4xODQx OTUmNj1lbiYzMz1wdWJsaWNhdGlvbnMmc2hvd0NoaWxkcmVuPXR ydWUmMzc9aW5mbw ~~#koinfo [Oct. 14, 2009]

.

UNEP

— See United Nations Environment Programme

United Nations Environment Programme , 2007. Montreal Protocol on substances that deplete the ozone layer. 2006 assessment. Methyl Bromide Technical Options Committee. UNEP, Ozone Secretariat, Nairobi, Kenya. [Onli ne.] Available: http://ozone.unep.org/Assessment_Panels/TEAP/Reports/MBTOC/index.shtml [March 15, 2007].

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 2003. Importation of solid wood packing material , f inal environmental impact statement

— August 2003. USDA

– APHIS

, Riverdale, MD.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 2007. Importation of solid wood packing material: supplement to the final environmental impact statement

— October 2007. USDA

– APHIS

, Riverdale, MD.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 2008. Pest risk assessment for fresh fruits of baby kiwi ( Actinidia

arguta ) from Chile imported into the continental United States: a qualitative, pathway

- initiated plant pest risk analysis. Plant Protection and Quarantine, Center for Plant Health Science and Technology, Plant Epidemiology and Risk Analysis La boratory. USDA

– APHIS, Raleigh,

NC.12 U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 2009a. Importation of fresh fruits of pomegranate ( Punica

granatum ) and fig ( Ficus carica ) from Chile into the continental United

States: a qualitative, pathway

- initiated plant pest risk analysis. Plant Protection and Quarantine, Center for Plant Health Science and Technology, Plant Epidemiology and Risk Analysis Laboratory. USDA

– APHIS, Raleigh, NC.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 2009b. Risk management document: Importation of fresh fruits of baby kiwi ( Actinidia arguta ) from Chile into the continental United States. Plant Protection and Quarantine, Plant Health Programs: Regulations, Permits a nd Manuals. December 18, 2009. USDA

– APHIS

, Riverdale, MD.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 2009c. Risk management document: Importation of fresh fruits of pomegranate ( Punica granatum ) and fig ( Ficus carica ) from Chile into the continental United States. Plant Protection and Quarantine, Plant Health Programs: Regulations, Permits and Manuals. December 18, 2009.

USDA

– APHIS, Riverdale, MD.

U.S. Department of Agriculture, Animal and Plant Health Inspectio n Service, 2009d. Determination by the Administrator: Pest

- free a reas in the Republic of Chile. 09

– 082

– 1 cover letter. September 18, 2009. USDA

– APHIS, Riverdale, MD.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service, 2009e. Amend treatment manual to add Chilean figs, baby kiwis and pomegranates to the list of commodities that could be treated with methyl bromide treatment T101

- i

- 2

- 1 for external feeders including Brevipalpus chilensis : treatment evaluation document. Decembe r 18,

2009. USDA

– APHIS, Riverdale, MD.