United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Importation of Fresh Shredded Lettuce, Lactuca sativa 

L., from Egypt into the Entire United States 

Risk Management Document

April 5, 2011

Plant Health Programs (PHP)

Regulations, Permits and Manuals (RPM)

Contact Person: Marc Phillips
Risk Management Document: Importation of fresh shredded lettuce from Egypt

April 5, 2011 2

1. Introduction

This document describes the risk management measures for the importation of fresh 

shredded lettuce, Lactuca sativa L., from Egypt into the entire United States. The 

volume of lettuce to be shipped from Egypt to the United States is estimated to be 500 

tons. (CAPQ, 2009)

United States Code of Federal Regulations (7 CFR 319.56) authorizes importation of 

fruits and vegetables from foreign countries into the United States. Currently, fresh 

lettuce from Egypt is prohibited by these regulations.

The United States Department of Agriculture, Animal and Plant Health Inspection 

Service (USDA, APHIS) conducted a pest risk assessment (PRA) in response to a request

to allow imports of fresh shredded lettuce from Egypt into the entire United States

(USDA, 2010). Twelve pests of quarantine significance were identified, which would be 

likely to be introduced into the United States via fresh lettuce. This document evaluates 

the appropriate pest risk management measures for these quarantine pests.

2. Quarantine Pests of Concern for fresh shredded Lettuce 

from Egypt 

The list of quarantine pests of fresh shredded lettuce from Egypt was prepared based on:

(1) Information submitted by the Egyptian Central Administration for Plant 

Quarantine (CAPQ),

(2) United States Department of Agriculture (USDA), Animal and Plant Health 

Inspection Service (APHIS) records of intercepted pests (USDA, 2009), and 

(3) Scientific literature.

The pest risk assessment, “Importation of Fresh Shredded Lettuce, Lactuca sativa L., 

from Egypt into the entire United States, A Pathway-Initiated Assessment”, represents a 

baseline risk associated with the unmitigated importation of fresh shredded lettuce from 

Egypt (USDA, 2010).

The PRA identified the following twelve pests of quarantine significance for the United 

States associated with lettuce leaves.

Arthropods:

Chromatomyia horticola (Goureau) Diptera: Agromyzidae

Liriomyza bryoniae Kaltenbach Diptera: Agromyzidae

Aleyrodes proletella (Linnaeus) Hemiptera: Aleyrodidae

Hyadaphis coriandri Das Hemiptera: Aphididae

Icerya seychellarum (Westwood) Hemiptera: Margarodidae

Maconellicoccus hirsutus Green Hemiptera: Pseudococcidae

Agrotis segetum Dennis & Schiffermüller Lepidoptera: Noctuidae
Risk Management Document: Importation of fresh shredded lettuce from Egypt

April 5, 2011 3

Helicoverpa armigera (Hübner) Lepidoptera: Noctuidae

Spodoptera littoralis (Boisduval) Lepidoptera: Noctuidae

Thysanoplusia orichalcea (Fabricius) Lepidoptera: Noctuidae

Frankliniella schultzei (Tryboom) Thysanoptera: Thripidae

Mollusk:

Theba pisana (Müller) Mollusca: Helicidae

Standard harvest and post–harvest processing measures for commercial shredded lettuce 

have been documented and proposed by Egypt (CAPQ, 2007), and these measures have 

been considered while preparing the pest risk assessment. The measures include:

 Quality inspection using visual inspection and cutting.

 Removing outer leaves.

 Shredding leaves.

 Washing and centrifuging shredded leaves.

 Vacuum sealing shredded leaves.

3. Risk Management Measures

APHIS proposes that fresh shredded lettuce grown in Egypt may be imported into the

entire United States only under the following conditions:

A) Fresh shredded lettuce must be imported as commercial consignments only.

B) To ensure that fresh shredded lettuce shipped to the United States from Egypt has 

been processed using the standard practices described above, the NPPO of Egypt will

ensure that packing houses are following sanitary and post – harvest processing 

measures to ensure freedom from quarantine pests. Details of measures will be 

included in an operational work plan (OWP) approved by NPPO of Egypt and 

APHIS.

C) Each consignment of shredded lettuce leaves must be accompanied by a 

Phytosanitary Certificate (PC) issued by the Central Administration of Plant 

Quarantine (CAPQ) with an Additional Declaration (AD) stating the following :

“Shredded lettuce leaves in this consignment were inspected and found free from 

quarantine pests”.

4. Rationale for Risk Management Measures

The PRA identified twelve quarantine pests that could be introduced into the United

States via the importation of shredded lettuce leaves from Egypt. These 11 arthropods 

and 1 mollusk affect lettuce leaves. Seven of the arthropod pests are sucking pests, which 

are usually present on the outer leaves of the lettuce head, and are also easily dislodged 

and removed during processing. The snail, Theba pisana, also is present on the outer 

leaves. The four lepidopterans feed on the leaves, and damaged heads can be culled while 

cutting. The post-harvest procedures consisting of (1) removing outer leaves, (2) visual 
Risk Management Document: Importation of fresh shredded lettuce from Egypt

April 5, 2011 4

inspection and culling, while cutting, (3) shredding leaves (4) washing and centrifuging 

shredded leaves and (5) vacuum sealing shredded leaves as described in section 1.3 

(USDA, 2010) will prevent the pests of quarantine significance from following the 

pathway. To ensure these procedures are applied in the exporting country, APHIS is 

requiring the measures described in section 3., including limiting imports to commercial 

consignments only and requiring that the NPPO of Egypt agree to certify exports only

from facilities that employ the post-harvest procedures described in this document. 

These risk mitigation measures (post-harvest processing procedures) are valid only for 

shredded lettuce leaves.

5. Summary

Removal of the outer leaves from lettuce heads will remove the sucking pests and snail 

that are normally present there. Cutting and examination of the heads will lead to the 

elimination of lepidopteran pests that may be present there by culling the infested heads.

The requirement of a Phytosanitary Certificate from CAPQ will document that the 

importation is a product of Egypt. A Phytosanitary Certificate also provides phytosanitary

security by requiring CAPQ to conduct inspections for pests.

Importations of shredded lettuce leaves from Egypt will also be subject to inspection at 

the first port of entry into the continental United States. These inspections double the 

number of inspections that each consignment of shredded lettuce leaves receives. 

Author

Devaiah A. Muruvanda, Ph.D., Senior Risk Manager, USDA, APHIS, PPQ, Regulations, 

Permits & Manuals

6. References

CAPQ, 2007. Letter from the Head of Central Administration for Plant Quarantine to the 

USDA, APHIS Attaché in Cairo, Egypt. Market access for lettuce. Page 11 in Arab 

Republic of Egypt. Ministry of Agriculture and Land Reclamation. Central 

Administration of Plant Quarantine.

CAPQ. 2009. Letter from the Head of Central Administration for Plant Quarantine to the 

USDA, APHIS Attaché in Cairo, Egypt.Post –harvesting processing for Lettuce. Page 

2 in Arab Republic of Egypt. Ministry of Agriculture and Land Reclamation. Central 

Administration of Plant Quarantine.

USDA. 2010. Importation of Fresh Shredded Lettuce, Lactuca sativa L., from Egypt into 

the entire United States. – A Pathway-Initiated Risk Assessment. March 2010. United 

States Department of Agriculture, Animal and Plant Health Inspection Service, Plant 

Protection and Quarantine, Center for Plant Health Inspection Service, Plant 

Epidemiology and Risk Analysis Laboratory. Raleigh, NC. 34 pp.