**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 Egy pt

April 5, 2011 2 

## 1. Introduction This document describes the risk management measures for the importation of fresh shredded l ettuce , Lactuca sativa L. , from Egy pt into the entire United States. The volume of lettuce to be shipped from Egy pt to the United States is estimated to be 500 tons . ( CAPQ , 200 9 ) United States Code of Federal Regulations ( 7 CFR 319.56 ) authorize s importation of fruits and vegetables from foreign countries into the United States. Currently , fresh l ettuce from Egy

pt is prohibited by these regulations

. The United States Department of Agriculture, Animal and Plant Health Inspection Service (USDA, APHI S) conducted a pest risk assessment (PRA) in response to a request to allow imports of fresh shredded l ettuce from Egy pt into the entire United States (USDA, 20 1 0). Tw elve 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 l ettuce from Egy pt was prepared based on: (1) In formation submitted by the Egy ptian Central Administration for Plant Quarantine (CAPQ), (2) United S tates Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS) records of intercepted pests (USDA, 200 9 ) , and (3) Scientific literature. The pest risk assessment, “ Importation of Fresh Shredded Lettuce, Lactuca sativa L. , from Egy pt into the entire United States , A Pathway

- Initiated Assessment ” , represents a baseline risk associated with the unmitigated importation of fresh shredded lettuce from Egy pt (USDA, 20 1 0)

. The P RA identified the following **tw elve**  pests of quarantine significance for the United States associated with lettuce leaves. Arthropods: Chromatomyia horticola (Goureau) Diptera: Agrom yz idae Liriomyza bryoniae Kaltenbach Diptera: Agrom yz idae Aleyrodes proletella (Linnaeus) Hemiptera: Aley rodidae Hyadaphis coriandri Das Hemiptera: Aphididae Icerya seychellarum (Westwood) Hemiptera: Margarodidae Maconellicoccus hirsutus Green Hemiptera: Pseudococcidae Agrotis segetum Dennis & Schiffermüller Lepidoptera: NoctuidaeRisk Management Document: Importation of fresh shredded lettuce from Egy pt

April 5, 2011 3 Helicoverpa armigera (Hübner) Lepidoptera: Noctuidae Spodoptera littoralis (Boisduval) Lepidoptera: Noctuidae Thysanoplusia orichalcea (Fabricius) Lepidoptera: Noctuidae Frankliniella schultzei (Try boom) Th ys anoptera: Thripidae Mollusk: Theba pisana (Müller) Mollusca: Helicidae Standard harvest an d post

– harvest processing measures for commercial shredded lettuce have been documented and proposed b y Egypt (CAPQ, 2007), and these measures have been considered while preparing the pest risk assessment. The measures include:

 Quality

inspection using vi sual inspection and cutting.
 Removing outer leaves.
 Shredding leaves.
 Washing and centrifuging shredded leaves.
 Vacuum sealing shredded leaves. 

## 3. **Risk Management Measures**  APHI S propose s that fresh shredded lettuce grown in Egy pt may be imported into the entire United States onl y under the following conditions: A) Fresh shredded lettuce must be imported as commercial consignments onl y. B) To ensure that fresh shredded lettuce shipped to the United States from Egy pt has been processed using the standard practices described above, the NPPO of Egy pt will ensur e 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 Egy

pt and APHI S

. C) Each consignment of shredded lettuce leaves must be accompanied by a P hy tosanitary C ertificate (PC ) issued by the Central Administration of Plant Quarantine (CAPQ) with an Additional Declaration (AD) stating the following : “ Shredded lettuce leaves in this consignment w ere inspected and found free from quarantine pests”. 

## 4. **Rationale for Risk Management Measures** The PRA identified tw elve quarantine pests that could be introduced into the United States via the importation o f shredded lettuce leaves from Egy pt. These 11 arthropods and 1 mollusk affect lettuce leaves. Seven of the arthropod pests are sucking pests, which are usuall y present on the outer leaves of the lettuce head , and are also easily dislodged and removed duri ng 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 ) r emoving outer leaves, ( 2 ) v isualRisk Management Document: Importation of fresh shredded lettuce from Egy pt

April 5, 2011 4 inspection and culling , while cutting, ( 3 ) s hredding 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 p athway

. To ensure these procedures are applied in the exporting country , APHI S is requiring the measures described in section 3., including limiting imports to commercial consignments onl y and requiring that the NPPO of Egy pt 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 **. Summ**  **ary** 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. T he requirement of a Ph ytosanitary C ertificate from CAPQ will document that the importation is a product of Egy pt. A Phy tosanitary Certificate also provides phy tosanitary security b y requiring CAPQ to conduct inspections for pests. Importations of shredded lettuce leaves from Egy pt 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. L etter from the Head of Central Administration for Plant Quarantine to the USDA, APHI S Attaché in Cairo, Egy pt. Market access for lettuce. Page 11 in Arab Republic of Egy

pt. Ministry

of Agriculture and Land Reclamation. Central Administration of Plant Quarantine. CAPQ. 2009. L etter from the Head of Central Administration for Plant Quarantine to the USDA, APHI S Attaché in Cairo, Egy pt.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 Egy pt into the entire United Stat es . – 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 Analy sis Laboratory . Raleigh, NC. 34 pp.