United States Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Risk Management Document

Importation of Banana, Musa spp., as Mature, 

Hard Green Fruit from the Philippines to the 

Continental United States 

November 16, 2010

Plant Health Programs (PHP)

Regulations, Permits and Manuals (RPM)

Contact Person: Meredith Jones
Version 1 November 16, 2010 2

Introduction

A Pest Risk Assessment (PRA) was submitted by the Philippine Bureau of Plant Industry (BPI) 

to the Animal and Plant Health Inspection Service (APHIS) in December 2005 in support of a 

market access request for Philippine green bananas to the continental United States (BPI, 2005). 

This pest risk assessment was originally prepared for Dole Philippines, Inc., Dole Asia Ltd., 

Makati, Philippines.

APHIS reviewed the relevant literature and pest interception records and revised the PRA 

(USDA, 2009). The APHIS-revised PRA identified 14 quarantine pests rated medium or high

risk that are likely to follow the pathway of fresh green bananas from the Philippines:

Taxa Scientific name Pest risk potential

Diptera: Tephritidae Bactrocera musae (Tryon) High

Bactrocera occipitalis (Bezzi) High

Bactrocera philippinensis Drew and Hancock High

Coleoptera: Cerambycidae Sybra alternans Wiedemann Medium

Hempitera: Coccidae Ceroplastes rubens Maskell Medium

Coccus viridis (Green) Medium

Hemiptera: Pseudococcidae Dysmicoccus neobrevipes Beardsley Medium 

Geococcus coffeae Green Medium

Maconellicoccus hirsutus (Green) Medium

Planococcus lilacinus (Cockerell) Medium

Planococcus minor (Maskell) Medium 

Pseudococcus cryptus Hempel Medium

Rastrococcus invadens Williams Medium 

Rastrococcus spinosus (Robinson) Medium

Pests that have medium or high pest risk potential may require measures in addition to port-ofentry inspection to mitigate risk (USDA, 2000). The PRA rated three species of fruit flies as

high risk, while one longhorned beetle, two soft scales and eight species of mealy bugs are rated 

medium risk.

Industry Standard Practices 

The following list of industry standard practices for banana production in the Philippines was 

submitted to APHIS by BPI (BPI, 2008). BPI indicated that these are standard industry practices, 

and that they will mitigate all risk from pests in green bananas from the Philippines. These 

practices include the following:

a) Use of tissue culture (tc) seedlings in new plantings, as they are relatively free from insect pests.
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b) Excellent weed management to limit proliferation of insect pests.

c) Pseudostem sanitation to eliminate refuse and breeding sites of insect pests.

d) Fruit obstruction removal (FOR) to prevent fruit damage as well as eliminate bridges that may

be utilized by the pests to infest the fruit.

e) Insecticidal bud injection to kill the banana flower thrips.

f ) Insecticide spray on the pseudostem to eliminate insect pests i.e., mealybugs, aphids, etc.

g) Regular spraying of bunches with insecticide to prevent mealybugs and scale insects from 

colonizing the developing fruit bunch. This spray would eliminate fruit flies if present.

h) Chlorpyrifos-impregnated polyethylene (PE) bags used to cover the fruit bunches after bunch 

spray to further prevent mealybug, scale and fruit fly insect infestation on the fruit.

i) Additional chlorpyrifos-impregnated PE material (in a form of "strip" or "square") installed on 

the fruit as additional control against insect pests when needed.

j) Bunches for harvest identified/tagged one (1) day before harvest in an operation called "precalibration." Bunches, in the process, are inspected for the presence of insect pest; 

bunches with mealybugs, scales and other insect damages are discarded during harvest.

k) Upon arrival of the fruit at the packing plant, fruit bunches are sprayed with high pressure water 

to eliminate any mealybug infestation. 

1) While bunches are waiting to be de-handed, the fruit inspector in the packing plant checks for 

insect damage, particularly mealybug infestation, on individual bunches.

m) During de-handing, individual hands are thoroughly inspected for possible mealybug 

infestation and any other evidence of insect damage.

n) After de-handing, individual hands are thoroughly cleaned with soap and water and further 

brushed with high-pressure water to eliminate infestation of mealybugs.

o) The individual hands are again inspected to confirm freedom from mealybugs and other insects 

during weighing and immediately before packing inside the box.

p) Only unused pallets, and those that are clean, dry and free from trash, soil, weed seeds and nonweed contaminants, are used during shipping.

q) Fruits remain in the wharf no longer than 3 hours before loading in the vessel or into cold 

storage. Wharf areas are kept clean and are located away from population areas and farms. 

Wharf is regularly cleaned to prevent contamination of fruit for export.

r) Vessels are cleaned with a recommended disinfectant before loading. Some vessels use ozone 

for disinfection between loads.

Some of these practices are viewed as necessary by APHIS and will be included as required risk 

mitigations. APHIS will also require some additional mitigations that are not on this list.

Risk Management Measures - Systems approach for green bananas

All of the following measures are required for the systems approach for green bananas. 

Monitoring and Oversight. The NPPO of the Philippines must provide a workplan to APHIS 

that details the activities that the NPPO of Philippines will, subject to APHIS’ approval of the 

workplan, carry out to meet the requirements of the systems approach and the specific quarantine 

treatments that may be required. 

The NPPO of the Philippines must visit and inspect registered places of production, starting

when fruit bags are emplaced and continuing until the end of the shipping season, to verify that 

the growers are complying with the requirements of the systems approach, including following 
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pest management guidelines and fruit bagging. 

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

monitor packinghouse operations to verify that the packinghouses are complying with the 

requirements of the systems approach.

 

If the NPPO of the Philippines determines 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 the NPPO of the Philippines

conducts an investigation and appropriate remedial actions have been implemented. 

The NPPO of the Philippines 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

provide them to APHIS for review upon request.

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

registered with the NPPO of the Philippines. To register, the place of production must provide 

Philippines' NPPO with the following information: Grower, exporter, orchard, and place of 

production names, region, township, province, locality, size of area planted to each fruit, and 

approximate date of harvest. Registration must be renewed annually. The NPPO of the 

Philippines will certify that each place of production follows pest control guidelines to reduce 

regulated pest populations. APHIS may monitor the places of production if necessary. 

Registration of places of production will allow trace back to the place of production if pest 

problems are found on fruit shipped to the United States. Problem places of production can then 

be removed from the program until further mitigation measures have been taken to reduce pest 

populations.

Traceability. Harvested bananas must be placed in field cartons or containers that are marked to 

show the official registration number of the place of production. The place of production where 

the bananas were grown must remain identifiable from the time when the fruit leaves the place of 

production, to the packinghouse, and throughout the export process. Fruit presented for 

inspection at the United States port of entry must be identified in the shipping documents 

accompanying each lot of fruit to specify the place or places of production in which the fruit was 

produced, and the packing house or houses in which the fruit was processed. This identification

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

Pest management program at the place of production including covering bananas with 

pesticide impregnated bags. Each place of production must follow a pest management program 

specified by the NPPO to reduce populations of quarantine pests. This includes applying 

pesticides to reduce pest populations and bagging bananas after flower drop with plastic bags 

impregnated with pesticides. During the growing period when the bag should be covering the 

fruit, if the bag falls off or is torn so that fruit flies can enter, that fruit is no longer eligible for

export to the United States.

Fruit fly population monitoring and management for low prevalence places of production.
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Several species of Bactrocera, including Bactrocera musae, B. occipitalis and B. philippinensis,

are present in the Philippines and may attack bananas. Bananas, and especially green bananas,

are generally considered to be poor hosts to most species of fruit flies; however, B. musae is 

recorded as attacking green bananas. Low prevalence in the place of production will be used as 

part of a systems approach to mitigate the risk from Bactrocera species fruit flies. Procedures for 

the establishment and maintenance of areas of low pest prevalence must comply with 

international standards (NAPPO, 2003; IPPC, 2005). Beginning at least 3 months before harvest 

begins and continuing through the completion of harvest, trapping in the places of banana

production for Bactrocera fruit fly species must be conducted with at least 1 trap per 0.2 km2by

the NPPO. APHIS-approved traps baited with APHIS-approved baits must be used and serviced 

at least once every 2 weeks. If more than 2.0 FTD (number of fruit flies per trap per day) are 

trapped, pesticide bait treatments (or bait stations) must be applied in the affected place of 

production in order for the place of production to remain eligible to export bananas. The NPPO 

must keep records of fruit fly detections for each trap, update the records each time the traps are 

checked, and make the records available to APHIS inspectors upon request. The records must be 

maintained for at least 1 year after harvest. If after two years of export inspections of banana 

fruit, no Bactrocera spp. larvae have been found in the banana export program, further fruit fly

trapping will not be required. 

Bananas harvested hard green (no color break or yellow visible). The bananas must be 

harvested at a mature green state. None of the bananas harvested for export may be at or past 

color break (turning yellow). Damaged fruit may not be harvested for export.

Safeguarding. Bananas must be safeguarded from exposure to fruit flies from harvest to export, 

including being packaged so as to prevent access by fruit flies and other injurious insect pests.

Packinghouses. Packinghouses must prevent the entry of pests (i.e., be pest exclusionary

packinghouses) with a double-door entry system and other measures designed to exclude fruit 

flies and other pests of quarantine concern. The packinghouse operations for export of bananas 

must be monitored by the NPPO. Bananas intended for United States markets must be properly

segregated and labeled from bananas intended for other markets.

Post-harvest processing. After harvest, all damaged or diseased fruit must be culled at the 

packinghouse. Fruit will be washed with a high pressure water spray, dehanded and washed with 

soap and water. Fruit for export must be packed into new, clean boxes, crates or other packing

materials. 

NPPO Inspection. Fruit must be inspected in the Philippines at an APHIS-approved inspection 

site under the direction of BPI inspectors, following post-harvest processing. A sample of boxes

from each consignment must be selected by BPI at a rate to be mutually agreed upon by BPI and 

APHIS. The fruit from these boxes must be visually inspected for quarantine pests. A portion of 

the fruit being inspected must be cut to detect internally feeding quarantine pests. If Bactrocera

spp. fruit flies are found upon inspection, the export program will be suspended until an 

investigation has been conducted by APHIS and the NPPO of the Philippines and appropriate 

mitigations have been implemented. If other quarantine pests are detected in this inspection, the 
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consignment will be rejected from the export program.

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

certificate issued by the NPPO of the Philippines that contains an additional declaration stating 

that “the fruit in the consignment was grown and packed in accordance with CFR and inspected 

and found free of quarantine pests”.

Port of Entry Inspection. Fruit must be inspected at the first United States port of entry by

Customs and Border Protection (CBP) inspectors from the Department of Homeland Security

(DHS). A sample of boxes from each consignment will be inspected for quarantine pests. If 

significant interceptions of quarantine pests occur, APHIS may ask BPI to suspend those places 

of production pending the result of an investigation by BPI, after which they may either be 

removed from the program or required to take remedial measures. 

Efficacy of Risk Management Measures

There are several measures available for mitigating the pests of concern from bananas from the 

Philippines. The measures chosen for risk management on bananas from the Philippines are 

summarized in Table 1. 

Table 1. Summary of risk management requirements that are components of a systems 

approach for bananas from the Philippines to the Continental United States.

Measure(s) Pests Efficacy

Monitoring and 

Oversight

All pests, but must be used 

in conjunction with other 

measures as part of a 

systems approach.

These measures are standard for many import programs 

and assist in maintaining quality of the program.

Traceability All pests, but must be used 

in conjunction with other 

measures as part of a 

systems approach.

Traceability allows track back to places of production if 

pests are found by inspection at the port of arrival to the 

United States. Places of production with quarantine pests 

can be removed from the program.

Production Site 

Registration

All pests, but must be used 

in conjunction with other 

measures as part of a 

systems approach.

Registration of places of production is required to manage 

place of production requirements and restrict access to 

the program to qualified sites. Commercially grown 

shipments from registered places of production use good 

agricultural practices to reduce or eliminate pests (FAO, 

2005). APHIS pest interception database indicates that 

commercial shipments are much less likely to have pest 

interceptions than non-commercial shipments or 

passenger baggage. Place of production registration is 

part of traceability that allows track back to production 

sites if pests are found by inspection at the port of arrival 

to the United States. Places of production with pests of 

quarantine concern can be removed from the program.

Place of production pest 

management program 

including bananas 

covered with pesticide 

impregnated bags

All pests, but must be used 

in conjunction with other 

measures as part of a 

systems approach.

Pesticide impregnated bags are industry standard 

practices in Central and South America production of 

bananas (Matlock and de la Cruz, 2003; Polidoro et al., 

2008; Simmonds, 1966). These bags reduce the number 

of quarantine pests that may follow the pathway of 

bananas. 
Version 1 November 16, 2010 7

Table 1. Summary of risk management requirements that are components of a systems 

approach for bananas from the Philippines to the Continental United States.

Measure(s) Pests Efficacy

Fruit fly population 

monitoring and 

management for low 

prevalence place of 

production. 

Bactrocera spp. fruit flies Fruit fly trapping and management is a key component of 

low-prevalence systems approaches for many 

commodities including tomatoes and peppers grown in 

pest exclusionary structures, and the papaya systems 

approach from Central and South America (Title 7, Code 

of Federal Regulations, 319.56-25, 28, 31 and 40). 

Bananas harvested hard 

green (no color break or 

yellow visible).

Bactrocera spp. fruit flies Harvesting bananas at a hard green stage is a standard 

industry practice for banana production in Central and 

South America, Hawaii, and most of the world. Ripe 

bananas are much more likely to be infested with Tephritid 

fruit flies (Armstrong, 1983; 2001; Allwood and Drew, 

1996).

Safeguarding from pest 

exposure

Bactrocera spp. fruit flies Safeguarding is standard for any import program where 

the fruit is a host to fruit flies. Most fruits become more 

susceptible to infestation after harvest and safeguarding 

prevents infestation, for example tomatoes from various 

countries and Mexican avocados (Title 7, Code of Federal 

Regulations, 319.56-28 and 30).

Packinghouses All pests, but specifically for 

Bactrocera spp. fruit flies.

Pest exclusionary packinghouses are a standard APHIS 

requirement for import programs where the fruit is fruit fly 

host material, for example the Mexican avocado program 

uses this risk mitigation (Title 7, Code of Federal 

Regulations, 319.56-30).

Postharvest Processing All pests, but must be used 

in conjunction with other 

measures as part of a 

systems approach.

Banana postharvest processing includes washing that 

removes surface pests such as mealybugs, and culling 

that removes any visible pests and damaged fruit (BPI, 

2005). 

NPPO inspection All pests, but must be used 

in conjunction with other 

measures as part of a 

systems approach. 

Inspections are recognized as an important part of a pest 

management program (Kahn and Mathur 1999). Trained 

inspectors can recognize infestations of pests and the 

damage they cause to the fruits, which would allow 

detection of these pests in some cases (CABI, 2007; 

NAPPO, 1998; USDA, 1982; USDA, 2004; Whittle, 1986)

Phytosanitary 

certification

All pests, but must be used 

in conjunction with other 

measures as part of a 

systems approach.

Requiring a phytosanitary certificate requires the NPPO to 

inspect the bananas for pests.

Phytosanitary inspection 

at port of entry

All pests, but must be used 

in conjunction with other 

measures as part of a 

systems approach.

Inspections are recognized as an important part of a pest 

management program (Kahn and Mathur 1999). Trained 

inspectors can recognize infestations of pests and the 

damage they cause to the fruits, which would allow 

detection of these pests in some cases (CABI, 2007; 

NAPPO, 1998; USDA, 1982; USDA, 2004; Whittle, 1986)

Summary

APHIS concludes that commercial shipments of Philippine bananas may safely be imported into 

the continental United States without the risk of introducing pests using the combination of the 

mitigations listed above. 
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Bananas are exported from Central and South America and Hawaii using most of the components 

described in this systems approach for bananas from the Philippines. Over 3.8 to 4 million 

metric tons of bananas have been imported into the United States every year from 2003 to 2007 

(NASS, 2008). Given the huge amount of fruit imported, the number of pest interceptions is very

small, with about 1,400 interceptions of actionable quarantine pests in that time period for 

bananas worldwide (AQAS-PestID, 2010). The majority of these interceptions are mealybugs, 

scarabeid beetles and weevils. The scarabeids and weevils intercepted are not internally feeding

on bananas, but are adult hitchhikers. Mealybugs are external feeders that are readily detected by

inspection at the port of entry. 

APHIS has intercepted only three of the 14 quarantine pests listed in the PRA (AQAS-PestID, 

2010) in commercial cargo in the past five years. Two Coccus viridis, 24 Dysmicoccus 

neobrevipes and 105 Planococcus minor have been intercepted; however, the volume of bananas 

imported has been very large. In the proposed Philippine banana systems approach, any places of 

production with interceptions of quarantine pests can be either removed from the program or 

required to take remedial measures. 

According to BPI, bananas are currently exported from the Philippines to Japan using part of the 

systems approach listed here (BPI, 2005). According to BPI, no quarantine pests have been 

intercepted using this approach.

Author 

Walter Gould, Ph.D.

Senior Risk Manager

Regulations, Permits and Manuals

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