United States Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine



# Importation of Aechmea, Cryptanthus, Guzmania, Hohenbergia, Neoregelia, Tillandsia and Vriesea , in growing media, into the United States from Belgium, Denmark and the Netherlands

7 CFR 319.37

Risk Management Document

February 2008 Revised: October 2008, November 2008, July 2009

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

Contact Person: William Aley1 

### Introduction

The European Union member countries of Be lgium, Denmark and the Netherlands have requested permission to export plants esta blished in growing media in the genera Aechmea, Cryptanthus, Guzmania, Hohenbergia, Neoregelia, Tillandsi a and Vriesea in the family Bromeliaceae to the United States (Embassy of Belgium, Royal Danish Embassy, Embassy of Israel, and Royal Netherlands Emba ssy, 1994; European Commission, 1998).

The importation of Bromeliaceae plants as restricted articles is authorized in 7 CFR 319.37 of the Code of Federal Regulations (CFR, 2008). Importa tion and pest interception data of currently enterable bromeliads in the above mentioned genera from Belgium, Denmark and the Netherlands are discussed in the Appendix. Howeve r, the importation of above mentioned genera as plants established in growing media is not currently authorized in 7 CFR 319.37-8 (Plants in Growing Media).

In response to the request by Belgium, Denmar k and the Netherlands, the Animal and Plant Health Inspection Service (APHIS) of the Unite d States Department of Agriculture (USDA) conducted a pest risk assessment (PRA) as requi red in 7 CFR 319.37-8(g). In the PRA, entitled “Importation of Aechmea, Cryptanthus, Guzmania, H ohenbergia, Neoregelia, Tillandsia and

Vriesea (Bromeliaceae) in Growing Me dia, into the United States From Belgium, Denmark and the Netherlands” (USDA, 2009), one quarantine pest was identified that could reasonably be expected to follow the pathway on these plants:

Fusarium oxysporum Schlechtend.:Fr. f. sp. aechmeae (Saut. & Gerlach) Gordon (Fungi Imperfecti: Hyphomycetes).

This fungus was characterized as having a lo w pest risk potential. According to APHIS guidelines (USDA, 2000), pests with a risk rating of “low” t ypically do not require specific mitigation measures. The standard port-of-entry inspection to which all commodities imported into the United States are subjected is expect ed to provide sufficien t phytosanitary security. Nevertheless, all plants establis hed in growing media must comply with the regulations in 7 CFR 319.37-8 (Plants in Growing Media).

APHIS will subsequently propose to amend 7 CFR 319.37-8(e) to add Aechmea, Cryptanthus, Guzmania, Hohenbergia, Neoregelia, Tillandsi a and Vriesea from Belgium, Denmark and the Netherlands to the list of approved plants. If imported into Hawaii, these Bromeliaceae will be subject to postentry quarantine in accordance with 7 CFR 319.37-7.2 

### Risk management measures

The following risk management measures will apply to articles in the genera Aechmea, Cryptanthus, Guzmania, Hohenbergia, Neoregelia, Tillandsi a and Vriesea in the family Bromeliaceae, imported in approved growing me dia into the United States from Belgium, Denmark, and the Netherlands. The articles must be:

1. Artificially propagated and not coll ected from the wild (USDA, 2009).

2. Established in approved growing media and in compliance with all requirements of 7

CFR 319.37-8.

3. Subject to postentry quarantine if importe d into Hawaii, in accordance with 7 CFR

319.37-7.

4. In compliance with all other requirement s in 7 CFR 319.37, and as specified in the written agreement between APHIS and the National Plant Protect ion Organizations (NPPOs) of the above three countries.



### Discussion of risk management measures

Bromeliads currently enterable as bare-root plants into the Unit ed States are grown in APHISapproved growing media and are then subject to washing of the r oot system with clean, potable water to remove growing media from the root system. Plants that are washed free of media facilitate visual inspection and the removal of symptomatic plants from the pathway, or rejection of infested plant lots. Regulatory officials in spect above- and below-ground plant parts for the presence of plant pests and diseases.

When plants are established in growing media, non-destructive visual inspections may be rendered more difficult. It may not be possible to inspect for plant pests and diseases or biological contaminants on below-ground plant part s without damaging the plant. Establishment in media may also lead to production of larger plants, or additional or larger plant parts - including leaves or roots. These may provide additional locations for pests to hide and may increase the difficulty of vi sual inspection (USDA, 2009).

However, the risks of importing propagative mate rials in growing media have been addressed by APHIS (Santacroce, 1991) and mitigated in regulations outlined in 7 CFR 319.37-8 (USDA,3 2009). Similar programs have been applied to vari ous other groups of plan ts listed in 7 CFR 319.37-8(e).

The requirements outlined in 7 CFR 319.37-8 comprise a “systems approach” with a combination of measures aimed at reducing pe st risk. The Internat ional Plant Protection Convention (IPPC) defines a “systems approach ” as “The integrati on of different risk management measures, at least two of which act independently, and which cumulatively achieve the appropriate level of protec tion against regulated pests” (IPPC, 2007). Similarly, the Plant Protection Act of 2000 (SEC. 401. 7 U.S.C. 7701) defi nes a “systems approach” as “...a defined set of phytosanitary procedures, at least two of which have an independent effect in mitigating pest risk associated with th e movement of commodities.”

Systems approaches are employed by an importing country to achieve an appropriate level of phytosanitary protection as an alte rnative to the use of single measures when a single measure is nonexistent, infeasible or undesirable. The co mbinations of measures comprising systems approaches provide overlapping or sequential safeguards rather than depending on single mitigation methodologies, such as fumigation or inspection alone (Jang and Moffitt, 1994; USDA, 2009).

The three main categories of mitigation measures specifically required in 7 CFR 319.37-8(e) include the use of pest-free pr opagation material, pest-exclusi onary greenhouses, and inspection and oversight.

Pest-free propagation material

The Aechmea, Cryptanthus, Guzmania, H ohenbergia, Neoregelia, Tillandsia and Vriesea spp. must be artificially propagated and not collected from the wild (USDA, 2009).

7 CFR 319.37-8(e)(2) requires the ar ticles to be developed from mo ther stock that was inspected and found free from evidence of pests and diseas es by an APHIS inspector or foreign NPPO inspector no more than 60 days prior to the tim e the article is established in the greenhouse, except for articles developed from seeds germinated in the greenhouse. The use of clean mother stock is an essential component of ornamental plant production. This requirement may reduce or

eliminate the initial in troduction of diseases and pests into the plant production environment (Kahn, 1977; Jarvis, 1992; Metcalf and Metcalf, 1993; Bodman et al., 1996; Agrios, 1997; Kahn and Mathur, 1999; Mizell and S hort, 1999; Jones and Benson, 2001).

If articles are grown fr om mother plants, 7 CFR 319.37-8(e)(2)(i v) requires the mother plant to be grown for at least 9 months in the exporting country prior to importation of the descendent4 plants into the United States. If the mother plant was imported into the exporting country from another country, it must be gr own for at least 12 months in the exporting country prior to importation of the descendent plants into the United States. The mother plant may also be treated at the time of importation into the exporting countr y as prescribed for pests of that plant by the NPPO of the exporting country, and then grown fo r at least 9 months in the exporting country prior to importation of the descende nt plants into the United States.

7 CFR 319.37-8(e)(2)(iii) further requir es the articles to be rooted and grown in an active state of foliar growth for at least four consecutive m onths immediately prior to importation into the United States, in a greenhouse unit that is used so lely for articles grown in compliance with this paragraph. Mother and descendent plants in an active state of grow th, and grown for the respective time periods required in 7 CFR 319.37-8(e)(2), are more likely to express potential symptoms of pests or pathogens that may be pres ent. These may then be more readily detected and eliminated from the pathway by inspection.

Pest-exclusionary greenhouses

According to 7 CFR 319.37-8(e)(2)( ii), the articles must be grown solely in a greenhouse in which sanitary procedures adequate to exclude plant pests and diseases are always employed, including cleaning and disinfection of floors, benc hes and tools, and the application of measures to protect against plant pests and diseases.

Sanitation is the general clean liness and pathogen-free condition of the nursery operation, aimed at reducing the overall inoculum level in the nursery (Jones and Benson, 2001). Pestexclusionary greenhouses employ good sanitation, e.g., surface disinfection of tools and plant materials (Jarvis, 1992; Barry, 1996; Agrios, 199 7; Kahn and Mathur, 19 99; Bessin, 2001; Jones and Benson, 2001), clean water sources (van de r Plank, 1963; Pirone, 1978; Jarvis, 1992; Bodman et al., 1996; Kahn and Mathur, 1999) , and use of approved growing media.

Growing media approved by APHIS are listed in 7 CFR 319.37-8(e)(1 ), and must not have been previously used. Articles must be rooted and grown in these media (7 CFR 319.37-8(e)(2)(vi)). Studies on APHIS-approved growing media indicated that pathogens are not present (Santacroce, 1991). According to 7 CFR 319.37-8(e)(2)(v), plants must be watered only with rainwater that has been boiled or pasteurized, with clean well water, or with potable water.

7 CFR 319.37-8(e)(2) requires the greenhouse to be free from sand and soil, and articles to be grown on benches supported by legs and raised at least 46 cm above the floor. Import restrictions barring soil carried with propaga tive horticultural plants preven t the introduction of various5 mollusks (Robinson, 2002). 7 CFR 319.37-8(e)(2)(vii) also requires the articles to be stored and packaged only in areas free of sand, soil, earth, and plant pests.

7 CFR 319.37-8(e)(2)(ii) requires sc reening with openings of not more than 0.6 mm on all vents and openings except entryways. A ll entryways must be equipped with automatic closing doors. Screens and doors exclude the entry of flying or crawling pests that ca nnot fit through screens (Metcalf and Metcalf, 1993; Bessin, 2001). The greenhouse enclosure further provides a physical barrier that reduces the plants’ exposure to fungal spores that ar e rain splashed or windborne (Pirone, 1978; Barry, 1996; Agrios, 1997).

While not specifically required in 7 CFR 319.37-8, various industry practices commonly used in the production of ornamentals ma y further reduce the likelihood of pests of concern following the pathway (USDA, 2009). These may include sa nitation and chemical treatments designed to reduce or eliminate pests and diseases (Reine rt, 1981; Mizell and Shor t, 1999; Bessin, 2001; Jones and Benson, 2001; Osborne, et. al., 2001; Ghidiu and Roberts, 2003), in vitro or aseptic vegetative propagation (Hartman et al., 2002), and cultural practices enhancing plant vigor and rendering the plants less sus ceptible to pests and diseases (Bodman et al., 1996; Kahn and Mathur, 1999; Jones and Benson, 2001).

Improper nursery practices are often the primary means by wh ich pathogens and pests are introduced and spread in the nursery (Jones and Benson, 2001). The inspection, oversight and written agreements required in 7 CFR 319.37-8 therefore provide a dditional phyt osanitary quality control and rigor, and reduce the possi bilities of improper practices being employed.

Inspection and oversight

According to 7 CFR 319.37-8(e)(2), articles impo rted under this paragraph must be grown in compliance with a written agreement signed by APHIS and the NPPO of the country where

grown.

7 CFR 319.37-8(e)(2)(i) also requ ires that articles are grown in compliance with a written agreement between the grower and the NPPO of the country where the article is grown. In this document, the grower agrees to comply with the provisions of this section and to allow inspectors, and representatives of the NPPO of the country wher e the article is grown, access to the growing facility as necessa ry to monitor compliance with the provisions of this section.

7 CFR 319.37-8(e)(2) requires article s to be inspected and found free from evidence of plant pests and diseases by an APHIS inspector or an inspector of the NPPO of the exporting country. Mother stock must be inspected no more than 60 da ys prior to establishment of the articles in the6 greenhouse. Articles must also be inspected in the greenhouse no more than 30 days prior to the date of export to the United St ates. Regular inspections are recogni zed as an important part of a pest management program (Kahn and Mathur, 1999).

Author

Carissa Marasas, PhD Senior Risk Manager, Plants for Planting



### References

Agrios, G. N. 1997. Plant Pathology. 4th Ed. Academic Press. San Diego.

Barry, D. W. (ed.). 1996. Greenhouse Pesticid e Management. Section 10 – Management of Greenhouse Diseases. http://www.ag.ndsu.nodak.edu/aginfo/pes ticid/publications/GreenH/gpm1.htm

.

Bessin, R. 2001. Controls for greenhouse orname ntal insect pests. Un iv. Kentucky Coop. Ext. Service. http://www.uky.edu/Agriculture/Entomology/entfacts

.

Bodman, K.; Carson, C.; Forsberg, L.; Gough, N.; Hughes, I.; Parker, R.; Ramsey, M. and M. Waterhouse. 1996. Ornamental Plants. De pt. Primary Industries, Info. Series QI 96001, Australia.

Code of Federal Regulations (CFR). 2008. http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&tpl=%2Findex.tpl . 7 CFR 319.37. Subpart–Nursery Stock, Plants, Roots, Bulbs, Seeds, and Other Plant Products. http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&sid=ec37e455be2142273f36279a61d28a 82&rgn=div6&view=text&node=7:5.1.1.1.

6.7&idno=7 [accessed October 2008].

Embassy of Belgium, Royal Danish Embassy, Embassy of Israel, and Royal Netherlands Embassy. 1994. Letter to the United States Depa rtment of Agriculture, dated August 18, 1994. [On file with the contact person].

European Commission. 1998. Letter to Internati onal Services, Animal and Plant Health Inspection Services, United States Department of Agriculture, dated June 19, 1998. [On file with the contact person].

Ghidiu, G. M. and W. J. Roberts. 2003. Gr eenhouse Screening for Insect Control, Factsheet FS640. The State University of New Jersey, Rutgers Cooperative Extension. www.rce.rutgers.edu/pubs/pdfs/fs640.pdf

.7 Hartmann, H. T., Kester, D. E., Davies, Jr., F. T, and R. L. Geneve. 2002. Hartmann and Kester's Plant Propagation Principles and Practic es. 7th ed., Prentice Hall, Upper Saddle River.

International Plant Protection Convention (IPPC), 2007. International Standards for Phytosanitary Measures. ISPM No. 5. Glossary of Phytosanitary Terms. https://www.ippc.int/servlet/BinaryDow nloaderServlet/184195_ISPM05_2007_E.doc?filename= 1180102644600_ISPM_05_2007.doc&refID=184195 [accessed October 2008].

Jang, E. B. and H. R. Moffitt. 1994. Systems appro aches to achieving quara ntine security. In: J. L. Sharp and G. J. Hallman (eds.). 1994. Quar antine treatments for pests of food plants. Westview Press, Boulder.

Jarvis, W. R. 1992. Managing Diseases in Green house Crops. American Phytopathology Society, St. Paul.

Jones, R. K. and D. M. Benson. 2001. Diseases of Woody Ornamentals and Trees in Nurseries. APS Press, St. Paul.

Kahn, R. P. 1977. Plant quarantine: Principles , methodology, and suggested approaches. In: W. B. Hewitt and L. Chiarappa. Plant Health and Qu arantine in International Transfer of Genetic Resources. CRC Press, Boca Raton.

Kahn, R. P. and S. B. Mathur. 1999. Containment F acilities and Safeguards. APS Press, St. Paul.

Metcalf, R. L. and R. A. Metcalf. 1993. Destructiv e and Useful Insects, th eir Habits and Control, 5th ed. McGraw-Hill, Inc., New York.

Mizell, R. F. and D. E. Short. 1999. Integrated pest management in the commercial ornamental nursery, 1999 Insect Management Guide. Univ. Florida, FL Coop Ext. Service. http://edis.ifas.ufl.edu

.

Osborne, L. S., Buss, E. A. Mannion, C. M. and J. F. Price. 2001. Commercial Foliage and Woody Ornamental Arthropod Pest Management. University of Florida Cooperative Extension Service, document ENY-311. http://edis.ifas.ufl.edu

.

Pirone, P. P. 1978. Diseases and Pests of Ornament al Plants, 5th ed. John Wiley and Sons, New York.

Plant Protection Act. 2000. SEC. 401. 7 U.S.C. 7701.

Reinert, J. A. 1981. Evaluation of Miticides for Control of Paracalacarus podocarpi on Podocarpus . J. Econ. Entomol. 74: 85 - 87.

Robinson, D. 2002. E-mail communication with M. Hennessey, April 2, 2002. Animal and Plant Health Inspection Service, Unite d States Department of Agricu lture. (Cited in USDA, 2009).8 Santacroce, N.G. 1991. An Evaluation of pests a ssociated with packaged peat, rockwool and expanded clay and their association with me dia in greenhouse production. Animal and Plant Health Inspection Service, United St ates Department of Agriculture.

United States Department of Agriculture (US DA). 2000. Guidelines for pathway-initiated pest risk assessments. Version 5.02. Animal and Plan t Health Inspection Se rvice, Riverdale, Maryland.

United States Department of Agri culture (USDA). 2009. Importation of Aechmea, Cryptanthus, Guzmania, Hohenbergia, Neoregelia, Tillandsia and Vriesea , in growing media, into the United States from Belgium, Denmark and the Netherlands. Animal and Plant Health Inspection Service. July 6, 2009.

van der Plank, J. E. 1963. Plant Diseases: Epidem ics and Control. Academic Press, New York.9 

### APPENDIX

Importation and pest interception data of currently enterable bromeliads

Table 1 indicates the volume of currently enterable Aechmea, Guzmania, Neoregelia, Tillandsi a and Vriesea plants imported into the United States fr om Belgium and the Netherlands in Fiscal Year 2007. No imports were recorded from Denmark, and no Cryptanthus and Hohenbergia spp. were imported from any of the three countries. More than 4.7 million plant units and 0.9 million flasks of plants were imported from Belgium and the Netherlands in 2007. Flasks were only imported from Belgium in this year, while flasks were also imported fr om the Netherlands in Fiscal Year 2006 (APHIS 280 data).

Table 1. Volume of Aechmea, Guzmania, Neoregelia, Tillandsia , and Vriesea spp. imported into the United States from Belgium and the Netherlands (2007)

Commodity Plant units Flasks Belgium Netherlands Total Belgium Aechmea 320,614 86,008 406,622 71,220 Guzmania 1,820,343 1,554,552 3,374,895 579,869 Neoregelia 38,571 39,310 77,881 84,444 Tillandsia 144,409 175,947 320,356 51,429

Vriesea 338,430 244,957 583,387 119,271 Total 2,662,367 2,100,774 4,763,141 906,233 Source: Adapted from APHIS 280 data

Interceptions recorded on certain bromeliads imported from Belgium and the Netherlands into the United States over the period 1985-2007 ar e discussed in the PRA (USDA, 2009). All interceptions were from permit cargo. No interceptions were recorded for Neoregelia or for Denmark. Though certain intercepted taxa were liste d as quarantine pests in the PRA, they were not further analyzed (USDA, 2009). Some listed taxa may cont ain actionable pests and were intercepted during port-of-entry inspections of these commodities. However, the listed taxa are based on incomplete identifications. This may be due to the state of the taxonomy, or the condition or life stage of the specimen submitted fo r identification. Some taxa, even if identified to species level, are not associated with these br omeliad genera in the scientific literature and were intercepted as biological contaminants during port-of-entry inspections. They would not be expected to be found with every shipment.

In the PRA (USDA, 2009), only one quarantine pest was identified that could reasonably be expected to follow the pathway on Aechmea, Cryptanthus, Guzmania, Hohenbergia, Neoregelia,

Tillandsi a and Vriesea spp. from Belgium, Denmark, a nd the Netherlands. This fungus, Fusarium oxysporum f. sp. aechmeae , was characterized as having a low pest risk potential.10 According to APHIS guidelines (USDA, 2000), pest s with a risk rating of “low” typically do not require specific mitigation measures. The standard port-of-entry inspection to which all commodities imported into the United States are subjected is expected to provide sufficient phytosanitary security. Nevertheless , all plants established in gr owing media must comply with the regulations in 7 CFR 319.37-8 (Plants in Growing Media).