Category : TECHNICAL instead of “treatment” or “fumigation treatment”. The TPG that the redundant term “fumigation treatment” is used in PT 22 (Sulfuryl fluoride fumigation treatment for insects in debarked wood) and PT 23 (Sulfuryl fluoride fumigation treatment for nematodes and insects in debarked wood), but that such instances should not allow for further inconsistencies. 73 G (General Comment) IPPC Regional Workshop Latin America Se requiere una revisión global de la norma en relación al término "fumigación" que debe ser usado en todo el texto y el término empleado "tratamiento" debe ser cambiado por "fumigación" Category : EDITORIAL See comment 72. TPG 1 32 TPG proposal (TPG 1). This standard provides technical guidance for NPPOs on the specific procedures for the application of fumigation as a phytosanitary measure for regulated pests or articles. […] TPG proposal (TPG 1). The TPG felt that the part “for regulated pests or articles” was redundant, as it would already be covered by the definition of “phytosanitary measures” and recommended the deletion of these words as a simplification, avoiding potential confusion and unnecessary controversies as apparent from other comments to this paragraph. 79 32 This standard provides technical guidance for NPPOs on the specific procedures for the application of fumigation as a phytosanitary measure for regulated pests or on IPPC Regional Workshop Asia 1. amend to "on regulated" 2. 3rd sentence to be moved to Background APPPC agreed by APPPC See TPG 1. In addition, the TPG did not support the suggestion to amend to “for regulated pests on regulated articles” because the text may
carried out effectively so that minimizes economic scheduled parameters are attained at the required level throughout the commodity for the required duration and environmental impactsat required temperature. Category : TECHNICAL The TPG noted that the content of the Outline of requirements with this and the draft ‘Temperature treatment’ draft standard have been reduced to an elaborate list of contents of the standard, rather than summarizing the main requirements, and that this is inconsistent with how Outline of requirements were previously written. The TPG suggested that the SC examines further how Outline of requirements are written in current draft standards because they are tending to become meaningless. 118 41 The standard describes how fumigation treatments should be carried out to achieve the stated efficacy as given in ISPM 28 for the regulated pests of concernpests. This standard also provides guidance for NPPOs on the procedural requirements for fumigation entities authorized to perform fumigation treatments as a phytosanitary measure. Argentina "Of concern" deleted because is redundant. The term "fumigation treatment" should be used for consistency, because Annexes to ISPM 28 refer to fumigation treatments for specific pests. Category : TECHNICAL TPG supports the deletion of “of concern” as confusing and inconsistent with other ISPMs. Regarding the use of “fumigation treatments”, see comment 72. 124 41 The standard describes how fumigation should be carried out to The NPPO of the country in the fumigation is conducted or initiated is responsible for the evaluation, approval and monitoring of the application of fumigation as a phytosanitary measure. European Union As for the previous paragraph, the text continues with another main requirement. Category : TECHNICAL Supported, see comment 113.
appropriate measures for their control” (Article I.1 of the IPPC). The requirement for, or application of, phytosanitary treatments to regulated articles is a phytosanitary measure used by contracting parties to prevent the introduction and spread of regulated pests. the IPPC should be exact, so as to avoid any (mis)interpretation. 173 44 La finalidad de la CIPF es “prevenir la diseminación e introducción de plagas de plantas y productos vegetales y promover medidas apropiadas para combatirlas” (Artículo I.1 de la CIPF). El requisito o la aplicación de Los tratamientos fitosanitarios como requisitos o sus aplicación a los artículos reglamentados es una medida fitosanitaria que usan las partes contratantes para prevenir la introducción entrada y dispersión de plagas reglamentadas. Panama Clarificar el texto, y el uso de la palabra “entrada” es consistente con la NIMF No. 5 Category : EDITORIAL See TPG 2. 196 47 Historically, fumigation has been widely applied to prevent the introduction and spread of target regulated pests into a regulated an area and has, therefore, been beneficial to biodiversity and the environment. However, fumigant gases, such as methyl bromide, sulphuryl fluoride, phosphine and ethyl formate, may be toxic to people may have a specific effects on human health and have negative Peru Reference to "target regulated pests" is suggested to clarify the use of fumigation treatments as a phytosanitary measure. We suggest to change "toxic to people" by "specific effects on human health" for consistency with other ISPMs Category : TECHNICAL The TPG supported the addition of “regulated” before “pests” but suggested to then remove “target” as it would be superfluous. The TPG supported the deletion of “regulated” before “area” because this sentence is unnecessarily restrictive if referring only to regulated areas.
can be proportionally be mitigated through the use of recapture technology to reduce gas emissions. 212 47 Historically, fumigation has been widely applied to prevent the introduction and spread of target regulated pests into a regulated an area and has, therefore, been beneficial to biodiversity and the environment. However, fumigant gases, such as methyl bromide, sulphuryl fluoride, phosphine and ethyl formate, may be toxic to people have specific effects on human health and have negative impacts on the environment. For example, the emission of methyl bromide into the atmosphere is known to deplete the ozone layer and sulphuryl fluoride is a recognized greenhouse gas. The IPPC Recommendation on the replacement or reduction of the use of methyl bromide as a phytosanitary measure (CPM R-03, 2017) has been adopted in relation to this issue. Environmental impacts of fumigants can be proportionally mitigated through the use of recapture technology to reduce emissions. Uruguay Reference to "target regulated pests" is suggested to clarify the use of fumigation treatments as a phytosanitary measure. We suggest to change "toxic to people" by "specific effects on human health" for consistency with other ISPMs Category : TECHNICAL See comment 196. 221 47 Históricamente, la fumigación se ha aplicado ampliamente para prevenir la introducción entrada y la Panama Para ser consistente con la NIMF No. 5 y una texto más comprensible The TPG did not support replacing “introduction” with “entry”.
the entity”). They further noted that “treatment provider” is only used in paragraph 73 of the the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures (2014-005), but is used many times in ISPM 15. The TPG noted that the treatment provider is a person or organization applying the treatment operating in a physical contruction (i.e. the treatment facility). Because “entity” could refer to the facility, the provider, or both, the TPG supported using “treatment provider” and “treatment facility” instead of “entity” when it was clear that the references in the draft ISPM were made to either the provider or the facility. They felt such an approach would be clearer, although they acknowledged it was not consistent with the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures The TPG supported “treatment provider” as in ISPM 15, rather than “fumigation provider”. 260 52 2. Fumigation entitiesproviders Australia The definition of providers as operators and facilities is confusing. The operator can be a company or individual and provides the service to the fumigant. The See TPG 4. The TPG supported using “treatment provider” rather than “fumigation provider”.
facility is where the fumigation is carried out and can be owned by an operator or a third party (i.e ships hold, sea container) . The treatment provider is the fumigator that carries out the fumigation. We would suggest that the terms above are used in the definition. Entity may be difficult for translation. This would require further changes throughout the document. Category : TECHNICAL 262 52 2. Fumigation entities PPPO to include NPPOs (to be accountable) as one of the fumigation providers. Category : SUBSTANTIVE See TPG 4. 263 52 2. Fumigation entities PPPO reservations with the use of the word "Entity" forward in the paragraphs. Substitute with Fumgation providers? Category : SUBSTANTIVE See TPG 4. 265 52 2. Points de fumigation Cameroon Entités Category : TRANSLATION See TPG 4. TPG 5 53 Fumigation is undertaken by treatment providers entities (e.g. fumigation companies or individuals) either in a treatment fumigation facility or at locations (e.g. cargo ship hold) (hereafter, fumigation facilities and fumigation operators are referred to as fumigation entities). See TPG 4. TPG recommended using “treatment providers” and “treatment facility”. TPG proposal (TPG 5): The TPG recommended to delete the last sentence (in brackets) as it refers to “fumigation entities”. 267 53 Fumigation is undertaken by entities providers (e.g. fumigation Ozone Secretariat The definition of providers as operators and See TPG 4 and TPG 5.
292 56 como parte integrante integral de las operaciones de embalajeembalaje-empaque Panama Mejor comprensión del texto y términos comúnmente utilizados en idioma español. Category : EDITORIAL Translation comment. The Secretariat will forward to FAO translation services. TPG 6 62 TPG proposal (TPG 6): The minimum requirement of fumigation is to ensure that the required scheduled parameters (e.g. concentration–time product (CT)) are is attained at the required level throughout the commodity for the scheduled specified treatment minimum temperature and duration, allowing the required efficacy to be achieved. Appendix 1 provides guidance for fumigation efficacy studies. TPG proposal (TPG 6): The TPG supported the changes proposed in comment 318 (except for changing “fumigation” to “fumigation treatment”) and proposed additional editorial changes for clarity and consistency with ISPM 15, as the paragraph was confusing. 318 62 The minimum requirement of fumigation treatment is to ensure that the scheduled parameters (e.g. concentration–time product (CT)) are attained at the required throughout the commodity for the scheduled specified treatment minimum temperature and duration, allowing the required efficacy to be achieved. Appendix 1 provides guidance for fumigation efficacy studies. Argentina Changes suggested to align with the draft ISPM on temperature treatments. Last sentence deleted as per general comment, proposing the deletion of Appendix 1. Category : TECHNICAL See TPG 6 and comment 72. 322 62 The minimum requirement of fumigation is to ensure that the scheduled parameters (e.g. concentration–time product (CT)) are attained at the required United States of America Compare to the Appendix in temperature treatments draft. Perhaps all such efficacy studies appendices from different drafts should be Beyond TPG mandate. See comment 1384.
throughout the commodity for the scheduled treatment minimum temperature and duration, allowing the required efficacy to be achieved. Appendix 1 provides guidance for fumigation efficacy studies. combined in 1 guidance document, and made Supplement to ISPM 28. Category : SUBSTANTIVE 323 62 The minimum requirement of fumigation is to ensure that the scheduled parameters (e.g. concentration–time product (CT)) are attained at the required throughout the commodity for the scheduled specified treatment minimum temperature and duration, allowing the required efficacy to be achieved. Appendix 1 provides guidance for fumigation efficacy studies. European Union For consistency with the draft standard on temperature treatments following first consultation. NB: last sentence moved to the end of paragraph 51. Category : SUBSTANTIVE See TPG 6. TPG 7 63 TPG proposal (TPG 7) Parameters to consider when applying fumigation are the minimum dose, temperature and duration of the treatment, and where applicable the humidity of the treatment environment or moisture content of the commodity, all of which should be compatible with officially approved treatment schedules or ISPM 28 TPG proposal (TPG 7) The TPG recommended to use the Glossary term “treatment schedule”. 351 64 The treatment protocol should describe the process of pre- and post-conditioning to reach the required dose, where these Argentina Text because it is important to mention the commodity quality, as it was included in the draft ISPM on temperature treatments. The TPG supported for consistency.
target pest. A list of commonly used fumigants and their chemical properties is provided in Appendix 2. 388 68 The most common forms of fumigation fumigations used are those that apply a single fumigant. General use fumigants such as methyl bromide, phosphine or sulphuryl fluoride rely on a mode of action that is effective against all pest groups or against one particular group (e.g. arthropods, fungi, nematodes) and all or most life stages. Treatment schedules for single fumigants are generally simple, requiring a single application to achieve a required minimum dose over a specified duration. A list of commonly used fumigants and their chemical properties is provided in Appendix 2. EPPO Groups, types, forms… There is no explanation in the draft what they are and what are differences between. Should be explained or re-written. If the IPPC society works on the replacement or reduction of the use of methyl bromide as a phytosanitary measure, whay this is not clearly stated during the text? MB is equaly described as the other fumigants? In addition, there are already other good examples. Category : SUBSTANTIVE See 365, 372 and 383 (point 1). Deletion of “methyl bromide”: beyond TPG mandate. 404 69 4.2 Combinations with other fumigants or treatments Argentina To clarify the type of treatment and to simplify the title of the section Category : TECHNICAL TPG supported the change but with “combination” in singular (i.e. “combination treatments”). 409 69 4.2 Combinaciones con fumigantes o tratamientos Panama Se elimina porque se sale del ámbito de la competencia de la presente norma. Category : TECHNICAL See comment 404. 412 70 Where a single fumigant treatment may not achieve the required efficacy without rendering the Argentina For consistency Category : TECHNICAL Not supported, “single” refers to “fumigant” (the TPG considered the
commodity unmarketable, or for reasons of economy or logistics, another fumigant or treatment may be included in the treatment schedule. confusion is due to a translation problem). 418 70 Cuando no se pueda alcanzar el nivel de eficacia requerido con un único fumigante sin que el producto se vuelva no comerciable, o por razones económicas o logísticas, podrá incluirse otro fumigante o tratamiento en el protocolo de tratamientofumigación. Panama Mejor comprensión del texto y en concordancia con toda la norma. Category : TECHNICAL Changes not supported: Regarding the proposed deletion of “or treatment”: see the explanations in paragraph 72 of the standard. “Treatment” is not redundant with “fumigant” in this case, because section 4.2 refers to combination with other treatments, and not only to combination with other fumigants. “Treatment schedule” is a Glossary term (see comment 9, third paragraph). TPG 9 71 73 TPG proposal (TPG 9): 4.2.1 Sequential combination treatments 4.2.2 Concurrent combination treatments TPG proposal (TPG 9): TPG suggested to delete “combination” because redundant with the title of section 4.2 (see comment 404). 427 72 Another treatment may be applied immediately before or after fumigation after a single fumigant treatment to increase the effectiveness efficacy of the entire treatment. For example, temperature single and temperature fumigant treatments applied sequentially may be necessary Peru Changes suggested for consistency and better understanding of the text, and also to clarify that in general fumigation treatments are applied before temperature treatments Category : TECHNICAL The TPG did not support the change from “effectiveness” to “efficacy” as what is indeed meant here is the increased effectiveness of the treatment, not the efficacy, which is established at the moment of research (efficacy under ideal conditions). The efficacy is
different treatments. An example of a temperature and fumigant combination treatment is fumigation with methyl bromide followed by a cold treatment. 450 74 Concurrent combinations of a single fumigant with other fumigants or treatments may be superior in increase efficacy, commodity tolerance, economics or logistics compared to treatment with a single fumigant treatment alone. Argentina For consistency Category : TECHNICAL The TPG supported the second and changes proposed by Argentina, and suggested two additional changes: “Concurrent combinations of a fumigant with other fumigants or treatments may increase be superior in efficacyeffectiveness, commodity tolerance, economics or logistics compared to treatment with a single fumigant alone.” 458 74 Concurrent combinations of a fumigant with fumigants or treatments may be superior in efficacy, commodity tolerance, economics or logistics to treatment with a single fumigant alone. Sri Lanka By the word "concurrent" may be misleading as a cocktail of treatments. i.e. mixing of few chemicals together and application. This type of applications needs to be studied further since the impact (health and environmental) is unknown. Therefore, the text needs to be more focussed on what is meant by "concurrent"). If the treatments are applied separately, there may be always a sequence of application. In that sense, we feel that 4.2 can be removed and 4.2.1 could be renumbered as 4.2 Category : SUBSTANTIVE The TPG finds the word “concurrent” to be clear and the intended meaning is as interpreted by Sri Lanka. The further technical issue is outside of TPG mandate. 467 75 4.23.2.1 Fumigation treatment underFumigant and modified Peru For consistency with of section 4.2.2.2. Numbering of section modified as a consequential change according comments in paragraph 74. The TPG supported the change, except “fumigation” should be used instead of “fumigation treatment” (see comment 72).
constructed from materials that maintain adequate fumigant concentrations over the fumigation period (e.g. materials that are not porous or absorbent to the fumigant). Surfaces such as soil, sand, base rock and paving (stones or blocks) are unlikely to provide a suitable floor for a tent fumigation enclosure. 578 86 5.2 Fumigation equipmentcalibration Ozone Secretariat Para 87 is all about calibration. Category : SUBSTANTIVE Not supported by TPG: paragraphs 88 to 107 are part of Section 5.2 and are not about calibration. 600 88 5.2.1 Dosing devicesdevices and materials Canada Category : TECHNICAL See comment 601. 601 88 5.2.1 Dosing devicesequipment Peru For consistency Category : EDITORIAL The TPG supported the change for consistency. TPG 10 97 and TPG proposal (TPG 10): Horizontal to be reviewed throughout the draft standard. TPG proposal (TPG 10): The TPG noted that the draft standard in several instances uses “will” which is translated with the future sense in some languages, and this should be changed to either present tense (if expressing a fact) or “may” (if offering a possibility or in the sense of is permitted to), as appropriate (see ). The TPG recommended the steward to review the use of “will” throughout the draft standard. 680 99 A suitable vacuum gauge, of appropriate accuracy and sensitivity, should be used to Peru For consistency The TPG supported for consistency.
based on assurance that the treatment is effective against the pest of concern under specific conditions and closely monitored systems the treatment has been properly applied. Systems for treatment deliverydelivery should be designed, used and for safeguarding of treated commodities, provide an assurance monitored to ensure that treatments are properly conductedconducted and commodities are protected from infestation and reinfestation. standard on temperature treatments that results from first consultation. Category : SUBSTANTIVE temperature treatments as phytosanitary measures, with some additional changes as follows (noting that reinfestation is an (unnecessary) subset of infestation, whereas contamination is presumably an equally important concern): “Well-designed Confidence in the adequacy of a fumigation as a phytosanitary measure is primarily based on assurance that the treatment is effective against the target pest of concern under specific conditions and that closely monitored systems the treatment has been properly applied. Systems for treatment deliverydelivery should be designed, used and for safeguarding of treated commodities, provide an assurance monitored to ensure that treatments are properly conductedconducted and commodities are protected from infestation and contamination reinfestation.” 167 The NPPO of the country in which the treatment facility is located or where treatments are initiated should ensure that treatments are properly applied to meet the phytosanitary import initiated, is responsible for ensuring system requirements of the importing country and that commodities are Argentina Text modified as a consequential change according comment in paragraph 166 Category : TECHNICAL TPG supported the proposed changes for consistency with the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures, with an editorial: “The NPPO of the country in which the treatment facility is located or where treatments are initiated should ensure that treatments are
treatment fumigation schedule and this standard, as required. […] 198 records of temperature sensor calibrations andand recording, where appropriate, calibration records and recording for humidity sensors or moisture meters European Union For consistency with the draft standard on temperature treatments. Category : SUBSTANTIVE The TPG supported the changes. 205 Appropriate records for fumigation treatment as a phytosanitary measure should be kept by the fumigation entity for at least one year to enable the trace-back of treated lots. The fumigation entity should keep all records for every treatment. Information that should be recorded includes: Peru For consistency Category : TECHNICAL See comment 72. 205 Appropriate records for fumigation as a phytosanitary measure should be kept by the fumigation entity for at least one year to enable the trace-back of treated lots. The fumigation entity should keep all appropriate records for every treatmenteach treatment application. Information that should may be required to be recorded includes: European 1) Recording requirements have to be feasible and useful. For example the place of production (paragraph 211) is not always available for grain in bulk. 2) For consistency with the draft standard on temperature treatments. Category : SUBSTANTIVE Beyond TPG mandate. The TPG supported the changes for consistency with the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures. 221 All NPPO procedures should be appropriately documented and records, including of monitoring inspections made and phytosanitary certificates issued, should be maintained for at least one year. In cases of non-compliance or new or European Union Important modification, and for consistency with other ISPMs. Category : SUBSTANTIVE The TPG supported for consistency, but suggested to use “upon request” instead as in the draft ISPM on Requirements for the use of temperature treatments as phytosanitary measures.