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Regional workshop for the review of draft International Standards for Phytosanitary MeasuresCARIBBEAN,

Port of Spain, Trinidad and Tobago6-10 of September 2010

Report

1. Opening of the session

The meeting was chaired by Mr. Gregg Rawlins, Inter-American Institute for Cooperation on Agriculture (IICA) Representative in Trinidad and Tobago. He welcomed the participants to the workshop and stressed its importance as a unique opportunity for countries to collectively review five draft International Standards for Phytosanitary Measures (ISPMs) and prepare the comments to be sent by the countries to the International Plant Protection Convention (IPPC) Secretariat, before 30 September 2010.

Ms Ana Peralta, Implementation Officer of the IPPC, welcomed the participants to the meeting and thanked the Trinidad and Tobago national authorities and IICA for hosting and organizing the meeting. She also described the scope of the IPPC and its standard setting process and noted the main purpose of the workshop was to discuss the draft ISPMs that were circulated for member consultation. The IPPC Secretariat hoped that the meeting would help the participants understand the drafts and to prepare country comments for

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submission to the Secretariat. Ms Peralta mentioned the need for participation in the discussions leading to the adoption of new standards and for consultation with stakeholders in each country. She also mentioned the need for Caribbean countries to analyze the possibility of taking action to dissolve the Caribbean Plant Protection Commission (CPPC) and subsequently replace it with the Caribbean Agricultural Health and Food Safety Agency (CAHFSA).

Ricardo Molins, Manager of IICA/AHFS1 Programme, thanked the IPPC for trusting IICA in the organization of this meeting and hoped it could be helpful in coordinating the comments of Caribbean countries. He also pointed out the importance of this training activity for developing countries, to get them prepared to be active participants in the decisions of the IPPC and other Sanitary and Phytosanitary (SPS) related Conventions. Finally, he expressed IICA’s will to go on working together with the IPPC in improving participation in the standard setting process.

Ms. Cynthra Persad, Director of Research in the Ministry of Food Production, Land and Marine Affairs of Trinidad and Tobago, welcomed the participants to the workshop, especially the delegates from CARICOM countries. She stressed the importance of consultation on ISPMs in general and the five being considered at this workshop in particular. She positioned the importance of IPPC with the three sisters (IPPC, OIE and CODEX) and stressed the importance of implementation of the SPS agreement. On behalf of the Permanent Secretary of the Ministry, she wished an active and collective participation and substantive inputs to the standards and congratulated IICA for its support of the workshop. Finally, she summarized the importance and impacts for her country of the drafts currently under consultation.

Dr. Gene Pollard, former CPPC/FAO Officer attended the opening session.1 Agricultural Health and Food Safety

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The meeting was attended by 16 experts from 13 countries and was facilitated by IICA and the IPPC Secretariat. See Appendix 1.

2. Purpose of the workshop

The purpose of the workshop was outlined in the opening session – to provide participants of the Caribbean region with a regional forum to discuss the draft ISPMs. These discussions could help participants gain a better understanding of the national and regional impacts of these proposed standards and provide a basis for the submission of national comments. This workshop covered the following draft ISPMs that were circulated for member consultation:

Systems approaches for pest risk management of fruit flies Submission of new treatments for inclusion in ISPM No.15 Integrated measures approach for managing pest risks associated with international trade of plants for

planting Irradiation treatment for Ceratitis capitata (Annex to ISPM 28) Diagnostic protocol for Plum pox virus.

3. Overview of the IPPC

Ms. Ana Peralta gave an overview of the IPPC, ISPMs and the standard setting process. It was noted that this meeting was held to assist countries in the preparation of their comments on draft ISPMs. Official comments should be submitted to the IPPC Secretariat by the national IPPC contact point, before the deadline of 30 September 2010.

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4. Adoption of the agenda

The agenda was discussed and adopted (Appendix 2).

Issues of particular interest for the Caribbean region were added under item 7. Any other business.

Dr. Mario Fortuné was elected as Chair of the meeting. Dr. Janil Gore-Francis and Mr. Ryan Anselm were elected as rapporteurs.

Due to time constraints related to the fixation of a religious holiday in Trinidad & Tobago on Friday 10 th of September, it was decided to extend the meeting one hour a day, from Monday to Thursday, to be able to finish the meeting on Friday 10th of September at noon.

5. Review of documents and discussion on draft ISPMs

Dr. Janil Gore-Francis incorporated comments to the templates of draft ISPMs on: Integrated measures approach for managing pest risks associated with international trade of plants for planting and Diagnostic protocol for Plum pox virus.

Mr. Ryan Anselm recorded comments performed on: Systems approaches for pest risk management of fruit flies, Submission of new treatments for inclusion in ISPM No.15 and Irradiation treatment for Ceratitis capitata (Annex to ISPM 28) .

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Participants were aware of the Instructions for the Use of the Template (see Appendix 3). Further, it was decided by the participants to forego introductory Powerpoint presentations on the draft ISPMs as the delegates were already aware of the background and history of the drafts.

Participants were invited to take note of the comments collected at this workshop and utilize these comments as they felt appropriate in their preparation of national comments. National comments should be submitted through the NPPO contact point to the IPPC Secretariat no later than 30 September 2010. Guidelines for the submission of comments on draft ISPMs are provided (see Appendix 5).

The following subsections capture the main discussion points for each of the draft ISPMs reviewed, when necessary.

5.1 DRAFT ISPM: Systems approaches for pest risk management of fruit flies.

Meeting participants considered that a substantive comment related to this draft, should be that it looks as a very useful draft for the Caribbean region, necessary, timely and appropriate to increase trade.Technical and editorial comments appear in the template under Appendix 4.

5.2 DRAFT ISPM: Submission of new treatments for inclusion in ISPM No.15.

Substantive, technical and editorial comments appear in the template under Appendix 4. Meeting participants understood that major reviews are needed for this draft and that Table 1 should be rewritten using biological taxonomic groups and not groups based on symptomatology. Considering that this appendix is based heavily on Table 1, the review of the Table should impact on the contents of the entire document.

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5.3 DRAFT ISPM: Integrated measures approach for managing pest risks associated with international trade of plants for planting

Substantive, technical and editorial comments appear in the template under Appendix 4. Participants to the meeting stressed that draft standards should not be used to arbitrarily create definitions. In this document this was done in paragraphs 79-88 and Appendix 2 (paragraphs 117 – 121) to create definitions of critical non-compliance and non-critical non-compliance. These definitions must first be agreed upon by the membership of the Commission on Phytosanitary Measures (CPM) before they can be adopted. For this reason, participants were not in a position to provide comments on the paragraphs mentioned and considered that only after the development of the definitions, this draft could be adequately addressed.

The proposed risk-based application measures outlined in paragraphs 59-88 and in appendix 2 are excessive and seem to be imposing private standards which small developing countries would have enormous difficulties implementing and as a result would not be able to export to countries that insist on these measures. The issue of private standards has been placed on the agenda at WTO/SPS Committee Meetings by St. Vincent and the Grenadines and is yet to be resolved.

Consequently, the participants are unable to support this draft in its present format.

5.4 DRAFT ISPM: Irradiation treatment for Ceratitis Capitata (Annex to ISPM 28)

Participants to the meeting wished to thank the authors for the work that has gone into the development and provision of this Draft Annex. They also wanted to draw the attention of members to the fact that live larvae

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and/or pupae of the target organism may be encountered during the import inspection process as alluded to in paragraph 12(j) of the draft. This is of great concern to Caribbean countries especially as there is no accompanying standardized protocol for lab analysis that would facilitate the verification of the treatment efficacy. This concern is also true of previous similar annexes (ISPM 28: Treatments 1 – 8). The development and provision of such an accompanying protocol would allow Caribbean countries (and other concerned members) to know what requirements may have to be put in place for such verification purposes. This may go a long way in assuaging their concerns. Without the availability of such a protocol they do not agree at this time with the passage of this draft since they are in no position to verify the viability of surviving life stages of the target pest that may occur on/in infested host commodities after the recommended treatment.

A general and an editorial comment appear in the template under Appendix 4.

5.5 DRAFT ISPM: Diagnostic protocol for Plum pox virus

Technical and editorial comments were made on this draft ISPM and these comments are attached to the report (see Appendix 4).

In general, participants considered that it would be useful if the protocols were to give some idea re: possible geographic regions where this pest could be established. Information has only been given on where the pest has occurred or currently occurs. Additionally, participants noted that disclaimers for the mention of brand names have not been included in the document. Wherever a brand name is mentioned, a disclaimer must be included as a footnote, as agreed in CPM-5.

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6. Organization of future regional workshops on draft ISPMs (2011 session)

Participants were asked to consider the future of regional workshops for the review of draft ISPMs.

Considering these workshops as important initiatives for the region, participants identified as potential sponsors (excluding the EU, that is currently a donor, and IICA that co-sponsored this meeting), the USDA/APHIS, FAO, GTZ, Caribbean Development Bank (CDB), CAHFSA and the government of Canada.

IICA stated its interest in continuing organizing the workshops in the Caribbean, as co-sponsors.

The following topics were put forward for consideration for discussion as future workshop agenda items: Consultation on draft Specifications CAHFSA Technical field visits Capacity building (including mentoring) Implementation of standards New non-indigenous invasive pest species Interaction with RPPOs of Latin America Interactive section on intra-regional issues

7. Any other business

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7.1 Progress reports by participants on the implementation of adopted ISPMs

As a comment applicable to all countries of the region, participants were of the opinion that implementation provisions were an important missing issue for the plant health sector. Insufficient human and financial resources, as well as drastic budget reductions had happened in the region, affecting the works of the NPPOs. Efforts had been performed to get possible resources from other national and international organizations, including the private sector.

Lack of awareness of the importance of the Plant Health area and impacts of the entry of new pests, was considered an important factor affecting the availability of resources. Additionally, even when agriculture was perceived as a priority area at the regional level, budgets were not allocated at an adequate level to support the plant health area for its protection.

Mentoring processes among countries of the region were perceived as important activities, with an added value related to the provision of hands–on training in conditions similar to the ones in the countries of the trainees. Jamaica made specific mention of PRA training of the country’s staff by Trinidad and Tobago. Jamaica publicly thanked Trinidad and Tobago for the support received.

The following are short notes on the comments made by participants that, in many cases, reflect the opinions presented by Barbados.

Barbados – Stated that in the current situation of limited resources, the development of pest lists at the national level could only be adequately achieved if a regional programme of survey/surveillance could be implemented, considering the trade and existing links among countries. In addition, it was felt that the

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practice of receiving PRA training for short periods was insufficient for countries to go about the development of PRAs. Countries were further hampered by the unavailability of enough staff to implement the procedures while some countries did not have a unit dedicated to the performance of PRAs. Barbados suggested that one of the ways to address the issue was to get one cooperation official working with each country for some months in the development of PRAs. Barbados also expressed doubts on the practical application of the sampling ISPM and the possibility to address the implementation of post-quarantine facilities without an architectural drawing/plan (this was a suggestion from the 2009 workshop). Barbados recognized that countries have problems in implementing many of the ISPMs and suggested that the IPPC looks at this issue.

Belize – The main problems exist as a result of insufficient staff and funds to effectively carry out its activities. Plant Health is a technical department working closely with animal health, food safety and the quarantine department. The NPPO has assessed its capacities and received a 2nd IDB project to support regulatory activities. The IDB project is in the second phase of implementation. Needs are related to strengthening of certification processes as well other training activities. An important strategy which can be used to raise political attention on Plant Health is the careful preparation of presentations and justifications for Cabinet, explaining what could happen if standards are not implemented and followed at the SPS/WTO level. Another strategy to stress the importance of phytosanitary issues is to work together with stakeholders and use their influence in sensitizing politicians. Belize considers that an important milestone to be obtained through CARICOM is regulatory harmonization at the regional level.

St. Vincent &the Grenadines– Shares Barbados’ concerns. Points out problems in implementation of ISPM 15 and explains that the most relevant pallets for banana exports are treated in Europe. There is an EU-funded project administered by FAO to address SPS issues. A workshop was held with stakeholders that

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exposed them to a number of ISPMs. Currently, the NPPO has office space allocated for PRA but lacks human and financial resources to conduct PRAs. There is also an unreliable internet connection. St. Vincent and the Grenadines reflected on the fact that the number of exotic pests recently found in the region is an indication of the country’s inability to implement a number of ISPMs. The meeting was informed that a new Plant Protection Act has been passed in 2006.

Grenada – Had similar problems to those of Barbados and identified an important constraint related to problems of availability of treatment facilities. Additionally, and even when importation of planting material is a relevant activity, there are problems of disposal of infested material, related to the lack of incinerators.

St. Kitts and Nevis– The country does not have a plant health unit to date but the process of addressing this short-coming has already begun. Due to serious economic constraints the Federation welcomes assistance in the areas of infrastructural development and human resource training for areas such as PRA, pest list development and similar matters relating to adherence to various standards.

Dominica– Expressed difficulties in the implementation of ISPM 15 at the national level. The NPPO has conducted several national consultations with the private sector as well as a study tour to Jamaica’s heat treatment facility. Dominica supports Barbados’ concerns regarding the implementation of ISPMs. Dominica made reference to the increased diplomatic relations with Asian countries and the demands for importation of new agricultural products without the necessary information to conduct PRA. A regional approach should be considered in conducting PRA. An important constraint is the lack of human resources to conduct surveillance, quarantine and PRA activities.

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Trinidad &Tobago– There were initial problems in the implementation of ISPM 15 and presently only the export part of the ISPM has been implemented. The country has a fully functional PRA Unit. There is need for training of staff in advanced PRA. Trinidad and Tobago is willing to assist other member countries in the mentoring process.

Jamaica– One major concern is the implementation of the import aspect of ISPM 15. A second attempt has been made to have the regulations adopted. Increased awareness of the three sisters (CODEX, OIE, IPPC) is needed at the policy level in order to increase support for active participation in these fora. Jamaica informed the meeting of its new PRA Unit and expressed thanks to Trinidad and Tobago for the mentoring programme that facilitated the process.

St. Lucia – Expressed similar concerns made by other countries. It is unable to implement many of the ISPMs due to the lack of financial and human resources. As it relates to ISPM 15, no treatment facilities are available. The NPPO is constrained by loss of trained and experienced staff as a result of the enforcement of mandatory retirement at age 55. Other scientifically minded staff have moved into administration because the technical staff in the NPPO are disadvantaged as a result of the organizational structure. This situation is an important challenge for the NPPO.

Haiti– Problems similar to those of other countries. Presently, Haiti works in the implementation of standards related to Fruit Flies in corporation with the USDA. The Plant Protection Division faces a big lack of scientists, facilities and budget in the services. Haiti is presently working on the project funded by the EU and administrated by the IDB to strengthen plant and animal health, quarantine and food safety. Haiti also works together with the Dominican Republic in plant and animal health through a bilateral commission to solve the common problems.

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Antigua & Barbuda – The country has received assistance from USDA in the implementation of many ISPMs. Maintenance of certain surveillance programs are at risk because of the lack of essential resources such as vehicles. Exposure to risk is constant because of continuous importation of large quantities of plants and plant products. There is no parallel development between the increased importation and support for Plant Protection activities. Antigua and Barbuda has developed a project for the construction of a Plant Protection facility but is experiencing difficulty accessing the funds allocated to this project. The NPPO had budgeted for incinerators to be placed at the ports of entry but due to financial constraints this item was cut from the budget. The NPPO is currently seeking to develop its organizational arrangements to ensure effective and efficient operation. Legislation developed through the assistance of FAO and CARICOM was adopted, but one year ago it was withdrawn from the parliamentary process and nothing has been done since. Antigua and Barbuda felt strongly that regional agencies should meet with the countries’ leaders in an appropriate forum to increase understanding of plant health issues.

Bahamas– The Bahamas’ comments mirror those of Barbados. An important constraint is the lack of human resources to conduct surveillance, quarantine and PRA activities. Additionally, the severe limitation of technical and financial resources is a matter of serious concern. Management of pest control activities is further compounded by the spatial nature of the Bahama islands. The Bahamas wishes to express gratitude to all related agencies for facilitation and funding of training workshops similar to this one.

Suriname – Suriname is exactly encountering the problems that so far have been indicated by the other members including lack of financial and human resources for the implementation of the ISPMs and other phytosanitary requirements. Suriname also mentioned that it is difficult to get technical staff trained in the right fields. Suriname is also doing some PRA at its Plant Protection Department and is having problems in

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the implementation of ISPMs due to outdated legislation. There is a draft Plant Protection Act awaiting enactment by the National Assembly. At this time Suriname is doing as much as it can to strengthen the Plant Protection Department.

7.2 Presentation of online comment system for draft ISPMs

Ms Peralta provided a Powerpoint presentation on the on-line comment system that the Secretariat was having developed by information technology (IT) specialists. Trinidad and Tobago, Barbados, Bahamas, Dominica, Jamaica and Antigua and Barbuda expressed their willingness to participate in the testing of the system.

7.3 Participant survey (Appendix 6)

Participants were instructed by Ms Peralta on how to complete the online survey form. The participants agreed to complete the survey during the meeting or after their return to headquarters.

7.4 Guidelines to Implementation of Phytosanitary Standards in Forestry

Ms Peralta introduced the guidelines which are currently under development by FAO Forestry Division. Most countries noted that they had not received the guidelines. Trinidad and Tobago and Dominica informed the meeting that they had received the information. Trinidad and Tobago provided comments at the time the document was posted for consultation.

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Participants discussed the need to improve communication between forestry and plant health officers and understood the relevance of making urgent contacts with Forestry officials or Forestry Departments for future possible activities of implementation of these guidelines.

7.5 Draft specifications

Ms Peralta outlined the process for making comments on draft specifications currently out for member consultation and encouraged countries to make any comments to the IPPC Secretariat by the deadline of 13 September 2010 using the templates provided. Participants were instructed on how to find and download the specifications and comments templates from the International Phytosanitary Portal (IPP).

7.6 CPPC/CAHFSA

Ms Peralta informed that FAO established a Caribbean Plant Protection Commission (CPPC) under Article VI.1 of the FAO constitution in 1967. The Technical Secretary of the CPPC was the FAO Plant Protection Officer for the Sub-Region of the Caribbean. The CPPC comprises the following countries: Barbados, Colombia, Costa Rica, Cuba, Dominica, Dominican Republic, France (for Guadeloupe, French Guiana, Martinique), Grenada, Guyana, Haiti, Jamaica, Mexico, Netherlands (for Aruba, Netherlands Antilles), Nicaragua, Panama, Saint Kitts and Nevis, Saint Lucia, Suriname, Trinidad and Tobago, United Kingdom (for British Virgin Islands), United States of America (for United States Virgin Islands, Puerto Rico), Venezuela.

At the 11th session of the CPPC held in 2001 in Port of Spain, Trinidad and Tobago, the main discussion topic related to the future of the CPPC and the possible creation of an independent regional organization, the

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Caribbean Agricultural Health and Food Safety Agency (CAHFSA) to promote a regional approach to food safety, plant health and animal health, which was envisioned to replace the CPPC. A preliminary study prepared by IICA in collaboration with the CARICOM Secretariat and FAO was discussed. The Commission made plans for further consultation of possible member countries in the region (i.e. all Caribbean countries, and not only CARICOM members) on this project, as well as the development of a draft international agreement which could be used to establish CAHFSA. The CARICOM Secretariat coordinated actions in collaboration with FAO, IICA and PAHO/WHO.The process for establishment of CAHFSA was spearheaded by CARICOM since 2001 and received support at the Twenty-First Inter-sessional meeting of the Conference of Heads of Government of CARICOM for its establishment. The Caribbean Agricultural Health and Food Safety Agency (CAHFSA) was inaugurated in Paramaribo on 18 March 2010. CAHFSA will be headquartered and hosted by the Government of Suriname. The IPPC Secretariat met with Mr. Sergio Garcia, Programme Manager, Agriculture and Industry of the Caribbean Community Secretariat and responsible officer for making CAHFSA operational, to initiate discussions with the CARICOM Secretariat to ensure that the topic is placed on the agenda of CAHFSA as well as to alert CAHFSA of opportunities that may be of interest to CARICOM/CAHFSA at this early stage before CAHFSA is fully operational.The following points were discussed:

1. CAHFSA as a Regional Plant protection Organisation (RPPO) for the Caribbean Considering the early stage in making CAHFSA operational, it was suggested that it would be opportune to table CAHFSA’s future role as an RPPO on the agenda of the next appropriate CARICOM planning meeting concerning CAHFSA. On confirmation that CAHFSA intends to be

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recognised as the RPPO for the Caribbean then the IPPC can begin to obtain support from member governments to dissolve the CPPC. Dissolution of the CPPC would require support from representative governments at the FAO Committee on Constitution and Legal Matters and a subsequent motion of support at FAO Council. CAHFSA would then have to submit to the IPPC formally for recognition as an RPPO. Mr Garcia suggested that it would also be necessary for CARICOM to seek the support of its members to propose replacement of the CPPC with CAHFSA. He also recognised that CAHFSA may need to introduce a legal mechanism to widen its membership (e.g. associate membership to include non-CARICOM countries). Such a mechanism could allow CAHFSA to match the number of countries presently members of the CPPC as well as open access to additional resources.The IPPC Secretariat agreed to send CARICOM more information on the process for the recognition of a regional plant protection organization by the IPPC.

Meeting participants addressed the issue, understanding that it was of key importance and were informed by Ms Sheila Harvey, from Jamaica, that next week senior agricultural and legal officers were going to meet in Suriname, to discuss the CAHFSA agreement.

7.7 Capacity development EWG

At CPM-5 (2010), the IPPC approved a relevant documents in the area of Capacity Building as a concept paper on national phytosanitary capacity and a phytosanitary capacity building strategy, that includes six strategic areas, as the components of a global strategy with stakeholders at national, regional and international level. These documents need now to be followed by an operational plan that has to be presented to CPM for approval.

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At the same meeting, the IPPC agreed to create an expert working group, intended to be long-standing, to review and refine the phytosanitary capacity development operational plan and assist the Secretariat with developing national phytosanitary capacity.

The Secretariat had been working on preparing the meeting of the WG to ‘review and refine the phytosanitary capacity development operational plan and assist the Secretariat with capacity building’ in accordance with the terms of reference approved by CPM-5 and following the instructions received from the Bureau in its June 2010 meeting on selection and characteristics of the participants.

The terms of reference for the EWG are the following:

MembershipOne person from each region with experience in phytosanitary capacity building.

Terms of ReferenceReview the draft Operational Plan under each of the logical frameworks identifying activities that are new and those that are part of existing activities. The group should also identify overlaps and linkages between different activities.1. Review and provide advice on priorities for activities taking into account the financial situation of the

IPPC.

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2. Provide advice on the timing of proposed activities and the potential benefits of cooperation with other organizations (e.g. Standards and Trade Development Facility - STDF).

3. Provide advice to the Secretariat on the preparation of advocacy materials needed to support fund raising for capacity building.

4. Provide advice on strategies that could be used to approach donors for contributions to support capacity building.

5. Provide recommendations on the future structure and mode of operation of the expert working group including the possibility of forming a subsidiary body on capacity building.

6. Report to CPM-6 through the Bureau and Informal Working Group on Strategic Planning and Technical Assistance (SPTA).

Date and venue

The meeting is fixed for 25-29 October 2010, at FAO Headquarters in Rome , Italy.

Possible outputs for the EWG could be:

Global plan on phytosanitary capacity building prepared, considering timing, overlaps, and interactions among activities of the IPPC and other organizations.

List of priority areas for IPPC capacity building activities, related to realities in different regions.

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Document on recommendations about the possibility of forming a Subsidiary body to the CPM, including its draft terms of reference and rules of procedure.

List of recommendations for preparing advocacy materials intended for fund raising. List of identified strategies to approach donors to raise funds for capacity building.

On behalf of Latin America and the Caribbean, Ms. Sheila Harvey from Jamaica is the person invited to participate in the EWG meeting. She asked for updated information of Caribbean countries on capacity building needs to update data obtained through the application of PCE and PVS in the Caribbean region. It was agreed with the participants that she was going to send by e-mail to all countries in Latin America and the Caribbean, a format to collect new information on the issue.

7.8 IICA Handbook on Good practices for participation in meetings of the IPPC

Participants received copies of this publication and Ms. Lourdes Fonalleras explained its objectives and uses. IICA was congratulated for this initiative, indicating that it was very helpful to improve and increase participation in IPPC activities.

8. Date and location of the next meeting

Participants indicated that August 22-26, 2011 could be an appropriate period for the next meeting. On the venue, they considered that all countries in the Caribbean could be possible candidates to host the meeting.

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9. Close

The Chair

Closing remarks were given by the IPPC Secretariat. Ms Peralta indicated that and pointed out four things of note:

1. The level of participation exhibited2. The attention paid to the detail of the templates, etc.3. As member of the Secretariat, participants were congratulated on the level and quality of the comments

and valuable opinions made. Participants were urged to ensure that their comments were prepared and submitted to the Secretariat as national comments prior to the deadline.

4. Ms. Peralta noted that participants welcomed the nature of the interaction among them and urged that this be continued

Participants, the Chair and both rapporteurs were thanked by Ms Peralta for their valuable contributions and encouraged to coordinate the submission of national country comments to the Secretariat. IICA staff members , and specially Ms. Lourdes Fonalleras, Carol Thomas and Mariela Madrigal were thanked for their special contribution, that helped make the workshop possible.

A vote of thanks was rendered by Michael James to the IICA Secretariat for their facilitation of the proceedings, the Chair for a job well done, to Bahamas for reading of the script, the rapporteurs and to the staff of the Hyatt hotel for the technical and other support. He further urged participants to maintain contact after the workshop and wished everyone a safe journey home.

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Ms. Fonalleras thanked Ms Peralta for her invaluable assistance in the process and expressed regret on behalf of Ms Carol Thomas for her absence as she was unable to remain for the duration of the workshop. Ms. Fonalleras further indicated the willingness of IICA to continue in its support of these workshops. Participants were congratulated for the nature and quality of the work throughout the workshop.

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APPENDIX 1: Agenda

AGENDA

Regional workshop for the review of draftInternational Standards for Phytosanitary Measures (ISPMs)

CARIBBEANPort of Spain, Trinidad and Tobago.

6-10 September 2010

Monday – 06/09/10

08.30 – 09.00 Registration

09:00 – 10:00 Official Opening of the workshop

10.00 - 10.30 Coffee break

10:30 – 11:30 - Adoption of the agenda- Election of chair and rapporteur- Overview of IPPC

11:30 – 12:30 Review and discussion of draft standards1. Systems approaches for pest risk management of fruit flies

12:30 – 13:30 Lunch


15:30 – 16:00 Coffee break

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Tuesday – 07/09/10




12:30 – 13:30 Lunch

13:30 – 15:30 Review and discussion of draft standards2. Irradiation treatment for Ceratitis Capitata (Annex to ISPM 28)


16:00 – 18:30 Review and discussion of draft standards3. Submission of new treatments for inclusion in ISPM No.15.

Wednesday – 08/09/10

08:30 – 10:00 Review and discussion of draft standards4. Integrated measures approach for managing pest risks associated with international trade of plants for planting



12:30 – 13:30 Lunch



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Thursday – 09/09/10

08:30 – 10:00 Review and discussion of draft standards5. Diagnostic protocol for Plum pox virus


10:30 – 12:30 Review and discussion of draft standards5. Diagnostic protocol for Plum pox virus

12:30 – 13:30 Lunch

13:30 – 15:30 Organization of future regional workshops

Any other business

1. Progress reports by participants on the implementation of adopted ISPMs2. Presentation of online comment system for draft ISPMs3. Participant survey4. Guidelines to implementation of phytosanitary standards in forestry5. Draft specifications6. CPPC/CAHFSA7. EWG on Capacity development8. IICA Handbook on Good practices for participation in meetings of the IPPC


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16:00 – 18:00 Any other business

1. Progress reports by participants on the implementation of adopted ISPMs2. Presentation of online comment system for draft ISPMs3. Participant survey4. Guidelines to implementation of phytosanitary standards in forestry5. Draft specifications6. CPPC/CAHFSA7. EWG on Capacity development8. IICA Handbook on Good practices for participation in meetings of the IPPC

Friday – 10/09/10

08:30 – 10:00 Other matters Adoption of report


10:30 – 12:30 Other matters Adoption of report Close

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APPENDIX 2: List of participants

+ -=-


6-10 September 2010Port of Spain, Trinidad & Tobago

Participants List

ParticipantsName: Peter JosephPosition: Plant Quarantine OfficerAddress: Ministry of Agriculture, Pest Management UnitAddress: Botanical Gardens St. George’s, GrenadaAddressAddress Country: GrenadaTel: 1-473-440-0019Fax: E-mail: [email protected]

Name: Melvin JamesPosition: Entomologist, Address: La Guerite, Basseterre, St. KittsAddress: Department of Agriculture, St. KittsAddressAddress Country: St. Kitts/Nevis Tel: :869-465-2335Fax: E-mail: [email protected]

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mailto:[email protected]


ParticipantsName: Jackson DonisAddress: Ministry of AgriculturePosition: Plant Protection DirectionAddress: B.P. 1441, Damien, Port-au-Prince, HaitiAddressAddress Country: HaitiTel: (509) 3611-7558Fax: E-mail: [email protected]

Name: Gregory SquiresPosition: Crop Protection OfficerAddress: Ministry of Agriculture, Fisheries & ForestryAddress: Waterfront, Castries, St. LuciaAddress AddressCountry: St. Lucia Tel: 1-758-452-2526 / 450-2375Fax: E-mail: [email protected]

Name: Sadhana JankiePosition: Laborant Pest Analyst of the DepartmentAddress: Department of Plant ProtectionAddress: Kankantrie Str. No. 9, Suriname of Plant Protection and Quality InspectionsAddressAddress Country: SurinameTel: 402040Fax: 403912E-mail: [email protected]

Name: Janil Gore-Francis Position: Plant Protection OfficerAddress: Ministry of Agriculture, Land, Housing & EnvironmentAddress: P.O. Box 1282, St. John’s AntiguaAddressAddress Country: AntiguaTel: 268-462-1213 / 268-764-1255Fax: 268-462-6104E-mail: [email protected]

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Participants List

ParticipantsName: Ryan AnselmPosition: Plant Protection &Quarantine OfficerAddress: Ministry of Agriculture & ForestryAddress: Botanical Gardens, RoseauCountry: DominicaTel: 1-767-266-3803Fax: 1-767-448-8632E-mail: [email protected] [email protected]

Name: Michael DelpechePosition: Agricultural OfficerAddress: Richmond Hill, Kingston P.O.AddressAddressAddress Country:St. Vincent and the Grenadines Tel: 1-784-456-1410 / 1-784-457-1283Fax: 1-784-457-1688E-mail: [email protected] [email protected]

Name: Shelia HarveyPosition: Chief Plant Quarantine/Produce InspectorAddress: 193 Old Hope Road, KingstonCountry: JamaicaTel: 977-0637Fax: 977-6992E-mail: [email protected] [email protected]

Name: Margarito GarciaPosition: Technical Director Quarantine & Inspection ServicesAddress: Belize Agricultural Health Authority Central Farm Research Station Cayo District, Belize Country: BelizeTel: 501-824-4899/4872Fax: 501-824-3773E-mail: [email protected]

29




ParticipantsName: Michael JamesPosition: Senior Agricultural OfficerAddressMinistry of AgricultureAddress: Graeme Hall, Christ Church, BarbadosCountry: BarbadosTel: 246-434-5112 / 246-434-5114Fax: 246-428-7777E-mail: [email protected]

Name: R. Gwendolyn HammertonPosition: Assistant Director of AgricultureAddress: Department of AgricultureAddress: P.O. Box N-3028, Nassau, BahamasCountry: BahamasTel: 242-325-7502 / 242-397-7426Fax: 242-356-4263E-mail: [email protected] [email protected]



30




Trinidad and Tobago ParticipantsName: Kishore RagbirPosition: Agricultural Officer 1 Address: Ministry of Food Production, Land and Marine AffairsAddress: Research Division, CentenoAddressAddress Country: TrinidadTel: 1-868-642-0718Fax: 1-868-642-0718E-mail: [email protected]

Name: Mario FortunePosition: Deputy DirectorAddress: Ministry of Food Production, Land & Marine AffairsAddress: Research Division, CentenoAddressAddress Country: TrinidadTel: 1-868-642-6008 / (472-7142 – CELL)Fax: 1-868-642-0718E-mail: [email protected]

Name: Dale NandlalPosition: EntomologistAddress: Ministry of Food Production, Land & Marine AffairsAddress: Research Division, CentenoAddressAddress Country: TrinidadTel: 1-868-646-4337 EXT# 4035Fax: 1-868-646-2149E-mail: [email protected]

Name: Tamika SealesPosition: Plant Protection SpecialistAddress: Division of Agriculture, Marine Affairs, Marketing and the Environment, Tobago House of AssemblyAddress: Glen Road, Scarborough, TobagoAddressAddress Country: TobagoTel: 1-868-639-9515Fax: 1-868-639-9515E-mail: [email protected]

31



32

IPPC SecretariatName: Ana PeraltaPosition: Implementation OfficerAddress: International Plant Protection Convention Secretariat, Plant Production and Protection DivisionAddress: Room: B-703, Viale delle Terme di Caracalla - 00153Country: RomeTel: +39 0657055322Fax: +39 0657054819E-mail: [email protected]

33



Observers

IICAName: Gregg C.E. RawlinsPosition: IICA Representative, Trinidad & TobagoAddress: #10 Austin Street, St. AugustineAddress: P.O. Box 1318, Port of SpainCountry: Trinidad and TobagoTel: 1-868-645-5020, 645-4555, 645-8886Fax: 1-868-662-8253E-mail: [email protected]

Name: Ricardo MolinsPosition: Manager, Agricultural Health &Food Safety ProgramAddress: San Josè, Country: Costa RicaTel: 506-2216-0222Fax: 506-2216-0221E-mail: [email protected]

34

IICAName: Carol ThomasPosition: Agricultural Health & Food Safety SpecialistAddress: Chelsea House, Chelsea Road, P.O. Box 705, BridgetownCountry: BarbadosTel: (246) 427-4740/1/2Fax: (246) 429-3509E-mail: [email protected]

Name: Lourdes FonallerasPosition: Agricultural Health & Food Safety SpecialistAddress: Luis Piera 1992Country: UruguayTel: (598) 24101676Fax: -E-mail: [email protected]

Name: Mariela MadrigalPosition: Administrative Assistant, Agricultural Health & Food Safety ProgramAddress: San Josè, Country: Costa RicaTel: 506-2216-0222Fax: 506-2216-0221E-mail: www.iica.int

Name: Geselle Edwards-HodgePosition: Secretary, IICA, Trinidad & TobagoAddress: #10 Austin Street, St. AugustineAddress: P.O. Box 1318, Port of SpainCountry: Trinidad and TobagoTel: 1-868-645-5020, 645-4555, 645-8886Fax: 1-868-662-8253E-mail: [email protected]

Name: Edwin FrancoPosition: Driver/Messenger, IICA, Trinidad & Address: #10 Austin Street, St. AugustineAddress: P.O. Box 1318, Port of SpainCountry: Trinidad and TobagoTel: 1-868-645-5020, 645-4555, 645-8886Fax: 1-868-662-8253E-mail: edwinefranco @yahoo.com

35




APPENDIX 3: Guidelines for use of templates for comments

INSTRUCTIONS FOR THE USE OF THE TEMPLATE

A template is provided to facilitate the submission and compilation of member comments. The instructions have been modified since last year; please review both the instructions and the examples. Paragraph numbers have been included in the draft standards, and each paragraph has a row in the template with the corresponding number. It is important to be accurate in allocating comments to paragraphs, since the compilation of comments will be done automatically and only based on paragraph numbers.

To facilitate compilation of comments and the work of the Standards Committee, please apply the following and refer to the table of examples below:- do not add or delete columns, and do not change their width or formatting of the actual table.- ensure that all comments refer to the appropriate section of the text and paragraph number.- if proposals are made to add, delete or move paragraphs to the text of the standard, subsequent comments should continue to refer to the paragraph numbers used in the draft standard sent for consultation.- only one type of comment should be made in each row of the template; when more than one type of comment needs to be made on the same

paragraph, insert a new row, include all appropriate information (including paragraph number) and fill in your comment. Do not use automatic numbering.

- ensure that all cells of the row are completed when a comment is made.- use formatting to indicate proposed additions (e.g. underline) and deletions (e.g. strikethrough), not tracked changes of the Word processor- only include those sentences from the draft standard to display the suggested modifications. Do not include paragraphs or sentences for which no

modifications are suggested.- to provide a comment on a footnote, please enter it in a row with the number of the paragraph with which the footnote is associated.- delete the rows of the template in which no comments are made.

Specific guidelines for each column in the template and examples of commentsGeneral comments apply to the entirety of the standard. Comments on specific sections of the standard can be provided as described below.

1. Section This gives the titles of sections as they appear in the draft, plus a row for general comments. To propose changes to section titles, include new

wording in the "proposed rewording" column.

2. Paragraph number (Para nber) To propose a new paragraph, add a row and qualify the paragraph number with a letter (e.g. 12a, to indicate that the new paragraph follows paragraph 12).

36

To propose to move a paragraph, indicate the new location in the “proposed rewording” column (e.g. move paragraph 51 to after paragraph 47). Do not alter the paragraph numbers.

3. Sentence/row/indent, etc. Clearly identify the specific place in the paragraph, such as sentence, row of a table, indent, etc, where the comment applies (e.g. sentence

2, indent 5, row 2, footnote 3, figure 15, etc). Table rows have been also numbered similar to the paragraphs The text as circulated for consultation should be used as a basis for counting sentences, bullet points, etc. Please do not refer to page or

line numbers as these may vary depending on the word processor used or language version of the draft.

4. Type of commentIndicate whether the type of comment refers to one of the three choices: substantive, editorial, or translation. Please only use these keywords: Substantive, Editorial, Translation. substantive comments include technical comments. They take into account conceptual changes, addition of new aspects or ideas, scientific corrections and

technical adjustments. editorial comments clarify or simplify the text without changing the meaning. This includes spelling or grammatical corrections, suggestions of different

but equivalent words, and simplification of sentence structure. translation comments correct points that are considered to be inaccurately translated into another language version of the text.

5. Proposed rewordingSuggestions to change the text should always include proposed rewording. Modifications to the original text should be clearly identifiable (i.e. text that is added or deleted should appear in a distinct way from unchanged text). For example, text added can be underlined and text deleted can be striked through (with colours as appropriate). Tracked changes should not be used.

6. ExplanationDetailed explanations should give justification for the comment made and should be sufficient for the Standard Committee to understand the intention of the comment and the proposed rewording.

7. Country There should be only one name in this column. The country name should be indicated in every row for which a comment is made. The country name should be that of the country submitting the

comments. Comments made on behalf of an organization (such as an RPPO) should include only the organization name, and not the names of the member

countries.

Examples of comments using the template

37

1. Section 2. Para nber

3. Sentence/row/indent, etc.

4. Type of comment (Substantive, Editorial, Translation) only

5. Proposed rewording 6. Explanation 7. Country

BACKGROUND [9] Sentence 1

Substantive

The main purpose of the IPPC is to protect plants secure common and effective actions to prevent the spread and introduction of pests of plants and plant products

To be consistent with the text of the IPPC.

COUNTRY NAME

BACKGROUND [9] Sentence 2 Editorial In doing so, contracting parties undertake the promotion of appropriate measures for the control of regulated pests.

The scope of the IPPC addresses regulated pests.

COUNTRY NAME

BACKGROUND [17] Sentence 4 Editorial ThusAdditionally, while pursuing the ....

Clearer wording COUNTRY NAME

1.4 Supervision activities

[26] Sentence 3 Substantive The FF-ALPP programme, including regulatory control domestic regulation

The term regulatory control is unclear and text should use specific terms clarifying what is meant.

COUNTRY NAME

1.4 Supervision activities

[32] New 2nd indent

Substantive - operation of surveillance procedures- fruit sampling- surveillance capability

Fruit sampling is necessary as part of surveillance

COUNTRY NAME

1.6 Tolerance level [44a]

After para 44 Substantive add new paragraph after 44:For quarantine pests the tolerance level generally equals zero. Setting the level of detection to zero implies that all units of the consignment must be included in the sample. Hence, for quarantine pests, a detection level that is as small as technically

to explain the particular situation for quarantine pests

COUNTRY NAME

38


3. Sentence/row/indent, etc.

4. Type of comment (Substantive, Editorial, Translation) only


possible approaches the zero tolerance level.

3. Phytosanitary Risk Categories and Measures

[61] Whole para Editorial Move para 61 to after para 47 More appropriate location. COUNTRY NAME

39

APPENDIX 4: Completed templates with workshop comments on each ISPM

Note on draft comments discussed at the Caribbean regional workshop to review draft ISPMs

Comments in this document have been compiled as a list of all ideas from NPPOs participating in the Caribbean workshop on draft ISPMs. Comments on which agreements have not been obtained are bracketed. IPPC contracting parties from the Caribbean can draw on these to prepare national comments on draft ISPMs. Each comment should be considered carefully and a decision made as to whether to support it. If a comment is not supported it should be deleted before submitting comments to the IPPC Secretariat. Additional national comments should also be added as necessary.

Caribbean workshop Template for comments - Draft ISPMs for country consultation, 2010

DRAFT ANNEX TO ISPM 28:2009IRRADIATION TREATMENT FOR CERATITIS CAPITATA

40


3. sentence/row/indent, etc.

4. Type of comment (Substantive,Editorial, Translation)

5. Proposed rewording 6. Explanation

7. Country

GENERAL COMMENTS

We wish to thank the authors for the work that has gone into the development and provision of this Draft Annex.We would wish to draw to the attention of members the fact that live larvae and/or pupae of the target organism may be encountered during the import inspection process as alluded to in sentence 12(j) of the document. This is of great concern to this party (ies) especially as there is no accompanying standardized protocol for lab analysis that would facilitate the verification of the treatment efficacy. This concern is also true of previous similar annexes (ISPM 28: Treatments 1 – 8).The development and provision of such an accompanying protocol would allow us (and other concerned members) to know what requirements may have to be put in place for such verification purposes. This may go a long way in assuaging our concerns.Without the availability of such a protocol we do not agree at this time with the passage of this draft since we are in no position to verify the viability of surviving life stages of the target pest that may occur on/in infested host commodities after the recommended treatment.

TITLEAdoption [1]Adoption [2]

Scope of the treatment

[3]

Scope of the

[4]

41





7. Country

treatment

Treatment description

[5]

Name of treatment

[6]

Active ingredient

[7]

Treatment type

[8]

Target pest

[9]

Target regulated articles

[10]

Treatment schedule

[11]Letter (I) Editorial

This irradiation treatment should not be applied to fruits fruit and vegetables stored in modified atmospheres

Other relevant information

[12]

References [13]

References [14]

42





7. Country

References [15]

References [16]

References [17]

References [18]

References [19]

References [20]

References [21]

References [22]

References [23]

References [24]

43


DRAFT: SYSTEMS APPROACHES FOR PEST RISK MANAGEMENT OF FRUIT FLIES (TEPHRITIDAE)



4. Type of comment (Substantive, Editorial, Translation)


GENERAL COMMENTS

1-It is suggested that risk mitigation should be changed to risk management throughout the document ( consistency with ISPM 5)2- Acceptable level of risk as opposed to appropriate level of risk.3-use of development to replace establishment throughout the document4- Change host status to host selection. Host status is not a measure and Paragraph 65 and 66 speaks about host selection and not host status

TITLEContentsIntroduction [1]

SCOPE [2]

SCOPE [3] Sentence one. Technical This standard provides guidelines for the establishment and use of systems approaches as

Be consistent with ISPM 5 Glossary

44





an option for pest risk management of fruit flies to facilitate trade of host commodities fruits. This standard applies to fruit flies (Tephritidae) of economic importance.

Terms

REFERENCES [4]

REFERENCES [5]

REFERENCES [6]

REFERENCES [7]

REFERENCES [8]

REFERENCES [9]

REFERENCES [10]

REFERENCES [11]

REFERENCES [12]

REFERENCES [13]

DEFINITIONS [14]

DEFINITIONS [15]

OUTLINE OF REQUIREMENTS

[16]

45






[17]


[18]

Sentence one , row two

Sentence one , row four

Technical

An important requirement for the establishment of an FF-SA is a low pest population level in the area of production of the host commodity in combination with other measures (such as host selection status, crop management practices or post-harvest and shipping measures) that are available to be integrated into the FF-SA to reduce pest risk to an(acceptable level, appropriate level of protection..) to meet the phytosanitary requirement of the importing country

Host status is not a measure Paragraph 65 and 66 speaks about host selection and not host status

See general comments number 2


[19]


[20]


[21]

46





BACKGROUND [22]

BACKGROUND [23] Sentence one, row one

Technical

Technical

Many Fruit flies are pests of economic importance affecting trade. The movement of infested host commodities may pose a pest risk for endangered areas. To identify and manage the risk, a pest risk analysis (PRA) should be conducted and risk management measures should be applied. (ISPM 2:2007, ISPM 11:2004)

Not all fruit flies are pests of economic importance

To be consistent with the Glossary terms ISPM 5

BACKGROUND [24]

BACKGROUND [25] Sentence three, row six

Technical . 1-(acceptable level, appropriate level of protection..) 2-to meet the phytosanitary requirement of the importing country

3- Appropriate level of phytosanitary protection


BACKGROUND [26]

BACKGROUND [27]

BACKGROUND [28]

BACKGROUND [29]

BACKGROUND [30] Indent two, row Editorial In addition to the facilitation of trade, the Consistency with the

47





three advantages of implementing an FF-SA may include: - increased fruit production and quality- promotion of the use of environmentally

friendly pest control methods

language of the paragraph

BACKGROUND [31]

BACKGROUND [32]

REQUIREMENTS

[33]

1. General Requirements

[34]

1.1. Pest risk analysis

[35]


[36] Sentence one , row two

Technical PRA determines whether a pest should be regulated and identifies the measures for pest risk management mitigation.



[37]


[38]Para 39, 40 and 41 should

48





be bullets of this para


[39]Proposed to be a bullet of the previous para.

Sentence one , row oneSentence two , row oneSentence two , row two

Editorial Editorial

Technical

-The host should be identified to the species level. In some cases, where when the cultivar is important as a risk management mitigation factor, such as resistance to infestation, it is important to identify the host to cultivar level.

1-Better language construction This is intended to be a bullet of paragraph 38. 2-See general comments number 1


[40] Sentence one Editorial -Data on the target fruit fly species associated with the host should be available (such as population density and fluctuation, host sequence).

This is intended to be a bullet of paragraph 38.


[41] Sentence one

Sentence one

Editorial

Technical

- The area proposed for an FF-SA should be defined, described and adequately documented

1-This is intended to be a bullet of para 38. 2- to have a clear idea of the area under FF-SS


[42]


[43] Sentence one , row one

Editorial

Technical

Measures may be applied at different stages of the production to distribution. production and distribution chain. Some of the measures to be applied under an FF-SA may include FFF-POP, FFF-PS, FF-ALPP, host selection status and limited distribution in the endangered area. See general comment

number 4

49





Sentence two , row two

1.2 Documentation and record-keeping

[44]


[45]


[46] -

1.3 Supervision [47]

1.3 Supervision [48]

1.3 Supervision [49] Sentence one , row one

Sentence two, row two

Technical

Technical

Compliance with the FF-SA should be certified verified by the NPPO of the exporting contracting party, through review of documentation and operational procedures. Verification Supervision can also be done by the NPPO of the importing contracting party

Exporting country should not be the one verifying but should be certifying the FF-SA and that the importing country should be the one verifying the FF-SA

50





2. Specific Requirements

[50]

2.1Development Establishment of an FF-SA


Technical Development Establishment of an FF-SA See general comments number 3

2.1Development Establishment of an FF-SA

[52]

2.1 Development Establishment of an FF-SA

[53]

2. Development Establishment of an FF-SA

[54]

2 Development Establishment of an FF-SA

[55]

2.1.1 Pre-harvest and at harvest

[56]

2.1.1 Pre-harvest and at harvest

[57]

2.1.1.1 (specified pest population level) Low level

[58] Technical (Low level of pest population. Specified pest population level)

(This title relates to paragraph 59 and 60 which deals with

51





of pest population specified pest population level and not low level of pest population)

2.1.1.1 (specified pest population level) Low level of pest population

[59] Sentence three, row five

Technical should be obtained as a result of surveillance using the methods described in the draft Appendix annex on trapping of ISPM 26:2006. ).

For consistency with CPM 5 decision to use appendix instead of annex.

2.1.1.1(specified pest population level)Low level of pest population

[60]

2.1.1.2 Fruit fly free places of production and fruit fly free production sites

[61]


[62]


[63] Sentence one, row one

Technical They may assure localized or temporal fruit fly free status freedom (ISPM 10:1999) and may include the following activities:

More accurate term

52






[64] First indent

Second indent

Technical

Editorial

- surveillance to confirm fruit fly free status freedom and to apply control measures in case of fruit fly detections (see ISPM 26:2006)

- phytosanitary certification (ISPM 7, 1997 and ISPM 12, 2001) to confirm compliance with the requirements of the FFF-POP or FFF-PS

More accurate term

For consistency and reference

2.1.1.3 Status of the host

[65] sentence one Technical Host selection Status of the host See general comments number 4

2.1.1.3 Status of the host


Third indent

Add fourth indent

Technical

Technical

Technical

Host selection Host status is an important risk mitigation measure that, when used in conjunction with other independent measures, can provide the appropriate level of protection. - selection of host that allows harvesting at a

less susceptible stage .- harvesting at a less susceptible stage or at a

particular time.- Selection of host that allows harvesting at

a time unfavourable for fruit flies.


For clarity of text

53





2.1.2 Post-harvest and shipping

[67]

2.1.2 Post-harvest and shipping

[68]

2.1.2.1 Post-harvest measures

[69]


[70] Indent three

Indent four

Technical

Technical

1-sampling and testing

2-inspection (ISPM 23:2005)

1-Sampling is not a complete measure . sampling and testing is the acurrate measure

2- inspection in the text does not relate to FF-SA but inspection of consignments



Sentence one , row two

Editorial

Technical

An FF-SA may also take into consideration the effects of measures applied for other pests that may contribute to reducing the risk of fruit flies (e.g. waxing, water dipping, cold storage).

1-Reads better

e.g are not appropriate , some of the measures do not apply for other pest but fruit flies

2.1.2.1 Post- [72] Sentence one In cases where the combination of such measures It has no relevance in

54





harvest measures adequately reduces the pest risk, there is no need to apply a supplementary phytosanitary treatment

the framework of a FF-SA to include supplementary measures .

2.1.2.2 Post-harvest treatments

[73]

2.1.2.2 Post-harvest treatments

[74] Sentence three , row four

Sentence three, row five

1-Technical 2-technical

. The type and (condition of) efficacy of such supplementary post-harvest treatments should be agreed to by the importing and exporting contracting parties.

1- Add condition of efficacy for clarity of text

2- Remove supplementary – wording is unnecessary and confusing

2.1.3 Entry and distribution

[75]

2.1.3 Entry and distribution

[76] Indent one....

Technical TechnicalTechnicalTechnical

- sampling and testing inspection - inspection - Phytosanitary treatments

- Quarantine for a specified time

1-Sample alone is not a measure , sampling and testing is a measure. 2-Inspection should stand alone as an important measure

55





3-phytosanitary treatment ( not stand alone measures) and Quarantine for a specified time should be include as these measures are important in a system approach

2.2

Maintenance of a fruit fly systems approach

[77] 2.2 Maintenance of a fruit fly systems approach

2.2


[78]

2.2


[79] Indent two Technical - host commodity fruit host being exported and related target fruit fly....

Be consistent with ISPM 5 Glossary Terms

2.2

Maintenance of a fruit fly systems

[80]

56





approach2.2



Sentence one, row two

Technical The NPPOs should monitor all stages and control points as appropriate, verifying compliance with the operational procedures and implementing corrective actions. as appropriate.

For clarity. Both contracting parties’ NPPO may be involved.

ANNEX 1 [82]

ANNEX 1 [83]

ANNEX 1 [84]

ANNEX 1 [85]

1. Non-compliance

[86]

1. Non-compliance


Technical Non-compliance involves (improper) incorrect implementation of the FF-SA operational procedures.

Better term

1.1 Non-compliance at the pre-harvest and harvest stage

[88]

1.1 Non-compliance at the

[89]

57





pre-harvest and harvest stage1.2 Non-compliance at the post-harvest and shipping stage

[90]

1.2 Non-compliance at the post-harvest and shipping stage

[91]

1.3 Non-compliance at entry and distribution

[92]

1.3 Non-compliance at entry and distribution

[93]

2. Ongoing verification of the systems approach

[94]

2. Ongoing verification of the systems approach

[95]

58


DRAFT APPENDIX to ISPM 15:2009SUBMISSION OF NEW TREATMENTS FOR INCLUSION IN ISPM 15



4. Type of comment (Substantive,Editorial,Translation)


GENERAL COMMENTS

Requires major revisions

TITLE [1]

Introduction [2]

Introduction [3]

Introduction [4]Introduction [5]

Introduction [6] Sentence one , row one

Indent three

Indent four

Editorial

Editorial

Editorial

The treatment developers and the submitting NPPO or RPPO should ensure that a range of factors is are or has have been tested in the development of a proposed phytosanitary treatment for IPPC evaluation. -effect on Treatment treatment efficacy on of wood types (e.g. hardwood vs softwood, timber vs logs) -effect of on environmental conditions (e.g. temperatures, moisture content)

Language is correct

For clarity

59





For clarity

Introduction [7] This sentence has been included under para 10

Technical Table 1 provides a listing of the most important quarantine pest groups associated with wood packaging material. Candidates selected from the pest groups indicated in Table 1 should be used for evaluation purposes. Steps 1–3 below provide guidance for determining selection of an appropriate pest(s), or an appropriate substitute organism(s), for testing.

Remove last sentence of paragraph 7 to paragraph 10 which gives a prologue to the rest this appendix to ISPM 15

60

TABLE 1 [8] Substantive This table should be rewritten using biological taxonomic groups and not groups base on symptomatology. This is most important as this appendix is base heavily on table one (1)

Introduction[9]

Delete entire paragraph

Technical The following criteria provide a step-wise process that the submitter should follow in the testing or development of justification for a new phytosanitary treatment for potential inclusion in ISPM 15. Included with each step is information that is intended to clarify how to interpret and respond to each criterion.

This is redundant in light of paragraph 3 and paragraph 10

Introduction [10] Add sentence three of paragraph seven to paragraph 10

Technical This step-wise process is broadly organized into two parts-Initially, submitters of treatments for evaluation should confirm that the groups of organisms associated with wood packaging material presented in Table 1 are susceptible to the proposed treatment and that the organism most resistant to the treatment is identified. Steps 1–3 below provide guidance for determining selection of an appropriate pest(s), or an appropriate substitute organism(s), for testing.- More detailed efficacy testing of this most resistant species is then used to provide confidence that the treatment is effective against all organisms associated with wood packaging material from all origins. Steps four (4) and five (5) provide guidelines on efficacy testing

Step 1 [11]

Step 1 [12]

Step 1 [13] Para 14 and 15 is added as indent

Editorial Examples of differential pest responses to treatments:- The mode of action of a pesticide may be specific to

Better formatting

61

under para 13

Sentence three, row four Editorial

a certain pest and may have little or no effect on another (e.g. neurotoxins have a limited effect on fungi).15- The first effects of heat treatment on organism viability occur when intercellular proteins begin to denature and disrupt vital cellular processes. Such protein denaturation occurs in all organisms. However, some organisms or life stages have mechanisms that provide a limited tolerance to these temperature effects. In regard to pests of wood, only a very few quarantine pests of wood of concern in international trade are known to have a slightly elevated tolerance to heat treatments.

Very is redundant

Step 1 [14]

Step 1 [15]

Step 2 [16]

Step 2 [17]Step 2 [18] Third and fourth

sentence should stand alone as new paragraph

Sentence four , row six

Editorial

Editorial

In cases where there is considerable variability expected in the treatment responses within the group, more species may need to be tested to determine the most treatment-resistant species

Of the species selected, if the most resistant life stage is not known , then all life stages that are likely to be associated with wood in international trade must be considered. In addition, where different life stages exhibit a different response to the proposed treatment, this must be taken into account

Different idea being express

Reads better

Step 2 [19] Para 20 and 21 Editorial Examples of life stage-dependent responses to Better

62

should be indent under para 19

treatments:- Irradiation treatments primarily affect pest viability through the creation of hydroxyl radicals that begin to break down the DNA in these organisms. Life stages that have higher levels of cell division or activity in general are likely to be more susceptible to irradiation treatments. Hence the later life stages such as adults or pupae are often found to be more resistant to the effects of irradiation than earlier life stages such as eggs or first instar larvae.- Some pests are known during certain life stages to be differentially susceptible to a specific pesticide (e.g. greater tolerances are shown by adult insect life stages treated with juvenile growth hormones).

formatting

Step 2 [20] Irradiation treatments primarily affect pest viability through the creation of hydroxyl radicals that begin to break down the DNA in these organisms. Life stages that have higher levels of cell division or activity in general are likely to be more susceptible to irradiation treatments. Hence the later life stages such as adults or pupae are often found to be more resistant to the effects of irradiation than earlier life stages such as eggs or first instar larvae.

Step 2 [21] Some pests are known during certain life stages to be differentially susceptible to a specific pesticide (e.g. greater tolerances are shown by adult insect life stages treated with juvenile growth hormones).

Step 2 [22] First sentence should stand alone and sentence 2 to 6 should be bulleted

Editorial If testing is required in order to identify the most resistant species and life stage within a pest group, the following approaches should be considered: . -The number of test units required for each species should be statistically valid in order to reflect the variability within the test population in an appropriate experimental design. In all cases, at least five test units

For better formatting

63

per species and life stage should be used.- The sample size of controls should be the same as the number of test organisms (e.g. five controls and five treated individuals), with demonstration of adequate survival of controls during treatment-Test units may be either individual pests or colonized pieces of wood containing the target pest. When colonized pieces of wood that may contain multiple individuals are used as test units, only complete mortality, deactivation or sterilization of all individuals is considered a successful result in identifying the resistant species or life stage

Step 2 [23]

Step 3 [24]

Step 3 [25] Sentence one , row one

Editorial Having identified the most resistant quarantine pest species and life stage (s)

Clarity

Step 4 [26]

Step 4 [27] Sentence one , row two

Editorial Efficacy testing can be completed either directly, using the numbers of test individuals required to demonstrate statistically the efficacy level, or by extrapolation by fitting dose-response data to a known theoretical dose-response curves

Step 4 [28] sentences three should stand alone as a new paragraph

Editorial The number of replicates required for extrapolation testing will depend on the fit of the actual response data to the theoretical dose-response curve ( and a required sensitivity of the outcome at the 95% confidence level.The type of test and its expected statistical limits will determine the potential responses of those individuals that are most resistant to the treatment being evaluated; the degree of variation at a determined dose

-Bracket is redundant-Add the word a reads better

64

and level of replication should reflect this. The efficacy data provided should also specify the statistical level of confidence supporting efficacy claims made for treatment of the specified pest and life stage.

Step 4 [29]

Step 5 [30]

Step 5 [31]

Assessment of treatment success

[32] Sentence one, row one

Technical Assessment of treatment (efficacy) success

Assessment of treatment success

[33]

Submission of treatment for approval

[34]

Submission of treatment for approval

[35]

65


DRAFT: INTEGRATED MEASURES APPROACH FOR PLANTS FOR PLANTING IN INTERNATIONAL TRADE

.





GENERAL COMMENTS

1. There is little difference between “systems approach” and “integrated measures” hence this change is to ensure consistency with other draft ISPMs2. draft Standards should not be used to arbitrarily create definitions In this document this was done in paragraphs 79-88 and Appendix 2 (paragraphs 117 – 121) to create definitions of critical non-compliance and non-critical non-compliance. These definitions must first be agreed upon by the membership of the CPM

66





before they can be adopted. Until then, any reference to these terms should be changed to non-compliance.3. The proposed risk-based application measures outlined in paragraphs 59-88 and in appendix 2 are excessive and seem to be imposing private standards which small developing countries would have enormous difficulties implementing and as a result would not be able to export to countries that insist on these measures. The issue of private standards has been raised by St. Vincent and the Grenadines at the WTO/SPS Committee Meeting and is yet to be resolved.

Consequently, this draft cannot be supported in its present format.

67





TITLE Title Editorial INTEGRATED MEASURES SYSTEMS APPROACH FOR PLANTS FOR PLANTING IN INTERNATIONAL TRADE

There is little difference between “systems approach” and “integrated measures” hence this change is to ensure consistency with other draft ISPMs

ContentsIntroduction [1]SCOPE [2]

SCOPE [3] 1st Sentence

2nd Sentence

1.technical

2.editorial

1. This standard provides guidelines for the development and implementation of integrated measures to manage the pest risks associated with the production and international movement of plants for planting (excluding botanically defined seeds)....

2. ... It outlines factors relevant for the determination of the

1. The standard addresses plants for planting excluding botanically defined seeds.

2. redundant

68





risk level associated with particular plants for planting and places of production, as well as risk-based application of measures and the responsibilities of the national plant protection organizations (NPPOs) of the importing and exporting countries.

REFERENCES [4]REFERENCES [5]

REFERENCES [6]REFERENCES [7]REFERENCES [8]

REFERENCES [9]

REFERENCES [10]

REFERENCES [11]

REFERENCES [12]

REFERENCES [13]

Definitions [14]

69





Definitions [15]

Outline of requirements

[16]


[17] 1. Technical

2. Editorial

3. Editorial

4. technical

This standard provides guidance for the use of integrated measures to manage the pest risks that plants for planting (excluding botanically defined seeds) pose as a pathway for regulated pests and to meet the phytosanitary requirements of the importing country’s NPPO. The use of integrated measures approaches requires the involvement of the NPPOs of both the importing and exporting countries contracting parties, as well as producers stakeholders, and relies on pest risk management measures applied throughout the production and distribution processes.

1. The standard addresses plants for planting excluding botanically defined seeds.

2. To clarify that it is countries that import and not the NPPO that imports

3. For brevity4. A more accurate

term

70






[18]


[19] technical The standard also provides general guidance for identifying and categorizing the risks that may be associated with particular types of plants for planting. These risks should be taken into account when determining the strength of measures applied in a particular situation.

Should be inclusive of all plants for planting

BACKGROUND [20]

BACKGROUND [21] Sentence 3 1. editorial2. technical

.... In any case Consequently, the conclusions from pest risk analysis analyses should be used to decide the appropriate measures to reduce the risk to an acceptable level for the importing country.

1.Reads better2. we are referring to more than one analysis

BACKGROUND [22] - 1. technical

- 2. editorial

3. technical

Export inspections Inspection of consignments of plants for planting has limitations which may include the

1. This comment is true for both import and export inspections

71





4. technical

5. editorial

following:- Some pests may be

difficult to detect visually, particularly at low pest population densities.

- Disease symptoms may be latent or masked at the time of inspection (e.g. as a result of pesticide use, dormancy of plants at time of shipping or removal of symptomatic leaves plant parts).

- The type of packaging and physical state of the consignment can influence the rigour of inspection.

Alternative or supplementary non-visual detection methods for many plant pests, particularly pathogens, are not available have not yet been developed.

2. “Inspections” changed to “inspection” for agreement between subject and verb

3. There may be other limitations than those listed

4. For greater accuracy

5. For clarity

BACKGROUND [23] editorial An integrated measures approach for pest risk

redundant

72





management may provide an alternative or supplement to single measures (particularly point of entry inspections) to meet the phytosanitary import requirements of the importing country. The use of integrated measures for pest risk management requires not only the participation of the NPPO of the exporting country but also the participation of the producer throughout all the production stages of the plants for planting.

BACKGROUND [24] 1. Editorial

2. technical

An integrated measures approach also has the advantage of better managing the risk, not only of known pests that are difficult to detect based on export or import inspections, but also of organisms that are unknown to science, contaminating pests and organisms that are not

1. proper punctuation required for sentence to read better2. One does not know if the measures applied would be effective for these organisms

73





quarantine pests in the country of origin.

BACKGROUND [25]

REQUIREMENTS

[26]

1. Factors that Affect the Pest Risk of Plants for Planting

[27]


[28] editorial The factors described in sections 1.1 to 1.4 should be considered by the importing country’s NPPO when conducting a PRA to identify the appropriate combination of measures to meet its phytosanitary requirements.

To clarify that it is countries that import and not the NPPO that imports


[29] 1.editorial

2.editorial

3. editorial

These factors should also be considered by the exporting country’s NPPO when establishing measures to be taken implemented at places of

1. To clarify that it is countries that import and not the NPPO that imports

3. better English

74





production participating in an integrated measures approach to ensure that plants for planting meet the importing country’s phytosanitary requirements.

4. Reads better

1.1 Pest factors that affect risk

[30]


[31] - 1. technical

2. editorial

3. editorial

- 4. editorial

5. editorial

6.technical

Pest factors that should be taken into consideration include:- whether the pest

occurs in the country/area of origin place of production

- type of pest (arthropod, fungus, virus, bacteria bacterium etc.)

- establishment and spread potential

- reproduction rate and numbers number of generation generations per year

- mode of transmission (e.g. vector, graft transmission,

1. Officially accepted terminology

2. Use of singular form of the Word like the other examples given

3. Consistency of language

4. For clarity5. Better description

from the standpoint of the pest. The pest does not have the ability to detect itself.

6. This is one of the most important factors to be considered

75





mechanical transmission)

- ability to detect the pest pest detectability, even at low population levels

- availability of control measures

- host range of the pest- presence of host plants

in the country of import

- latency of infection.

- Potential economic impact of the pest


[32]

1.2 Plant-related factors that affect risk

[33]


[34]


[35]

76





1.2 Plant- related factors that affect risk

[35b]

substantive An additional important factor will be the level of susceptibility, tolerance or resistance of the plant to pests

Critical factor to be included


[36]

1.3Production factors that affect risk

[37]


[38]

1.3 Production factors that affect risk

[39] 1.technical

2. technical

In general, use of soil and soil-free media as a growing medium is likely to pose a greater risk than a soil-free medium pose a great risk because soil and soil-free media may carry pests (e.g., soil-borne pathogens, insects arthropods, or nematodes, unwanted plants, and life stages of other organisms such as snails and snail eggs). Sterilization or pasteurization of the growing medium prior to

1.Scope should be broadened to include soil-free media which could also serve as pest entry pathways.2. pasteurization is a form of sterilization

77





planting may mitigate some risk.


[40] editorial The source and quality of irrigation water can affect pest risk. For certain pests spread by water, surface water may pose a greater risk than treated or deep well water. Likewise the method of irrigation may produce microclimates or conditions favourable for pest growth and spread (e.g. overhead, (rather than drip) irrigation).

Correct punctuation


[41]

1.3 Production factors that affect risk

[42] 1. editorial

2. technical

3. Editorial

4. Editorial

5. technical

Enclosures such as growth chambers, glasshouses and screen houses usually provide better control over plant material and better opportunity for pest exclusion than field-grown plants. Field-grown crops which are generally subject to cultural, biological and chemical

1. re: “which” in sentence 2 – better sentence structure2. re: “biological” inserted for completeness3. re: “field plants grown in…” showing different levels of protection with different growing conditions

78





pest control, and field plants grown in containers with sterilized growing medium and plants grown on a membrane may afford some protection from soil-borne pests. Wild collected Plants collected from the wild do not have any form of classical pest control and may therefore be unprotected from pests.

4. re: “plants collected from the wild” changed for consistency in keeping with the classification of paragraph 415. re: classical control – there may be natural pest control in the wild

1.4 Intended uses that affect risk

[43]

1.4 Intended uses that affect risk

[44]

2. Application of Risk Mitigation Measures

[45]

2. Application of Risk Mitigation Measures

[46]

3. Integrated Measures Approach

[47]

79





3. Integrated Measures Approach

[48]

3.1 General integrated measures

[49]

3.1General integrated measures

[50]

3.1.1Authorization

of places of production

[51]

3.1.1Authorization

of places of production

[52] 1. technical2. technical3. technical

The following conditions should form part of the authorization process for places of production seeking to participate in the general integrated measures approach:- maintaining an updated

plan of the place of production describing when, where and how plants for planting were produced, (treated,) stored or prepared for movement from the

1. Adding “treated” makes the process more complete

2. Many countries do not have the manpower to designate a single person as a contact

3. Re: Bullet 3 - as written this places a heavy burden on small developing states

80





place of production (including information on plant species and type of plant material such as cuttings, in vitro cultures, bare root plants)

- keeping, for at least three years, records that verify where and how plants for planting were purchased, stored, produced and distributed

- designating a person with a well-established working knowledge of pest identification and control as a contact person for the NPPO of the exporting country

- Version 1: establishing a system whereby the NPPO of the exporting country can readily obtain information on the pest status of the place of production

- Version 2: designate a person to liaise with the NPPO of the exporting

which do not have the manpower to designate a person for each place of production

81





country on matters of pest identification and management

- notifying their NPPO if any relevant pests are observed.

Any failure of products or procedures to adhere to the requirements for authorization (non-compliance) should result in the suspension of authorization of the place of production until corrective actions have been successfully completed.

3.1.2Requirements

for the place of production

[53] 1.editorial2. editorial3. technical

3.1.2 Requirements for the place of production

The following measures may be sufficient to meet the phytosanitary requirements of the importing country when the PRA indicates that they the measures are consistent with the risk (e.g. plants of a well-

1. For clarity2. Divide 1st bullet

into two bullets as it represents two different ideas

3. Last bullet: it is an important function of production systems

82





documented plant species with known risks originating from a country or area place of production with a documented history of safe exports of the species):

- conducting visual examinations of plants and places of production by designated staff as necessary, at appropriate times and according to protocols provided by the NPPO of the exporting country (Records of all examinations, including a description of pests found and corrective actions taken, should be made.)

- keeping records of all examinations, including a description of pests found and corrective actions taken

- establishing a system ...

83





3.2Integrated measures in high-risk situations

[54]

3.2 Integrated measures in high-risk situations

[55]

3.2.1

Requirements for the place of production in high-risk situations

[56]

3.2.1


[57]

3.2.1


[58] See general comment no. 3

3.2.1.1 Place of production manual


84









3.2.1.2 Pest management plan



[63] [100] See general comment no. 3



3.2.1.3 Crop protection specialist


3.2.1.3 Crop protection specialist

[66][101] [102] See general comment no. 3

3.2.1.4 Training of employees


3.2.1.4 Training of employees


3.2.1.5

Examination of


85





plant material

3.2.1.5

Examination of plant material


3.2.1.6 Packing and transportation

[71][107] 3.2.1.6 Packing and

transportation

See also general comment no. 3

3.2.1.6 Packing and transportation

[72] - - 1. editorial

2. technical

[108] The following considerations apply to packing and transport operations:- Plant material should be

packed in a manner to prevent infestation or reinfestation by regulated pests.

- Packing material Packaging should meet the requirements of the importing country.

- Each unit of a consignment should be identified in a way that links it to the consignment and to the

1. Re: bullets 2 & 4, Packaging is defined in the glossary

2. “and boxes” is redundant

3. See also general comment no. 3

86





phytosanitary certificate.- Packing material

Packaging and boxes should be clean, unused, disinfested or decontaminated.

- Conveyances at the place of production should be examined and cleaned as necessary prior to loading.

3.2.1.7 Internal audits

[73] See general comment no.3


[74][109] [110] 1.editorial Internal audits should be conducted to ensure that the place of production is in compliance with its phytosanitary manual. ....

1.Consistency of terms with respect to paragraph 592. See also general comment no.3


[75][111] [112] See general comment no.3


[76] technical [113] If a place of production identifies any critical non-compliances, it should immediately notify its If any non-compliance is identified in a place of production by the audit,

See general comment no. 2 and 3

87





the NPPO should be immediately notified in writing and the NPPO should ensure that non-compliant plants for planting are not exported. Immediate corrective actions should be taken in cooperation with the NPPO.

3.2.1.8 Records [77] See general comment no. 3

3.2.1.8 Records [78] 1. Editorial2. Editorial3. Editorial4. technical

[114] Accurate and up-to-date records should be kept and should be able to be retrieved be retrievable when required by the NPPO. Records that verify compliance with the phytosanitary manual and the requirements of the NPPO should be maintained for at least three years. Records should include date, name and signature of the person who carried out the task and/or prepared the document. Examples of records that may be

1. better language 2.Consistency of terms with respect to paragraph 593. redundant4. not unanimous5. See also general comment no.3

88





required include:- invoices, phytosanitary

certificates and other information that substantiate the origin and the phytosanitary status of all incoming plant material

- results of the inspection of incoming plant material

- results of internal audits and external audits

- records of examination during production including any pests, damage or symptoms detected and corrective actions taken

- records of examination of outgoing plant material, including type and quantity of material exported

- copies of phytosanitary certificates for plant material exported by the place of production

- records of pest management measures

89





taken to prevent or control pests (including method of application, product applied, dosage and date of application, and results of their application, (planting material treated and efficacy of the treatment)

- records of non-compliances identified and the corrective or preventative actions taken

- records of training of staff and their qualifications.

3.2.2 Non-compliance with requirements for the place of production

[79] See general comment no. 2 and 3



90











3.2.2.1 Critical non-compliance


3.2.2.1 Critical non-compliance

[85][115] [116] See general comment no. 2 and 3

3.2.2.2 Non-critical non-compliance


91








[88][117] [118] See general comment no. 2 and 3

4. Responsibilities of the NPPO of the Exporting Country

[89]

4. Responsibilities of the NPPO of the Exporting Country

[90] editorial [119] The NPPO of the exporting country is responsible for:- establishing the

implementation of the integrated measures systems approaches

- authorizing places of production seeking participation in an integrated measures systems approach

For clarity, bullet no. 1 is divided into two

4.1 [91]

92





Establishing integrated measures approaches

4.1

Establishing integrated measures approaches

[92]

4.2

Authorization of places of production

[93]

4.2


[94][120] [121]

4.2


[95] editorial [122] The authorization of places of production seeking to participate in the integrated measures approach for high-risk situations described in

A better sentence structure and consistency in view of 1st bullet and paragraph 96

93





section 3.2 should be based upon:- A documentation

audit and a review of the phytosanitary manual and an initial documentation audit at the place of production to verify that it is complying with the requirements established according to the risk factors of its production

- an implementation audit whose objectives are to verify that:

the place of production complies with the protocols, procedures and standards specified in its phytosanitary manual

required supporting documentation...

94





4.2


[96][123] [124]

4.3 Oversight of authorized places of production

[97]

4.3 Oversight of authorized places of production

[98]

4.4 Export inspections and issuance of phytosanitary certificates

[99]

4.4 Export inspections and issuance of phytosanitary certificates

[100]

[125] [126] editorial The integrated risk management measures may reduce the need for growing season inspections and intensive export inspections of every individual consignment (if agreed to by the importing NPPO of the importing country). ....

redundant

4.5 Providing adequate

[101]

95





information 4.5 Providing adequate information

[102]

[127] [128] editorial [129] Upon request, the NPPO of the exporting country should provide adequate information to the NPPO of the importing country to support the evaluation and acceptance of the integrated measures approach.

Proper punctuation

5. Responsibilities of the NPPO of the Importing Country

[103]


[104]

[130] [131]


[105]

[132] [133]


[106]

editorial ……. The NPPO of the importing country should notify the NPPO of the exporting country of any non-compliances (see ISPM 13:2001).

For clarity

96





5.1

Traceability procedures

[107]

5.1

Traceability procedures

[108]

[134] editorial [135] The NPPO of the importing country is encouraged to establish procedures that ensure the traceability of that plants imported under an integrated measures a systems approach can be traced back and forward from the importer and that the importer notifies the NPPO of the occurrence of regulated pests and other pests not normally present in the area. This may be accomplished through a registration/authorization process for importers.

Better sentence structure & for clarity

5.2 Auditing by the importing NPPO

[109]

97





5.2 Auditing by the importing NPPO

[110]

Appendix 1: Examples of pest management measures to reduce the phytosanitary risk of plants for planting

[111]

Appendix 1: Examples of pest management measures to reduce the phytosanitary risk of plants for planting

[112] [136]

Table 1 [113]

[137] [138] Table 1. Measures to reduce the phytosanitary risk of plants for planting categorized by pest group category

More clearly describes the content of the table and less cumbersome

Table 1 [114]

1. Editorial2.technical3. editorial4. editorial

[139] 1. The following table provides examples for different measures.

1. redundant2. same reason as

for change in paragraph 113

98





5. technical

2.Subject row of table, 1st columnPest group category

3. Pest category 2Pests having Visible visible stages of pests and pests causing visible symptoms during the growing season

4. Pest Category 3, Available measures bullet 4Planning of activities to work with high-health healthy plants first

5. Pest category 8 under available measures

Add bullet: post-entry quarantine

3. clarity and consistency with wording of other pest categories

4. better English5. added to cover

life stage of pests that are unaffected by chemical treatments

Table 2 [115]

[140] editorial [141] Table 2. Examples for measures to reduce the phytosanitary risk of plants for planting based on the type of plant material

Remove all references to group 10 since it does not exist in Table 1

Appendix 2: [116

99





Examples of non-compliance

]

Appendix 2: Examples of non-compliance

[117] [142]

See general comment no. 2. Comments can not be provided on this appendix until further clarification on general comment no. 2.

Critical non-compliance

[118]

See general comment no. 2

Critical non-compliance

[119]

See general comment no. 2

Non-critical non-compliance

[120]


Non-critical non-compliance

[121]

- See general comment no. 2

To be more clear, the text of Table 1: Examples of pest management measures to reduce the phytosanitary risk of plants for planting is included below, showing suggested changes.

Pest group category Available measures

1 Pests causing latent infections and those that are likely to be transmitted by plants for planting without signs or symptoms

• Production in a pest free area or at a pest free place of production/production site • Derivation from mother plants that have been tested and found free from the relevant pest

100


• Isolation from sources of infection (e.g. buffer zone or geographical distance from other host plants, physical isolation using a glasshouse or polytunnel, temporal isolation)

• Testing of samples of the plants for freedom from pests • Production within a specified certification scheme or clean stock programme that takes into

consideration the pests of concern to the importing country

2 Pests having Visible visible stages of pests and pests causing visible symptoms during the growing season

• Growing season inspection for freedom from pests or symptoms (e.g. at timed intervals, for example monthly for the three months before export or at different growth stages, if appropriate)

• Growing season inspection of the mother plants• Inspection after harvest to meet a specified tolerance for a pest (e.g. tolerance for bulb rots by

fungi/bacteria)• Routine pesticide applications

3 Pests spread by contact • Production in a pest free area or at a pest free place of production/production site • Prevention of contact with sources of infection (e.g. other plants)• Hygiene measures for handling pruning tools and equipment between different batches/lots• Planning of activities to work with high-health healthy plants first • Use of dedicated clothing and equipment in isolated places (e.g. screen houses)• Routine pesticide applications

4 Pests transmitted by vectors • Production area/place of production free from vectors• Production in a pest free area or at a pest free place of production/production site [confirmed

by monitoring or measures specified below] • Isolation from sources of infection (e.g. buffer zone or geographical distance from other host

plants, physical isolation using a glasshouse or polytunnel, temporal isolation) • Pre-planting soil testing for freedom from or to meet a tolerance for soil-borne viruses or

their nematode vectors • Pesticide treatments for control of insect vectors of viruses (e.g. aphids)

101


5 Pests spread by wind • Production in a pest free area or at a pest free place of production/production site [confirmed by monitoring or measures specified below]

• Isolation from sources of infection (e.g. buffer zone or geographical distance from other host plants, physical isolation using a glasshouse or polytunnel)

• Routine pesticide applications

6 Pests spread by water • Production in a pest free area or at a pest free place of production/production site [confirmed by monitoring or measures specified below]

• Use of uncontaminated water sources• Irrigation water to be disinfected or sterilized before use• Isolation from sources of infection (e.g. buffer zone or geographical distance from other host

plants, physical isolation using a glasshouse or polytunnel, temporal isolation)

7 Soil-borne pests able to colonize the plant • Production in a pest free area or at a pest free place of production/production site [confirmed by monitoring or measures specified below]

• Isolation from sources of infection (e.g. buffer zone or geographical distance from other host plants, physical isolation using a glasshouse or polytunnel, growth of plants on raised benches, temporal isolation)

• Derivation from mother plants that have been tested and found free from the relevant pest• Production within a specified certification scheme or clean stock programme• Testing of samples of the plants for freedom from pests• Pre-planting soil testing for freedom from pests such as fungi, nematodes, viruses

transmittable by nematodes

8 Soil-borne pests in growing medium attached to plants • Growing medium to be sterilized before use• Use of inert growing media• Use of soil-less growing media• Isolation from sources of infection, maintenance of plants in such a way that contact with soil

is prevented (e.g. on raised benches)• Pesticide treatment (e.g. drench or fumigation) prior to export• Roots washed free from growing medium (and repotted in sterile growing medium)

102


Post-entry quarantine

9 Soil-borne pests in natural soil attached to plants • Production in a pest free area or at a pest free place of production/production site [confirmed by monitoring or measures specified below]

• Isolation from sources of infection (e.g. buffer zone or geographical distance from other host plants, temporal isolation)

• Pre-planting soil testing for freedom from pests (especially nematodes, fungi)• Pesticide treatment (fumigation) prior to export• Roots washed free from soil (and repotted in sterile growing medium)

103


DRAFT ANNEX TO ISPM 27:2010Plum pox virus





GENERAL COMMENTS

1. It would be useful if the standard were to give some idea re: possible geographic regions where this pest could be established. Information has only been given on where the pest has occurred or currently occurs2. Disclaimers for the mention of brand names have not been included in the document. Wherever a brand name is mentioned, a disclaimer must be included as a footnote as agreed in CPM-5.

TITLEAdoptionContents1. Pest Information [1]1. Pest Information [2]

1. Pest Information [3]

104





1. Pest Information [4] 1.editorial2. editorial3.technical4. technical5. technical

PPV is a member of the genus Potyvirus in the family Potyviridae. The virus particles are flexuous rods of about 700 nm × 11 nm and are composed of a single-stranded RNA molecule consisting of almost 10 000 nucleotides coated by up to 2 000 subunits of a single coat protein (García and Cambra, 2007). PPV is transmitted in the field by aphids in a non-persistent manner, but movement of infected propagative plant material has been and is the main way in which sharka PPV is spread over long distances.

1. “of” added for clarity2. “and are” added to be more specific3. information is required re: the specific aphids that are vectors of PPV4. More clarity is needed. Does this mean that the virus is non-persistent in the aphid or non-persistent in the host plant?5. to be more technically correct the name of the virus and not the name of the disease should be used.

1. Pest Information [5] editorial PPV isolates can be classified into seven types or strains: D (Dideron), M (Marcus), C (Cherry), EA (El Amar), W (Winona), and Rec (Recombinant) and T (Turkish) (Candresse and Cambra, 2006; James and Glasa, 2006; Ulubaş Serçe et al., 2009). Most PPV isolates belong to the D and M types. PPV D and M strains can easily infect apricots and plums but differ in their ability to infect peach cultivars. M isolates cause, in general, faster epidemics and more severe symptoms in peach than D isolates. El Amar isolates (PPV-EA) are geographically restricted to Egypt and little information is

Correct punctuation

105





available about their epidemiology and biological properties. Cherries were not considered a host of PPV for a long time. However, a number of PPV isolates infecting sour cherry (P. cerasus) and sweet cherry (P. avium) have been identified in several European countries and Turkey. These isolates form a distinct type that has been defined as PPV-C. An atypical PPV was isolated from European plum in Canada (PPV-W) representing a distinct PPV type. In addition, natural recombinants between the D and M types of PPV have been described as PPV-Rec showing an epidemiological behaviour similar to the D type. Recently a second type of recombinant isolate has been reported in Turkey (T type).

1. Pest Information [6]

2.Taxonomic Information

[7]

3.Detection and Identification

[8]


[9]

106






[10] 1. editorial2. editorial3. editorial4. technical

…. The alcohol or spirits produced from this these fruits are unmarketable owing to an undesirable flavour. In severe cases the diseased fruits drop prematurely from the tree. In general, the fruits of early bearing cultivars show more marked symptoms than those of late cultivars.

1., 2. And 3. For proper sentence construction4. for clarity


[11] 1. Editorial2. Editorial3. technical

Appropriate sample selection is critical for PPV detection. If typical symptoms are present, collect flowers, leaves or fruits showing symptoms. In symptomless plants, samples should be taken from at least one-year-old shoots with mature leaves or fully expanded leaves collected from the middle of each of the main branches. Sampling must be done avoiding should not be done during months with the highest temperatures. Plant material should preferably be collected from the internal parts of the canopy of the tree. In springtime, samples can be flowers, young shoots with fully expanded leaves or fruits. In summer and autumn mature leaves and the skin of mature fruits collected from the field or packinghouses can be used for analysis. Flowers, leaves, shoots and fruit skin can be stored at 4 °C for not more than 7 days

1. proper sentence structure2. sentence cumbersome3. This is ambiguous. Included in this paragraph should be a specific temperature range.

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before processing. Fruits can be stored for one month at 4 °C before processing. In winter dormant buds or bark tissues from the basal part of twigs, shoots or branches, or complete spurs or dards can be selected.


[12]

Figure 1 [13]


[14] editorial In this diagnostic protocol, methods (including reference to brand names) are described as published, as these defined the original level of sensitivity, specificity and/or reproducibility achieved......

Methods still exist and hence still define the protocol


[15]

3.1Biological detection and identification

[16]


[17] 1. Technical2. editorial

Budwood to be grafted must be collected from at least three different branches of each plant (this is critical because of the uneven distribution of PPV). The main indicator plants used for PPV indexing are seedlings of P. persicae cv. GF305, P. persicae × P. davidiana cv.

1. For clarity of sampling method

2. Less ambiguous statement

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Nemaguard, or P. tomentosa. Indicator plants are raised from seed, planted in a well-drained soil mixture and maintained in an insect-proof greenhouse between 18 °C and 25 °C until they are large enough to graft (usually 25–30 cm high with a diameter of 3–4 mm). The indicators must be graft-inoculated according to conventional methods such as bud grafting (Desvignes, 1999), using at least four replicates per indicator plant. Following grafting, the indicator plants are maintained in the same conditions and after 3 weeks are pruned to a few centimetres above the top graft (Gentit, 2006). Symptoms, in particular chlorotic banding and patterns, are observed on the new growth after 3–4 weeks and must be compared with positive and healthy controls.


[18] editorial There is are no quantitative data published on the specificity, sensitivity or reliability of grafting.....

For sentence –verb agreement

3.2Serological detection and identification

[19]


[20]

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[21] editorial For sample processing, approximately 1 g of fresh plant material is weighed, cut into small pieces and placed in a suitable tube or plastic bag. About 20 volumes of extraction buffer are added and the sample is homogenized in tubes using a Polytron (Kinematica) or similar apparatus. Alternatively, the sample can be homogenized in plastic bags using a tissue homogenizer such as the Homex 6 machine (Bioreba) or a manual roller, hammer, or similar implement. The composition of the extraction buffer is phosphate-buffered saline (PBS) pH 7.2–7.4, containing 2% polyvinylpyrrolidone and 0.2% sodium diethyl dithiocarbamate (Cambra et al., 1994). Plant material should be homogenized thoroughly and used fresh.

Remove the deleted sentence and place as a footnote immediately after “…20 volumes of extraction buffer” in sentence 2 of this paragraph


[22] editorial 3.2.1 Double-antibody sandwich indirect enzyme-linked immunosorbent assay (DASI-ELISA)

Consistent formatting


[23] editorial DASI-ELISA, also called triple-antibody sandwich (TAS)-ELISA, should be performed according to Cambra et al. al. (1994) using the specific monoclonal antibody 5B-IVIA following the manufacturer’s instructions

Correct formatting

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[24] editorial ......The proportion of true negatives (number of true negatives diagnosed by the technique/number of healthy plants) identified by DASI-ELISA using the 5B-IVIA monoclonal antibody was 99.0%, compared with real-time RT-PCR using purified nucleic acid (89.2%) or spotted samples (98.0%), or immunocapture IC- RT-PCR (96.1%). Capote et al. (2009) also reported that there is a 98.8% probability that a positive result obtained in winter with DASI-ELISA using the 5B-IVIA monoclonal antibody was a true positive.

For consistency with the acronym that has already been defined


[25]


[26] editorial 3.2.2 Double-antibody sandwich indirect enzyme-linked immunosorbent assay (DASI-ELISA)

Consistency of formatting


[27] editorial The C conventional or biotin/streptavidin system of DAS-ELISA should be performed using kits based on the specific monoclonal antibody 5B-IVIA or on polyclonal antibodies that have been demonstrated to detect all strains of PPV without cross-reacting with other viruses or healthy plant material. The test should be done according to the manufacturer’s

For completeness of the sentence

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instructions.


[28]


[29]

3.3 Molecular detection and identification

[30]


[31]


[32] technical Fresh or frozen (stored between −20 °C and −80 °C for periods of at least up to one year) plant extracts can be used for molecular tests. .....

This is the correct time-frame

3.3.1Reverse transcription-polymerase chain reaction (RT-PCR)

[33]


[34]

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[35] 1. Editorial2. editorial

The 25 μl reaction mixture is composed as follows: 1 μM of each primer (P1/P2 or the 3′NCR primer pair), 250 μM dNTPs, 1 unit AMV reverse transcriptase, 0.5 units Taq DNA polymerase, 2.5 μl 10 × Taq polymerase buffer, 1.5 mM MgCl22, and 0.3% Triton X-100. The reaction is performed under the following thermocycling conditions: 45 min at 42 °C, 2 min at 94 ºC, 40 cycles of 30 s at 94 °C, 30 s at either 60 °C (P1/P2 primers) or 62 °C (3′NCR primers), 1 min at 72 °C, followed by a final extension for 10 min at 72 °C and then quickly cooled to room temperature. The PCR products are analysed by gel electrophoresis. The P1/P2 and 3′NCR primers produce a 243 base pair (bp) and 220 bp amplicon, respectively.

1. Correct way of writing the formula

2. Added for clarity


[36] editorial ....The assay was able to detect 20 fg of viral RNA, corresponding to 2000 2 000 viral particles (Wetzel et al., 1991).....

For consistency with the way other figures are written throughout the document


[37] editorial 3.3.2 Immunocapture Polymerase Reverse Transcription Polymerase Chain Reaction (IC-RT-PCR)

For consistency

3.3.2 Immunocapture RT-PCR

[38]

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[39] editorial ....Wash the tubes three times with 150 μl of sterile PBS-Tween (washing buffer).....

redundant


[40]

3.3.3Co-operational RT-PCR

[41] editorial 3.3.3 Co-operational Reverse Transcription - Polymerase Chain Reaction (Co-RT-PCR)

For consistency


[42]


[43] 1. editorial2. editorial

The 20 μl reaction mixture is composed as follows: 0.1 μM of P1 and P2 primers, 0.05 μM of P10 and P20 primers, 400 μM dNTPs, 2 units AMV reverse transcriptase, 1 unit Taq DNA polymerase, 2 μl 10 × reaction buffer, 3 mM MgCl22, 5% DMSO, and 0.3% Triton X-100. The reaction mixture and 5 μl of RNA sample are added to a sterile microfuge tube. The RT-PCR is performed under the following thermocycling conditions: 45 min at 42 °C, 2 min at 94 °C, 60 cycles of 15 s at 94 °C, 15 s at 50 °C, 30 s at 72 °C, followed by a final extension for 10 min at 72 °C and quickly

1. Care to be taken in the final version of the draft that the 10 does not fall on a separate line to the x

2. Correct formula format

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cooled to room temperature.


[44] 1.editorial2. editorial

The RT-PCR reaction is coupled to a colorimetric detection of amplicons using a 3´digoxigenin-labelled PPV universal probe (5′-TCG TTT ATT TGG CTT GGA TGG AA-Digoxigenin-3′; Roche Molecular Biochemicals) as follows.: D denature the amplified cDNA at 95 °C for 5 min and immediately place on ice. .....

1.Correct punctuation2. letter case change


[45]

3.3.4Real-time RT-PCRMitigation Measures

[46]

3.3.4Real-time RT-PCR Mitigation Measures

[47]


[48] 1& 2. Editorial3.editorial

The 25 μl reaction mixture is composed as follows: 1 × reaction mix (0.2mM of each dNTP and 1.2 mM MgSO44), 200 nM of forward and reverse primers, 100 nM TAMRA probe, 4.8 mM MgSO44 and 0.5 μl RT/Platinum® Taq mix (Superscript™ One-Step RT-PCR with Platinum® Taq kit [(Invitrogen)]). The reaction mixture and 300

1. & 2. Correct formula format3. better for the parentheses to be of different forms in such instances.

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pg of RNA template are added to a sterile microfuge tube or equivalent. The RT-PCR is performed under the following thermocycling conditions: 15 min at 52 °C, 5 min at 95 °C, 60 cycles of 15 s at 95 °C, 30 s at 60 °C, and quickly cooled to room temperature. The PCR products are analysed in real-time according to the manufacturer’s instructions.


[49]


[50]


[51]


[52]


[53]

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[54]


[55]


[56]

4.Identification of Strains

[57] technical 4. Identification of Strains The strain identification seems to lack some specificity and may not be reliable between laboratories


[58] editorial The methods described in sections 3.2 and 3.3 for serological and molecular detection can also be used for identification of the virus. This section describes additional methods (DASI-ELISA, RT-PCR, Co-RT-PCR and real-time RT-PCR) for identification of PPV strains (see Figure 2). It is not necessary to determine which strain is present in order to identify PPV, but an NPPO may wish to determine the identity of the strain, for example, to assist in predicting

This sentence is redundant

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its epidemiological behaviour.


[59]

Figure 2 [60]


[61]

4.1Serological identification of strains

[62]


[63]


[64]


[65]


[66]

4.2 Molecular identification of strains

[67]

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4.2.1 RT-PCR [68]4.2.1 RT-PCR [69]

4.2.1 RT-PCR [70] editorial The 25 μl reaction mixture is composed as follows: 1 μM of P1 primer, 1 μM of either PD or PM primer, 250 μM dNTPs, 1 unit AMV reverse transcriptase (10 units μl−1), 0.5 units Taq DNA polymerase (5 units μl−1), 2.5 μl 10 × Taq polymerase buffer, 1.5 mM MgCl22, 0.3% Triton X-100 and 2% formamide. The RT-PCR is performed under the following thermocycling conditions: 45 min at 42 °C, 2 min at 94 °C, 40 cycles of 30 s at 94 °C, 30 s at 60 °C, 1 min at 72 °C, followed by a final extension for 10 min at 72 °C and quickly cooled to room temperature. The PCR products are analysed by gel electrophoresis. The P1/PD and P1/PM primers produce a 198 bp amplicon. The method was evaluated using six isolates of PPV-D and four PPV-M isolates.

Correct formulation format

4.2.1 RT-PCR [71] editorial PPV-Rec is identified using the mD5/mM3 Rec-specific primers described by Šubr et al et al. (2004):

mD5 (5′-TAT GTC ACA TAA AGG CGT TCT C-3′)

Proper format

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mM3 (5′-CAT TTC CAT AAA CTC CAA AAG AC-3′).

4.2.1 RT-PCR [72] editorial The 25 μl reaction mixture is composed as follows (modified from Šubr et al., 2004): 1 μM of each primer, 250 μM dNTPs, 1 unit AMV reverse transcriptase (10 units μl−1), 0.5 units Taq DNA polymerase (5 units μl−1), 2.5 μl 10 × Taq polymerase buffer, 2.5 mM MgCl22, 0.3% Triton X-100 and 5 μl of extracted RNA (see section 3.3). The PCR product of 605 bp is analysed by gel electrophoresis.

Correct formulation format

4.2.2Immunocapture RT-PCR

[73]

4.2.2Immunocapture RT-PCR

[74]

4.2.3 Co-operational RT-PCR

[75]


[76]


[77]

4.2.4 Real-time RT-PCR

[78]

4.2.4 Real-time [79]

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RT-PCR4.2.4 Real-time RT-PCR

[80] 1.editorial2. editorial

The primers and TaqMan probes used in the method of Capote et al et al. (2006) are:

PPV-MGB-F primer (5′-CAG ACT ACA GCC TCG CCA GA-3′)PPV-MGB-R primer (5′-CTC AAT GCT GCT GCC TTC AT-3′)MGB-D probe (5′- FAM-TTC AAC GAC ACC CGT A-MGB-3′)MGB-M probe (5′-FAM-TTC AAC AAC GCC TGT G-MGB-3′).

1. Correct format2. Correct punctuation


[81]


[82] editorial PPV-C, PPV-EA and PPV-W are specifically identified using SYBR Green I chemistry according to the method of Varga and James (2006). The primers used in this method are:

P1 (5′-ACC GAG ACC ACT ACA CTC CC-3′)PPV-U (5′-TGA AGG CAG CAG CAT TGA GA-3′)PPV-RR (5′-CTC TTC TTG TGT TCC GAC GTT TC-3′).

Correct punctuation

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[83]


[84] 1. editorial2. editorial3. editorial

The 25 μl RT-PCR reaction is composed as follows: 2.5 μl of a 1/10 water dilution of extracted RNA (see section 3.3) and 22.5 μl of master mix. The master mix has the following composition: 2.5 μl of Karsai Buffer (Karsai et al., 2002); 0.5 μl each of 5 μM primers PPV-U, PPV-RR or P1, Nad5R and Nad5F; 0.5 μl of 10 mM dNTPs; 1 μl of 50 mM MgCl22; 0.2 μl of RNaseOUT™ (40 units μl−1; Invitrogen); 0.1 μl of Superscript™ III (200 units μl-1; Invitrogen); 0.1 μl of Platinum® Taq DNA high fidelity polymerase (5 units μl-1, Invitrogen); and 1 μl of 1:5 000 (in TE, pH 7.5) SYBR Green I (Sigma) in 16.1 μl water. The reaction is performed under the following thermocycling conditions: 10 min at 50 °C, 2 min at 95 °C, 29 cycles of 15 s at 95 °C, and 60 s at 60 °C. Melting curve analysis is performed by incubation at 60 °C to 95 °C at 0.1 °C s−1 melt rates with a smooth curve setting averaging 1 point. The melting temperatures for each product are:

C strain (74 bp fragment): 79.84 °CEA strain (74 bp fragment): 81.27 °CW strain (74 bp fragment): 80.68 °C.

1. correct formulation format2. correct punctuation3. correct punctuation

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[85]

5. Records [86]

5. Records [87]

5. Records [88] -

6.Contact Points for Further Information

[89]


[90]


[91]


[92]


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[94]


[95]


[96]

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7.Acknowledgements

[97]

7.Acknowledgements

[98]

8. References [99]

8. References [100]

8. References [101]

8. References [102]

8. References [103]

8. References [104]

8. References [105]

8. References [106]

8. References [107]

8. References [108]

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8. References [109]

8. References [110][100]




8. References [114]


8. References [116]





8. References [12[109]

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1](122)[110]

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APPENDIX 5: Guidelines for the submission of comments on draft international standards for phytosanitary measures (ISPMs)

Draft ISPMs are distributed by the Secretariat of the International Plant Protection Convention (IPPC) to National Plant Protection Organizations (NPPOs), Regional Plant Protection Organizations (RPPOs) and relevant international organizations upon the recommendation of the Standards Committee or Standards Committee Working Group (SC-7).

The following elements are part of the standard setting procedures:- Members are provided 100 days to review the draft standards, consult on their content, and compile and submit comments to the Secretariat.- The Secretariat provides a format for member comments. Members are asked to provide comments electronically using one of the formats provided to

allow comments to be compiled more easily.- Member comments should be submitted through templates provided by the Secretariat. Member comments should be submitted through the IPPC contact

point and this should be easily verifiable.- Compiled member comments will be published on the International Phytosanitary Portal (IPP).

The Secretariat encourages submissions as early as possible to facilitate the timely compilation of comments for the Standards Committee.

The following are guidelines for the submission of comments to help ensure maximum benefit from the consultation process, and faster compilation of comments:

1. Members will have to submit comments using the templates provided by the Secretariat for each standard. These templates are available as electronic documents that can be downloaded from the IPP (https://www.ippc.int/index.php?id=draft_ispms&no_cache=1&L=0 ) or obtained by e-mail from the IPPC Secretariat on request to [email protected]. Instructions for the use of the templates are given at the end of each template. Templates with comments should be submitted by e-mail as a word processing file (Word or similar) to [email protected]. Comments should be submitted through the IPPC contact point and the accompanying e-mail message should contain sufficient information so that this can be verified. If this cannot be verified, the member comments will not be retained. The text of the e-mail should also clearly indicate the country from which the comments are sent. Members are requested to submit only one set of comments for each standard and if several sets are received, the Secretariat will retain the last version received prior to the deadline.

2. If a contracting party wishes to support all of the comments submitted by another contracting party or RPPO, this should be indicated in a letter or e-mail (instead of sending the comments under the country’s own name). The name of the country will still appear in the comments compiled for the Standards Committee.

Please note that comments from RPPOs are considered to represent the views of the organization and which may be based on consultation within the organization. Such comments, however, are not considered to represent the views of individual contracting parties unless specifically indicated as such by the contracting party(ies) (for example, by indicating this in the templates of comments, or a letter or e-mail).

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3. Comments should be supported by an explanation of their purpose. Alternative text should be proposed where appropriate. It is essential that care is taken to ensure all comments and their rationale are clear.

4. Note that paragraphs in the draft standards are numbered. It is essential to ensure that the paragraph numbers used when submitting comments correspond to that of the draft standard as sent for consultation as these numbers will be used to compile the comments for the Standards Committee. Comments submitted with errors in paragraph numbering will not be ordered properly in the compiled tables and will cause confusion.

5. Due to the short time available between the end of the consultation period and the Standards Committee meeting, and to avoid misinterpretation in translation, countries sending comments in a language other than English are encouraged to send an English translation as well.

Note: The Secretariat only distributes to the Standards Committee comments received from contracting parties, RPPOs and relevant international organizations. Any comments on the draft standards from the public should be channelled through the national IPPC contact point for the respective countries. IPPC contact points can be found on the IPP (https://www.ippc.int/index.php?id=1110520&no_cache=1&type=contactpoints&L=0 ).

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