report on the national voluntary audit-based systems approach to
TRANSCRIPT
Report on the National Voluntary Audit-Based Systems Approach to
Nursery Certification Project 2011
By The National Plant Board
Cooperative Agreement # 11-8100-1550-CA December 1, 2012
CENTRAL PLANT BOARD: Illinois -- Indiana --Iowa -- Kansas -- Michigan -- Minnesota --Missouri
North Dakota -- Nebraska -- Ohio South Dakota -- Wisconsin
EASTERN PLANT BOARD: Connecticut -- Delaware -- Massachusetts -- Maryland -- Maine
New Hampshire -- New Jersey -- New York--- Pennsylvania Rhode Island -- Vermont -- West Virginia
WESTERN PLANT BOARD: Alaska -- Arizona -- California -- Colorado -- Hawaii -- Idaho -- Montana
Nevada -- New Mexico -- Oregon -- Utah -- Washington -- Wyoming
SOUTHERN PLANT BOARD: Alabama -- Arkansas -- Florida -- Georgia -- Kentucky - Louisiana Mississippi -- North Carolina -- Oklahoma -- Puerto Rico -- South
Carolina -- Tennessee -- Texas -- Virginia
December 20, 2012 PRESIDENT MICHAEL E. COOPER IDAHO VICE PRESIDENT GEIR FRIISOE MINNESOTA SECRETARY-TREASURER Wayne N. Dixon Florida PAST PRESIDENT CARL P. SCHULZE JR New Jersey EXECUTIVE SECRETARY AURELIO POSADAS P.O. BOX 847 ELK GROVE, CA 95759 916-709-3484 [email protected]
DIRECTORS CENTRAL PLANT BOARD PHILIP MARSHALL INDIANA JULIE C. VAN METER NEBRASKA EASTERN PLANT BOARD VICTORIA SMITH CONNECTICUT CAROL HOLKO MARYLAND SOUTHERN PLANT BOARD CHRISTEL HARDEN SOUTH CAROLINA LARRY NICHOLS VIRGINIA WESTERN PLANT BOARD MITCHELL YERGERT COLORADO ROBERT LEAVITT CALIFORNIA
Dr. Robert S. Johnson Assistant Director Preclearance and Offshore Programs (POP) USDA/APHIS/PPQ Plant Health Programs 4700 River Rd., Unit 60 Riverdale, MD 20737 Re: Cooperative Agreement 11-8100-1550- CA Final Report Dear Dr. Johnson, The National Plant Board finalizes its responsibility to the cooperative agreement, Number 11-8100-1550-CA, between the National Plant Board (NPB) and the United States Department of Agriculture, Animal and Plant Health Inspection Services, Plant Protection and Quarantine (PPQ) by presenting this report to you. The NPB would like to thank PPQ for the opportunity to continue work on a national audit based nursery certification program. And we would like to acknowledge the NPB members involved in this effort, the Horticultural Inspection Society Chapters, the Nursery Industry and PPQ staff for their involvement and support. Sincerely,
Michael E. Cooper President National Plant Board
www.nationalplantboard.org
National Voluntary
Audit-Based Systems Approach to
Nursery Certification
Cooperative Agreement
Work Plan
August 31, 2011 – August 30, 2012
Farm Bill 2008 – Section 10201(d) Cooperative Agreement Program Name of Project: National Voluntary Audit-Based Systems Approach to Nursery Certification Project - 2011 Cooperative Agreement Award No. 11-8100-1550-CA Short Project Description: (as identified in the work plan) The National Plant Board will establish a work group to evaluate the findings of audit-based certification studies funded under the Farm Bill; and to determine the feasibility of developing and harmonizing national standards for a voluntary audit-based nursery certification program. Principle Investigator: Michael E. Cooper Name of Entity: National Plant Board Address: PO Box 790 City, State, Zip: Boise, ID 83712 Office Phone: 208-332-8620 Cell Phone: 208-850-1125 Fax: 208-334-2283 E-mail Address (Principle Investigator): [email protected] Project Purpose: Section 10201(d) of the 2008 Farm Bill directs the Secretary to provide funds and technical assistance to State and local agencies working with specialty crop growers and organizations for the development and implementation of audit-based certification systems to mitigate the risk of plant pests in the movement of plants and plant products; and nursery plant pest risk management systems, to enable growers to identify and prioritize nursery plant pests and diseases of regulatory significance; to prevent the introduction, establishment, and spread of those plant pests and diseases; and to reduce the risk of and mitigate those plant pests and diseases. Stakeholder Participation and Industry Focus
A. Stakeholder Participation: Eastern Plant Board Central Plant Board Western Plant Board Southern Plant Board American Nursery and Landscape Association Horticultural Inspection Society USDA APHIS PPQ
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B. Industry Focus: In the event a national systems-based nursery certification program is implemented, producers and retailers of nursery and greenhouse crops should benefit from expedited interstate and international shipments, a reduction in the dissemination (of) plant pests associated with movement of greenhouse and nursery stock. Commercial tree fruit, small fruit growers and specialty crop growers and consumers will benefit by receiving higher quality pest and pathogen free plant material. In addition, the program is expected to safeguard agricultural and natural resources. Project Description A workgroup coordinated by the National Plant Board evaluated the United States Nursery Certification Program (USNCP) pilot, the Grower Assisted Inspection Program (GAIP) developed by the Oregon Department of Agriculture (ODA) and other audit or systems-based models. A white paper summarizing those findings and recommendations was provided to USDA APHIS PPQ and industry. The work group conducted a preliminary survey of the members of the National Plant Board to determine where opportunities to incorporate a voluntary audit-based certification system reside and to identify hurdles or barriers that would hamper or prevent implementation. Four subcommittees were established:
ο Outreach and Education Subcommittee: The mission of this Subcommittee is to initiate the development of materials and opportunities to express the significance of nursery certification and in particular the value of a systems approach to nursery certification.
ο NPB Model Nursery Bill and Regulations Subcommittee: The mission of the Model Bill/Regulations Subcommittee is to update and revise the model bill and regulation to provide a template that promotes uniform state nursery certification legislation, improves pest management and quality nursery production, and advances the value of state certification programs and the image of the nursery industry.
ο Training Subcommittee: The mission of this subcommittee is to develop
training materials and opportunities for industry and state regulatory staffs that promote strong harmonized nursery certification programs and encourage systems or risk based approaches.
ο Systems approach/Compliance Agreement Subcommittee: The mission of this subcommittee is to develop examples and templates of compliance agreements and other systems approach components that may be utilized as models by regulatory staffs and industry personnel.
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Expectations (as identified in the Work Plan) The work group will conduct a scoping session at the National Plant Board annual meeting, followed by teleconferences and workshops to analyze existing State nursery certification laws and regulations to determine where opportunities to incorporate a voluntary audit-based certification system reside and identify hurdles or barriers that would prevent implementation. The workgroup also will work with industry groups to identify hurdles or barriers that would prevent implementation by industry and or states. The National Plant Board will identify and support workshops (trainer-the-trainer) held by regional plant boards and the chapters of the Horticultural Inspection Society to enable inspection staff, and thereby growers, to identify and prioritize nursery plant pests and diseases of regulatory significance. The National Plant Board will begin development of a harmonized pilot systems-based certification program among the states for the domestic movement of nursery stock. A series of workshops will be held by regional plant boards and the chapters of the Horticultural Inspection Society to better enable inspection staff to identify critical control points. This initiative will also work with growers to review the critical control points in their nurseries and implement best management practices at the local state level. The National Plant Board will partner with the nursery industry and extension to communicate critical control points and best management practices to nurseries to mitigate nursery plant pests and diseases; and the National Plant Board will identify current best management practices to mitigate those special nursery plant pests and diseases of regulatory significance.
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National Voluntary
Audit-Based Systems Approach to
Nursery Certification
Cooperative Agreement
Background and Accomplishments
Final Report
December 1, 2012
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Background 2010-11 A USDA Cooperative Agreement (#10-8100-1550-CA) with the National Plant Board to perform a feasibility study regarding audit based nursery certification resulted in final report dated December 1, 2011. As a part of this feasibility study a workgroup coordinated by the National Plant Board evaluated the United States Nursery Certification Program (USNCP) pilot, the Grower Assisted Inspection Program (GAIP) developed by the Oregon Department of Agriculture (ODA), and other audit or systems-based models. A white paper summarizing those findings and recommendations was provided to USDA APHIS PPQ and industry. The workgroup conducted a preliminary survey of the members of the National Plant Board to determine where opportunities to incorporate a voluntary audit-based certification system reside and to identify hurdles or barriers that would hamper or prevent implementation. As a result of this project, the workgroup determined that in fact an audit based systems approach for nursery certification would enhance the existing certification program by improving consistency, facilitate more training for regulatory and industry staffs, reduce pest risk, and ultimately improve the quality of nursery stock. Four subcommittees: outreach, training, model bills, and compliance agreements were established to assist in moving this project forward. 2011-12 Project – Executive Summary The National Plant Board (NPB) has worked collaboratively with USDA and industry to accomplish the goals set out in the project description and milestones noted in Attachment 1. These accomplishments are described below under the headings of Gathering Input and Building Support, Harmonization, Training, and Outreach. As the SANC team completes this second year of work on this project it is still clear that the current nursery certification system is not broken, but can greatly benefit from improved harmonization of legislation and inspection/certification processes, enhanced training for both regulatory and industry staffs, and a transition to an audited-based systems approach to certification that identifies critical control points (CCPs) and encourages growers to utilize best management practices (BMPs). A draft SANC Framework that provides background on audit-based certification systems and describes the critical elements and principles for such systems was developed. Much needs to be accomplished before implementation of the working audit-based approach can be realized including greater input from industry, but the building blocks noted in this report have been and continue to be put into place. Accomplishments Much of the shared coordination of this project has been accomplished through a system of committees; the Core Group – providing leadership and direction, the Coordinating Team made up of the core group, subcommittee chairs, and HIS representatives, and the Workgroup (Attachment 2) made up of the core group, the
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coordinating team, and representatives from USDA and Industry. The workgroup is utilized to inform cooperators and the coordinating team of the ongoing project activities and accomplishments Much of the work accomplished during this past year is attributed to the work of Subcommittees: Model Bills, Training, Outreach and Education, and Compliance Agreements and Templates. As noted in Attachment 3 (SANC Regulatory Partners), these subcommittees are made up of NPB members, HIS members, and USDA representatives. Nineteen states (38%) and two USDA- PPQ units are represented on these subcommittees and the core group in an effort to include input and participation from a broad base of the regulatory community. Gathering Input and Building Support: Nursery Certification Survey: In January 2012 the NPB led by the SANC Model Bill Subcommittee conducted a nursery certification survey to gather information regarding the current financial status of the industry, state-funding mechanisms, legislative and regulatory competencies, and the general fit of a Systems Approach for certification. A copy of these survey results is shown in Attachment 4. This information is being used to guide revisions to the NPB model nursery and plant pest bills as well as revisions to the NPB Plant Quarantine, Nursery Inspection and Certification Guidelines. . This baseline information along with results from the Nursery Survey conducted in January 2010 will guide the scope and progress of this project. National and Regional Plant Board Presentations: Members of the SANC core group provided an update on the progress of the SANC project at each of the regional plant board meetings during April, May, and June, 2012. Gray Haun, SANC project co-chair presented an update PowerPoint presentation at the National Plant Board meeting in July 2012. Each of these presentations provided the opportunity to update state and federal officials, but also gather input and test the applicability of current progress. For the national meeting, the Outreach and Education (O&E) Subcommittee developed a SANC poster describing the concepts and goals of the project. Workgroup Conf. Calls: The SANC Workgroup made up of the SANC core group, coordinating team, USDA and Industry members met by phone on five occasions during this agreement cycle; October 7, November 10, November 21, February 28, and May 22. In January, this team decided for efficiency sake to meet on a quarterly basis. These meetings provide an opportunity for the SANC project leadership to share information and gather input from industry and USDA regarding the progress of the program. Systems Approach Program Partnership (SAP-P): Plant Board representatives met with the SAP-P partners in September, 2011 to again exchange progress reports and build consensus of support and direction for a systems approach for the domestic interstate nursery production industry. A significant accomplishment of this meeting was an agreement to have USDA organize a technical working group made up of researchers to develop a draft set of general production CCPs and BMPs to minimize
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pest risk in nursery production. This draft has been completed and is being reviewed by an industry advisory team. Following this review, this set of CCPs and BMPs will be assessed by the NPB and SANC for applicability for regulatory pest management. After this regulatory assessment, they will be incorporated into the SOPs for the SANC program and will form a large portion of the foundation on which nurseries will develop a systems approach management plan for their operations. SANC Subcommittee Workshop and NPB Board of Directors (BOD) Update: The SANC Coordinating Team met in Riverdale, MD March 5&6 to identify 2012 goals and to work collaboratively on subcommittee projects. This face-to-face meeting between the Core Group and Subcommittees also provided an opportunity to update the USDA and NPB Board of Directors (BOD) on the progress, activities and goals of the project. A draft of the goals identified by the subcommittees is presented as Attachment 5. SANC Framework Development: The SANC Core Group met in Nashville, TN on May 30&31, 2012 to review the current progress of the SANC project, assess critical assumptions, expectations and challenges, and to provide a plan for continued development and implementation. Attachment 6 contains a copy of the meeting agenda. A primary product of this meeting was the development a NPB SANC Framework document. This draft document (Attachment 7) provides background on audit based certification systems and describes the critical elements and principles for such systems. Harmonization: Revision of NPB Model Bills and the Plant Quarantine, Nursery Inspection, and Certification Guidelines: Early in the process, the SANC Core Group recognized the role that current, relevant, and consistent state legislation, regulations, and standards play in maintaining consistency in the certification of nursery stock and interstate shipping. The Model Bill Subcommittee has developed workgroups to review the current model bills and standards and draft updated model bills have been developed. It is anticipated that these updated drafts will be finalized during the coming year and rolled out to the NPB membership for their approval at the 2013 NPB annual meeting. Horticulture Inspection Society (HIS) Interstate Inspections: The SANC Core Group worked with the Southern and Central HIS Chapters during this agreement period to support interstate training exercises for state inspection staff. This hands-on training, held at nursery locations in Tennessee and Illinois during June 2012, was meant to allow inspectors to share inspection and certification techniques, technical pest information, and discuss management options thus promoting uniformity. SANC funds were used for development of training materials and travel. SANC funds were also committed to support interstate inspection exercises in the Eastern and Western chapters of HIS during September 2012.
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Boxwood Blight Compliance Agreement: In response to early season outbreaks of boxwood blight and requests from wholesale purchasers to state regulatory officials for official verification of product condition, the SANC Compliance Agreement Subcommittee and Core Group in cooperation with ANLA staff developed a compliance agreement template for use by SPRO’s. This quick response to a disease outbreak involved numerous conference calls between researchers, USDA, ANLA and SANC members. Likewise, SANC worked with ANLA to develop an acceptable set of BMP’s that could be used to address this disease. This compliance agreement (Attachment 8) was supplied to SPROs on April 10, 2012. Compliance Agreements: The SANC Compliance Agreement Subcommittee met by conference call on numerous occasions and in face-to-face meetings in March and August, 2012. In addition to the boxwood blight compliance agreement template, this team has developed a template to address snails (Attachment 9) and is currently working on a master compliance agreement template and a Japanese Beetle Compliance Agreement template. In addition, this team is working on a set of Standard Operating Procedures (SOPs) for compliance agreement use. All of this guidance information is being made available to state departments of agriculture to assist with understanding and implementing the SANC process. Impacts of IPPC ISPM 36 and NAPPO RSPM 24: Recent adoption of the International Plant Protection Convention’s (IPPC) International Standards for Phytosanitary Measures (ISPM) 36* titled “Integrated Measures for Plants for Planting” and adoption of the North American Plant Protection Organization’s (NAPPO) Regional Standard for Phytosanitary Measures (RSPM) 24* titled “Integrated Pest Risk Management Measures for the Importation of Plants for Planting into NAPPO Member Countries” by NAPPO has provided a new level of urgency to provide a systems approach option to U.S. nursery producers that is consistent with changing international expectations. The NPB is interested in insuring that this SANC program provides standards that are consistent with these regional and international standards to assure producer access to international markets. The SANC program is intended to provide a certification process that joins seamlessly with international standards. Finally, the NPB and SANC team are working with USDA as certification programs such as the USNCP and US/Canada Greenhouse programs are reviewed for effectiveness. CCPs and BMPs Development: SANC participation with SAP-P during this past year led to an agreement to have USDA organize a technical working group made up of 1researchers to develop a draft set of general production CCPs and BMPs to minimize pest risk in nursery production. This draft has been completed and is being reviewed by an industry advisory team. Following the review by this industry workgroup and adoption by SANC, this set of CCPs and BMPs will form the foundation on which the growers can develop a management plan for a systems approach. Additionally, the SANC Compliance Agreement Subcommittee has begun work to develop pest * Documents are posted and available on the NPB website at: http://nationalplantboard.org/committee/nonnpb.html (scroll down to Systems Approach to Nursery Certification).
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specific/host specific CCPs and BMPs to meet the production and certification needs to address unique quarantine and regulated pests. Training: Interstate Inspections - HIS and State Officials: The SANC Core Group worked with the Southern and Central HIS Chapters during this agreement period to support interstate training efforts for inspection staff. This hands-on training, held at Quad Cities, IL and McMinnville, TN during June, 2012, provided an opportunity to introduce SANC concepts to approximately 80 nursery inspectors from 22 states and to pilot those concepts as part of nursery inspection training including discussing systems approach components with growers, identifying CCPs and BMPs, and critiquing the process during a final meeting. These inspection sessions provided a great deal of feedback on staff impressions as well as program practicality. A summary of the Central HIS session is noted in Attachment 10. USDA Audit Training: In September 2011 the NPB coordinated audit training through the USDA PPQ Personnel Development Center (PDC) at the Raleigh, NC and Fort Collins, CO USDA APHIS PPQ Offices. Thirteen state regulatory staff members attended this training to better understand audit-based inspection and certification systems in preparation for an audit based SANC program. Training Modules: The SANC has organized training in conjunction with HIS annual meetings and regional plant board meetings as noted above. In addition, the training subcommittee has met on numerous conference calls and a face-to-face meeting in March 2012 to develop training modules for both regulatory and industry personnel to provide a complete understanding of systems approach concepts and expectations. Working collaboratively with the USDA-PPQ-PDC, this team has developed and circulated two questionnaires to provide the necessary detail to build these modules. The second of these questionnaires is noted in Attachment 11. Outreach: The SANC Outreach and Education (O&E) Subcommittee has developed a number of materials and mechanisms to explain SANC to state regulatory staffs and industry: SANC Factsheet: A SANC Factsheet (Attachment 12) was developed to provide a brief description of SANC and its benefits for use in discussion with industry and regulatory staff. SANC Snapshots for SPROs: The O&E subcommittee is committed to producing at least quarterly messages for SPROs to keep state agencies informed of the progress of SANC. Five of these messages have been delivered to NPB members during this agreement period covering such subjects as training, face-to-face subcommittee workshop, boxwood blight and interstate inspections. Attachment 13 is an example of these regular messages that have evolved into a product called SANC Snapshots for SPROs.
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PowerPoint Productions and SANC Poster: The SANC O&E Subcommittee produced informational PowerPoint’s (ppts) for presentations by Core Team members at each of the annual HIS chapter meetings in September, and October 2011 and April 2012, at each of regional plant board meetings in April, May and June 2012 and the NPB annual meeting in July 2012. These ppts provided background on SANC concepts and an update of current activities and accomplishments. Similarly a ppt presentation was developed to assist with SANC discussion at the interstate inspection sessions. These ppts were used to reach over 600 regulatory staff national wide and are accessible on the NPB website at: www.nationalplantboard.org. Finally, the O&E Subcommittee developed a SANC informational poster for use at the NPB annual meeting and HIS Chapter meetings. This poster is available on the NPB website as well. Conference Calls: During the agreement period the SANC Core Group conducted over 70 conference call meetings with the core team, SANC subcommittees, coordinating teams, and the SANC Workgroup. These calls involved outreach, strategic planning, project development and coordination as well as assessment and direction at all levels of the project. Call minutes are available upon request. Updates to NASDA and PPQ Mgt Team: NPB president Mike Cooper provided an update on the SANC project to NASDA members at the annual NASDA meeting in September 2011. Additionally, the NPB executive team regularly provides updates to the PPQ management team during joint conference calls held twice a month. SANC Logo and Website: The SANC O&E subcommittee has developed a SANC logo “Growing Better with SANC” to differentiate program materials and to provide a consistent face for the project. An example of the logo is displayed on the cover of this report. In addition, the O&E team initiated work to develop a dedicated website for SANC. This website will provide a full slate of training, education and update information to anyone interested in the SANC Initiative. It is meant to serve the needs of both industry and the regulatory community and is estimated to be on line during December 2012. Summary of Communication Activities: The following meetings and conference calls were conducted or participated in to support the SANC project. Workgroup Conference Calls: Oct. 7, Nov. 10, Nov. 22, Feb. 28, and May 22 – Total 5 Core Group Conference Calls: Sept. 12, Oct. 6, Oct. 27, Nov. 4, Nov. 21, Dec. 9, Jan. 6, 27, Feb. 9, 10, 15, 29, 29, March 14, 16, 20, 29, April 10, 24, 26, May 9,17, June 4, 14, 18, July 2, 3, 5, 12, Aug. 6, 10, 17 Total 32 Western Fact Finding Trip Conference Calls: Oct. 10, 14, 18, 25, and 26 Total - 5 SAPP Meeting: Sept. 26 and 27
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Core Group/Subcommittee chair Conference Calls: Oct. 14 and Oct. 27, Dec. 13(3), &14, Jan. 5, 11 (2), 17 (2), 20, 24, 31, Feb. 3(2), 10, 13,14, 16, 22(2), 29, May 2, 3, 9 (2), June 19, Aug 20, 21, 22, Total 30 HIS Chapter Annual Meetings: Southern – Sept. 8-20, Western – Oct. 3-6, Central – Oct. 13-15, Eastern – April 16-18 Update presentations by core group members. HIS Interstate Inspections: Central – Quad Cities, IL June 11 -13, and Southern - McMinnville, TN June 26-28 Update presentations by core group members. Core Group/HIS Conference Calls: Feb 28(3), March 2, May 9 Total 5 Boxwood Blight Conf. Calls: Feb. 28, March 14, 16, 20, 21, 23, 26, April 10 Total – 8 SANC Subcommittee/ NPB BOD Face-to-Face meeting in Riverdale, MD – March 5&6 Strategic Planning Session – (Core Group) – Nashville, TN – May 30&31 SANC Compliance Agreement Face-to-Face meeting in San Diego – August 21&22 Regional Plant Board Meetings: Eastern April 16-18, Southern April 15-18, Western May 14-17, and Central June 3-7 Update presentations National Plant Board meeting – Mystic, CT – July 23-26 Update presentation and Poster NASDA Annual Meeting and Mid-year meetings: September, 2011 & February, 2012 – NPB President’s Report NAPPO Annual International Meeting, October 2011 - Participation by SANC Core Group In addition, numerous impromptu conference calls were held between core group members, USDA, industry representatives, and other SANC participants to plan agendas, resolve scheduling issues and set SANC direction. Conclusion The goals and milestones agreed upon in the SANC work plan have been accomplished as indicated in the accomplishments section of this report. Throughout this cooperative agreement period the SANC project team has placed a high priority on working towards the development of a voluntary audit-based systems approach that will bring greater consistency to interstate and international nursery certification, reduce pest risk, and enhance industry involvement in pest risk management. Tremendous strides have been made during this agreement period in communicating the goals and benefits of this project and engaging the support of the NPB membership, HIS, and industry. Training modules for regulators and potentially for industry are being developed, and
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compliance agreement templates based on CCP’s and BMPS are in process. Finally a SANC Framework document that provides background on audit-based certification systems and describes the critical elements and principles for such systems is being finalized. Much needs to be accomplished before implementation of the working audit-based approach can be realized including greater input from industry, but the building blocks noted in this report have been and continue to be put into place. Final Thoughts The SANC project leadership team recognizes that there are benefits that will be gained from the implementation of a voluntary systems approach for the certification of nursery stock for the nursery industry, regulators and the consuming public in terms of efficiencies, flexibility, and better pest management. We also recognize that implementation of such an approach must be thoughtful and deliberate, including a clear communication with regulators and industry as to the nature and benefits of such an approach, training for regulators and industry, and a strong desire on the part of all stakeholders to find effective and efficient solutions to project issues or obstacles. The National Plant Board, as the national representative of state agencies responsible for facilitating the interstate movement of pest free, high quality nursery stock, is anxious to continue to move forward with the industry and USDA in developing a voluntary systems approach for certification of nursery stock. Appreciation The SANC Core Group appreciates the cooperation and support of USDA staff in carrying out this cooperative agreement. Much remains to be done to put a fully operational audit-based systems approach process in place. However, good progress has been made during this agreement period and the work teams and partnerships are in place to achieve our long-term goals.
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National Voluntary
Audit-Based Systems Approach to
Nursery Certification
Cooperative Agreement
Attachments
Final Report
December 1, 2012
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ATTACHMENTS: Attachment 1 - 2011 Work Plan Milestones Attachment 2 – SANC Workgroup Members Attachment 3 – SANC Regulatory Partners (March 2012) Attachment 4 - Systems Approach to Nursery Certification Survey (February 2012) Attachment 5 - SANC Subcommittee Goals – 2012 (March 2012) Attachment 6 – SANC Strategic Planning Session - Agenda (May 2012) Attachment 7 – Framework for a Systems Approach to Nursery Certification (August 2012) Attachment 8 - Boxwood Blight Compliance Agreement Template (April 2012) Attachment 9 - Brown Garden Snail Compliance Agreement Template (August 2012) Attachment 10 – Comments on the CHIS Quad Cities Interstate Inspection (June 2012) Attachment 11- Part 2 Questionnaire – Training Module (August 2012) Attachment 12 - SANC Fact Sheet (February 2012) Attachment 13 – Snapshots for SPROs – Interstate Inspections (June 2012) Attachments are posted and available on the NPB website at: http://nationalplantboard.org/committee/nonnpb.html (scroll down to Systems Approach to Nursery Certification).
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Attachment 1
Milestones – (as described in the National Voluntary Audit-Based Nursery Certification Project Work Plan): Define the major milestones for the project and provide a target date for achieving each milestone. List the specific performance measures that will be used to evaluate the success of the project and how each element will be measured. The performance measures should be ‘outcome’ based and indicate the quantity or type of deliverables anticipated under this project as well as the impact of producing and providing those deliverables. A presentation of the concept and development of a system approach to nursery certification will be given to the 4 chapters of the Horticulture Inspectors Societies during their Annual Meetings. Southern Chapter – September 2011 Western Chapter - October
2011 Central Chapter – October 2011 Eastern Chapter – April 2012
Presentations will be given at the Spring 2012 Regional Plant Board meetings. Southern -April Eastern – April Western – May Central - June A presentation will be given to the membership of the National Plant Board at their annual meeting during July 2012. At least monthly conference calls with the SANC core leadership group and at least monthly conference calls with the full SANC working group will be carried out to gather information, steer the working group, and to develop a pilot nursery inspection certification program. Face to Face meetings will be organized as needed for the full working group and or core leadership group. Face to face meetings will be organized as needed to gather additional information /input from industry representatives.
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Attachment 2
SANC Workgroup Members
Core Group: Gray Haun TN, Co-Chair Carl Schulze NJ, Co-Chair Michael Cooper ID, NPB Pres. Geir Friisoe MN, NPB V. Pres. Wayne Dixon FL, NPB Sec/Treas Aurelio Posadas, NPB Exec. Sec. Ken Rauscher, NPB Prog. Assoc. Subcommittee Co-Chairs: Collin Wamsley MO, Training Gary McAninch OR, Training Mike Colvin CA, Compliance Ag. Dan Kenny OH, Compliance Ag. Wayne Dixon FL, Model Bills Gene Cross NC, Model Bills Ruth Welliver PA, Outreach &Ed Carol Holko MD, Outreach & Ed HIS Representatives: Sarah Scally ME, EHIS David Gordon CO, WHIS John Rochelle TN, SHIS Susan Ehlenbeck MO, CHIS Industry Representatives: Jerry Lee, Monrovia Nursery, GA Craig Regelbrugge, ANLA Lin Schmale, SAF USDA Representatives: David Kaplan, APHIS PPQ Scott Pfister, APHIS PPQ Phil Berger, APHIS PPQ CPHST Prakash Hebbar, APHIS PPQ Erich Rudyj, APHIS PPQ University Liaisons: David Fujino, UCNFA
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Attachment 3
SANC – Regulatory Partners
Core Group: State *Gray Haun 615-837-5338 TN [email protected] *Carl Schulze 609-406-6939 NJ [email protected] Mike Cooper 208-332-8620 ID [email protected] Geir Friisoe 651-201-6174 MN [email protected] Aurelio Posadas 916-709-3484 (NPB) [email protected]
Ken Rauscher 517-455-3141 (NPB) [email protected] Training Subcommittee: *Collin Wamsley 573-751-5505 MO [email protected] *Gary McAninch 503/986-4644 OR [email protected] Ann Gibbs 207-287-7602 ME [email protected] John Rochelle 423-341-2324 TN [email protected] Terry Walker 501-225-1598 AR [email protected] Kara Spofford 240-529-0276 (PDC) [email protected] Education and Outreach Subcommittee: *Ruth Welliver 717-772-5222 PA [email protected] *Carol Holko 410-841-5870 MD [email protected] Karen Rane 301 405-1611 MD [email protected] Tad Hardy 225-952-8100 LA [email protected] Susan Ehlenbeck 636-745-8049 MO [email protected] Compliance Agreements Subcommittee: *Dan Kenny 614-728-6400 OH [email protected] *Mike Colvin 916-654-0493 CA [email protected] Amber Morris 916-403-6711 CA [email protected] Sarah Scally 207-287-3891 ME [email protected] Dana Rhodes 717-772-5205 PA [email protected] Tyson Emery 352-372-3505 FL [email protected] Tom Wessels 360-902-1984 WA [email protected] David Gordon 970-209-0348 CO [email protected]
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Attachment 3
Model Bill Subcommittee: *Wayne Dixon 352-372-3505 FL [email protected] Gene Cross 919-733-3933 NC [email protected] Gray Haun 615-837-5338 TN [email protected] Dan Hilburn 503-986-4663 OR [email protected] Jeff Zimmer 517-335-3968 MI [email protected] Vicki Smith 203-974-8466 CT [email protected] David Blackburn 479-363-9904 AR [email protected] Mark Taylor 410-543-6613 MD [email protected] USDA APHIS PPQ Liaison: Scott Pfister 301-851-2287 [email protected] 19 of 50 states participating in the development of SANC – 38% States Participating: AR, CA, CO, CT, FL, ID, LA, MD, ME, MI, MN, MO, NC, NJ, OH, OR, PA, TN, WA * Chairperson
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Attachment 4
NATIONAL PLANT BOARD 2012:
SYSTEMS APROACH TO NURSERY CERTIFICATION SURVEY
Systems Approach to Nursery Certification Core Group
W. Dixon, K. Rauscher, G. Cross, G. Haun, M. Cooper, C. Schulze, G. Friisoe
1. What is your state’s most current national ranking with regards to greenhouse, floriculture nursery and Christmas tree cash receipts?
a. 36th – 2010 b. 29th ‐ 2007 c. Greenhouse, floriculture, nursery and sod d. 65th , Xmas trees 11th 2007 e. These industries account for ~4% of the state's cash receipts – 2004
(stuffaboutstates.com); f. 22nd (floriculture), 19th (nursery) – 2007; nursery 4th g. floriculture 1st in some categories, Christmas trees 4th 2006 ‐ see
http://usda01.library.cornell.edu/usda/current/NursProd/NursProd‐09‐26‐2007.pdf;
h. 7th – 2009 i. 4th ‐ 2010 j. 9th in Greenhouse, 12th in Nursery, 4th in Christmas Trees – 2009 k. 24th ‐ 2007 l. 14th – 200; m. 11‐14th (not sure) – 2007 n. 43rd – 2006 o. 3rd or 4th – 2011 p. 14th – 2010 q. 18th ‐ 2007 r. 2nd – 2011 s. other answers were N/A or Unknown
2. What is your state’s most current estimate of cash receipts for greenhouse,
floriculture, nursery and Christmas trees (include year of ranking)? a. $49.7 million b. $66 million c. Greenhouse & Nursery $240.6 million; Xmas trees $13.8 million ‐ 2011 Ag Stats. d. $79 million gross farm value (2010), LSU Ag Summary; $20,000 1910 e. Nursery $261 million 2005; Greenhouse & floriculture $382 million ; Christmas
trees $41.5 million 2005 f. $2.61 million in 2009
19
Attachment 4
g. $42 million based on sketchy NASS stats from 2007; likely significantly higher h. $849.7 million i. $1.775 million in 2009 j. $204 million (2007); k. $59.3 million l. $327 million for nursery and $23 million for Xmas trees (2007) m. $32.4 million in 2006 n. $850 million o. $270 million p. $31.1 million q. $914 million
3. What year was your state’s enabling statutory authority for nursery certification
established? 1905, 1911, 1915, 1918, 1920, 1924, 1931, 1940, 1950, 1957, 1961, 1963, 1970, 1980, 1985, 1991, 1992, 1993
4. Was the NPB model bill(s) utilized in the development of your statute or subsequent amendments?
Yes 23% No 77%
Comments Added:
a. 1967 was year Plant Pest Act of WV was put into effect to register nursery/nursery dealers.
b. We have used it in development of proposed amendments c. Utilized somewhat (perhaps 25% modeled) d. The last amendment in 1996 ‐ the model bill was utilized to harmonize our
statute with other states. The biggest change was referencing the Commissioner of Agriculture as an authority and taking out the Director of Plant Industries. The statute gives the Commissioner the right to promulgate rules. That is where most of the programs are spelled out. Definitions were used from the model bills.
e. Industry brings legislation. The NPB model bill was shared with industry for consideration.
f. In 2003, we did a complete re‐write of our nursery and plant protection/export certification statutes. We attempted to utilize as much of the NPB model law as we could.
20
Attachment 4
5. Please provide a brief explanation of any recent amendments that may have been
made to your statutory authority (include web link if appropriate). a. Biomass and biofuel including nonnative, transgenic, plants, plant groups or
blue‐green algae b. Fee adjustments and research fund established c. In 2008 we amended our rules and in 2010 we amended our statutes. The rule
change updated our fee tables and separated out the 3 license types we have. We significantly increased our penalty provisions and provided more enforcement options. http://docs.legis.wisconsin.gov/statutes/statutes/94
d. No amendments in the last five years. e. None in at least 10 years. f. State Entomologist Law: amended definition of nursery stock; amended method
of fund disposition. Horticulture Law: amended regulated profession definitions; amended certain exam requirements for licensure; amended certain civil proceedings and special provisions / exceptions; amended fees.
g. Increased licensing and inspection fees from $75 to $100 in 2004. h. Most recent was to add quarantine violation authority. Proposed changes in
progress will allow or state dept of ag to inspect every other year. i. Statute was changed in 2008, but only to renumber. j. Currently reviewing Plant Pest Act of 1992. Revising and updating k. 1,000 Canker Disease Imported Fire Ant Quarantine expansion
http://www.oda.state.ok.us/cps‐nurseries.htm l. Explained above. Also, a new Regulatory Fund statute was put in place to allow
for administrative fees to be promulgated. Part 7 Regulatory Fund Act 43‐1‐701 through 43‐1‐705.
m. Required Christmas tree growers to be licensed; established a grapevine assessment.
n. Statute was changed to restore reciprocity, move to risk based inspections, and exempt small plant vendors from licensing in 2009: http://data.opi.mt.gov/bills/mca_toc/80_7_1.htm
o. Authority for a surcharge to license fees for a pest and disease emergency fund added in 2005.
p. Fee adjustments, collecting wildflowers for resale, tree care registry creation, nursery storage requirements, and nursery label tolerance.
q. No statutory authority amendments adopted.
6. Please note any subsequent nursery rules adopted pursuant to this statutory authority. a. We have rules. Only regular update is to keep list of reportable pests current. b. Our current horticulture and quarantine regulations can be found on our website:
http://www.ldaf.state.la.us/portal/Offices/AgriculturalEnvironmentalSciences/HorticultureQuarantinePrograms/tabid/120/Default.aspx
c. Regulations adjusted to reflect fee increase.
21
Attachment 4
d. 2VAC5‐440 Regulation for Enforcement of Virginia Plant & Plant Products Inspection
Law. e. The fees were taken out of statute and put into rules. f. 02NCAC 48A .1200 Nursery Certification. g. The biggest nursery rule change was to require businesses selling plant materials to
another business (ie Landscaper) is required to get a copy of that persons current certificate and keep for a period of 3 years.
h. Nursery and Christmass tree license fees grapevines assessments. Notification requirement for incoming nursery stock labeling requirement freedom From Infestation rule.
i. Rules establishing risk based inspection and fee structure for inspections currently published for comment: http://www.mtrules.org/gateway/ShowNoticeFile.asp?TID=3909
j. Rule requiring notification of imported stock adopted in 2004. Rule adding surcharge for emergency fund adopted in 2006.
k. All nursery rules contained in Arkansas State Plant Board.
7. How closely aligned do you see your statutory authority to the current NPB model bill?
Very close 0 % Close 17% Partially close 78% Not close 5%
8. Outline any shortcomings or deficiencies that you may have observed with your
state’s statutory authority. Have these conflicts hindered the implementation of your field operations? a. Work closely with industry to meet their needs as well as our responsibility of
safeguarding. b. Nothing hindering ‐ but need better violation/penalty abilities. Other states may
not like our regs, but we didn't adopt our regs to only serve other states. It was put in place to protect OUR citizens.
c. Nursery sources should be required, not voluntary. We should have 1 nursery license with 3 subcategories, not 3 separate license types. Yes, our licensees often fail to renew their license (without follow‐up) and licensees often apply for the wrong license type.
d. Our statute does not deal at all well with internet sales. e. Shortcomings of the Compliance agreement/certificate process and movement of
plants thru this process. f. While nursery‐related issues fall under two different laws in Louisiana, the vast
majority are under authority of the 'State Entomologist Law.' This simple law has broad, police‐power type authority and rarely are we faced with problems.
g. Lack of administrative fines. Antiquated enforcement options requiring court trial. No late fees for delinquent firms. Operations are hindered because of lost revenue
22
Attachment 4
from deadbeat firms, large amount of work required to take a violator to court. High administrative costs to retrieve funds owed for inspections.
h. Definition of nursery stock is basically restricted to woody stemmed plants. It would help if definition of nursery stock is closely aligned in all states. Penalty for violation of Virginia's statute is a class 1 misdemeanor; violation should result in a civil penalty, not criminal.
i. Violations are subject only to misdemeanors. It is expected civil penalty authority would greatly enhance implementation and compliance.
j. It's difficult to increase fees. k. Constant struggle between large nurseries and small plant vendors on how the
program will be funded. Currently small plant vendors are exempt from licensing and the state only has authority to inspect licensed nurseries.
l. No incentives for nurseries to adopt BMPs. They pay their fee, they get a license. Shipping permits are automatically given to all licensed nurseries.
m. Would like to have had administrative penalty authority. Would like greater flexibility to assess and collect fees for unique inspections or certifications.
9. Outline any unique aspects of your adopted statute you feel might be valuable to
include in a potential update to the NPB model bill. a. Making sure to have both civil and criminal penalty options and latitude within each
of them. b. Our main statute, the 'State Entomologist Law,' is very short and general compared
with the model law. Most of what the model law contains is covered in rules and not statute in Louisiana. This seems like a preferred situation.
c. Broad authority of the Secretary to declare something to be a pest. Md. Agric. Art. § 5‐301(g)
d. Allowing access to private property if reasonable cause to suspect there is a pest threat.
e. Broadly defined plant pest. f. Charging for overtime or for special requested services. g. Nursery license surcharge for research. Grapevine and Fruit tree assessments to
support certification programs. Establishes Advisory committees (nursery fruit trees, grapevine and Christmas trees)
h. All businesses selling nursery stock should be licensed even if there are no fees associated with the license.
i. Emergency fund to deal with plant pest and disease issues built into fee structure. j. Stand alone enforcement chapter with robust civil and criminal provisions, Tree
Care registry Have a state GMO permit process.
23
Attachment 4
10. What is the current source of funding for your state’s nursery certification program?
Receipt‐
State supported appropriations (fees) Other 22 45 32 100 25 22 53
100 60 40 50 50 100 90 10 60 40 40 60 62 38 50 50 95 5 5 95
11. How would you describe the financial stability of your current nursery certification program?
Non‐sustainable 17% Sustainable 52% Growing 5% Unclear/Unknown 26%
12. Is your state’s current staffing for the nursery certification program adequate? Please indicate "Yes" or "No."
10 Yes: a. Yes. But ... no one solely does nursery inspections. I have a staff of 4 FTEs + 1 CAPS
coordinator + 1 adm assist, that take care of grower inspections and various other tasks related to export certification, seed permits, noxious weed law, etc.
b. most of these questions are N/A for WV as we don't have certification in place. We do have 2 nursery inspectors on staff currently for the entire state. Would/could use more.
c. Yes, but stretched.
13 No
24
Attachment 4
13. If “No” please describe any limitations.
a. Sufficient but many new pest programs are making nursery inspections more difficult due to manpower diversions.
b. Funding and personnel. c. Inspectors don't complete all of the assigned inspections and sometimes are rushing
to complete inspection and move on. Sometimes compliance issues are not followed up on at the desired level.
d. The number of interstate shipments continues to grow and we need more staff at the program manager level as well as inspectors to keep up and do a good job
e. In the past 12 years we have lost 30‐40% of our field force. Although 6 of those lost positions have been refilled in the past 2 years, we still have fewer than 50 field inspectors statewide. These positions are cross‐utilized among dozens of program responsibilities unrelated to horticulture / nursery work.
f. Not enough people to cover territory. Budget cuts. g. Recent loss of staff due to retirements & no new hires. h. We need more seasonal staff during the spring season. i. Additional inspectors required. j. difficult to keep field inspectors partially due to expansive areas assigned k. All nurseries cannot be inspected in a given year. Movement to a risk based model
will allow Department to schedule inspection on a multiple year schedule. The fee structure and license requirements have changed in all (2007, 2009, 2011) of the most recent legislative sessions.
l. We've lost two inspector positions in the past couple of years and the prospects for replacing them aren't good.
14. From your perspective, what is the most pressing issue your state has experienced with regards to interstate shipping?
a. Perceiving that there is a fair level playing field across all states. Adage of DSDR: different states, different rules in terms of PPQ.
b. Canada and California border stations. c. Our law does not consider perennials to be 'nursery stock.' Other states do.
Confusion abounds. d. Knowing which licensees should be inspected for interstate shipment, timely
inspections. The need for more site certifications and inspections and the lack of ability to add staff in a down economy.
e. Quarantine compliance. Finding "pests" at inspection stations to hold up shipments f. Certain states have long lists of restrictions and special requirements. Also, in a few
cases states will prohibit entry or require conditions unwarranted by their own pest status.
g. compliance with federal quarantines. h. Knowing, understanding, and meeting all the different shipping requirements for
each individual state.
25
Attachment 4
i. Violations of state and federal quarantines by firms shipping into Nebraska, often
under compliance agreements. j. Interpreting the nuances of other states requirements. There is often a difference in
interpretation. k. Traceability of plant material. l. Japanese beetle certification and shipment to western states. m. Doing last minute phyto inspections. n. keeping up with current regulations. o. Japanese beetle detections in two of the last five years at a large importing nursery p. SOD certification based on an expensive and labor intensive inspection/testing
program. q. Introduction of harmful invasive pests. We have detected several introductions of
Gypsy moth in the nursery trade. r. SOD movement from regulated areas on the west coast.
15. Is your state's list of state quarantines as outlined on the NPB web page? If not, please list your state’s current list of state external quarantine pests below.
18 Yes. Not listed: Thousand Cankers Disease and Firewood
16. Are you aware of the NPB’s initiative to develop a systems approach to nursery certification?
100% (24 yes)
17. If you answered "Yes" or "No" to question 15, please provide additional comments as applicable.
a. I am not fond of the systems approach. Inspecting 'control points' is not enough. If the stock is to be apparently free from pests, then the stock needs to be inspected.
b. Still reading up on SANC emails, etc. Hope the April HIS meeting will discuss this for feedback from our nursery inspectors.
c. We sent an inspector to the Nursery Audit Training in Raleigh, NC in September 2011.
d. Much more information needs to be circulated as to what is going on and the progress; when critical decision points will occur, etc.
e. I became aware of SANC only recently and plan to participate on a subcommittee (O&E).
f. Ken Rauscher has explained the initiative to us. g. NC has been involved by having an HIS‐SC member participate in SANC committee
meetings. HIS‐SC has also been presented with concept also at the fall 2011 meeting. h. I have spoken to some NPB members regarding the systems approach.
26
Attachment 4
i. Have been at various meetings when early discussions were taking place and have
answered other surveys on this subject. j. Thank goodness. It is about time.
18. As you understand the concept of systems approach to nursery certification, do you believe it could be useful in your state?
Yes 83% No 17%
19. If you answered "Yes" or "No" to question 17, please provide additional comments as applicable.
a. There only a very few who might consider it and nationally they are considered a medium size nursery.
b. As long as it's volunteer which we are assured it is. c. It could be potentially useful for a few of the larger nurseries. It would be more than
most of our nurseries would need. d. Help industry manage risk; Help inspectors target risk and assist growers. e. SANC would allow us to concentrate resources on firms that present greater pest risk
than a well managed firm. f. From an importing state perspective as we don't do very much exporting of plant
material to other states. g. The vast majority of NC nurseries are very small and sell only locally. We do not have the
infra‐structure to participate in an initiative of this type. h. I believe assisting the industry in establishing nursery certification would only continue
to strength the nursery industry and solidify the working relationship between regulatory and industry.
i. Most of the large growers in our state implement this approach to best management practices already.
j. A voluntary system would take some of the load off of inspectors and I believe move a cleaner product interstate.
k. We already use a systems approach in our 8 planting stock certification programs l. We have incorporated aspects (such as critical control points) of the system based
approach into our nursery inspection program. m. SOD and boxwood blight are good examples of diseases that are not going to be
stopped by end point visual inspections.
20. Would you be willing to assist in some aspect of the NPB model bill revision process?
Yes 61% No 39%
27
Attachment 4
21. Have you discussed with your nursery industry any of the components of a systems approach to nursery certification?
Yes 54% No 46%
22. If you answered question 20 with "Yes", please provide a description of industry interest, questions or comments.
a. Preliminary discussion with representative industry. b. No one seemed too interested. c. Have been waiting to find out more about SANC. d. Only a very small bit at the conceptual level. e. We have encouraged Michigan firms to consider the USNCP and also we developed an
audit based certification program for conifers which has many of the SANC components. Biggest concern from industry is cost to develop a manual.
f. They agree it could help strengthen the industry and be used as a marketing tool for sales outside of the state. They would like some guidance in how to establish and implement the program.
g. Several have asked when the system will be in place and what training will be provided to them.
h. I have talked with the TNLA nursery Board of Directors on a 50,000 ft level. i. We talked to our nurseries about the USNCP and US/Canada Greenhouse program j. Nurseries have limited interest unless they see a financial benefit. k. The Oregon Association of Nurseries is interested. Some nurseries have signed up for
pilot programs. Other nurseries are hanging back. There is no incentive at this time. l. They are interested but very guarded.
23. Do you feel there is a nursery or nurseries in your state that may be willing to pilot a systems approach?
Yes 81% No 19%
24. Other comments or suggestions?
a. We register nurseries/nursery dealers in order to do inspections for injurious insects/diseases/weeds. This is to ensure clean nursery stock for consumers within and outside of WV. We do issue federal and state phytosanitary certificates.
b. Maybe 1 nursery re question 23. c. Maybe.
28
Attachment 4
d. Answered this survey to the best of my ability. Have only been working with the Bureau
in MS for a few months, but would certainly be willing to help the National Plant Board anyway I can with SANC.
e. The previous question is difficult to answer. We may have 1 or 2 interested but we would need to gauge their interest.
f. 2 Oklahoma field inspectors are attending the training exercise in TN. g. We just have to show that participation in the program is cost effective to both the
nursery as well as the regulatory community and is as good if not better then what we are currently doing in moving good clean plant materials in a seamless way.
h. For any program to succeed, there has to be a significant monetary incentive for participants.
i. Think incentives. Without them people are content to stick with the status quo. j. The current NPB nursery and plant protection templates are too complex and
bureaucratic.
Responses from:
Alabama
Arkansas
Colorado
Florida
Idaho
Iowa
Louisiana
Maine
Maryland
Michigan
Minnesota
Mississippi
Montana
Nebraska
New Hampshire
North Carolina
Oklahoma
Oregon
Pennsylvania
Tennessee
Virginia
Washington
West Virginia
Wisconsin
29
Attachment 5
S(
ANC Goals as Stated by Subcommittees at the March 5&6, 2012 Face to Face Session)
Tra inin g Subcommittee erm
1. ra interstate inspections – June, 2012 Short T
T ining materials for
‐ pilot training tools
ule e tools
‐ e‐learning mod‐ ppt will be one of th
2. ‐ field exercises HIS chapter meetings ‐ PDC overview or intro to audits
g rm1.
Lon Te inspectors – December, 2012
tages of risk based certification Training for state and county
‐ Understanding the advan
‐ ID and understand CCPs
ss ‐ ID and understand BMPs
e
‐ Understand the audit procer avenues
2. ponent ‐ Use HIS and oth
vaIndustry training com
– rious avenues ‐ various materials
cate SANC ‐ Educate and communi
Comments:
1. Regular Conference calls 2. Training for development of compliance agreements
Com lp iance Agreements Subcommittee
erm1. ev agreement template
Short T D elop Boxwood Blight com
pliance 3‐9 ‐ Draft by the end of the week‐ Vet by the subcommittee ‐ Vet by the workgroup 3‐16 ‐ consideration
2. gional Plant Board mtgs. Provide to the Core Group and NPB BOD for
Develop Compliance agreement materials for Re‐ Need to meet with the Training committee
ge Term 1. Develo nt templates – Annual NPB meeting
(July, 2
Lon rp a set of compliance agreeme012)
omments: May need face to face meeting C Model Bill Subcommittee
erm 1. Develop Revisions to the Nursery and Plant Pest Model Bills
Short T
30
Attachment 5
‐ Initial drafts – May 1
‐ Review by the Subcommittee
‐ Review by the SANC Coordinating Team ‐ Deliver to NPB BOD – June 1, 2012 ‐ Present to NPB membership – July, 2012
ge Term 1. Develop revisions to QNSC Guidelines (Quarantine standards)
L
on r
Edu t ommitteeca ion and Outreach Subc Goals:
1. Promoting the initiative
2. Providing marketing tools te
1. Action I ms
r with SANC Producing the Face of SANC ‐ Growing Better trademark – perhaps Growing Bette
family of products 2. professionally developed
‐ Other SANC materials – a ific website –
ite New SANC spec‐ unique URL@ NPB webs
‐ components
i ‐ links to other webs tes 3. Rane – March 30 Power Point presentation – Karen
e fact sheet ‐ General overview
th ‐ Content similar to ‐ Regional examples ‐ Post on website
4. Communication with SPRO’s – SANC Snapshot ‐ Once per month ‐ Get a copy to nursery managers and supervisors as well
Comments: 1. Retailers – are they an audience involved in the distribution chain
e problem of material coming in
2. Perception that SANC does not address th
from other countries
3. Measures of Success – do we need them? the work of the E&O Subcommittee? Subcommittees,
sident 4. Who needs to review
or PB Pre5. ro :
C e Group, N
P motional Items
0X ‐ lanyards
‐ hand lens 2
‐ LED lights
ards ‐ Clipbo
‐ Pen/pencils
rman (micro) ‐ Knife ‐ Leathe‐ Caps
31
Attachment 6
SANC Core Group
Strategic Planning Session Nashville, TN May 30 & 31
Goal Statement: This meeting is to provide an opportunity for the Systems Approach to Nursery Certification (SANC) Core Group to review the progress of this Farm Bill initiative and to strategically plan for the successful development and implementation of this alternative approach to certification of nursery stock for interstate shipping. Wednesday, May 30, 2012 :00 AM Welcome Core Group members/ Initial Perspectives ‐ Gray Haun and Carl 8Schulze ‐ SANC Co‐Chairs
oper 8:10 President’s Comments – Mike Co 8:15 Housekeeping Matters – Aurelio 8:20 Review SANC Accomplishments – are we on the right track? – Carl and Gray :35 Review our SANC specific goals. (As identified in the Farm Bill proposals and 8as identified by current subcommittees). Gray and Carl 9:00 Brainstorming: Identify what “Success” looks like ‐ SANC End Products –
e this project fully What are our goals and in what year should we expect to havxecuted? 2016 ? 2015? arl and Anni – HeC ow about a quick refresher on Q‐storming rainstorming: Identify what “Success for this Initiative for the final product year – B
say 2016 and work backward
Identify Incremental Goals 10:00 2015 2014
013 2 1 2:00 PM Lunch
32
Attachment 6
:00 Brainstorming: Identify challenges and proposed solutions to be addressed 1to reach each goal beginning in 2013 and work forward 2013 Identify challenges to be addressed to reach goals – determine subcommittee o address challenges or needed subcommittee. Identify resources needed –
mittees, etc. tfinancial, personnel, partners, additional subcom
2:00 2014 Identify challenges – same as above 3:00 2015 Identify challenges – same as above
:00 2016 Identify challenges – same as above 4
f progress for the day. Review agenda for tomorrow 4:50 Review o 5:00 Adjourn Thursday, May 31, 2012
d? 8:00 AM Review planning progress from Wednesday. What have we misse
ar plan together year by year. Is it complete? Will it work? Put the four ye 10:00 Break
0:15 Current SANC Budget Sta 1 tus Look at the balance of 2012 (We can collapse this area if we need more time for
rategic plan) Adeveloping the st 10:30 Outreach
‐ Trademark, SANC Family of Products
‐ Website ‐ PPT (presentations for industry, local associations, etc) ‐ Communication with SPROs (nursery managers and supervisors) ‐ follow
h throug 11:00 raT ining:
am ‐ ? How do we best implement a train‐the‐trainer progr
‐ What is the on‐going role of HIS in the SANC process? ‐ How do we bring the industry‐training piece along? role of USDA at the regional and state level in regard to
interstate shipping and application of federal quarantines? ‐ What is the
facilitating‐ Timetable
33
Attachment 6
1:15 Model Bill comments on initial drafts of Plant Pest and Nursery Model Bills, 1Timetable 11:15 Break 11:30 omC pliance Agreements:
‐ PBasic BMP’s from the SAP‐ Additional Templates
Technical Committee
‐ Interaction with training 1:45 Interstate shipping training – oversight from this group for the upcoming essions? 1s 12:00 PM Lunch
ing up the plans 12:30 Annual Meeting Presentation – firm 1:00 Consideration of Parking Lot Issues
ny initial thoughts? 1:30 Development of the 2012 Workplan – A 2:00 Recap – Next Steps – Gray, Carl, Mike
:15 Adjourn 2 Needs: Easel Flip Chart Pads ackground D6B ocuments
that Participants: Please give some reflective thought to the significant questionshould help drive our discussion and lead to a strategic plan for SANC.
s
May 28, 2012
34
Attachment 7 1
Framework for Systems Approach to Nursery Certification
Framework for a Systems Approach to Nursery Certification National Plant Board 2012
W.N. Dixon, M.E. Cooper, A. Posadas, G. Friisoe, C. P. Schulze, G. Haun, K. Rauscher
“A system is an entity, whi action of its parts.” ch maintains its existence through the mutual interLudwig von Bertalanffy, Aus rian Biologist (1901–1972) t
INTRODUCTION: The Systems Approach to Nursery Certification (SANC) is an enhanced strategic methodology to meet the many challenges in the movement of plants within the environment of regulatory agriculture and business activities. Plant pests and pathogens are undesirable yet potential accompanists to plants that are moved in the domestic, interstate and international trade. The common business model is well suited to growing small to large numbers of desirable plants for propagation or sale and moving them from vendor to buyer over small and long distances. It is encouraging that the everyday nursery may well incorporate several elements of a systems approach to mitigating the risk and effects of nursery pests. As the challenges of escalating costs of nursery production, increasing regulatory agriculture requirements and more movement of plants come into focus, SANC will be a vital response to adequately meeting the pest challenges within a fiscally limited environment. It is becoming more evident that all the stakeholders must ork together more closely to meet the expansion of the world market and yet adequately itigate the plant pests and
wm pathogen risks associated with plants. DEFINITION of a CONCEPT: A systems approach strategy incorporates specific operational nursery practices that minimize the likelihood of incursion, establishment and growth of plant pests and pathogens in a nursery. A systems approach requires two or more measures that are independent of each other, and may include any number of measures that are dependent on each other. An advantage of the systems approach is flexibility in the bility to address variability and uncertainty by modifying the number and strength of ameasures to meet phytosanitary import requirements. Cultural practices, crop treatment, post‐harvest disinfestation, inspection and other procedures, to name a few, may be integrated in a systems approach. Risk management measures designed to prevent contamination or re‐infestation are generally included in a systems approach (e.g., maintaining the integrity of lots, requiring pest‐proof packaging, creening packing areas). Likewise, procedures such as pest surveillance, trapping and ampling can also be components of a systems approach. ss
35
Attachment 7 2
Framework for Systems Approach to Nursery Certification Measures that do not kill pests or reduce their prevalence, but reduce their potential for entry or establishment (safeguards) can be included in a systems approach. Examples include designated harvest or shipping periods, restrictions on the maturity, color, ardness, or other condition of the commodity, the use of resistant hosts, and limited
tination. hdistribution or restricted use at the des Dependent and Independent Measures A systems approach may be composed of independent and dependent measures. By definition, a systems approach must have at least two independent measures. An independent measure may be composed of several dependent measures. With dependent measures the probability of failure is approximately additive. All dependent measures are needed for the system to be effective. If one measure fails, it too fails the other measure. For example, a pest‐free glasshouse where both a double‐door and screening of all openings is required is an example where dependent measures are combined to form an independent measure. If the probability that the screening fails is 0.1 and the probability that the double doors fail is 0.1 (1 chance in 10), then the probability that the glasshouse will be infested is the approximate sum of the two values, 0.2 (1 chance in 5). The probability that at least one of the measures fails is the sum of both probabilities minus the probability that both fail at the same time. In this example, the probability is 0.19 (0.1 + 0.1 − 0.01), since both the measures could fail at the same time. The failure of either measure directly influences the uccess or failure of the other measure and accounts for the little change in overall sprobability of failure in the nursery. Where measures are independent of each other, both measures must fail for the system to fail. With independent measures, the probability of failure is the product of all the independent measures. For example, if the inspection of a shipment has a 0.2 probability of failure and the limiting of movement to certain areas through regulations has a 0.2 probability of failure, then the probability of the system failing would be 0.04 (0.2 × 0.2). rom these examples, it becomes evident that independent measures can provide a much Fpreferred lower level of potential failure of a system approach to mitigate a pest problem. Utilizing a systems approach to nursery certification is focused on better confidence in the pest‐free status of a nursery plant through the lowered risk of a plant pest introduction and reproduction. For the nursery grower it also can result in lesser need for chemical controls and lower costs, fewer losses to plant pests and greater productivity. Conversely, for the buyer the risk of purchasing an infested plant and establishing new infection foci in a new area is much reduced.
Utilizing a systems approach mitigates shortcomings of end‐point inspections, e.g., infected plants are symptomless, pesticides may be suppressing symptoms, signs or symptoms of infestation/infection may not be recognized, detection limit is too high.
LEMENTS of a FRAMEWORK: A SANC for any nursery requires a framework built from everal ts include: Es
elements. These key elemen
• Risk analysis of the nursery
• ritical control points identified at the nursery C
•
36
Attachment 7 F am 3 r e
work for Systems Approach to Nursery Certification
• evelopment and implementation of appropriate best management practices as Drequired by pest species or group
• Monitoring and recording of pests found on plants when received in the nursery and when plants are shipped
• Recording of actions at the nursery, including IPM practices, staff training and production methods
• Documenting the source, movement and buyers of plants, for incoming and outgoing plants to allow traceability (i.e., trace forward or trace back if a plant problem becomes known).
Utilizing a SANC is focused on higher confidence in the pest‐free status of a nursery plant through the lowered risk of a plant pest introduction and reproduction. For the nursery grower, a SANC can result in lesser need for chemical controls and lower costs, fewer losses to plant pests and greater productivity. Conversely, for the buyer the risk of purchasing an infested plant and establishing a new infection site in a new area is much reduced.
This paper will focus on the first three elements which form the essential framework of a ation. systems approach to nursery certific
Hazards and Critical Control Points
Hazard is the potential to cause harm; risk on the other hand is the likelihood of harm (in defined circumstances, and usually qualified by some statement of the severity of the harm).Plant pests can cause a hazard in a nursery by damaging plants as well as lead to restriction of sales or movement of the affected plants. A risk analysis is a systematic way of gathering, evaluating, and recording information leading to recommendations for a position or action in response to an identified hazard. Risk analysis of a nursery can be achieved through use of Hazard Analysis and Critical Control Points (HACCP). This strategy is a systematic preventive approach widely used in food and pharmaceutical safety that identifies physical, allergenic, chemical and biological hazards in production processes that can cause the finished product to be unsafe, and designs measurements to reduce these risks to a safe level. In this manner, HACCP is referred as the prevention of hazards rather than finished product inspection. A critical control point (CCP) is a point, step or procedure at which controls can be applied and a nursery pest hazard can be prevented, eliminated or reduced to acceptable (critical) levels. In food safety, the most common CCP is cooking, where food safety managers designate critical limits, e.g., for poultry, minimum internal temperature is 165°F (74°C) for 15 seconds. In a nursery, it may be requiring that re‐used containers must e sterilized with a specific concentration of a disinfectant between uses to ensure adequate bkill of pathogens. The application of a critical control point system for phytosanitary purposes may be useful to identify and evaluate hazards as well as the points in a pathway where risks can be reduced and monitored and adjustments made where necessary. The use of a critical control point system for phytosanitary purposes does not imply or prescribe that pplication of controls is necessary to all control points. However, critical control point ystems only rely on specific independent procedures known as control points. These are as
37
Attachment 7 Framework for Systems Approach to Nursery Certification 4 ddressed by risk management procedures whose contribution to the efficacy of the system acan be measured and controlled. Therefore, a systems approach for phytosanitary purposes may include components that do not need to be entirely consistent with critical control point concept because they are considered to be important elements in a systems approach for phytosanitary purposes. For example, certain measures or conditions exist or are included to compensate for uncertainty. These may not be monitored as independent procedures (e.g.. packhouse sorting), or may be monitored, but not controlled (e.g., host preference/susceptibility).
As a SANC is developed, it is useful to look at the seven principles of HACCP which form the basis of understanding and controlling the risks of pest hazards:
Principle 1: Conduct a hazard analysis. Determine the nursery pest hazards and identify the preventive measures the nursery can apply to control these pest hazards. A nursery pest hazard is any biological, chemical, or physical property that may cause a nursery plant to not remain pest‐free. There may be certain types of hazards in association with specific pests or types of pests which can vary from nursery to nursery.
Principle 2: Identify critical control points. A critical control point (CCP) is a point, step, or procedure in a nursery at which an independent control measure can be applied and, as a result, a pest hazard can be prevented, eliminated or reduced to an acceptable critical limit.
Principle 3: Establish critical limits for each critical control point. A critical limit is the maximum or minimum value to which a nursery pest hazard must be controlled at a critical control point to prevent, eliminate or reduce to an acceptable level.
Principle 4: Establish critical control point monitoring requirements. Monitoring activities are necessary to ensure that the process is under control at each critical control point.
Principle 5: Establish corrective actions. These are actions to be taken when monitoring indicates a deviation from an established critical limit. Corrective actions are intended to ensure that no nursery product injurious to other plants enters commerce.
Principle 6: Establish procedures for ensuring the HACCP system is working as intended. Verification ensures that the nurseries do what they were designed to do; that is, they are successful in ensuring the production of pest‐free plants. Verification ensures the HACCP plan is adequate—it is working as intended. Verification procedures may include such activities as review of HACCP plans, CCP records and critical limits. Verification also includes 'validation' – the process of finding evidence for the accuracy of the HACCP system (e.g., scientific evidence for critical limitations).
38
Attachment 7 Framework for Systems Approach to Nursery Certification 5
Principle 7: Establish record keeping procedures. The HACCP approach requires that all nurseries maintain certain documents, including its hazard analysis and written HACCP plan, and records documenting the monitoring of critical control points, critical limits, verification activities and the handling of production deviations.
In terms of a nursery, we can refine and reduce this to a Critical Control Point System CCPS). A critical control point system in a nursery would involve the following ro(p
cedures:
m 1. Determine the pest hazards and the objectives for measures within a defined syste2. Identify independent procedures that can be monitored and controlled
ontrol 3. Establish criteria or limits for the acceptance/failure of each independent cmeasure
4. Implement the system with monitoring as required for the desired level of
at criteria are not met confidence
ndicate th
5. Take corrective action when monitoring results i6. Review or test to validate system efficacy and confidence7. Maintain adequate records and documentation.
Critical Control Points and Best Management Practices Determining the hazards can start with a production flow chart of the nursery to form the hazard analysis. As an example, we can use Phytophthora ramorum as a known pest hazard. This is a pathogen moved by soil, water and infected plant material. In the case of a container nursery, procedures used in handling of potting media and containers, water, plant procurement and propagation and plant disease management are important to the survival and movement of the pathogen. Additional information would be needed on the site being used including its preparation and maintenance. Depending on the operation, greenhouse or field production areas, as well as cull piles, are where additional hazard analyses are warranted. Several critical control points and resulting independent control measures, i.e., best management practices, have been identified (Table 1). From the identification of the CCPs, best management practices can be developed to constrain the hazard. A best management practice is a method or technique found to be the most effective nd practical means in achieving an objective (such as preventing or minimizing a pest nfestation) while making the optimum use of the nursery resources. ai Table 1. Critical control points form the basis of best management practices for Phytophthora ramorum.
Critical Control Point Best Management Practice Placement of container plants on contaminated ground
Do not place containers on contaminated ground
Use of contaminated irrigation water Treat irrigation water before use Use of contaminated pots Use new pots or properly disinfest used pots Buy‐ins of infected pots Buy only from certified suppliers; quarantine plants
for 90 days Poor drainage Prevent standing water Accumulation of infested leafy debris Prevent accumulation of infested leafy debris
39
Attachment 7 Framework for Systems Approach to Nursery Certification 6 As another example, the armored Euonymus scale damages deciduous and evergreen euonymus (Euonymus spp.), pachysandra (Pachysandra spp.) and bittersweet (Celastrus spp.). Vine‐type euonymus are extremely susceptible to attack by this scale. Several independent control measures or best management practices can be utilized to limit this pest hazard in a nursery (Table 2). Table 2. Critical control points form the basis of best management practices for the Euonymus scale. Critical Control Point Best Management Practice Growing nursery plants near wild host plants Remove wild host plants a minimum distance
Buy‐ins of infested plants for grow‐out Buy only from certified suppliers; inspect and segregate plants into holding areas
Disposal of newly infested plant parts Destroy cull pile material daily
Water stress Manage water levels for thrifty growth and group plants with similar water needs
Equipment movement of pest Clean equipment between production areas Cultivar or species susceptibility Use resistant cultivars or species
As has been illustrated, conducting a hazard analysis to delineate the pest hazards, identification of critical control points and resulting use of best management practices form the essential framework to a systems approach to nursery certification. Many best anagement practices that would result from a critical point system are often already m
utilized, in whole or part, in current nursery operations. Depending on the plant species and associated pests or diseases, a systems approach to ursery certification would include independent and dependent measures that can be roadly onb
categorized int three best management practice types:
1. Pre‐planting: Use healthy planting material, resistant or less susceptible cultivars, s, pest‐free areas, pest‐free places of production or pest‐free production site
producer registration and training. 2. Growing: Use field management procedures (e.g., inspection, pre‐harvest treatments, pesticides, biological control, etc.), protected conditions (e.g., screen
on, houses, greenhouses), pest mating disruption, cultural controls (e.g., sanitatiweed control), low pest prevalence (continuous or at specific times), testing.
3. Pre‐shipment: Use plants at a specific stage of development or time of year (e.g., after deciduous leaves fall, juvenile or mature), sanitation (e.g., removal of leaf litter), testing, treatment (e.g., pesticide application, exclusion); inspection and grading (including selection for certain maturity or quality stages); sanitation
reas. (including removal of parts of the host plant); testing; screening of storage a Once the hazard analyses are conducted, critical control points are identified and best management practices are developed, the remaining elements can be formulated for the SANC. These would include implementing the system with monitoring; taking corrective actions if so identified from monitoring; validating the system on a regular basis; and maintaining records and documentation. Even these steps may be found to be wholly or
40
Attachment 7 7
Framework for Systems Approach to Nursery Certification artially done in many nurseries, but have not been built into a structured systems papproach per se. Overall, a systems approach for nursery certification requires a methodical gathering of information pertinent to the pest hazards associated with a nursery followed by
to development and use of best management practices that can be documented and verifieddemonstrate the successful performance of the systems approach. As often the case, the first step is the hardest, but once the journey is underway, the next steps are much easier.
41
Attachment 7 Framework for Systems Approach to Nursery Certification 8
References Food and Agriculture Organization of the United Nations, International Plant Protection
Convention. 2002. International Standards for Phytosanitary Measures 14: The use of integrated measures in a systems approach for pest risk management. Secretariat of the International Plant Protection Convention. Food and Agriculture Organization of the United Nations. 13 pp. https://www.ippc.int/file_uploaded/1323945406_ISPM_14_2002_En_2011‐11‐29_Refor.pdf
Food and Agriculture Organization of the United Nations , International Plant Protection
Convention. 2008. International Standards for Phytosanitary Measures 24: Guidelines for the determination and recognition of equivalence of phytosanitary
d measures. Secretariat of the International Plant Protection Convention. Food anAgriculture Organization of the United Nations. 13 pp. https://www.ippc.int/file_uploaded/1323946244_ISPM_24_2005_En_2011‐11‐9_Refor.pdf
Food and Agriculture Organization of the United Nations, International Plant Protection
Convention. 2012. International standards for phytosanitary measures 36: Integrated measures for plants for planting. Secretariat of the International Plant Protection Convention. Food and Agriculture Organization of the United Nations. 20 pp.
‐05‐02.pdfhttps://www.ippc.int/file_uploaded/1335957921_ISPM_36_2012_En_2012 Canadian Nursery Certification Institute. 2011. Clean plants standard: Domestic
phytosanitary nursery certification program. Version 2.0. Agriculture and Agri‐Food 54Canada. 27 pp. http://www.cleanplants.ca/Page.asp?PageID=924&ContentID=8
Griesbach, J. A., J. L. Parks, G. A. Chjastagner, N. J. Grinuwald and J. Aguirre. 2011. Safe
production of ille, Oregon. 96 pp.
procurement and production manual: a systems approach for thehealthy nursery stock. Oregon Association of Nurseries. Wilsonvhttp://oan.org/associations/4440/files/pdf/SafeProduction.pdf
USDA APHIS PPQ. 2008. U. S. ‐ Canadian Greenhouse Certification Program. United States
Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Riverdale, Maryland. 111 pp. http://www.aphis.usda.gov/plant_health/acns/downloads/USNCP‐Standards.pdf
USDA APHIS PPQ. 2012. U. S. ‐ Canadian Greenhouse Certification Program. United States
Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine, Riverdale, Maryland. 14 pp.
use.pdfhttp://www.aphis.usda.gov/plant_health/acns/downloads/canadian_greenho MacDonald, D.J. 1996. HACCP and pest control. pp. 87‐90. In: K.B. Wildey (editor).
Proceedings of the Second International Conference on Urban Pests. Edinburgh, Scotland. http://www.icup.org.uk/reports%5CICUP711.pdf
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Attachment 7 9
Framework for Systems Approach to Nursery Certification Parke, J. 2010. A systems approach for IPM: critical control points.
http://www.cals.ncsu.edu/plantpath/activities/societies/ornamental/2010_presentations/Parke_Systems_approach.pdf
Parke , J. 2011. A systems approach to pest management. Digger Farwest Edition: 157‐160.
ttp://cropandsoil.oregonstate.edu/sites/default/files/people/parke/parke_digger_ahug2011_systems_approaches.pdf
Parke, J., and N. Gumwald. 2012. A systems approach for management of pests and pathogens of nursery crops. Plant Disease. (accepted for publication:
6‐FEhttp://apsjournals.apsnet.org/doi/abs/10.1094/PDIS‐11‐11‐098 Anonymous. 2008. Voluntary Industry Best Management Practices for Phytophthora
ramorum Introduction or Establishment in Nursery Operations ‐ Version 1.0. Horticultural Research Institute. Research affiliate of the American Nursery & Landscape Association. Washington, D.C. 18 pp. http://www.hriresearch.org/docs/Publications/HRI%20Publications/VoluntaryIndustryBestManagementPracticesPramorumweb1.pdf
Mizell, R. F., III and D. E. Short. 2012. Integrated Pest Management in the Commercial
Ornamental Nursery. University of Florida, Institute of Food and Agricultural Sciences. ENY‐336. 8 pp. https://edis.ifas.ufl.edu/pdffiles/IG/IG14400.pdf
Chappell, M., J. Williams‐Woodward, A. V. LeBude, A. Fulcher, S. White, S. Frank, and J. Neal.
2011. Top 10 nursery production integrated pest management practices in the Southeast. University of Georgia, Cooperative Extension. Circular 1008. 6 pp. http://www.caes.uga.edu/applications/publications/files/pdf/C%201008_1.PDF
Masiuk, M. 2002. Euonymus scale. Penn State University, Cooperative Extension. Woody
ornamental IPM. 2 pp. http://woodypests.cas.psu.edu/FactSheets/InsectFactSheets/pdf/EuonymusScale.pdf
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Attachment 8
Form # BWB 4/5/2012 Page 1
Atta
State Department of Agriculture (Letterhead) Street address City, State, Zip
Phone # Fax #
Boxwood Blight Compliance Agreement for Production Nurseries
Agreement number:
Business Name and Address: Locations(s):
Email:
Regulated Articles: Applicable State Quarantine(s) or regulations and authority (if applicable): Introduction: <name of nursery> has been inspected by <State Department of Agriculture> on <insert date> and found to be apparently free from Boxwood Blight. The <State Department of Agriculture> hereby approves <name of nursery> as a participant in the Boxwood Blight Cleanliness Program.
Boxwood Blight is caused by the fungus Cylindrocladium pseudonaviculatum (syn. C. buxicola). Buxus spp., Sarcococca spp. and Pachysandra terminalis are known hosts of Boxwood Blight. The participant agrees to grow species and cultivars of Boxwood Blight host plants according to best management practices designed to prevent the introduction and minimize the risk of spreading Boxwood Blight. This agreement does not preclude the inspection, sampling, and testing of plants by the destination State Department of Agriculture or similar authority and rejection as a result of any positive finds.
To meet the requirements of the Boxwood Blight Cleanliness Program, the participant agrees to the following:
Insert State Seal
(Compliance Agreement Template)
44
Attachment 8
Form # BWB 4/5/2012 Page 2
A. EXCLUSION OF THE PATHOGEN
1. Utilize suppliers or nurseries that have been officially inspected by the <State Department of Agriculture>and found to be apparently free from boxwood blight or hold a “Boxwood Blight Cleanliness Program compliance agreement”.
2. Inspect incoming host plants and/or cuttings at the time of delivery. If the host material is symptomatic, contact the <State Department of Agriculture> immediately.
3. Newly received host plants or rooted cuttings shall be isolated by a minimum of 3 meters (approximately 10 feet), by a physical barrier, or by another isolation method approved by the <State Department of Agriculture> from existing host plants in the nursery for at least 30 days.
a. Keep newly received host plants obtained from different vendors separated. b. The isolation area will have a surface, such as concrete or landscape fabric, that can
be cleaned of plant debris. All plant debris shall be removed on a weekly basis. c. No fungicides active against Cylindrocladium sp. shall be applied during the
isolation/holding period. d. The isolation area for incoming host plants must be positioned to prevent water run-
off into potting media and other host production areas. 4. Returns of host plants shall only be accepted into the isolation area and treated as newly
received host plants (see 3 above). Do not allow returns that have been comingled with host plants from another source into the nursery.
5. Unload incoming vehicles delivering host plant material into the isolation area, or if a common loading dock must be used, clean up and proper disposal shall occur after unloading (see C1). Vehicles for pick-up must be free from host plants and debris before entering the host plant production area.
B. WATER MANAGEMENT 1. Avoid overhead watering and conduct watering so as to allow leaves of host plants to dry
before nightfall. 2. Monitor for host plant debris in water run-off. Minimize water run-off such that it does not
run from one host plant production area into another. 3. Minimize standing water in host plant blocks.
C. SANITATION
1. Host plant production areas shall be inspected regularly for the accumulation of host plant debris. Minimize host plant debris by regular cleaning of the substrate and pot surfaces. Host plants or host plant debris shall not be used in compost.
2. Sanitize tools and equipment between blocks/lots of host plant material with an effective disinfectant such as quaternary ammonium solution (prepared and maintained at labeled
45
Attachment 8
Form # BWB 4/5/2012 Page 3
rates) or 5% sodium hypochlorite solution (commercial bleach with a minimum of 5.25% NaOCl).
3. After every crop production cycle, remove all crop debris and disinfect propagation mist beds, cutting benches, machines, and tools, using an appropriately labeled disinfectant such as quaternary ammonium solution (prepared and maintained at labeled rates) or 5% sodium hypochlorite solution (commercial bleach with a minimum of 5.25% NaOCl).
4. Use new, sanitized or pots/flats that have been thoroughly cleaned of soil and plant debris for host plant production. Do not reuse potting mix previously used in host plant production unless the used potting media has been sterilized.
D. INSPECTION 1. Inspect all host plants in the isolation area on a weekly basis and other host plants monthly
throughout the growing season by trained personnel. a. If boxwood blight symptoms are detected they shall be reported immediately to the
<State Department of Agriculture> to have the disease identified. b. No symptomatic host plants shall be sold until they have been examined and cleared
by the < State Department of Agriculture>. 2. The nursery shall allow the <State Department of Agriculture> access to conduct inspections
and, if necessary, collect samples to test for the presence of Boxwood Blight.
E. TRAINING 1. The participant shall educate and train appropriate personnel on the following:
a. Recognizing basic signs and symptoms of Boxwood Blight. b. Proper sanitation practices to meet the intent of this compliance agreement, including
training on worker safety. c. The stipulations of the Boxwood Blight Cleanliness Program compliance agreement.
2. Approved training materials may be obtained from the ANLA Boxwood Blight website, National Plant Board website or from the <State Department of Agriculture>.
F. RECORD KEEPING/TRACEABILITY
1. Records shall be made available upon request for verification. Records of host plants will be maintained for a minimum of 12 months for the following:
a. Incoming plants including quantity and sources b. Location of isolation area(s) for incoming host plants c. Shipping records (dates, quantity, plants shipped, destinations) d. Fungicide applications e. Inspection Records f. Personnel training (dates, attendees, subject matter, trainer)
2. The participant shall allow the <State Department of Agriculture> to audit all necessary records and protocols to ensure compliance with the above-mentioned requirements.
46
Attachment 8
Form # BWB 4/5/2012 Page 4
Interviews of employees may also be conducted to ensure compliance with training requirements.
This Agreement becomes effective when signed and will remain in effect for one year unless rescinded for non-compliance, but may be revised as necessary. In the event of the detection of Boxwood Blight at this location, this agreement shall be voided or suspended until remedial action can be taken to the satisfaction of the <State Department of Agriculture>.
The <State Department of Agriculture> shall provide an official written statement that attests to the following: “The nursery has been inspected and found to be apparently free of Boxwood Blight, Cylindrocladium pseudonaviculatum. The responsible party has agreed to the stipulations of a compliance agreement designed to prevent the introduction and minimize the risk of spreading Boxwood Blight.”
I, ______________________the undersigned, agree to handle, pack, process, and move host plants of boxwood blight in accordance with all applicable best management practices, nursery laws and regulations; use all permits and certificates in accordance with instructions; maintain and offer for inspection such records as may be required; and abide by the above listed stipulations. The affixing of the signatures below will validate this agreement.
Name (Please Print) Date
Signature Title
State Government Official (Print) Agreement Number
Signature Date
Effective Date Expiration Date
47
Attachment 9
Form # BGS 8/22/2012 Draft Page 1
State Department of Agriculture (Letterhead) Street address City, State, Zip
Phone # Fax #
Brown Garden Snail Compliance Agreement for Snail Free Production Nurseries
Agreement number:
Business Name and Address: Locations(s):
Email:
Regulated Articles: Applicable State Quarantine(s) or regulations and authority (if applicable): Introduction: The above nursery enters into this compliance agreement with the <State Department of Agriculture> in order to qualify plant material as being free of phytophagous snails* for shipment to Canada and states with snail* regulations. <name of nursery> has been inspected by <State Department of Agriculture> on <insert date> and found to be apparently free from Brown Garden Snail. The <State Department of Agriculture> hereby approves <name of nursery> as a participant in the Brown Garden Snail Compliance Agreement.
Thirteen states (Alabama, Arkansas, Florida, Louisiana, Mississippi, North Carolina, Oregon, South Carolina, Tennessee, Texas, Virginia, Washington, and West Virginia) and Canada currently quarantine the European Brown Garden Snail. Some states regulate ornamentals, nursery stock, or other plants. Other states also regulate soil, sand, peat, gravel or any article, which may move snails. This agreement
Insert State Seal
(Compliance Agreement Template)
48
Attachment 9
Form # BGS 8/22/2012 Draft Page 2
does not preclude the inspection, sampling, and testing of plants by the destination State Department of Agriculture or similar authority and rejection as a result of any positive finds.
To meet the requirements of the Brown Garden Snail Compliance Agreement, the participant agrees to the following: *For Canada and the states of Arkansas, Alabama, Mississippi, Texas, Tennessee, and Virginia "snail" as used in this agreement means European Brown Garden snail (Helix aspersa = Cryptomphalus aspersa = Cornu aspersum). For Florida, Idaho, Louisiana,North Carolina, Oregon, South Carolina, and West Virginia, "snail" means Helix spp., Achatina spp., Theba pisana, Megalobulimus oblongus, and any other non-native phytophagous snails of quarantine significance A. EXCLUSION OF THE PEST
1. The nursery must have an approved ongoing snail exclusion program. The program shall include some or all of the following:
a. Maintenance of nursery production boundaries to prevent the entry of snails from adjacent properties. b. Maintenance of a quarantine/treatment area for shipments imported from any nursery not certified
as snail-free. c. Regular inspection of incoming nursery stock, including trucks for the presence of snails. Trucks
found infested or containing debris shall be cleaned and handled in a manner to prevent contamination of the nursery.
d. Bulk regulated articles, such as potting soil, compost, and/or hardgoods stored outside will be safeguarded in an approved manner. B. SANITATION
1. Debris shall be removed from the containers at the time they are removed from the growing area or holding area prior to shipment.
2. Maintain regulated articles in areas where they are kept free of weeds, debris or other materials which are good habitats for and may harbor brown garden snail.
C. INSPECTION
1. The nursery must have an approved ongoing snail detection program such as visual inspection, and baiting.
2.The nursery shall allow the <State Department of Agriculture> access to conduct inspections and, if necessary, collect samples to test for the presence of Brown Garden Snail.
3. A minimum of two inspections for snails will be conducted each year by <State Department of Agriculture>
D. TRAINING
1. The participant shall educate and train appropriate personnel on the following: a. Recognizing basic signs and symptoms of Brown Garden Snail. b. Proper sanitation practices to meet the intent of this compliance agreement, including
training on worker safety. c. The stipulations of the Brown Garden Snail Compliance agreement.
49
Attachment 9
Form # BGS 8/22/2012 Draft Page 3
E. RECORD KEEPING 1. Records shall be made available upon request for verification. Records of incoming plant
material will be maintained for a minimum of 12 months for the following: a. Incoming plant material including quantity and sources b. Location of isolation/quarantine area(s) for incoming plant material, if applicable c. Shipping records (dates, quantity, plants shipped, destinations) d. Pesticide applications e. Inspection Records f. Personnel training (dates, attendees, subject matter, trainer)
2. The participant shall allow the <State Department of Agriculture> to audit all necessary records and protocols to ensure compliance with the above-mentioned requirements. Interviews of employees may also be conducted to ensure compliance with training requirements.
50
Attachment 9
Form # BGS 8/22/2012 Draft Page 4
This Agreement becomes effective when signed and will remain in effect for one year unless rescinded for non-compliance, but may be revised as necessary. In the event of the detection of Brown Garden Snail at this location, this agreement shall be voided or suspended until remedial action can be taken to the satisfaction of the <State Department of Agriculture>.
The <State Department of Agriculture> shall provide an official written statement that attests to the following: “The nursery has been inspected and found to be apparently free of Brown Garden Snail, Insert scientific name. The responsible party has agreed to the stipulations of a compliance agreement designed to prevent the introduction and minimize the risk of spreading Brown Garden Snail.”
I, ______________________the undersigned, agree to handle, pack, process, and move plants Brown Garden Snail in accordance with all applicable best management practices, nursery laws and regulations; use all permits and certificates in accordance with instructions; maintain and offer for inspection such records as may be required; and abide by the above listed stipulations. The affixing of the signatures below will validate this agreement.
Name (Please Print) Date
Signature Title
State Government Official (Print) Agreement Number
Signature Date
Effective Date Expiration Date
Review language in green. Additional language/definition needed in red.
51
Attachment 10 Comments and thoughts on Quad Cities Interstate Inspection Central Chapter – Horticultural Inspection Society (HIS) June 12 and 13, 2012 Approximately 30 people attended from 9 states. This included John Rochelle and Mark Taylor from S-HIS and E- HIS respectively and 11 inspectors from the State of Illinois. We visited 4 nursery operations (3 growers and one retail garden center) Susan Ehlenbeck and the Central HIS leadership did a terrific job of presenting the SANC ppt and examples of CCP and BMP’s (P. ramorum, boxwood, OAN etc.) at the introductory session. I provided a bit of background and history of the SANC initiative. At each location the inspectors worked through the fields in groups in a traditional interstate inspection fashion, comparing finds and thoughts on pests. Informally we discussed the critical control points of the operation and best management practices that might be considered in a potential discussion with the management. As we initiated the inspection, Susan discussed the SANC initiative with the nursery owner or manager in a general fashion. She talked about the potential advantages of SANC for the operator and inspectors, i.e. better managing risk, making treatments more effective, better utilizing staff and ultimately producing a better quality of stock. Toward the end of the inspection Susan and I and a couple inspectors spent more time with the manager talking more specifically about CCP’s such as procurement, sanitation, water issues, staff training, pruning equipment, recordkeeping, pesticide treatment, material tracking. These discussions were positive and in each case there was an indication that the manager/ owner was conducting management practices that addressed many of the CCP’s. At all the sites where we stopped the managers had been in business for some time and had a good amount of experience to draw on in terms of management practices. Again, the inspection planners and especially Susan did a terrific job of choosing a variable set of sites, challenging the inspectors and having great discussions with management. This Interstate inspection project was a tremendous success from my perspective and I believe inspectors left with some initial information on SANC and a better sense about how their counterparts other state deal with pest issues. We had an opportunity (actually about a 2.5 hour discussion after dinner on Tuesday evening) to talk about what inspectors had seen that day and their thoughts about SANC. Here are a few examples of what was said:
- Really liked the information sharing of the interstate inspection - SANC seems like a good concept but I think it favors the large operators over the
small - SANC may be good for the exporting nurseries, but I don’t think it will be adopted by
the intrastate nurseries or small operators - We are going to need incentives for the nurseries to adopt - We need a lot more training and support materials to have that good critical point
discussion with managers and owners
52
Attachment 10
- I like the proactive approach of SANC but I think only a few will benefit - Bailey’s in MN are already doing a lot of this - Uncertain about the level of support for inspectors and scouts – this process may
require more staff time. - The SANC systems needs to be adopted to our paperless systems – not really sure
what this means - SANC program will conflict with the traditional inspection programs - Nurseries are hungry for information and support, but Extension is not available to
them. - Good concept but I don’t think it will work. - It will require a change on the part of our main office - Love the interstate inspection concept – need a lot more of them - Really like the concept of SANC, but we need a lot more information and support - Good to see us move to more industry involvement and state oversight - Would like to see more organization in the interstate inspection process. - Concerns expressed about the time for growers to adopt SANC principles and still
get their other production activities done - Concern that SANC will drive the price of nursery stock up and put the little guy out
of business – I didn’t follow this reasoning, but the concern is out there - There will definitely be benefit to the small grower if he is looking to manage risk - Consumers don’t care about quality they just want something cheap that looks good. - Educational component will be important i.e. Check lists and more general SANC
guidelines for growers needed - Interstate inspection is a great learning process – - Everything is dependent on the bottom line. Can growers afford to implement it? - The industry it in serous economic trouble and this may not be the time implement
SANC changes My general reaction to this session:
- The interstate inspections certainly meet our goal of promoting inspection harmony and regulatory education
- Inspection staff and nursery managers need more training materials and background information for their own benefit and to have that serious conversation with managers and owners
- We need a uniform set of CCP’s (a general set) to assist inspectors and growers – what we have is good, but inspectors are looking at two or three of four set of the CCP’s and it gets confusing - (KISS)
- Inspectors really like to look at nursery stock and write reports. Getting them to have that good discussion about SANC and how it will benefit the grower with take some training and experience. Nursery program managers and SPROs will have to push this component
- We clearly were talking to a small percentage of the total state inspection force. We have to find a way to get to all of them. Probably through SPRO’s and nursery managers.
- Inspectors with good communication skills and positive attitudes will make the process work
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- The success of SANC will be based on working relationships between inspectors and growers.
- The SANC components work well in nursery production operations, but many of the CCP’s will also fit for garden centers, i.e. procurement, sanitation, returned materials, treatment records etc.
- All in all this was terrific two days with a terrific group of people. Hats off to the organizers and especially Susan. She put in two long days on Tuesday and Wednesday and I’m sure a lot of prep time. She expressed her appreciation to NPB and SANC for the funding to put this session together.
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Questions for SANC Training Committee: Part 2 (Questions stemming from Part 1 responses)
1. What is your long term vision for this training? 2. What do you deem success to look like for the training? i.e. for the course? For the inspector? For
the industry member? 3. How do you anticipate its maintenance (including revisions)? How and who will manage the
training? 4. Proposed delivery media: Online training course or Webinar
• Modules to be constructed are finalized and realized as a result of the Task Analysis. We have started this process briefly with the first questionnaire. We will need all or some members of the core group, training group and any other field staff, SMEs or industry to attend. (TBD)
• Format and delivery will be dictated by space, numbers of students, timespan allotted, frequency and duration of need of training required.
• Questions to consider: o Where will this be housed? i.e. NPB website? o What are the technology constraints? IE what are the minimum operating computer
hardware and software requirements? o How do you intend to promote this training? Is it mandatory or voluntary? Ex.
Mandatory for Nursery inspectors and program managers? Voluntary for Industry? o Are you looking for a qualified cadre of inspectors to be able to perform these
functions? Or is it a new performance requirement for every nursery inspectors and program manager across the States?
o Are there aspects of the training that you might not want to share with other people on a website? i.e. Does it need to be secure? Or can it be available to the public?
o Do you need to record or track who takes the training? IE is Certification required? Is a pass/fail record required?
o What is the degree of competency required for completion? o Is this expected to be a one-time training requirement or is recertification or
refresher training required? o What are the inspector / industry attitudes or perceptions towards training? i.e.
positive, negative 5. Desired course length: Four hours (Maximum) Could be broken down into 4 - 1 hour courses
a. Is this set in stone no more than 4 hours duration? Is there a justification for the number? Or a guess? Often we go through the task analysis and determine what is required for inspectors to be able to be successful, then the timeframe and length determines itself. Keep in mind that if deemed to have more content requirements than this timeframe based on requirements for qualification, the duration of time and the content required can be adjusted, however content and delivery may have to be changed.
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6. What are how does the training facilitate meeting SANC’s business goal? (If there were no training components and SANC moves forward, is there an impact? Is there a difference? What is the expectation that training will accomplish in relation to SANC’s business goal?) “SANC goal is to develop, promote and implement a risk based nursery certification system for the states utilizing existing state authorities and programs to enhance uniformity, increase efficiency and reduce pest distribution threats.”
7. What major job outcomes are involved? These are excellent in terms of knowledge based information. We’d like you to start thinking about performance based, task oriented steps. Start thinking of… as a nursery inspector involved in the SANC program. The expectation is that an Inspector. Program Manager, Nursery manager will be able to….
a. Departments of Agriculture Nursery Inspectors • Understand SANC concepts,
• What do you mean by understanding? Is this the same as ability to explain or is this something different?
• Ability to explain SANC concepts, • List the SANC concepts. What are they specifically? Is this captured in a
document? • Ability to verify compliance with SANC agreements between nurseries and the state
• What are the steps for verifying compliance? What does this entail? • Is there an SOP, manual, plan document that states these steps? • Is this the same as auditing? • An inspector that will be verifying? Is this audit training? • Is there a certification requirement for this? Therefore is Audit training,
certification or a level of qualification required to be able to perform this function?
• Provide certification • What does this entail? What does this mean? • What happens in certification? • Are there documents, SOPs associated with this? Are there other
requirements? • Should this be included: Identify and apply Critical Control Points (CCP’s) and Best
Management Practices. (BMP’s) b. Department of Agriculture Program Managers
• Understand SANC concepts • Ability to explain SANC concepts • Develop compliance agreements
• What does this entail? • What are the steps involved in developing compliance agreements that a
Program manager would be required to do? • Is there a SOP, procedure, plan, document or manual for this?
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• Should this be included: Identify and apply Critical Control Points (CCP’s) and Best Management Practices. (BMP’s)
c. Nursery Manager/owners • Understand SANC concepts • Does this need to be added? Ability to explain SANC concepts • Identify and apply Critical Control Points (CCP’s) and Best Management Practices.
(BMP’s) • What are the CCPs and BMPs? • Is this documented somewhere? What are SANC’s CCPs, BMPs?
• Implement systems approach program at nursery • Is there an SOP, procedure, document, manual, or plan that can be provided
for this? • Participate in compliance agreement audits
This seems more like a role, that an outcome or performance task. • What does this mean? What does it entail? • Does this mean they are an auditee? Or are there more requirements
involved. • What are the steps required for them to participate in a CA audit? What
needs to be trained to perform this as a task? 8. What is the measure of job performance success?
A. Regulatory Officials - Using SANC concepts, certifying nursery stock free of injurious pests and diseases of concern. Might need a rethink? I think that your statement for Regulatory Officially is the measure of success of SANC, not the individual measure of success for the specific Regulatory official.
• What is the specific measure of success for an individual regulatory officer? IE accurately complete compliance verification? Accurately create a compliance agreement?
• For example, Does success for a regulatory official mean they are successfully performing the verification function?
• Are there other aspects of the task that indicate success (completion)? B. Nursery Owners and Managers – Understand and utilize SANC, concepts, including development of an operations manual, and identification of CCPs and BMPs
• For example, Does this mean that upon completion of training, the measure of job performance that indicates the employee is successful at accomplishing the task, they can develop an operations manual?
• Does this mean that the nursery owners and managers can identify CCPs and BMPs or implement CCPs and BMPs?
• Does this mean that the nursery is certified and maintains participation in the SANC program?
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9. Project constraints and parameters: (Explain or elaborate on answer) a. Important Deadlines or target dates: December 2012 b. Commitments that will seriously affect the time to conduct analysis: SANC training
subcommittee members have full-time jobs already. Sometimes difficult to find time to devote to development of SANC training course.
• Know that as we move through the ADDIE process, SME’s and Contacts must be able to devote time to this project in order to keep development moving forward. The turnaround time on documents, review of training material and content etc., will be based on the speed at which each of the parties can respond.
• FYI: Many people new to the process underestimate how much time is involved and as a result impacts the turnaround time and completion date.
c. Must live with times or targets Grant funding deadline. • What is tied into grant funding for December 2012 deadline? • PDC’s development costs for this project should be nil. What costs do you anticipate on
your end? • Any costs PDC can identify thus far are related to web or server space needed to house
the training in the future or host webinars if necessary, software needed to host the material, or travel associated with a Task Analysis to the PDC and any other meetings deemed necessary.
d. Regulatory or policy constraints relevant to the project: Regulatory officials must have laws that allow participation in SANC programs.
• Do we need to address regulatory authorities in the training? If so, specifically what are they?
• Are all necessary policies that are required for the program in place in order to develop training?
e. Budgetary aspects of the project. Grant dollars available to cover costs of development of training program
10. What is the formal authority that enables the job/job title to perform this function? State plant laws What is this law? Is there a specific one law or are there 50 laws? Or do we have the assumption that the authority fits under the existing regulations that enable officer to be able to perform inspections?
11. What data sources are to be used in the development of this project/training material (i.e. Regulations, compliance agreements, policy etc.) Compliance agreement templates developed by SANC subcommittee; State Plant laws; CPHST developed CCP’s & BMPS; NPB Model Nursery Law
Please provide us with the specific documents listed above that are required to: • Perform the job functions. • Policies that give authority to do the job or guide the program
12. Who are the available contacts for the following roles for the duration of this project? List information, job title and their contact details.
This is a great list of resources, however please list specific name(s) and contact(s) that the PDC can contact? The contacts need to be aware that they are listed as a PDC contact or this project and can answer questions related to this training (ex. CPHST).
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a. Subject Matter Expert(s) • SANC Compliance Agreement Subcommittee • SANC Training Subcommittee • SANC Outreach & Education Subcommittee • CPHST - who specifically • Others (?)
b. Technical Authorit(ies) – are these the same as above?
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GROWING BETTER: A Systems Approach to Nursery Certification (SANC)
The NPB welcomes the input of all stakeholders as we review our current processes and search for new risk-based approaches that better meet the needs of the industry and regulatory communities.
Overview Certification of nursery stock for intrastate, interstate, and international shipping has become increasingly challenging for industry and regulatory agencies due to higher shipping volumes, increasing regulated pest pressure, more rigorous shipping requirements, and dwindling resources. The National Plant Board (NPB) is looking into the feasibility of incorporating a Systems Approach to Nursery Stock Certification (SANC) to enhance existing programs.
Concepts and Approach The NPB SANC Workgroup strongly believes that current state baseline nursery certification and quarantine programs are sound. We also recognize the opportunity to reduce pest risk and improve assurances by building on and improving existing systems. This can be accomplished by:
• Promoting a harmonized risk-based systems approach to enhance nursery certification processes while recognizing varying states’ authorities and industry needs.
• Developing education and outreach materials for both regulatory agencies and industry that describe the components and benefits of a risk-based systems approach.
• Providing uniform training materials and inspection templates to help state inspectors identify critical control points (CCPs) in nursery production, and best management practices (BMPs) to address them.
• Updating and revising the model nursery law. • Developing examples of compliance agreements and other systems approach components. • Transitioning the risk-based approach to a voluntary system that allows for participating nurseries to
ship interstate and to Canada without onerous load by load shipping point inspections, but still meet specific quarantine requirements, blending with existing certification programs such as the US Nursery Certification Program and Japanese Beetle Harmonization Program where appropriate.
Benefits We envision transitioning to a voluntary risk-based systems approach that focuses resources to more effectively manage risk. One size doesn’t fit all and there may be up-front costs, but there also will be overall process improvement and long-term benefits, including reduction in pest risk, cost efficiencies, more direct interaction between nursery staff and regulators, increased uniformity among state programs, and a tiered approach to certification that supports the expertise and economic means of individual producers and the market.
FACT SHEET
Goal Develop, promote and implement a risk based nursery certification system utilizing existing state authorities and programs to enhance uniformity, increase efficiency and reduce pest distribution threats.
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…… Growing Better with SANC
SANC: Systems Approach to Nursery Certification “Promoting a harmonized, risk-based systems approach to nursery certification”
SANC Initiative Snapshots: HIS Interstate Inspections! On June 12-13, 2012, 27 inspectors from 9 states gathered in the Quad Cities of Illinois and Iowa to participate in an interstate inspection sponsored by the Central Chapter of the Horticultural Inspection Society (CHIS) with support from the SANC leadership team. Susan Ehlenbeck, Missouri Dept. of Agriculture and CHIS – SANC liaison provided inspectors with a background in SANC, shared SANC outreach materials and introduced the concept of looking at nurseries from the standpoint of critical control points and best management practices to reduce pest risk. An evening session after the first day provided an opportunity for inspectors to critique the inspection/learning process and SANC strategy. For a meeting summary, and much more information about SANC, visit: http://nationalplantboard.org/committee/nonnpb.html#sanc Upcoming interstate inspection opportunities in the other HIS chapters:
Southern Chapter: June 25-27, 2012 Contact John Rochelle ([email protected])
Eastern Chapter: Being planned for October, New York Contact Ethan Angell ([email protected])
Western Chapter: SANC training session during their annual meeting, Sacramento CA, October 2-4, 2012 Contact Beth Slate ([email protected])
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