Monday, October 17, 2011

Yin and Yang at Ports of Entry

There is always a pile of folders and papers on my desk. It is my active pile—the stuff that needs attention. Every morning I shuffle the pile and pick out the highest priority projects. Some stuff gets dealt with quickly, and some stays in the pile for a long time. Recently I had to chuckle when an Associated Press (AP) news release on invasive species slipping through our ports (quick action) surfaced back-to-back with a long-time-in-the pile federal register notice about Not Authorized Pending Pest Risk Analysis (NAPPRA). Yin and Yang—two sides of the invasive species coin. Let me explain.

Invasive species reach the United States in different ways. Some of them stow away in vessels, containers, and commodities (e.g., Asian gypsy moth, yellowstarthistle, and zebra mussels); others are brought in intentionally (e.g., Scotch broom, Asian carp, and gypsy moth). These pathways intersect at our airports, seaports, and land ports of entry. Inspectors at the ports are checking both pathways; they are looking for invasive hitchhikers, and they are verifying that intentionally imported plants and animals are allowable species. When they are inspecting live plants and animals for hitch hiking pests, they are doing both at the same time.

The gist of the AP story was that more invasive species have slipped through the ports in the years following 9/11 when inspectors started focusing more on preventing terrorism. Stopping thugs and drugs has became a higher priority than stopping bugs. According to the article, the number of introductions of crop-threatening pests spiked from eight in 1999 to 30 last year. Not good, but not surprising, because we only have enough inspectors to look at a tiny fraction of what we import. Thankfully, the next item in the pile contained better news.

NAPPRA is finally here; it stands for Not Authorized Pending Pest Risk Analysis. The US Department of Agriculture (USDA) is adopting important new regulations. Until recently, if someone wanted to bring in living plants, they could apply for an import permit—plants were enterable unless listed on the federal noxious weed list. It was a “prohibited list” approach—plants were presumed to be harmless unless they were known bad actors. NAPPRA changes that.

The USDA is putting 148 taxa of plants on the NAPPRA list. This indicates that these plants could became weeds or carry harmful pests, so they are not being approved pending a risk anyalsis. In effect, there will be three categories:

1.) prohibited (noxious weeds);
2.) enterable (history of safe introduction or having a low risk rating from a completed risk analysis); and
3.) not approved pending risk analysis (risk unknown, prohibited until analysis completed).

It makes sense to me. The only thing I don’t like about this idea is the way it is being implemented. Discussion of the need for NAPPRA started a decade ago, and it is just now seeing the light of day. Then instead of all new plants being automatically listed with NAPPRA, the USDA is going to post federal notices and solicit public comment every time they propose adding new taxa. The first list was open for comment for 60 days, and because of requests for more time, the USDA is planning to reopen the comment period for another 30 days! Ugh. Why does it have to be so slow and complicated? Simpler would be better.

In the battle to prevent harmful invasions, the rules of engagement change slowly. Hopefully, this slow but important step in the right direction will improve our success rate at excluding invasive species, and AP’s next story on invasive pest introductions won’t be so discouraging. My active pile is already too tall. . . .

Dan Hilburn

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