Proposed Commerce - Dan's Thoughts and Comments

-- Posted on behalf of Dan Hilburn

ODA is often asked to comment on permit applications and proposed import/export ideas. Typically I farm the requests out to staff members for analysis. When their reports come back, I combine their research on the risk with my reading of Oregon’s regulations, and submit comments. Occasionally the risk level is obvious and the laws clear; more often that not, there are grey areas.

This week we were asked to comment on four issues:

1. Importation of onion leaves for consumption from Hawaii
2. Commercial sales of a giant African millipede as a pet
3. Importation of raspberries and blackberries for consumption from Ecuador
4. Ash logs from the emerald ash borer-infested areas in the central US transiting Oregon for export to Asia. 

 My thoughts and comments follow; the thoughts are in italics.

1.) Onion leaves. 

Dan thinks, "We’re importing onion leaves? You’ve got to be kidding. Oregon grows tons of onions and we throw the tops away. I see that USDA has done a 39-page pathway risk assessment and concluded that only three potential pests have a medium or high likelihood of introduction via this pathway! Of course, none of the three are covered by Oregon quarantines because who would have imagined anyone would want to import onion leaves?"

Oregon grows many tons of onions and discards the tops.
Oregon may import onion leaves from Hawaii. 

Comments: 

None yet. There are no Oregon laws that apply. The pathway risk assessment is thorough and USDA will use it to choose appropriate phytosanitary measures to mitigate the pest risk. We’ll comment on the final proposal if we think they’ve missed something.

2.) African millipede pet. 

Dan thinks, "Another giant African millipede? What’s wrong with the five species we’ve already determined to be low risk put on our approved list? According to staff the scientific name given is wrong, though widely used in the pet trade. There is very little known about this species except that it comes from central Africa and it eats lettuce and cucumbers in captivity. Oh, it is also readily available on the Internet."

Comments:
“Oregon Department of Agriculture staff have reviewed this application and draft permit. The scientific name should be Spiropoeus fischeri [instead of Mardonius parilis]. We have no concerns. [Except the general unease that comes from knowing someone, somewhere will release them and we are just guessing as to the risk. Note to self: add this species to the approved list. Cross fingers.]

3.) Berries from Ecuador. 

Dan thinks, "I know there is demand for fresh fruit year-round. I like fresh berries on my cereal and now that they are available all year at our grocery store, I’ve gotten spoiled. We’re already importing lots of fresh fruit from Chile during our winter (their summer). 

Comments: 

None yet, I haven’t heard back from staff. [The fact that Oregon grows blackberries and raspberries increases the risk. On the other hand, off-season introductions of fresh fruit that are eaten soon after importation are relatively low risk.]

4.) Ash logs to Asia. 

Dan thinks, "It can’t be economical to ship ash logs half way around the world! Actually it probably is because of all the empty containers and light ships heading back to Asia. The pest risk for the receiving countries is low because emerald ash borer likely came from Eurasia. Of course we don’t have regulations because we’re preempted by the federal emerald ash borer quarantine and no one has ever proposed such an improbable scheme. The staff analysis indicates the risk is high. I’ll have to bluff."

Oregon may ship ash logs infected with emerald ash borer. 

So far, the pest is not found in the state. 

Comments:
“Thanks for asking for our thoughts on this proposal. We do have concerns. Here is our feedback:

1.) Oregon doesn’t have state regulations that would apply. On the other hand, Oregon does have native ash trees and ash is an important street tree. Keeping EAB out of the state is a priority.

2.) The risk from the proposed actions as described would be acceptable only during the months of December through February. During the winter we’d expect the logs to arrive cold and the weather would be cool enough here to make EAB emergence unlikely. If the shipments were restricted to the winter months, we’d be comfortable with the proposed protocol.

3.) For non-winter shipments, we’d like to see additional safeguards. Here are some possibilities that would give us more comfort:

• Shipping in refrigerated containers.
• Fumigation at origin.
• Debarking before inspection, and inspections of individual logs rather than piles of logs.
• Restricting origin of logs to outside the EAB-quarantined area, and setting a maximum time logs could be in transit through Oregon.

Thank you for consulting us. Please keep us informed of any new developments.”

In this business, we keep our fingers crossed a lot -- and put out lots of insect traps to detect what gets missed at the borders. Living in a global economy makes for grey areas, and grey hairs. I always ask my barber to cut the grey ones, but she misses more and more!