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USDA’s Operational Experience in the Growing Use of Irradiation as a Plant Quarantine Treatment USDA’s Operational Experience in the Growing Use of Irradiation as a Plant Quarantine Treatment Alan Green Executive Director USDA, APHIS, PPQ Riverdale, MD, USA

Irradiation as a Commodity Treatment International Standard: l Endorsed by International Standards: – International Irradiation as a Commodity Treatment International Standard: l Endorsed by International Standards: – International Plant Protection Convention (ISPM 18) USDA Regulations: l October 23, 2002: Overall requirements for irradiation as a quarantine treatment (Closely followed ISPM 18) l January 27, 2006: Establishes generic doses for insects and specifically for fruit flies

USDA Rule and ISPM 18 Require: • • • Establish dose to neutralize pest USDA Rule and ISPM 18 Require: • • • Establish dose to neutralize pest Ensure minimum dose is delivered Establish safeguards to identify treated product and prevent infestation

Why Irradiation was different l Manages a very wide range of pests l Objective Why Irradiation was different l Manages a very wide range of pests l Objective of treatment is not death of pest l Concerns about consumer acceptance

Regulation January 27, 2006 l Establishes a generic minimum dose of 400 Gray for Regulation January 27, 2006 l Establishes a generic minimum dose of 400 Gray for all insects (other than Lepidoptera adult and pupae)

New Regulation January 27, 2006 l Establishes a generic minimum dose of 150 gray New Regulation January 27, 2006 l Establishes a generic minimum dose of 150 gray for all fruit flies of the Family Tephritidae (Ceratitis, Bactrocera, Anastrepha, Rhagoletis, etc. )

Regulation January 27, 2006 Does NOT include: Mites • Mollusks • Nematodes • Plant Regulation January 27, 2006 Does NOT include: Mites • Mollusks • Nematodes • Plant pathogens •

Other Agreements Required by USDA Rule • Irradiation Framework Equivalency Work Plan • • Other Agreements Required by USDA Rule • Irradiation Framework Equivalency Work Plan • • Fundamental requirements to allow irradiation Provides for reciprocal trade in irradiated products

Other Agreements Required by USDA Rule • Operational (preclearance) work plan • • • Other Agreements Required by USDA Rule • Operational (preclearance) work plan • • • Field pest risk mitigations (good agricultural practices) Preclearance inspection procedures Dosimetry systems Treatment verification process Post treatment safeguarding Product labeling

APHIS Irradiation Regulations 400 Gray treatment for the following: l March 12, 2007: Indian APHIS Irradiation Regulations 400 Gray treatment for the following: l March 12, 2007: Indian Mango l June 21, 2007: Litchi, Longan, Rambutan, Mangosteen, Mango, and Pineapple from Thailand l August 1, 2008: Dragonfruit from Vietnam l Proposed 2008: Guava from Mexico. Mango and citrus at 150 Gray

Current Programs l l Thailand (two facilities): Litchi, longon, rambutan, mangosteen, pineapple India (second Current Programs l l Thailand (two facilities): Litchi, longon, rambutan, mangosteen, pineapple India (second facility in 2009): Mango Vietnam (second facility in 2009): Dragon fruit. Litchi, longon, and rambutan in 2009 Mexico (second facility in 2009): Guava, mango, (citrus)

2007/2008 Shipping Seasons l l l India and Thailand have shipped successfully for two 2007/2008 Shipping Seasons l l l India and Thailand have shipped successfully for two season Fruit was successfully treated, transported, and sold No issues of consumer concerns Allowed imports of fruit, otherwise prohibited Excellent fruit quality

Obstacles and Challenges l l l Program oversight costs Research and Methods Development needs Obstacles and Challenges l l l Program oversight costs Research and Methods Development needs Involvement of National Plant Protection Organization Single export association In-country logistics Treatment verification

Delivery and Verification of Dose l Dose verification – – l Process configuration approval Delivery and Verification of Dose l Dose verification – – l Process configuration approval – l National Institute of Standards and Technology Facility dosimeters Dose mapping of configuration to receive treatment Treatment dosimetry – Irradiation Reporting and Accountability Database (IRADS)

Areas For Attention Cost of Program Increased costs of air freight l Logistics of Areas For Attention Cost of Program Increased costs of air freight l Logistics of treatment not completely planned l High level of USDA oversight l “Economy of scale” l – – Diversity of commodities Throughput

Research and Methods Development l l l Fruit/Variety tolerance Ideal stages of harvest ripeness Research and Methods Development l l l Fruit/Variety tolerance Ideal stages of harvest ripeness Storage and transportation temperature, humidity, and atmosphere conditions Maritime and overland transportation Generic doses for mites and classes of insects

Areas for Attention: USDA Preclearance Oversight l l Initially present for all treatments and Areas for Attention: USDA Preclearance Oversight l l Initially present for all treatments and inspections US Statute mandates full cost recovery Verification of all treatments Regulatory inspections at each facility (Thailand)

Areas for Attention: Operational Logistics l l l Orchards at great distance from irradiators Areas for Attention: Operational Logistics l l l Orchards at great distance from irradiators Centralize inspection stations serving multiple irradiators Changing of packaging required repeated dose mapping Good agricultural practices Facility engineering

Changes To Consider Reduce Oversight Costs l l Use of “Foreign Service Nationals” or Changes To Consider Reduce Oversight Costs l l Use of “Foreign Service Nationals” or national plant protection organization of exporting country Accredit local entities to perform dose mapping

Potential New Exports l Otherwise prohibited commodities – l Substitute irradiation for existing treatments Potential New Exports l Otherwise prohibited commodities – l Substitute irradiation for existing treatments – l l Tropical fruit Mexican citrus and mango Irradiators at US ports of embarkation or US-Mexico Border Potential US exports – – Stone fruit Pome fruit




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