May 2011SC-7 Report
REPORT
Rome, Italy9-13 May 2011 / StandardsCommittee
Working Group (SC-7)
May 2011
Food and Agriculture Organization of the United Nations
International Plant Protection ConventionPage 1 of 26
May 2011SC-7 Report
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Table of Contents
1. Opening of the meeting
1.1 Welcome by the IPPC Secretariat
1.2 Election of the Rapporteur
1.3 Adoption of the Agenda
2. Administrative Matters
2.1 Documents List
2.2 Participants List
2.3 Local Information
3. Updates from the Standards Committee Meeting
4. Review of Draft ISPMs
4.1 Integrated measures approach for plants for planting in international trade (2005-002)
4.2 Systems approaches for pest risk management of fruit flies (2004-022)
4.3 Revision of ISPM 15 (Regulation of wood packaging material in international trade), specifically criteria for treatments for wood packaging material in international trade (2006-010)
5. Other business
6. Close of the meeting
Appendix 1 – Agenda
Appendix 2 – Documents List
Appendix 3 – Participants List
1. Opening of the meeting
1.1 Welcome by the IPPC Secretariat
The IPPC Standards Officeropened the meeting and welcomed the participants to the Standards Committee Working Group (SC-7) meeting. The group also welcomed the newest SC-7 member fromDenmark.
The Stewardsfor the draft ISPMs Integrated measures approach for plants for planting in international trade (2005-002) and Systems approaches for pest risk management of fruit flies (2004-022)were in attendance.The Steward for the draft ISPM Revision of ISPM 15 (Regulation of wood packaging material in international trade), specifically criteria for treatments for wood packaging material in international trade (2006-010)was not able to attend.
The SC-7 selectedMr Mike Holtzhausen, (South Africa) as Chairperson.
1.2 Election of the Rapporteur
The SC-7 requested Ms Stephanie Dubon (IPPC Secretariat) to take on the role of Rapporteur.
1.3 Adoption of the Agenda
The SC-7 adopted the agenda as presented in Appendix 1. The SC-7 reviewed the draft ISPMs in the order presented in the agenda.
2. Administrative Matters
2.1 Documents List
The Chair reviewed the documents and the SC-7 noted the documents list (Appendix 2).
2.2 Participants List
The Chair reviewed the documents and the SC-7 noted the participants list (Appendix 3).
2.3 Local Information
The Chair reviewed the documents and the SC-7 noted the local information document (Appendix 4).
3. Updates from the Standards Committee Meeting
There were no updates from the SC May 2011 meeting for the SC-7.
4. Review of Draft ISPMs
4.1 Integrated measures approach for plants for planting in international trade (2005-002)
The SC-7 reviewed the documents provided by the Steward[1]. The Steward noted that some comments (in particular Comment 1[2]) describedconcerns that the draft ISPM does not include all tasks outlined in the specification. The comment also statedthat half of the standard is related to pest risk analysis (PRA) and the other half is related toplaces of production (POP) while itwas deemed that it should only address the pest risk of plants for planting. The Steward did not agree with these opinions and requested guidance from the SC-7.
The SC-7 noted that the specification and draft ISPM had gone through three Expert Working groups (EWG), two SC meetings, and a previous SC-7 meeting andgroup noted that the SC May 2009 requested that risk factors be added and the SC May 2010 send the draft ISPM for member consultation (MC) in 2010 confirming that the EWGs and Steward had addressed all the tasks in the specification and all subsequent requests by the SC. The SC-7also noted that members that provide comments should provide more specific comments and further explanation, including guidance and proposed text changes. It wasconcluded that the SC-7would make the effort to finalize the draft ISPM after six years of drafting, instead of returning the draft.
The SC-7 discussed some options to address Comment 1 and other various general comments regarding the focus of the text and decidedto retain all the content of the sections and create some new annexes and appendixes and move some of this content into them in orderto make the draft ISPM flow better and be more focused.
The Steward agreed with the comment from the TPG regarding the personification of place of production, i.e. that a place of production was being represented as a person and therefore inserted a footnote into the Outline of requirements Producer hereafter refers to a producer of plants for planting at the place of production to address this issue and requested the Steward make appropriate changes accordingly.
The SC-7discussed whether to include the responsibilities of plant brokers in the country of export (Comment 825). The Steward was concerned that addingnew text may be problematic for members to accept. It was decided not to add additional text because, as stated in the IPPC, it is the responsibility of the NPPO of the exporting country to maintain phytosanitary security up to the point of export.
The role of the plant protection specialist (Comment 529) was discussed andit was noted that this issue was already sufficiently covered in Section 3.2.1.1, Place of production manual and therefore simplified the text.
The SC-7need for addingSection 4.6 Assistance with on-site inspection by the NPPO of the importing country(Comment 768)was discussed andit was noted that this is already covered in Section 5.2, Auditing and therefore there was no need to add a section on this.
The Steward noted that conflictingmember comments suggested to reorder the sections of the draft or to move some sections to an appendix. It was noted that if these sections were moved, the appendixes would have more information that the body of the text. The SC-7 members had different opinions on whethersome sections of text should be moved, but agreed that the sections on Pest risk factors should be moved to a new appendix.
With regards to the text on Place of production manual, the group found this an essential part but some SC-7 members wanted to keep it in the core text while others wanted to put it into a new annex. The SC-7tentatively decided to keep it in the main text and let the SC make the decision.
Detailed comments by sections of the draft ISPM
Title
The group agreed toremove approachfrom the title and throughout the draft text and explained that systems approach refers to phytosanitary measures whereas the current draft refers to actions that are not phytosanitary measures.
The SC-7 also recommends thatthe SC send the term systems approachand the concept of integrated measurestogether to the Technical Panel on the Glossary (TPG) for their consideration.
Scope
The SC-7 considered adding an environmental statement in the Scopebased on Comment 25andnoted thatas this is a draft standard it may need an environmental statement and decided to place a suggestion for such statement in the Background.
The group considered whether or not pollen should be listed as an exclusion to the draft ISPM and concluded that while pollen is included in the definition as part of a plant, pollen is not included in the definition of plants for planting and therefore should not be added as an exclusion. However, the SC-7 did add plants as pests to the exclusion in both the Scope and Outline of Requirements.
The SC-7 decided to change phytosanitary measuresback to integrated measures because that terminology is in the specification andalso made a global change of mitigatepest risk to manage pest risk.
The termparticular and phraseand places of productionwere deleted to keep the focus on plants for planting and noted this proposed text also addresses some concerns from Comment 1.
The text was modified to clarify that this ISPM coversplants for planting asa pathway (which then implicitly excludes plants as pests).
References
The SC-7 had no significant comments on this section.
Definitions
The SC-7 had no significant comments on this section.
Outline of requirements
The SC-7 decided to use the term producers instead of places of productiondue to personification issues: producer refers to a producer of plants for planting at the place of production.
The Steward will finalize this Section and will send the draft to the SC-7 for final review in order to have the text posted for the SC by 15 July 2011.
Background
The SC-7replaced the wordincreased withhigh because the pest risk is high, not increased; replaceddisease symptomswithsymptoms of infestationto use glossary terms; added nutrient imbalances because these can mask symptoms for diseases; deleted or antibiotic because antibiotics are covered under pesticides; included visual and beforenon-visual detectionmethods to address other visual instruments; and addedanenvironmental statement which addresses the risks to biodiversity and theenvironment. The SC-7 revised the statement to include plants collected from the wild that may be subject to endangered species regulations.
1 Basis for regulation
The SC-7 agreed to move Sections 1.1 to 1.4 into a new annex/appendix.
The SC-7expandednew text for Section 1 to clarify upfront the roles and responsibilities of the NPPO of the importing and exporting countries. The exporting country may develop an integrated approach even whenthe importing country does not explicitly require them. The proposed text also addresses some concerns from Comment 1.
References to ISPMs 2, 11 and 20 were added.
One SC-7 member considered section 1 Factors that affect the pest risk of plants for plantingsmall and repetitive and suggested moving parts of this section to 3.1.2;deleted the section header and first sentence and moved the rest of the section to 3.1.2; and deleted the repetitive paragraphs in 3.1.2.
2 Pest management measures
See Section 3.1.2 Requirements for the place of productionof this report.
3Integrated measures
The Steward, referring to Comment395, suggested includingauthorization of a place of production in the chapeau of this section to make it general for both high and low risk situations. The SC-7 concluded that approving a place of production is already mentioned under Section 3.1 in regards to both high and low risk situations and that there was a clear explanation justifying keeping them separate.
The Steward, referring to a similar comment from threemembers (Comment 398), suggested amalgamating Sections4.1 and 4.2. One SC-7 member, who was present at the third EWG meeting for this draft ISPM, informed the group that the EWG discussed this very topic. The EWG recognized that there is a continuum of risk and in an ideal world one could describe a continuum of management measures. The EWG tried to make this section modular, but decided this is not possible to describe in the standard.
Therepetitious text in Sections 2 and 3was discussed and it was agreed to delete the repetitious text in Section 2.
3.1 General integrated measures
The SC-7 discussed replacing places of production with site. The Steward noted that the places of productionis used throughout the draft standard whilesite is not used anywhere. It was also noted that the glossary term places of production includes sites so the SC-7 made no change.
3.1.1 Approval of places of production
The SC-7 agreed to make a global change to replace the wordauthorizationwithapproval.
Referring to the second indent of this section and to Comment 354, there was concern that one year is not a sufficient length of time to keep records and recommend at least two years or as long as there is an agreement between the two countries.It was noted that the text has a caveat of or longer, if justified, which sufficiently addresses the concern. The Secretariatreminded the group that the experts from the EWG concluded that three years was an adequate length of time to keep records because of the risk of plants for planting. The Steward noted that he made the change to be consistent with other standards, but some SC-7 members stated that there was no specified length of time used in all ISPMs.There was also concern that three years is too long and that the text should state the shorted possible scenario and to keep the caveat of or longer, if justified. The text was changed back to three years (or longer, if justified) because the experts from the EWG had originally concluded this was an adequate length of time.
It was also suggested recommending the SC forwarding theinconsistency between ISPMs on this issue to the TPG for review.
3.1.2 Requirements for the place of production
The group moved text to this section from a previous section.
In the first sentence of this section, one SC-7 member wanted to replace the term sufficient with the term necessary because ifa measure is sufficient, then no additional measures are needed. It was noted that because the text is referring to places of production and systems, some members may never accept this change. There was no change.
In the last paragraph, the SC-7 deleted the last sentence regarding dependencies on requirements because it was repetitive.
The SC-7 discussed whether to refer to mitigation or management in this section and to delete the word risk from the section heading and the first sentence of the section. One SC-7 member, who is also a member of the TPG, explained that the TPG has discussed these two issues at length and that the TPG recommends avoiding the use of the term mitigationand use onlyreduceormanage pest risk and also recommends the use of pest managementin this context instead of pest risk management (PRM) because PRM is a stage in a PRA and this standard is addressing pest management.
It was suggested to add a statement to the first paragraph that risk management measures should be taken to reduce pest risk because this first paragraph is not clear about risk management and plants for planting have a potentially high pest risk. The group edited the first paragraph to address this issue.
3.2 Integrated measures in high pest risk situations
It was noted that the first sentence of the text describes general integrated measures while the heading of the section is integrated measures in high pest risk situations.The SC-7noted the confusion and made a change to Section 3 to provide a clear reference throughout the standard.
3.2.1 Requirements for the place of production in high pest risk situations
It was proposed to revise the first paragraph of this section to reorder and simplify the text. The group agreed the text proposal was easier to understand and accepted the revision.
The Steward noted that one member comment suggested changing this section heading to Administrative measures. However, it was noted that if the SC decided to move sections 3.2.1.1 through 3.2.1.8 to an annex/appendix, it should be discussed at that time.
3.2.1.1 Place of production manual
It was proposed to move Subsections 3.2.1.1 to 3.2.1.8 to an annex to address the issues from Comment 1, and others. The Steward was unsure of making the change because other member comments suggested bringing some of the appendix texts into the body of the draft while the group was proposing the opposite and suggested waiting to ask the SC for their input. The group decided to wait moving the text to an annex until further discussions with the SC.
The last two sentences of the first paragraph in this section were reworded for clarity and simplicity.
Referring to the sixth indent, it was noted there is text regarding the approval process of subcontractorswas confusing, so the text was modified to address this issue.
One SC-7 member noted that the last two indents referring to recall and plan were not clear and was explained that this was meant to cover a recall of plants and the group agreed to modify the text. In the last indent, the SC-7replaced plan with procedures and modified the rest of the indent for simplicity.
3.2.1.2 Pest management programme
One SC-7 member suggested modifying the wording tosuppressing pest populations at or below the tolerance levelbecause the tolerance level is an acceptable number and was noted that it was not clear who would set the level of tolerance. The SC-7decided to delete the references to level of tolerance because it was not necessary in this context.
The addition of indent removal of contaminated substrate and the meaning of substrate were discussed. One SC-7 member considered substrate as what the plant containers were resting on while growing media is what the roots are in. It was decided not to insert the indent as this is a list of examples and to avoid confusion.