It is necessary to obtain APHIS--PPQ permits for the "importation, transit, domestic movement, and environmental release of Organisms that impact plants, and the importation and transit of Plants and Plant Products.". These requirements were specified under the Plant Protection Act of 2000. Though it may seem like a daunting and unnecessary task to obtain these permits (because of course you and your program will take all necessary precautions when dealing with plant pests and pathogens), the requirements are a necessary aspect of APHIS’s PPQ program’s mission to "protect agriculture and the environment against pest and disease threats" for preservation of the both the environment and the food supply. By obtaining proper permits for your organisms, you help to ensure that APHIS is able to monitor and manage threats to plant productivity and ecosystem health within the United States.
 Plant Import Permits, USDA-APHIS website. Plant Heath PPQ, USDA-APHIS website.
APHIS—PPQ permits must be obtained for the importation, transit, domestic movement, and environmental release of many organisms that we work with as plant pathologists. For most of us, the most relevant of these permits is the PPQ 526, which is necessary.
"for the importation, interstate movement and environmental release of plant pests (plant feeding insects, mites, snails, slugs, and plant pathogenic bacteria, viruses, fungi, etc.), biological control organisms of plant pests and weeds, bees, parasitic plants and Federally listed noxious weeds."
In other words, you will need a PPQ 526 for anything pathogen/pest-related that you are obtaining from outside the state in which you reside. Additionally, a PPQ 526 is required to import soil or receive soil from another state, if you intend to isolate microbes—pathogenic, beneficial, or otherwise—from that soil.
It should also be noted that a PPQ 526 is required for most biological control products, microbial plant growth enhancers and biofertilizers. These include invertebrate pests, parasites, predators, and herbivores, and microbial pathogens and non-pathogens used for management of plant pests and pathogens and of weeds. If a biocontrol agent has been registered with the EPA as a biopesticide, then a PPQ 526 is generally not necessary for interstate transport. The regulations regarding biofertilizers are a bit a less clear and are probably best dealt with by contacting your APHIS representative. More information on the permitting requirements for biofertilizers can be found here.
If you are planning to import plants or plant parts from another country, other than Canada, for your research, you may also need to obtain PPQ 586 and 587 permits, which are for transit across the United States and import into the United States, respectively, of plants and plant parts. There are a number of additional permits for plant and plant products that may be needed under different circumstances. You can read more about these permits here.
In order to submit a PPQ permit application online, you will need to apply for and obtain a Level 2 eAuthentication account. This requires filling out an on-line form and showing up, in person, at a local office with a government-issued photo ID. In some cases, you may be able to avoid actually traveling to the USDA office, but will need to speak with a representative on the phone. This process will verify your identity and grant you Level 2 access. Once obtained, you will then be able to activate your account and fill out the on-line permit application forms. Alternatively, you can fill out a PDF form and mail it, but this is not recommended by APHIS.
Filling out the form, itself, can be a fairly long process and it will help to think and have a clear plan for what you want to do with the pathogen and what life state/form you expect to receive (pure culture on plates, lyophilized culture, plant material, etc.) you want to receive it in before you go the fill out the form. We’ve put together a tutorial for you on how to fill out a PPQ 526 form that can be found elsewhere on the CADRE website. It is helpful and greatly appreciated by the permit reviewers if you take the time to carefully and thoroughly complete your permit application. We have also found that it can be very helpful to call APHIS with any questions you have during the application process. In fact, we had a permit approved within days because the person who approved our permit got to know us so well from our frequent phone calls!
To make the process easier, and to help you understand how the permitting procedure works, APHIS has compiled a number of on-line learning modules. They are, admittedly, not the most exciting material out there, but provide a useful resource. These learning modules can be found here on the APHIS website.
Obtaining an APHIS-PPQ permit can be a fairly time-consuming process and it can vary quite a bit. I have had some permits issued within days of application and others that have taken months, and an inspection, to complete. Generally, the PPQ website states that the average time for issuance of a permit is 80 days. However, the website also states that it can take 8 weeks to 18 months to obtain a permit. Submitting your permit application on-line, versus using the manual process, is a much more stream-lined process and is recommended by APHIS.
Much of the variation in the time for issuance of a permit depends on the organism you intend to work with and how prevalent it is. It is also likely to take more time to obtain a permit if you intend to import pathogens from out countries, as opposed to simply transporting across state lines. APS has compiled lists of widely prevalent pathogens by state. It is generally easiest and fastest to obtain permits for pathogen on these lists, which exist for fungi and oomycetes, viruses, and bacteria. According the APHIS-PPQ website, there is no list for insect pests yet but they are working with the ESA on making one available in the future.
Ultimately, you should expect that it will take a few month to obtain the permits you need to obtain pathogens from other states or countries. Plan ahead and submit your permit application early. This will allow plenty of time for the process and, hopefully, allow you to have the proper permits in place by the time you are planning to start working with the pathogen.
Here’s the best thing—at this point in time, all APHIS permits are free! They really are in place to safeguard agriculture and the environment and not to make money off those interested in performing research on plant pests and pathogens. Yes, there is a bit of a cost when you think about the time and effort required to obtain the permits but beyond that, the PPQ application process is entirely free.
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