Summary of Discussion Session V
How does one analyze entry risks and risk reduction options?

Dr. Susan D. Cohen, moderator

The following authors presented papers in this session. Marcel Dawson, Canadian Food Inspection Agency (Canada), presented a perspective on risk management: elements to consider in developing plant health policy for forest products. John Clarke, Virginia Polytechnic Institute and State University (USA), discussed the economic impact of solid wood packaging material pest reduction strategies. Lee Humble, Canadian Forest Service (Canada), wrote about the environmental impacts of risk reduction options for organisms associated with solid wood packing. Hugh Bigsby, Lincoln University (New Zealand), proposed an iso-risk framework for quantifying phytosanitary barriers to trade. David McNamara, European and Mediterranean Plant Protection Organization (France), described the international cooperation in risk analysis and development of regulations. A total of twenty-nine comments were posted in Session VI. For the purposes of this summary, comments will be grouped into nine different topic areas such as outside input, species-based versus commodity-based risk assessments, data gaps, research compendia, precautionary principle, weediness predictors, potential hosts, peer review, and moderator administration (Figure 1).

Figure 1. Discussion Session VI: Number of Comments Categorized By Topic Area. Topics are as follows: 1) outside input, 2) species-based versus commodity/pathway-based assessment, 3) data gaps, 4) compendia, 5) precautionary principle, 6) weediness predictors, 7) potential hosts, 8) peer review, and 9) moderator administration.

Participants posted approximately 10% of the comments on the need for input from the public and other interested parties into the policy process. Questions were raised as to whether the public was fully participating in the process in the USA prior to the publication of a proposed rule in the Federal Register. Workshop participants were concerned about how to engage the general public in policy development. USA responded that in the current situation the public becomes involved through written comments or public hearings. Discussion then continued in Session VIII that focused on problems associated with implementation of regulations.

The majority of the comments (41%) dealt with the issues surrounding a species-initiated versus a commodity/pathway initiated risk assessment. Participants requested clarification on WTO-SPS (World Trade Organization's Sanitary and Phytosanitary) agreement on trade prohibition tied to increased risk associated with a specific pest species. Some participants felt this document implied that pest risk assessments were focused on single pests and not commodities/pathways. Pest risk analysis guidelines prepared by FAO-IPPC (Food and Agriculture Organization-International Plant Protection Commission) and regional plant protection agencies have addressed these issues. These agencies recognize the distinction between species-initiated and commodity/pathway-initiated risk assessment processes. Pathway-initiated risk assessments consider all the pests carried by the commodities and give a combined pest risk. Risk managers can then recommend mitigation measures be applied that provide protection against a range of pests. One comment pointed out the greatest weakness with the pathway approach is the lack of available research data. Other comments recognized how the quality of a risk assessment may be affected by the lack of available scientific information and the judgment of the assessor. The international standards for SWPM recognize the need to set appropriate safeguard levels even if scientific information is not available to fully document the pest risk status of a particular pathway. Discussion continued on methods for commodity or pathway risk assessment. Currently, a qualitative approach for pest-initiated and pathway-initiated risk assessment is followed by the international regulatory agencies. This approach is based on biological evidence reported in scientific studies. A limitation of this evidence is that many of the studies are done in laboratory settings and don't necessarily reflect responses of the pests under actual field conditions. Quantitative approaches have been used when the data is available. Acceptable level of risk associated with commodities/pathways is also another related issue and Hugh Bigsby suggests a quantitative approach to handling this difficult topic.

One participant cited the affects of data gaps on pest risk assessment and offered an interesting example, Chlorophorus annularis from Asia. The scientific literature lists bamboo as a primary host of this species but other economically important hosts were listed for this species without substantiation. Experts in Asia and Hawaii when contacted know very little of the species habits. Many of the host association reports may be attributed to just observations of adult beetles visiting flowers of these plants. The lack of data in this case has a major impact on regulatory decisions.

Another comment, specific to issues surrounding solid wood packing material, addressed the need for efficient access to worldwide scientific information on timber and forest pests. Much of the information about agricultural pests is available in the Crop Protection Compendium published by CAB international. However, information on forest and timber pests and phytosanitary issues is often more difficult to locate. CAB international proposes releasing a compendium of information on forest and timber pests and invites input from workshop participants. Centralized and peer reviewed information resources such as compendia are effective tools for information retrieval, identification of data gaps, and information sources for pest risk assessments.

Risk management and the precautionary principle were briefly discussed in 7% of the comments. There was some thought that mitigation measures should be based on the actual pest risks and supported by scientifically sound information. It was suggested that mitigation measures should be appropriate to the problem and not overly restrictive to trade. There was some thought that it would be better to increase the inspections for exotics at the point of origin to prevent entry of exotics into the importing country.

Assessing weediness of imported plant was another concern posted in 7 % of the comments. Questions were raised as to the type of guidelines used to determine the weediness factor of a potential import. USA reported that guidelines are published on the web (http://www.aphis.usda.gov/ppq/weeds) and they are similar to ones used by Australia.

Potential pest risk increased by host availability was discussed in 14% of the comments. Two invading insect examples, insects colonizing eucalypts in New Zealand and Ips typographus in UK, were discussed in light of climate, management and host availability. In the case of New Zealand, it was thought that insects migrated by westerly wind currents to New Zealand. Available commercial plantations of eucalypts in New Zealand increased the risk of pest invasion and establishment. In the UK, Ips typographus has increased during the last 100 years because of extensive planting of spruce. The spread of this pest seems to be influenced by debarking management practices and not by wind dissemination as is the case of New Zealand.

Peer review of pest risk assessments was an issue raised in one comment. There was some concern that too much speculation was included in pest risk assessments (PRAs) and that PRAs have moved from science-based decision making documents to documents that justify regulations. The discussion comment stated PRAs should be peer reviewed and reviews taken seriously by the agency responsible for completion of the assessments.

Most of the discussion centered on issues related to pest risk assessments since FAO-IPPC has published international standards for pest risk analysis and the USA has recently published a draft pest risk assessment on importation of solid wood packing materials into the United States. However, more pressing issues need to be addressed in the pest risk management area. For example, solid wood packing materials carrying pests of concern have been moving internationally for sometime by a number of routes. This calls for a careful examination of suitable mitigation measures that are effective against an array of exotic pest species. Data gaps are abundant for many of the exotic pest species described in this workshop and this may require more scientific studies on the nature and the risk posed by these pests and their pathways. Collection of risk management specific data will now be more important than ever before as we evaluate possible mitigation options and appropriate risk reduction analysis methods. Regulatory agencies will also need to increase the ways to communicate risk management issues to the public, industry, and scientific community and find appropriate ways to involve these participants in the risk management process.