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Susan D. Cohen International movement of logs, lumber, and other wood products has changed in response to worldwide commerce demands. Currently, the United States imports about 25 percent of the lumber and 36 percent of the pulp products used by the domestic industry. To keep up with domestic demands, there is interest in importing more wood products from additional countries. The U. S. government at the same time is greatly concerned that increased movement of wood products will increase the risk of importing exotic forest pests into the country. In 1995, the U. S. Department of Agriculture, Animal and Plant Health Inspection Service (USDA-APHIS), responded to these changes in risk awareness by revising the regulations in 7 CFR Part 319, §§ 319.40-1 through 319.40-11, (referred to below as Quarantine 40). This rule differed from previous wood regulations in the past as it was designed to be comprehensive and includes risk assessment standards (Fig. 1).
Quarantine 40 regulations establish phytosanitary standards that ensure imported logs, lumber, and other regulated wood products are free from damaging pests (insects, diseases, nematodes, etc.). These standards provide safeguards from the day the logs are harvested until wood product shipments arrive in the United States. Treatments and safeguards such as debarking, heat treatment, kiln drying, fungicide/insecticide application, methyl bromide fumigation, and storage are covered under the phytosanitary requirements. Creation of new quarantine regulations such as Quarantine 40 requires an immense number of resources, multi-agency cooperation and multiple analyses within the regulatory agency. For example, new regulations may require public hearings, then the public comment period. Time is required for communication with stakeholders and trading partners, harmonization with internationally recognized standards, regulatory work plans, risk assessments, risk management documents, environmental impact statements, and economic analysis. In addition, a number of reviews are required at different levels within a regulatory agency and higher governmental levels prior to publishing a rule-making document in the Federal Register. These factors all contribute to extending the time until publication of the final rule. The Quarantine 40 regulations were promulgated on May 25, 1995. On January 20, 1999, APHIS published an advance notice of proposed rule-making in response to new information about exotic pest interceptions on solid wood packing material. Between August 1995 and March 1998, approximately 500 shipments were found by port inspectors to be infested with a variety of exotic plant pests that threaten forests. Ninety-seven percent of these interceptions were associated with solid wood packing material and originated from numerous countries including Europe, Africa, South America, and Asia. A draft pest risk assessment on solid wood packing material has been completed, but several more analyses must be completed prior to any further rule-making activities related to solid wood packing material (Fig. 2). In response to outbreaks of Asian longhorned beetle associated with solid wood packing material, APHIS promulgated interim regulations specific to solid wood packing material coming from China and Hong Kong. Interim regulations take less time to implement than a comprehensive regulation, but are usually implemented because of emergency situations. Quarantine regulations may also be pathogen-specific, such as the regulation of European larch canker, Lachnellula willkommii, 7 CFR 301.91. These regulations are designed as risk management actions to limit spread, control, or eradicate a fungal pathogen.
Prior to publication of regulations, a number of issues must be addressed before preparing documents on risk assessment, risk reduction management, environmental impact, and economic analysis. Initially, the pests of concern must be identified by taxonomic position and quarantine status. Fungal pathogens of concern, in particular, present a wide range of difficult issues for regulatory agencies. Out of an estimated 1.5 million fungi, only 70,000 have been described taxonomically. This means there are many more fungal pathogens that are not yet identified, and very little information available for a risk assessment on them. Classification of fungi is changing with the advent of molecular tools, and many fungi are being renamed, causing confusion in the scientific literature. Regulatory agencies are now forced to collect more biological and molecular research data to bolster identification, and to ascertain whether fungal strains are exotic, endemic, or new genetic strains derived from local or non-pathogenic strains. The use of DNA sequencing and other molecular techniques are more important than ever for determining the exotic or endemic nature of fungal pathogens, and whether new combinations of genes have occurred between strains of different geographic locations. In the future, it will be important to store information on fungal morphology, DNA sequences, and population genetics in a centralized database linked to a pest risk information system that will support research and regulatory needs. Regulatory agencies worry about the identity of the pathogen, and also need to be cognizant of the nature of the plant host range. Often, pathogens have the ability to jump to new hosts and create a higher risk problem. Multi-agency cooperation will be required in the future to predict which ecosystems are fragile and susceptible to invasion by exotic pest introductions. Regulatory measures can then be applied to limit introduction of pest-associated plants into such fragile areas, or to direct shipments of these plants to areas that lack susceptible hosts and habitat fragility. Risk management of exotic pests requires extensive knowledge of the pathways for introduction of commodities and global trading patterns. As human-assisted pathways have increased, the potential for pest introductions has risen. In addition, unexpected new pathways of pest movement develop and regulatory agencies must be vigilant to detect these pathways and reduce the potential for introduction of exotic pests. Available mitigation measures also require testing and evaluation before they are included into regulations. Selection of effective mitigation measures is resource- and time-intensive. Their evaluation requires a good deal of interaction between industry and regulatory agencies prior to final rule-making activities. Lack of targeted research data on mitigation measures can also result in delays before publication of regulations. Risk analysis methods adopted by the United States need to be harmonious with the standards agreed on by multiple federal agencies, e.g., the North American Plant Protection Organization (NAPPO), and the International Plant Protection Convention (IPPC). Methods should be consistent, transparent and understandable so that all federal agencies and other countries are able to evaluate the results. A significant amount of time is spent, by regulatory agencies, in developing pest risk analysis guidelines at the national and international level to ensure consistency of risk analyses done for regulations. U. S. federal agencies have agreed on and published the first comprehensive guidelines for ecological risk assessment. At the international level, IPPC has published standards for pest risk analysis. In the future, standards for pest risk analysis must be flexible in response to new scientific approaches and the ever-evolving nature of risk analysis. References Cohen, S.D., L.W. Chang, R. L. Griffin, and R. L. Orr. 1995. Plant pest risk information system (PPRIS) for USDA-APHIS:design of a functional prototype. EPPO Bull. 25:637-650. Hamelin, R. C. 2000. Molecular epidemiology of tree pathogens. Pages 375-393. In: Molecular Biology of Woody Plants. Vol. 2. S. M. Jain and S. C. Minocha, eds. Kluwer Academic Publishers, Dordrecht. USDA-APHIS-PPD. Final economic analysis of proposed 7CFR Part 319, Quarantine 40 regulations: importation of logs, lumber, and other raw or processed wood products. May 1, 1995. USDA-Forest Service. 1991. Pest risk assessment of the importation of larch from Siberia and the Soviet Far East. Miscellaneous Publication No. 1495. USDA-Forest Service and USDA-APHIS. 1999. Draft pest risk assessment of solid wood packing material. August 2000.
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