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20
Translating pest risk analysis into policy: the CFIA approach


Gregory Wolff

Canadian Food Inspection Agency, 59 Camelot Drive, Ottawa, Ontario K1A 0Y9, Canada; e-mail: wolffg@inspection.gc.ca

Abstract

The Canadian Food Inspection Agency’s (CFIA’s) Plant Health Division fulfils the CFIA’s obligations as Canada’s national plant protection organization, and is responsible for plant pest risk management. For invasive alien species that fall within the scope of the International Plant Protection Convention, the CFIA will continue to assess and regulate these under existing legal authorities and policy frameworks, and using common tools. The CFIA’s legal authority to regulate invasive alien species (quarantine pests) is provided by Canada’s Plant Protection Act, Plant Protection Regulations and, to some extent, its Seeds Act and Seeds Regulations. There are a number of obligations and principles that must be adhered to in developing pest risk management policies. In addition, as stated in the World Trade Organization’s Agreement on the Application of Sanitary and Phytosanitary Measures, measures should be based on international standards as appropriate and where they exist. This paper provides a broad description of the approach taken by the CFIA’s Plant Health Division in translating pest risk assessments into applied phytosanitary measures.

Introduction

The Canadian Food Inspection Agency’s Plant Health Division fulfils the CFIA’s specific obligations as Canada’s national plant protection organization, and is responsible for completion of stage three of pest risk analysis, namely pest risk management. Effectively, therefore, the division is responsible for translating pest risk assessment data into policies implementing phytosanitary measures.

In many ways the term "invasive alien species" is simply a new term for an old and well-understood problem, that is, quarantine pests ("exotic" pests). Good examples of plant pests that would also qualify as invasive alien species include Dutch elm disease, chestnut blight and, more recently, Asian longhorned beetle and sudden oak death. Therefore, for invasive alien species that fall within the scope of the International Plant Protection Convention, the CFIA will continue to assess and regulate these under existing legal authorities and policy frameworks, and using common tools (pest risk analysis etc.). This is also in keeping with decision VI/23 of the Conference of the Parties to the Convention on Biological Diversity (CBD, 2002; refer also footnote on page 7).

As an indicator of the potential economic impacts at stake for Canada from invasive alien species, the annual cost of the damage that invasive species cause to Canada’s managed agricultural and forestry sectors has been estimated at around 7.5 billion Canadian dollars (Dawson, 2002). This estimate does not include costs related to environmental impacts or unmanaged plant stands.

The CFIA’s Plant Health Division’s mandate includes responsibility for:

The CFIA’s legal authority to regulate invasive alien species that are quarantine pests of plants is provided by Canada’s Plant Protection Act, Plant Protection Regulations and, to some extent, its Seeds Act and Seeds Regulations (all available at www.inspection.gc.ca).

Pest risk analysis

Pest risk assessments are completed by the CFIA’s Plant Health Risk Assessment Unit, housed within the Science Division. In effect, PRA stages 1 and 2 of the revised ISPM 11 (now ISPM 11 [2004]: Pest risk analysis for quarantine pests, including analysis of environmental risks and living modified organisms) are carried out by the PHRA Unit. Stage 3, pest risk management, is carried out by the Plant Health Division, although broad recommendations for management approaches are usually also provided by the PHRA Unit. However, liaison between the Plant Health Division and PHRA Unit continues throughout the period when pest risk management options are considered, as detailed questions on pest biology and the appropriateness of a prospective measure may often arise.

International obligations and principles

Obligations and principles under the IPPC and the World Trade Organization’s Agreement on the Application of Sanitary and Phytosanitary Measures (WTO, 1994) must be adhered to and, therefore, must be considered at an early stage during development of phytosanitary measures and related policies. In addition, consideration of costs and benefits of measures drives development of acceptable policies, the premise being that if the cost of a proposed policy outweighs the benefits, then the approach is inappropriate. However, the benefits need not, of course, be of a purely financial nature.

Specific obligations that should be prominent during development of phytosanitary policies include: technical justification for measures; the requirement to base measures on standards; assessment of risk; and transparency. In relation to the latter, once the measures are developed and are ready to implement, the notification requirements described under annex B of the SPS Agreement, Transparency of sanitary and phytosanitary regulations, must be observed. Of course, many of the specific NPPO obligations under the IPPC support these, for example, surveillance and inspection, protection of areas and official control. In addition, IPPC obligations based on international cooperation, particularly pest reporting, should not be forgotten.

In addition to specific obligations, key international principles and concepts should be considered in the formulation of any phytosanitary measures and plant protection policies. These include sovereignty, necessity, minimal impact, modification, transparency, harmonization, equivalence, risk analysis and regionalization. Most of these are described in ISPM 1: Principles of plant quarantine as related to international trade, although some are described only in the SPS Agreement at present.

Plant protection strategies

For invasive alien species, there are four broad approaches that can be taken:

Within these broad approaches integration of a series of different specific measures usually occurs (examples of options are described in ISPM 11, section 3.4). Such measures are also captured in related policies such as import requirements and restrictions on domestic movement. ISPM 14: The use of integrated measures in a systems approach for pest risk management deals with this concept.

It is desirable to develop emergency response plans for known quarantine pests that present high risks. In addition, given the level of international trade and the inevitability of pest incursions occurring from time to time, the CFIA has conducted emergency response simulations for certain pests. These simulations have allowed the CFIA to develop emergency response plans further, to identify strengths and weaknesses of current systems and to maximize the efficiency of actions in true pest situations.

International standards

As stated in the SPS Agreement, measures should be based on international standards as appropriate and where they exist. The key standards relating to invasive alien species include:

ISPM 2: Guidelines for pest risk analysis and ISPM 11 [2004]: Pest risk analysis for quarantine pests, including analysis of environmental risks and living modified organisms

ISPM 4: Requirements for the establishment of pest free areas

ISPM 6: Guidelines for surveillance ISPM 8: Determination of pest status in an area

ISPM 9: Guidelines for pest eradication programmes

ISPM 14: The use of integrated measures in a systems approach for pest risk management

ISPM 17: Pest reporting.

For invasive alien species, ISPM 9 is perhaps the most important standard (not forgetting pest risk analysis as the basis for measures). Standards that elaborate on key obligations, such as pest reporting, are significant too.

Dialogue and communications

Dialogue with the industry (or other domestic) sector impacted is vital when developing policies. This is important both in terms of assessing the practicalities of proposed options, and in ensuring that the policies are understood and accepted. Success is unlikely if the targeted stakeholder group is resistant to the approach. In addition, if the underlying rationale for specific measures and the importance of the target pest is well understood by the stakeholder groups, cooperation is much more likely to ensue.

The CFIA publishes its plant protection policies on the Internet (available at www.inspection.gc.ca). The use of directives is a good example of meeting the obligations for transparency and, through scheduled review, the IPPC principle of modification of measures as the pest situation changes.

Conclusion

Despite the fact that the CFIA’s policies are based on formal pest risk analyses that take time to prepare, it should be remembered that when we are dealing with plant pests, we are dealing with biological systems. This means that our policies need also to be "living" and flexible when necessary.

International commitments must be considered at an early stage during selection of phytosanitary measures and development of appropriate policies. In addition, consultation of key ISPMs will assist in the development of effective policies.

Despite import controls and associated inspections and detection techniques, there is an inevitability of quarantine pest incursions. Trade in plants and plant products cannot proceed without some element of risk. Therefore, risk management is the overall approach to be pursued. In this regard, development of emergency response plans should be considered vital. Emergency response simulations are also extremely useful to assess the capacity of the organization to deal with pest situations and to allow further development of emergency response plans.

Phytosanitary measures and policies should not be developed in isolation. Consultations should take place with domestic stakeholders and international trading partners. In addition, cooperation and technical assistance (and expertise) may be available from other NPPOs and from regional plant protection organizations.

References

CBD. 2002. Sixth Conference of the Parties, The Hague, the Netherlands, 7 - 19 April 2002: Decision VI/23: Alien species that threaten ecosystems, habitats or species to which is annexed Guiding principles for the prevention, introduction and mitigation of impacts of alien species that threaten ecosystems, habitats or species (available at www.biodiv.org).

Dawson, M. 2002. Plant quarantine: preventing the introduction and spread of alien species harmful to plants. In R. Claudi, P. Nantel & E. Muckle-Jeffs, eds. Alien invaders in Canada’s waters, wetlands, and forests, pp. 243 - 251. Ottawa, Ontario, Canada, Natural Resources Canada, Canadian Forest Service.

WTO. 1994. Agreement on the application of sanitary and phytosanitary measures. In: Agreement establishing the World Trade Organization: Annex 1A: Multilateral agreements on trade in goods. Geneva, Switzerland (available at www.wto.org).


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