Reminder: Friday is the deadline for commenting on APHIS’ draft environmental assessment for the Asian longhorned beetle eradication program in South Carolina. Comments should be submitted at https://beta.regulations.gov/commenton/APHIS-2020-0086-0001
The Center for Invasive Species Prevention submitted comments that supported the eradication effort because of the well-documented threat that the ALB poses to the forests of North America. We also supported the preferred alternative in the EA.
However, we found the environmental assessment (EA) to be deficient in several ways:
the EA does not identify the host species present in the program area – not even of the 5,800 trees inspected by the program as of mid-August.
the EA provides no estimate of the proportion of deciduous trees and shrubs in the area that are host species. Conifers dominate the area. This means that any fauna dependent on deciduous trees and shrubs for food and shelter already contend with limited resources. Consequently, while we concur with the EA that any impacts will be localized, they might be exacerbated by the relative rarity of hardwood species in the local area. It is particularly important that the EA address this question since the Programmatic EIS was written under the assumption that forests at risk to the ALB are like those in the Northeast and Midwest, where hardwoods dominate.
Without knowing the proportion of deciduous flora comprised of host species, no one can evaluate the amount of wildlife food that could be removed or treated by pesticides. Some wildlife species are potentially vulnerable, including those that feed on pollen and nectar (i.e., bees and other pollinators) and those that feed on insects and other invertebrates. The latter include two species listed federally as threatened species: the frosted flatwood salamander (Ambystoma cingulatum) and northern long-eared bat (Myotis septentrionalis). Also vulnerable are birds, 96% of which feed their young on insects and other invertebrates. I worry about sublethal effects and possible bioaccumulation. Aquatic organisms, especially invertebrates, might also be affected.
The information gaps in the EA highlight weaknesses in the Programmatic EIS, on which it relies. The most important gap is the dearth of pesticide dose/mortality data for terrestrial amphibians. Apparently, EPA has not required such studies before approving pesticides.
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
APHIS has apparently passed up an opportunity to pressure China to clean up its wood packaging – although China ranks among the countries that most often violates ISPM#15 and sends wood packaging infested by quarantine pests. (See the blogs under the category “wood packaging” on this site.)
In May, a large delegation of APHIS employees met (virtually) with an equally large delegation of its Chinese counterpart to negotiate “technical protocols” linked to the Phase 1 trade agreement with China. The focus of the negotiations was on Chinese phytosanitary barriers that block exports of US products to China.
The two countries have now signed technical protocols to allow the United States to export to China a wide range of commodities estimated to be worth between $700 million and $760 million annually when the agreement is fully implemented. These commodities include barley for processing, hay, some fruits (blueberries, avocados, nectarines), almond meal, and chipping potatoes.
Some of the agreements cap years of effort. The example cited is chipping potatoes. Negotiations continue on some other U.S. exports to China, including logs.
An article in APHIS’ online newsletter reports that “On the import side, we are working on the requirements for China’s requested commodities….” Presumably these would be exports to the U.S. The examples listed were all fruits.
US & Chinese delegations (APHIS photo)
I inquired whether wood packaging was part of the negotiation.
Andrea B. Simao, Assistant Deputy Administrator and Director of PPQ’s Phytosanitary Issues Management unit, replied that SWPM was not raised “since there has [sic] not been significant issues.” Instead, she detailed efforts in the ongoing negotiations to persuade China that U.S. phytosanitary treatments are sufficient to control various pathogens in logs: oak wilt, phosphine on conifers, pinewood nematode.
Apparently the focus was fully on US exports and nobody raised US concerns about the risks of imports from China. This approach fits the Administration’s emphasis on exporting agricultural commodities to China. However, this is not reality. Over the past five years, I have frequently cited USDA’s own data – which demonstrate the likelihood that wood packaging will transport tree-killing pests from China to the U.S.
APHIS PPQ Deputy Administrator Osama El-Lissy & Chinese counterpart Li Jainwei sign agreement (APHIS photo)
Please inform your Member of Congress and Senators (or candidates for House or Senate) about how you feel about this failure of USDA to protect America’s natural resources. We must raise the political heat in order to pressure USDA into placing as high a priority on protecting US natural resources as it does on supporting agricultural exports.
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
U.S. phytosanitary policy is set by politicians – the Secretary of Agriculture, trade officials, and members of the House and Senate. Elected or appointed state officials determine how aggressively trees are protected in their jurisdictions. To fix the problems, those politicians need to hear from those of us who know about the pest risk associated with wood packaging and other imports.
Politics is how our country makes important decisions. And in politics, the squeaky wheel gets the grease.
Election seasons provide opportunities to raise issues. Politicians pay more attention to constituents’ concerns when they are courting our votes.
Further, if new people take up positions in January (whether elected or appointed), they will be more open to learning about issues new to them than were the people who have occupied an office for some time.
These messages need to be repeated periodically. Proctor and Gamble does not make its profits by asking us to buy their toothpaste once a year. We cannot duplicate a major corporation’s advertising budget – but we can speak up!
Tell your member of Congress and senators that you are worried that our trees are still being put at risk by insects arriving in wood packaging or diseases being spread by shipments of plants. Ask them to urge theUSDA Secretary to take action to curtail introductions of additional tree-killing pests.
Ask your friends and neighbors to join you in communicating these concerns to their Congressional representatives and senators.
If you are a member of an association – a scientific or professional society, an environmental advocacy group, a homeowners’ association – ask your association and fellow members to join you in communicating these concerns to their Congressional representatives and senators.
Write letters to the editors of your local newspaper or TV news station.
What should we say?
Our goal should be to hold foreign suppliers responsible for complying with ISPM#15. Here are five pieces of a comprehensive approach. It is best to advocate for all. However, if you feel more comfortable focusing on one or two specific actions, please do so!
1) One approach is to penalize violators. APHIS should:
Fine an importer for each new shipment found to be out of compliance with ISPM#15 in those cases where the foreign supplier of that shipment has a record of repeated violations.
Prohibit imports in packaging made from solid wood (boards, 4 x 4s, etc.) from foreign suppliers that have a record of repeated violations.
Allow continued imports from those same suppliers as long as they are contained in other types of packaging materials, including plastic, metals, fiberboards.
APHIS has the authority to take these action under the “emergency action” provision (Sec. 5.7) of the World Trade Organization Agreement on Sanitary and Phytosanitary Standards. (See a lengthy discussion of the SPS agreement in Chapter III of Fading Forests II, available here.) http://treeimprovement.utk.edu/FadingForests.htm
USDA and CBP should take other steps to help importers comply with ISPM#15.
USDA should also step up efforts to help U.S. importers to determine – and then use – those foreign suppliers of wood packaging and dunnage have good compliance records.
APHIS should join the DHS CBP in providing incentives to importers to join an expanded Customs-Trade Partnership Against Terrorism program (C-TPAT) that would require participants to assume full responsibility for ensuring that their packaging complies with IPPC standards.
The Government should strengthen underlying regulations.
Once a new president is elected, urge him to instruct the Office of Management and Budget to allow APHIS to finalize regulations – proposed more than five years ago! – that would apply ISPM#15 to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)
USDA needs to understand the “approach rate” of pests in wood packaging in order to identify and fix weaknesses in its policies. To reach this understanding, APHIS should authorize Robert Haack to repeat the study documented in Haack et al. (2014). Furthermore, APHIS should collaborate with foreign counterparts to determine the relative importance of possible causes of the persistent pest presence problem – fraud, accidental misapplication of treatments, or other failures of treatment. Once the study has been completed, APHIS and its colleagues should work through the IPPC to fix the problems.
There are also recommendations of the Tree-Smart Trade program at www.tree-smart-trade.org Tree-Smart also has a Twitter account: @treeSMARTtrade
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
I first blogged about wood packaging in July 2015 – it was my first blog! I have written 15 times about wood packaging since. To see the series, visit www.nivemnic.us, scroll down below “archives” to “categories”, click on “wood packaging”.
For five years, I have called upon USDA to act. It’s long past time to replace decade-old policies that have failed to prevent introductions. More recently, I have begun calling for revising the international phytosanitary system, too.
As I’ve demonstrated in my blogs – and documented by Aukema et al. 2011 and others—wood-boring beetles have been among the most damaging tree-killing pests introduced to the U.S. Local governments, homeowners, and businesses spend billions of dollars each year to manage dying and dead trees. Landowners bear added costs in reduced property values. The ecosystem impacts are substantial, but still poorly quantified.
International efforts – i.e., ISPM#15 – have apparently reduced the rate at which wood-borer pests approach our shores. However, the reduction has not been sufficient to prevent a tripling of the number of non-native wood-borers established in U.S. by 2050 (Leung et al. 2014) — as I have demonstrated over and over.
Also, I have documented again and again the continued presence of wood-borers in incoming wood packaging and resulting introductions (visit the “wood packaging” category in the blog archives).
Part of the blame for inadequate protection from pests might arise from the specific requirements of current international standards (see Nadel et al. 2016 and Krishnankutty et al. 2020b). But I think most of the blame falls on APHIS’ choice to be forgiving, rather than strict, in enforcing its own regulations that implement the international standard.
There is widespread evidence of exporters’ failures to implement international standards. The evidence is clear: we cannot rely on exporters to meet either international standards or importing country’s phytosanitary requirements. The same countries – and even individual exporting businesses! – fail to comply with ISPM#15 year after year (Haack et al. 2014; APHIS interception database). APHIS has not taken effective action to end imports from these scofflaws.
U.S. phytosanitary policy is set by politicians. Politicians pay more attention to constituents’ concerns during election seasons – so NOW is the time to press for changes! I will discuss how to do this in an accompanying second blog.
U.S. imports have decreased significantly in recent years, especially from the two countries with the worst records of non-compliance with ISPM#15 (Mexico and China). But economic collapse is not a long-term strategy for reducing pest risk.
Quantifying Pest Risk for Wood Packaging: We Don’t Know
Here’s my best estimate of the pest risk associated with wood packaging. Remember, though, that key data remain missing.
Haack et al. published a landmark analysis of pest approach rates in 2014, using data from 2009. However, they did not include imports from China, Mexico, or Canada. Given the history of interceptions, it is probable that a recalculation of the approach rate that included China and Mexico would raise the estimate. It is more difficult to provide a more accurate estimate re: Canada, because CBP rarely inspects those shipments. (The U.S. and Canada do not require each other to treat wood packaging.)
As of mid-October 2019, CBP said it received 11 million containers at seaports annually (CBP website). If 75% of those incoming sea-borne containers have wood packaging (per Meissner et al. 2009), that equals 8,250,000 containers. If 0.1% of those containers with wood packaging is infested (per Haack et al. 2014), we are receiving 8,250 infested shipping containers via maritime shipping – even now, when imports have decreased substantially. This is more than 22 infested containers every day.
As of a decade ago, Chinese shipments were only half as likely to be enclosed in wood packaging as are shipments from other exporters. Perhaps this reflects a greater reliance on air shipments – air shipments globally are half as likely as maritime shipments to be encased in packaging made of wood (Meissner et al. 2009). Despite the lower proportion of wood packaging use, shipments from China still rank second (to Mexico) in the number of shipments detected as infested. In part, the data reflect inspection priorities: due to the great damage caused by Asian insects to North American trees and their record of poor compliance, CBP targets shipments from China for more intense scrutiny. Still, the high number of detections reflects continuing non-compliance by Chinese exporters. And remember: first, the U.S. and Canada began requiring treatment of wood packaging from China at the end of 1998 – 21 years ago! And second, APHIS almost never penalizes importers for poor compliance.
Understanding the pest risk from Mexico and Canada is important, because they are our second and third largest trading partners. As of October 2019, the numbers of shipping containers arriving overland (by truck or rail) from these countries annually were 13.7 million (CBP website). No one has estimated the proportion of these containers that contain wood packaging. If it is the same proportion as in maritime shipments, the approach rate would be another 10,275 infested containers per year – or 28 per day.
The total of maritime and land-based shipments that are probably infested (excluding air shipments) – would be 18,525 containers annually or 50 per day.
If I am right that shipments from China and Mexico have a higher pest-infestation rate than the 0.1% global estimate developed by Haack et al. (2014), the pest approach rate is probably higher than the 18,525 containers given above.
(I noted in my previous blog that insect species arriving from our neighbors pose a lower risk than the species from Asia or Europe – although the risk is not “0”. I addressed the Mexican woodborers in the previous blog. The risk from Canada could arise from non-native woodborers established in that country but not yet in the U.S. e.g., brown spruce longhorned beetle. Another risk is that shipments from off-shore origins might be transshipped through Canada and escape inspection because they are claimed to have been re-packaged there – as CBP staff have told me.)
The point is, we don’t know how many pests are reaching the U.S. daily. The current approach rate might be significantly higher or lower than Haack and colleagues estimated a decade ago due to
Exclusion of China, Mexico, and Canada from the original study.
Changes in the treatment requirements of ISPM#15.
Another decade of experience – which might have led to better compliance (however, see below).
Despite my urging, APHIS has not agreed to a study to update Haack’s estimate.
It is also true that shipping containers provide shelter for a vast range of hitchhiking organisms in addition to insects in the wood, e.g., other insects’ eggs attached to the sides of the container, snails, weed seeds, even vertebrates.
Enforcement: One Agency Steps Up
When ISPM#15 was adopted, APHIS expected that importers would clean up their supply chains in order to avoid the lost income and costly delays that result from CBP interception of a non-compliant shipment. However, the data clearly show that this disincentive to violate ISPM#15 is insufficient to prompt companies to fix the problem. We need to find a more efficacious approach.
Clearly, enforcement in the form of penalties had been rare before 2017. CBP staff reported that as of January 2017 (before the agency strengthened its own enforcement effort), only about 30 of the nearly 21,000 non-compliant import shipments had received a financial penalty. CBP staff cited two reasons for the low penalty rate: 1) USDA policy requires that an importer be caught five times in a year with non-compliant wood packaging before imposing a fine; and 2) APHIS had not designated wood packaging as a high-risk commodity. After CBP initiated more aggressive enforcement in November 2017, enforcement actions rose by 400% (John Sagle, CBP. pers. comm) – although from a very low starting point!
Data on CBP interceptions in 2019 (Harriger) show decreases in the number of non-compliant shipments from earlier years in all categories: a 19% decrease below the 2010-2018 average of shipments intercepted; a 13% decrease in number of shipments intercepted because the wood packaging lacked the ISPM#15 mark; a decrease of 6% in the number of shipments intercepted that had a quarantine pest. Still, percentages based on absolute numbers don’t tell the whole story. They can be affected by inspection effort and other variables. So while these decreases are encouraging, it is still too early to determine the impact of CBP’s enforcement upgrade.
Unfortunately, there has not yet been the substantive/overall change needed in federal policy. At a minimum, APHIS continues to allow importers five violations per twelve month period.
While the cities that import the most goods – especially from Asia – would seem to be at particular risk, experience shows that pests can be introduced anywhere. This is demonstrated by establishment of the Asian longhorned beetle in semi-rural Clermont County, Ohio and the velvet longhorned beetle in Utah (Krishnankutty, et al. 2020a).
“Treated” Wood Still Transports Pests
According to interception data provided to me by CBP (Harriger), 97% of pest-infested shipments detected over a period of 6 years (FYs 2010 – 2015) bore the stamp indicating they’d been treated in compliance with ISPM#15. These shipments came from all importing countries. Unfortunately, CBP has not provided the necessary breakdown of its data in more recent years to calculate this proportion.
Krishnankutty et al. (2020b) analyzed wood packaging from 42 countries intercepted by CBP over six years (April 2012 – January 2018). They found that 87% of the infested wood packaging included in this study bore the ISPM mark. This is a lower non-compliance rate than that shown by CBP data, but still too high.
European scientists carried out an intensive survey of wood packaging associated with shipments of stone from China to the 28 European Union countries during 2013-2016. They also found that 97.5% of consignments that harbored pests bore the ISPM#15 mark (Eyre et al. 2018). The problem did not decrease over time.
The possible causes of this problem are long-known. What effort is APHIS making to determine their relative importance? Is it fraud? Is it accidental misapplication of the treatments? Is it that the treatments do not work as well as necessary?
By comparing Haack’s estimate with the CBP data, I estimate that CBP is detecting and halting the importation of 4 – 8% of the shipments that actually contain pest-infested wood. Wu et al. (2020) concurred that the majority of infesting larvae would probably not be intercepted – despite CBP’s best efforts – and would be transported to the cargo’s intended destinations.
Since CBP inspects only about 2% of incoming shipments, this detection rate demonstrates the value of CBP’s program to target likely violators. It deserves praise. But it is obviously too low a “catch” rate to provide an adequate level of protection for our forests. I do not believe that increasing the inspection workforce and effort will result in substantial improvement in this rate. Instead, we need action to curtail imports of wood packaging from countries and exporters with records of non-compliance.
What Federal Agencies Are Doing to Better Prevent Introductions
Other than CBP’s welcome newly rigorous enforcement policy, most actions have focused on educating exporters, importers, shippers, customs brokers, and exporting countries’ phytosanitary agencies.
Since upgrading its enforcement actions, CBP has expanded its long-standing educational efforts. APHIS co-sponsored workshops for agricultural agencies and exporters in Asia and the Americas earlier in the decade.
APHIS also planned to host international symposia on wood packaging issues as part of events recognizing 2020 as the International Year of Plant Health. These symposia have been postponed by travel and other restrictions arising from the coronavirus pandemic.
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
SOURCES
Aukema, J.E., B. Leung, K. Kovacs, C. Chivers, K. O. Britton, J. Englin, S.J. Frankel, R. G. Haight, T. P. Holmes, A. Liebhold, D.G. McCullough, B. Von Holle.. 2011. Economic Impacts of Non-Native Forest Insects in the Continental United States PLoS One September 2011 (Volume 6 Issue 9)
Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)
Haack, R. A. 2006. Exotic bark- and wood-boring Coleoptera in the United States: recent establishments and interceptions. Can. J. For. Res. 36: 269–288.
Haack, R.A., F. Herard, J. Sun, J.J. Burgeon. 2009. Managing Invasive Populations of Asian Longhorned Beetle and Citrus Longhorned Beetle: A Worldwide Perspective. Annu. Rev. Entomol. 2010. 55:521-46.
Haack, R. A., K. O. Britton, E. G. Brockerhoff, J. F. Cavey, L. J. Garrett, M. Kimberley, F. Lowenstein, A. Nuding, L. J. Olson, J. Turner, and K. N. Vasilaky. 2014. Effectiveness of the international phytosanitary standard ISPM no. 15 on reducing wood borer infestation rates in wood packaging material entering the United States. Plos One 9:e96611.
Krishnankutty, S.M., K. Bigsby, J. Hastings, Y. Takeuchi, Y. Wu, S.W. Lingafelter, H. Nadel, S.W. Myers, and A.M. Ray. 2020a. Predicting Establishment Potential of an Invasive Wood-Boring Beetle, Trichoferus campestris (Coleoptera) in the United States. Annals of the Entomological Society of America, XX(X), 2020, 1–12
Krishnankutty, S., H. Nadel, A.M. Taylor, M.C. Wiemann, Y. Wu, S.W. Lingafelter, S.W. Myers, and A.M. Ray. 2020b. Identification of Tree Genera Used in the Construction of Solid Wood-Packaging Materials That Arrived at U.S. Ports Infested With Live Wood-Boring Insects. Commodity Treatment and Quarantine Entomology
Leung, B., M.R. Springborn, J.A. Turner, E.G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. The Ecological Society of America. Frontiers of Ecology.org
Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory
Nadel, H. S. Meyers, J. Molongoski, Y. Wu, S. Lingafelter, A. Ray, S. Krishnankutty, A. Taylor. 2017. Identification of Port Interceptions in Wood Packing Material Cumulative Progress Report, April 2012 – June 2017
Oregon Department of Agriculture, Plant Protection & Conservation Programs. 2019. Annual Report 2019.
USDA APHIS interception database – pers. comm. January 2017.
Wu, Y., S.M. Krishnankutty, K.A. Vieira, B. Wang. 2020. Invasion of Trichoferus campestris (Coleoptera: Cerambycidae) into the United States characterized by high levels of genetic diversity and recurrent intros. Biological Invasions Volume 22, pages1309–1323(2020)
A shipping container being off-loaded in Long Beach
In 2018, China supplied 21.2% of all U.S. imports of goods. Import volumes had been rising rapidly: 427% since China joined WTO in 2001 (17 years!).
However, volumes of U.S. imports from China dropped significantly following imposition of tariffs in the second half of 2019. See a graph published in the Washington Post. U.S. Census Bureau data show U.S. imports from China declined 16% in 2019 compared to 2018 (from $539 billion to $452 billion). The Post graph shows imports from China have begun to rise again in 2020, although they are still far below levels in 2016-2018.
What might this imply for imports of pests?
2019 Imports from China
Heavy goods – are the ones most likely to be packaged in wooden crates or on wooden pallets that can transport pests. These include metal and stone products (including tile); machinery (such as automobile parts and farm equipment); electronics; bulk food shipments; and finished wood articles
Many goods imported from China are heavy so their packaging might facilitate pest invasions. Unfortunately, the various websites combine types of imports in different categories, so it is difficult to compare data from the various years. Worse, while I easily found data for 2019 and 2020, I could not find 2018 data (it must be there somewhere!). Still, six of the top eleven categories in 2019 appear to fall into the “heavy” categories.
Also, China is the third largest supplier of agricultural imports, primarily processed fruits and vegetables, including juices (together, about $1.5 billion), snack foods ($222 million), spices ($167) million, and fresh vegetables ($160 million).
Trade from Hong Kong is reported separately, but it is not a significant amount – $6.3 billion in 2018; and is declining. Electrical machinery is the largest category, at $980 million.
2020 Imports from China
Import volumes declined substantially during the first five months of 2020, compared to the same period in 2019:
Cell phones & related equipment fell 18.53%
Computers fell 4.86%
Miscellaneous textile rose 300%
Motor vehicle parts fell 26%
Seats excluding medical and dental fell 32.5%
The principal sea ports receiving goods from China during the period January – May 2020 were
Los Angeles $35.27 billion – fell 31.9%
Long Beach $10.61 billion – fell 22%
Newark $9.21 billion – fell 28%
Savannah $8.38 billion
Oakland $4.94 billion
Houston $4.29 billion
Pest Implications
These reduced volume of imports would seem to promise a reduced pest risk. Other factors point in the same direction.
Mode of transport is also significant, that is, air freight versus sea or land transport. In the first five months of 2020, https://ustr.gov/countries-regions/china-mongolia-taiwan/peoples-republic-china a quarter of U.S. imports from China, or $36 billion, entered through just four airports: Chicago’s O’Hare, Los Angeles, Anchorage, and JFK in New York. It is also encouraging that the volumes shipped by air apparently rose. The data show that at O’Hare imports rose 8.4%; at Los Angeles they rose 22%. The website does not provide data for Anchorage or New York. This could be a temporary fluke, for example, if importers were trying to acquire supplies quickly, before new tariffs took effect.
A larger proportion of goods shipped by air might result in a lower approach rate for wood-boring insects, since airborne goods are probably less likely to be packaged in wood. More than a decade ago, Meissner et al. (2009) found that only a third of air shipments (from all countries) were packaged in wood, compared to three-quarters of maritime shipments. I wonder if this is the reason that they found that shipments from China were only half as likely to be enclosed in wood packaging as were shipments from other exporting countries.
Even if China is cutting its imports in quantity, significant problems with quality persist. China consistently ranks second (to Mexico) in the number of shipments containing wood packaging that does not comply with international and U.S. regulations. Over the period 2011-2016, shipments from China constituted 11% of shipments detected by the Bureau of Customs and Border Protection as non-compliant (APHIS database / pers. comm).
So the pest risk persists. Remember that in 1986 – about the time the Asian longhorned beetle and the emerald ash borer were introduced from China – the U.S. imported only $3.8 billion worth of goods from that country. Of course, the U.S. did not require treatment of wood packaging from China until January 1999. My previous blogs have frequently documented the continuing presence of pests in wood packaging from China. To see the series, visit www.nivemnic.us, scroll down below archives to “categories”, click on “wood packaging”.
goldspotted oak borer
Because Mexico has an even worse record of compliance with wood packaging regulations than does China, it is good news that U.S. imports from there fell even more precipitously (see graph here). Pests that might be introduced in wood from Mexico generally pose less of a risk, but the risk is not zero! Three woodborers from Mexico – goldspotted oak borer, soapberry borer, and walnut twig beetle – have proved lethal to naïve species growing in the U.S. Each is described here.
Conclusion
Although the presumably temporary collapse of global trade might provide a respite from pest introductions, it is not a long-term strategy. Furthermore, resulting decreases in user fees will reduce the CBP’s inspection staff. I call again for revision of the international phytosanitary system to focus on preventing the movement of plant pests. The designation of 2020 as the International Year of Plant Health means now is the appropriate time to initiate such action.
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
SOURCES
Haack, R.A., F. Herard, and J. Sun, and J.J. Turgeon. 2010. Managing Invasive populations of Asian longhorned beetle and citrus longhorned beetle: a worldwide perspective. Annual Review of Entomology 55: 521-546.
Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory
The U.N. Food and Agriculture Organization has declared 2020 to be the International Year of Plant Health. APHIS, U.N. FAO, and others planned celebratory events — most now postponed.
The designation prompts consideration of whether the current global phytosanitary system – created in 1995 – is succeeding in preventing movement of invasive plant pests and invasive plants. Join me in this evaluation!
I focus on evaluating the most widespread invasive pests killing trees – and the pathways on which they travel. Some of the most damaging tree pests, of course, were moved around the world decades ago. But too many have been transported after the modern plant health system was developed in the mid-20th Century with the adoption of the original International Plant Protection Convention (IPPC) in 1951.
Of course, this is also the period when trade volume exploded, resulting in new source countries, new products, and new technologies that facilitated newly rapid movement of goods and accompanying pests. See my earlier blog here and the book by Marc Levinson, The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger. It iswell-documented that rising trade volumes, new trade connections, new products have and will continue to exacerbate unintended movement of species (Seebens et al., 2018).
The phytosanitary regime was massively revised in the mid-1990s through adoption of the World Trade Organization and the Agreement on Sanitary and Phytosanitary Standards (SPS Agreement). Two principal changes were to constrain individual countries’ freedom to establish their own phytosanitary regulations and to require evidence of risk rather than allowing action on the basis of “if in doubt, keep it out”. I have written a critique of the new system in Fading Forests II. See Chapter 3, available here.
USDA officials burn infested cherry trees – gifts from Japan Washington, D.C. 1912
Has the new regime allowed spread of pests, as I predicted in my critique?
Of course, the explosion of global trade has made prevention of species introductions far more difficult. So the rising numbers of introductions cannot be blamed entirely on the SPS Agreement. Still, it is vital to review pest status in order to see whether the SPS Agreement is succeeding in protecting Earth’s flora. Here, I am looking at only one type of bioinvader. Many more types need to be evaluated, even among plants and plant pests. Nor do I pretend that my list is comprehensive even in the category I focus on – tree-killing insects, nematodes, and pathogens.
My definition of “global invader” is an insect, pathogen, or nematode that has been moved from its known or probable place of origin to at least two novel continents or widespread island groups.
Before the SPS Agreement
Of course, many highly damaging forest insects and pathogens spread widely before the eruption of global trade in the second half of the 20th Century. Examples include several pathogens:
American chestnut bred to be resistant to blight photo by F.T. Campbell
Phytophthora cinnamomi – Europe, North America, Oceania, South America
Cryphonectria parasitica – Europe and North America; Oceania probably much later
Dutch elm disease causal agents Ophiostoma ulmi & novo-ulmi (the vectors are sometimes native insects) – Europe, North America, Oceania;
And some insects:
Hylastes ater – Oceania, South America, Africa
Scolytus multistriatus (Dutch elm disease vector) – North America 1909; later to Oceania; mid-20th Century to Africa
There have also been initial introductions of some organisms that would become “global” later:
Phytophthora lateralis – North America before 1950
During the period 1950 – 1995 –when trade began exploding and countries were adopting their own phytosanitary regulations as allowed under the original IPPC – the following pests were introduced “globally”:
P. ramorum in Big Sur, California photo by Matteo Garbelotto
Phytophthora ramorum was introduced from Southeast Asia to Europe and North America.
Hylurgus ligniperda – Oceania, South America, Africa, Asia after 1950; North America before 1995
Phoracantha recurva – detected in various geographies after 1995, but almost certainly introduced to North America, South America, Europe, Africa, and Oceania before that date
Palm pests – red palm weevil (Rhynchophorus ferrugineus) to most areas of the Old World and Oceania where palms grow; coconut rhinoceros beetle (Oryctes rhinoceros) around Africa, Mauritius, Reunion; Oceania;
Again, there were initial introductions of numerous insects in wood packaging and on “plants for planting” that would expand to “global” ranges after 1995:
Anoplophora glabripennis
To North America: Anoplophora glabripennis;, Agrilus planipennis; Austropuccinia psidii; Phoracantha recurve; Glycaspis brimblecombei
To Asia: Pine wood nematode Bursaphelenchus xylophilus
To Oceania, South America – Sirex noctillio;
After the SPS Agreement
There has been an apparent explosion of spread since adoption of SPS Agreement in 1995. No doubt these introductions were made possible by the concurrent explosion of trade volumes and more pest-friendly shipping practices (e.g., use of shipping containers and more rapid transportation). The principal vector appears to be plants for planting. About 50% of new plant pathogen invasions are associated with plants for planting (Jimu et al. 2016). Wood packaging is a strong second vector.
Tree-killing pests of which I am aware that have apparently spread globally after 1995 include:
Insects
Aulacaspis ysumatsui – North America, Caribbean, Pacific Ocean islands, Oceania, Africa, Europe, various islands off Southeast Asia that are probably outside original range
Erythrina humeana in the Manie van der Schijff Botanical Garden, Pretoria vulnerable to Euwallacea / Fusarium complex
Quadrastichus erythrinae – North America, Southeast Asia, islands in the Indian and Pacific oceans
Euwallacea fornicatus complex, esp. Euwallacea whitfordiodendrus and E. kuroshio and their Fusarium symbionts Fusarium euwallaceae, Graphium euwallaceae, & Paracremonium pembeum – North America, Africa
Several insects that attack Eucalyptus have been widely introduced to areas where plantations of these species have been planted, e.g.,
Blue gum chalcid wasp or eucalyptus gall wasp Leptocybe invasa – throughout Africa, the Middle East, Asia, the Pacific Region, Europe, South America, Mexico, and the United States [CABI]
Red gum lerp psyllid (Glycaspis brimblecombei) Europe 2009 [EPPO]
Eucalyptus snout beetles Gonipterus spp complex à two species introduced to five continents (Schroder et al. 2019).
Eucalyptus gall wasp(Ophelimus maskelli) – Mediterranean Region, the Middle East, South Africa, Europe, U.S., New Zealand [CABI]
Continued spread of species that had been introduced to a single new continent before 1995:
Pine wood nematode Bursaphelenchus xylophilus – to Europe
Phytophthora lateralis – to Europe and South America
Myrtle rust Austropuccinia psidii – to Pacific oceanic islands and Oceania
Anoplophora glabripennis and A. chinensis – to Europe
Sirex noctillio – to North America
Agrilus planipennis – to Russia and western Europe
Red palm weevil (Rhynchophorus ferrugineus) – to North America (California- eradicated)
Coconut rhinoceros beetle (Oryctes rhinoceros) – to Pacific islands, e.g., Guam and Hawai`i
I note that several studies have identified large numbers of introduced species in certain categories, although the dates of introduction are uncertain. Some were probably introduced before 1995. Here I cite the following:
Jung et al. (2015) found 59 putative Phytophthora taxa in forest and landscape planting sites in Europe; none had been detected by inspectors at the European Union borders.
Jimu et al. (2019) report global spread of Eucalyptus pathogens carried by the trade in seed and cuttings to support establishment of new plantations and breeding programs.
Numerous species of Phytophthora across North America – about 60 species in California native plant nurseries; eleven species in Minnesota (both from Swiecki et al. 2018); Parke et al. (2014) identified 28 Phytophthora taxa in four Oregon nurseries.
Nine species of Phytophthora associated in urban streetscapes, parks, gardens, and remnant native vegetation in urban settings in Western Australia (Barber et al. 2013).
So What’s the Bigger Picture?
I have blogged frequently about the weaknesses of the international standard governing wood packaging; go here.
Clearly the weaknesses of the international phytosanitary system are not limited to the wood packaging pathway. And I repeat that the phytosanitary system is under severe challenge by trade volumes and practices – at least before the Covid-19 pandemic. Still, it is clear that the international phytosanitary system has failed in achieving its purpose: to provide adequate protection in response to this challenge.
I have two suggestions:
1) I hope that the most affected countries will take actionper their authority under Section 5.7 of the SPS Agreement. This allows emergency action to prevent further introductions via the principal pathways and from the geographic origins posing the greatest threats (e.g., China for wood packaging, Southeast Asia for Phytophthorapathogens).
2) I hope further that all the nearly 200 countries that are parties to the SPS Agreement and the IPPC will rapidly institute an analysis of the current phytosanitary system to quickly identify amendments to the agreements that would better enable countries to protect their plants from non-native pests.
SOURCES
Barber, P.A., T. Paap, T.I. Burgess, W. Dunstan, G.E.St.J. Hardy. 2013. A diverse range of Phytophthora species are associated with dying urban trees. Urban Forestry & Urban Greening 12 (2013) 569-575
Jimu, L., M. Kemler, M.J. Wingfield, E. Mwenje, and J. Roux. 2016. The Eucalyptus stem canker pathogen Teratosphaeria zuluensis detected in seed samples. Forestry 2016 89 316-324 https://academic.oup.com/forestry/article/89/3/316/1749105
Levinson, M. The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger Princeton University Press 2008
Schroder, M. Slippers, B., Wingfield, M.J., Hurley, B.P, Invasion history and management of Eucalyptus snout beetles in the Gopterus scutellatus species complex. 2019. Journal of Pest Science
Parke, J.L., B.J. Knaus, V.J. Fieland, C.Lewis, and N.J. Grünwald. 2014. Phytophthora Community Structure Analyses in Oregon Nurseries Inform Systems Approaches to Disease Management. Phytopathology Vol. 104, No 10.
Schroder, M. Slippers, B., Wingfield, M.J.,Hurley, B.P, Invasion history and managementof Eucalyptus snout beetles in the Gopterus scutellatus species complex. 2019. Journal of Pest Science
Seebens, H., T.M. Blackburn, E.E. Dyer, P. Genovesi, P.E. Hulme, J.M. Jeschke, S. Pagad, P. Pyse, M. van Kleunen, M. Winter, M. Ansong, M. Arianoutsou, S. Bacher, B. Blasius, E.G. Brockerhoff, G. Brundu, C. Capinha, C.E. Causton, L. Celesti-Grapow, W. Dawson, S. Dullinger, E.P. Economo, N. Fuentes, B. Guénard, H. Jäger, J. Kartesz, M. Kenis, I. Kühn, B. Lenzner, A.M. Liebhold, A. Mosen, D. Moser, W. Nentwig, M. Nishino, D. Pearman, J. Pergl, W. Rabitsch, J. Rojas-Sandoval, A. Roques, S. Rorke, S. Rossinelli, H.E. Roy, R. Scalera, S. Schindler, K. Stajerová, B. Tokarska-Guzik, K. Walker, D.F. Ward, T. Yamanaka, and F. Essl. 2018. Global rise in emerging alien species results from increased accessibility of new source pools. PNAS Plus. Available at http://www.nature.com/articles/ncomms14435
Swiecki, T.J., E.A. Bernhardt, and S.J. Frankel. 2018. Phytophthoraroot disease and the need for clean nursery stock in urban forests: Part 1 Phytophthora invasions in the urban forest and beyond. Western Arborist Fall 2018.
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
myrtle rust infestation; source: New Zealand Department of Agriculture alert May 2017
Pacific countries’ policy and management responses to the spread of the myrtle rust pathogen, Austropuccinia psidii (formerly Puccinia psidii), has had puzzling – even infuriating – gaps … which perhaps have contributed to its spread and damage.
Reminder: ‘ōhi‘a or myrtle rust attacks species in the Myrtaceae – a family now said to include 5,600 species (Stewart et al. 2018). Ten percent of Australia’s native flora is in the family – or about 1,300 species. New Zealand is home to 27 native plants in the Myrtaceae family (Bereford et al. 2019) and the Hawaiian Islands to eight (JB Friday pers. comm.). See a writeup about the disease here.
Austropuccinia psidii is one of the global invaders: it has invaded 27 countries on several continents. It is apparently native to parts of the American tropics.
Levels of worry rose considerably with the pathogen’s spread across the Pacific beginning with the detection in Hawai‘i in spring 2005. Additional introductions in the region were Japan in 2009; China in 2011; Australia, New Caledonia, and South Africa in 2013; and New Zealand in 2017.
The known host range currently exceeds 500 species in 86 genera – all in the Myrtaceae family. The pathogen has several strains or biotypes; the impact of the various biotypes on the various host species differs. Environmental factors also apparently affect disease.
[For my earlier discussions of threats to the unique Hawaiian flora, go here for dryland flora, here and here for more general discussions. I discuss National Park Service efforts – including in Hawai`i – here.]
There are several factors that militate against a political entity choosing to act:
1) Inherent Difficulty in Controlling Wind-Borne pathogen
In both Hawai`i and Australia, the rust spread rapidly once it was established outside of nurseries. In Hawai`i, it had spread to all the islands within a few months of its detection in spring 2005 (Loope and La Rosa 2008). In Australia, the rust was established in natural ecosystems throughout coastal New South Wales and to far northern Queensland by mid-2012 – less than two years after detection (Carnegie et al. 2016). The number of host species also expanded rapidly – from 214 native plants in 2016 (Carnegie et al. 2016) to 393 species by 2019 (Winzer et al. 2019). Myrtle rust is believed to have been carried to Australia and New Caledonia on imported plants or cut vegetation; then to New Zealand by winds from Australia across the Tasman Sea (Toome-Heller et al. 2020).
2) Lack of Clarity About Probable Impacts
Austropuccinia psidiihad been introduced fairly widely before 2000, and some biotypes had caused significant damage on introduced species within both the native and introduced ranges of the rust – e.g., Eucalyptus in Brazil, allspice (Pimento doica) in Jamaica, rose apple (Syzygium jambos) in Hawai`i. However, the rust had had little impact on native floras in introduced ranges, especially not on widespread species (Carnegie et al. 2016).
However, concerns existed in the Pacific region because of:
Its wide host range (before the introduction to Australia, the known host range was “only” 129 species in 33 genera Carnegie et al. 2016).
The severe damage to Australian genera growing outside their native range, e.g., nurseries and plantations of Eucalyptus in South America and Melaleuca quinquenervia and Rhodomyrtus tomentosa in Florida (Carnegie et al. 2016)
In Hawai`i, ‘ōhi‘a rust caused little damage to the dominant tree species in Hawaiian forests, ‘ōhi‘a lehua for the first 10 years after its introduction. The rust did cause severe damage to the invasive alien shrub rose apple and several native plants, especially the endangered Eugenia koolauensis. A more damaging outbreak in ‘ōhi‘a lehua trees in 2017 has increased concern.
ohia rust on E. kooaulensis photo by Edward Eickhoff via Flickr
So – while Austropuccinia psidii has an extremely wide host range, its impact in naïve ecosystems to which it might be introduced is unclear.
In most cases, lack of knowledge about a pest’s impacts on naïve hosts in new ranges is almost inevitable – unless scientists undertake host vulnerability tests. Such tests are rarely done in advance of an introduction. One exception is European scientists evaluating European trees’ vulnerability to a suite of newly discovered Phytophthora species in Vietnam and elsewhere. (I am unaware that U.S. scientists are carrying out parallel studies.)
Still, environmental and other factors play important roles and might counter expectations raised by lab experiments or experience of hosts planted in non-native sites. In Australia, McRae (2013) noted that the “mycological firestorm” predicted by environmentalists to result from introduction of the rust had not occurred. This at least partly explained waning interest in combatting the pathogen (Carnegie et al. 2016).
In my view, the swings in perceptions of the risk reflected more flaws in understanding than actual risk. Impacts can take time to manifest – especially when, as with Austropuccinia psidii – the pathogen is known to affect primarily new growth and fruit and flowers (Carnegie et al. 2016). The impact might be greatest in the form of suppressing regeneration rather than by killing mature trees right away. [See beech leaf disease as another possible example of this phenomenon.]
Questions hampering predictions of impact were further confused by taxonomic questions (Carnegie et al. 2016). Austropuccinia psidii has at least nine genetically distinct clusters. So far, two have been introduced outside South/Central America. One strain – called the “pandemic biotype” – has been found at all introduction sites in Florida, Hawai‘i, Asia, and the Pacific – Australia, New Zealand, New Caledonia (Stewart et al. 2018). This biotype is not known to be present in Brazil (Toome-Heller et al. 2020). A second biotype has been introduced to South Africa; it has been shown to be able to infect some Myrtaceae in New Zealand (Toome-Heller et al. 2020). See especially Stewart et al. 2017, full citation below.
3) Policy Barriers Created by Phytosanitary Regulations
In the U.S., the pathogen has been established in one state – Florida – since 1977. There, it is not considered to be causing damage to important species. Under U.S. regulations – reflecting the international trade rules – an organism that is already in the country cannot be treated as a “quarantine pest” unless there is an “official control program” targeting the pest. (For a discussion of this issue, see the analysis of the SPS Agreement in Chapter 3 and Appendix 3 of Fading Forests II). For this reason, when ‘ōhi‘a rust was detected in Hawai`i in 2005, USDA’s Animal and Plant Health Inspection Service (APHIS) was unable to adopt regulations governing imports or interstate movement of vectors (i.e., cuttings or nursery stock of plant species in the Myrtaceae).
The State responded to the initial detection by adopting an emergency order two years later, in August 2007. This prohibited importation of plants in the myrtle family from “infested areas”- specified as South America, Florida, and California. This state rule expired in August 2008.
It became apparent that USDA APHIS would not take action to assist Hawai`i unless APHIS accepted scientific findings as proving that additional biotypes of the rust existed that could pose a more severe threat to plants on the Islands. Such studies were undertaken, some funded by the USDA Forest Service. This process took years. During this period, Hawai`i developed a permanent rule which was adopted in May 2020. This regulation restricts the importation to Hawai`i of plants in the Myrtaceae, including live plants and foliage used in cut flower arrangements. Dried, non-living plant parts, seeds that are surface sterilized, and tissue cultured plants in sterile media and containers are exempted from the ban. Other importations may be done by permit.
Meanwhile, in 2019, APHIS proposed to include all taxa in the Myrtaceae destined for Hawai`i in an existing regulatory category of “plants for planting” not authorized for importation pending pest risk assessment (NAPPRA). The intent was to reduce the probability of introduction of additional strains of Austropuccinia psidii to the Islands. This proposal appeared 14 years after the rust was first detected in Hawai`i. And the proposal has not yet taken effect. Therefore, imports of most living plants and cut foliage are still subject only to inspection (7 Code of Federal Regulations 319.37). The tiny size of the rust spores makes detection during inspection unlikely unless the plant is displaying symptoms of the disease.
Imports of logs and lumber involving tropical hardwood species (including Eucalyptus) into Hawai`i are regulated under separate provisions which have been in effect since 1995. The wood must be debarked or fumigated [Code of Federal Regulations – 7 CFR 319.40-5(c)]. Incoming wood packaging is regulated under ISPM#15; I think it unlikely that the treatments prescribed therein would kill any rust spores present.
Policy Responses in Other Vulnerable Countries
Australia
Austropuccinia psidii had been recognized as a potentially serious biosecurity threat to Australia as early as 1985 (publications cited by Carnegie et al. (2016). The introduction of ‘ōhi‘a rust to Hawai`i so alarmed plant health and conservation officials in Australia and New Zealand that they sent representatives half way around the world to participate in the North American Plant Protection Organization’s annual meeting in Newfoundland, Canada, in October 2007! Yet interest in Australia waned when large scale tree mortality and major impacts on industries did not immediately occur (Carnegie et al. 2016). The state of New South Wales listed the rust as a Key Threatening Process to the Natural Environment, but the federal agencies rejected a petition to do the same at a national level (Carnegie et al. 2016).
Groups of scientists are carrying out research with the goal of demonstrating that the rust is already having severe effects on key species in natural ecosystems, and probably significantly affecting a wider range of species (Carnegie et al. 2016; Winzer et al. 2019; Winzer et al. 2020)
In 2018 a scientist affiliated with the Australian Network for Plant Conservation published a draft conservation plan. Its development had input from staff at the Plant Biosecurity Cooperative Research Centre and the Australian Government Department of the Environment and Energy. The goal was to help direct and stimulate further research on critical questions and build awareness of the potentially devastating effects myrtle rust might have if it remains unchecked. As of April 2020, no funding had yet become available to finalize and implement the report (Dr Michael Robinson, Managing Director, Plant Biosecurity Science Foundation).
New Zealand
New Zealand has been more aggressive in its policy approach. It adopted a strategy when Australia announced arrival of the rust in 2010. The islands had bad luck – myrtle rust is believed to have been carried to New Zealand by wind from Australia across the Tasman Sea.
As soon as the rust was first detected in 2017, two government agencies initiated broad surveys of Myrtaceae across natural and urban areas, with active outreach to citizens (Toome-Heller et al. 2020). By April 2018, it was recognized that the pathogen was too widespread to be eradicated. Significant finds were made on the western side of the North Island and at the very northern tip of the South Island (see map in Beresford et al. 2019). At that point, the government changed its focus to long-term management of the disease.
A. psidii is still very much a focus for Maori (indigenous) groups, central and local government, community groups, Myrtaceae-based industries, and research institutions.
Several research programmes are currently looking for management options, including resistance breeding (Toome-Heller et al. 2020). See research plan and reports of results to date here. However, which plant species can become infected, and under what environmental conditions, remain unclear.
New Zealand researchers have made some findings that should be of concern to forest pathologists working with all Myrtaceae:
A. psidii can overwinter as a latent infection without reproducing.
A. psidii can reproduce sexually, although the importance of the sexual cycle in seasonal epidemic development is not yet understood and teliospores have only infrequently been found in New Zealand (Bereford et al. 2019).
the unique biotype found in South Africa has already been found to be pathogenic towards some New Zealand native Myrtaceae (Toome-Heller et al. 2020).
We can expect these finding to have implications for elsewhere, including in Hawaii.
Pathways of Introduction
It is thought probable that the rust was introduced to Hawai`i on cut foliage imported from Florida. The first Australian detection was at a cut flower facility (Australian Invasive Species Council).
CABI considers plants and plant parts (including cuttings, flowers, and germplasm) to be the principal pathway. Other pathways appear to be contaminated plant waste, timber, wood packaging and dunnage; and – over short distances – contaminated equipment and tools and clothing, shoes and other personal effects.
Conclusions
The saga of myrtle rust demonstrates both the biological and technical difficulties of controlling an airborne pathogen and the inability of the existing phytosanitary system to respond to new situations. Regulatory officials are obligated to demand levels of knowledge and certainty that just are not realistic. The gap is especially great at the crucial time – before an invasion or at its earliest stage — when phytosanitary actions might be most effective.
This saga also demonstrates that efforts often wane at the management and restoration stages. At least in Hawai`i and New Zealand, government resources are still being allocated to research possible resistance breeding or other possible long-term approaches. I refer you to the article by Enrico Bonello, me, and others about the need to provide sufficient resources to such efforts in the U.S.
Sources
Australian Invasive Species Council.2011. www.invasives.org.au Environmental impacts of myrtle rust Fact Sheet February 2011
Carnegie, A.J., A. Kathuria, G.S. Pegg, P. Entwistle, M. Nagel, F.R. Giblin. 2016. Impact of the invasive rust Puccinia psidii (myrtle rust) on native Myrtaceae in natural ecosystems in Australia. Biological Invasions (2016) 18:127–144
Code of Federal Regulations. January 1, 2005 (Title 7, Volume 5). 7 CFR319.40-5: Logs, lumber, and other unmanufactured wood articles – importation and entry requirements for specified articles. (available by using search engines/retrieval services at http://www.gpoaccess.gov/fr/index.html).
Code of Federal Regulations. January 1, 2005 (Title 7, Volume 5). 7 CFR319.37: Nursery stock, plants, roots, bulbs, seeds, and other plant products – prohibitions and restrictions on importation: disposal of articles refused importation. (available by using search engines/retrieval services at http://www.gpoaccess.gov/fr/index.html).
Loope, L. and A.M. La Rosa. 2008. An Analysis of the Risk of Introduction of Additional Strains of the Rust Puccinia psidii Winter (`Ohi`a Rust) to Hawa`i. Pacific Island Ecosystems Research Center
Stewart, J. E., A. L. Ross-Davis, R. N. Graça, A. C. Alfenas, T. L. Peever, J. W. Hanna, J. Y. Uchida, R. D. Hauff, C. Y. Kadooka, M.-S. Kim, P. G. Cannon, S. Namba, S. Simeto, C. A. Pérez, M. B. Rayamajhi, D. J. Lodge, M. Agruedas, R. Medel-Ortiz, M. A. López-Ramirez, P. Tennant, M. Glen, P. S. Machado, A. R. McTaggart, A. J. Carnegie, and N. B. Klopfenstein. 2018. Genetic diversity of the myrtle rust pathogen (Austropuccinia psidii) in the Americas and Hawaii: Global implications for invasive threat assessments. Forest Pathology 48(1): 1-13. https://doi.org/10.1111/efp.12378
Toome-Heller, M. W.W.H. Ho, R.J. Ganley, C.E.A. Elliott, B. Quinn, H.G. Pearson, B.J.R. Alexander. 2020. Chasing myrtle rust in New Zealand: host range and distribution over the first year after invasion. Australasian Plant Pathology
Winzer, L.F., K.A. Berthon, A.J. Carnegie, G.S. Pegg, M.R. Leishman. 2019. Austropuccinia psidii on the move: survey based insights to its geographical distribution, host species, impacts and management in Australia. Biological Invasions April 2019, Volume 21, Issue 4, pp 1215–1225
Winzer, L.F., K.A. Berthon, P. Entwistle, A. Manea, N. Winzer, G.S. Pegg, A.J. Carnegie, M.R. Leishman. 2020. Direct and indirect community effects of the invasive plant pathogen Austropuccinia psidii (myrtle rust) in eastern Australian rainforests. Biological Invasions. Volume 22, pages2357–2369 (2020)
Here we go again … another Asian longhorned beetle population established in the U.S.
For the ninth time in 24 years, the Asian longhorned beetle (ALB) has been found in North America – this time in South Carolina.
This means thousands – perhaps tens of thousands – of trees will be removed. Thousands more will be injected with imadacloprid. Millions of dollars will be spent. There will be uncounted aesthetic and spiritual losses. There will be unmeasured damage to at least the local environment – which probably includes bottomland hardwood forests – protection of which South Carolina has declared to be a conservation priority. All this destruction is necessitated by the need to prevent catastrophic damage to North America’s hardwood forests by the ALB.
By early August I have learned that the South Carolina outbreak has been present for seven years or longer, and that it might be related to the Ohio outbreak (which was detected in 2011 but was probably introduced at least four years earlier). APHIS reports that, as of the end of July, nearly 1,300 infested trees had been detected. The area around the neighborhood where the detection was made is swampy – complicating search and removal operations and probably home to many box elder and willows – preferred hosts for the ALB.
Why did we let this happen? Why do we persist with a policy that has allowed repeated introductions of this pest via the well-documented wood packaging pathway? After all, we learned about this risk 22 years ago – after the ALB introductions to New York and Chicago. We have had plenty of evidence that the policy is failing. We know how to stop this. Why do we – through our elected and appointed government officials – not act to prevent it?
What We Need: a New, Protective Policy
With live pests continuing to be present in wood packaging 14 years after the U.S. and Canada imposed the treatment requirements in ISPM#15 – and 21 years after we required China to treat its wood packaging – we urgently need better federal policy. I have long advocated:
USDA APHIS join Bureau of Customs and Border Protection in penalizing violators for each violation; stop allowing five violations over a 12-month period before applying a penalty.
APHIS and the Canadian Food Inspection Agency (CFIA) should apply their rights under Section 5.7 of the World Trade Organization Sanitary and Phytosanitary Agreement to immediately prohibit China from packaging its exports in wood. China can use crates and pallets made from such alternative materials as plastic, metal, or oriented strand board.
APHIS and CFIA should being the process of supporting permanent application of this policy to China and other trade partners with poor compliance records. This step would require that they cite the need for setting a higher “level of protection” and then prepare a risk assessment to justify adopting more restrictive regulations.
USDA Foreign Agriculture Service (FAS) should assist U.S. importers to determine which suppliers reliably provide wood packaging that complies with ISPM#15 requirements.
USDA FAS and APHIS should help importers convey their complaints about specific shipments to the exporting countries’ National Plant Protection Organizations (NPPOs; departments of agriculture).
APHIS should increase pressure on foreign NPPOs and the International Plant Protection Convention more generally to ascertain the reasons ISPM#15 is failing and to fix the problems.
APHIS should fund more studies and audits of wood packaging to document the current efficacy of the standard, especially
Update the Haack study of pest approach rate.
Determine whether high rates of pest infestation of wood bearing the ISPM#15 mark results from fraud or failures of treatment – and whether any failures are due to mistakes/misapplication or shortcomings in the treatment themselves.
Allocate the risk among the three major types of wood packaging: pallets, crates, and dunnage.
These folks work for us – tell them to protect our forests!
Tree-Smart also has a Twitter account: @treeSMARTtrade
Justification
The ALB poses a threat to 10% of US forests and nearly all of Canada’s hardwoods, so eradication of the South Carolina outbreak is essential. For a longer discussion of ALB introduction history, the threat, and eradication efforts to date, visit here. https://www.dontmovefirewood.org/pest_pathogen/asian-long-horned-beetle-html/).
Another ALB Outbreak in the US: No Surprise
This Chinese insect is a world traveler. It has been detected 36 times outside its natural range: in North America, Europe, and Japan. Seventeen of these outbreaks have been detected since 2012 (Eyre & Haack 2017). These 17 introduction have occurred six years or later after the 2006 implementation of the International Standard for Phytosanitary Measures (ISPM) #15 – which was intended to reduce the likelihood of such introductions. .Ten of the outbreaks have been eradicated (Eyre & Haack 2017; APHIS press release October 2019). This includes four in the United States and Canada; see here.
Despite U.S. and international efforts, ALB and related pests have been detected continuously in imported goods. U.S. and European data (Eyre and Haack 2017) document rising numbers of Cerambycids detected in wood packaging in recent years. (For a description of pest prevention efforts, see Fading Forests II and III here and this blog).
It is also not surprising that the newly introduced pest is from China. It has long been among countries with the worst records on implementing ISPM#15.
The APHIS-CBP joint study of pest interceptions over the period 2012 – 2017 (Krishnankutty et al. 2020b) found the highest numbers of interceptions came from Mexico, China, and Turkey. During the period 2011 – 2016, China accounted for 11% of interceptions (APHIS interception database – pers. comm. January 2017).
These numbers reflect in part the huge volumes of goods imported from China. But China’s poor performance has continued, perhaps even increased in recent years. For example, consider the choice of wood used to manufacture packaging. Authorities recognized by the late 1990s that wood from plantations of Populus from northern China was highly likely to be infested by the Asian longhorned beetle. Yet, more than a dozen years later, this high-risk wood was still being used: between 2012 and 2017, the ALB was intercepted six times in wood packaging made of Populus wood – each time originating from a single wood-treatment facility in China (Krishnankutty et al. 2020b).
The location just outside Charleston also is not a surprise. Charleston ranked seventh in receipt of incoming shipping containers in 2018. Charleston received 1,022,000 containers, or TEUs measured as 20-foot equivalents, in 2018 (DOT report). This was a 14% increase over the 894,000 TEUs in 2017 http://www.marad.dot.gov/MARAD_statistics/index.html – click on “trade statistics”, then “US Waterborne trade” (1st bullet). I expect decreased import volumes in 2019 and 2020 due to the tariffs/trade war and the 2020 economic crash linked to the Covid-19 virus.
Why US and International Policy Still Fails
Leung et al. (2014) estimated that implementation of the International Standard of Phytosanitary Measures (ISPM)#15 resulted in only a 52% reduction in pest interceptions. They concluded that continued implementation at the 2009 level of efficacy could triple the number of wood borers established (not just intercepted) in the U.S. by 2050.
Since 2010 the Department of Homeland Security’s Bureau of Customs and Border Protection (CBP) has found an average of 794 shipments infested by pests each year (Harriger). In 2019 specifically, live pests were found in 747 shipments (Stephen Brady, CBP, April 2020). These violations were occurring four to 13 years after the U.S. began implementing ISPM#15 in 2006. According to my calculations, based on estimates of pest approach rates by Haack et al. (2014), these detections probably represented about eight percent of the total number of infested shipments entering the country each year.
And there are good reasons to think this estimate is low. First, Haack et al. (2014) did not include imports from China, Canada, or Mexico in their calculations. Both China and Mexico rank high among countries with poor compliance records. Second, Haack and Meissner based their calculations on 2009 data – 11 years out of date. Since 2009, ISPM#15 has been amended to make it more effective. The most important change was restricting the size of bark remnants that may remain on wood. Also, countries and trading companies have 11 more years of implementation – so they might have improved their performance. I have asked several times that APHIS commission a new analysis of Agriculture Quarantine Inspection Monitoring data. We all need an up-to-date determination of the pest approach rate, not only before but also after the CBP action. Without it, there’s no evidence whether the more aggressive enforcement stance CBP adopted in 2017 (see below) has led to reductions in non-compliant shipments at the border.
Another demonstration of the failure of ISPM#15 is the repeated presence of the velvet longhorned beetle (Trichoferus (=Hesperophanes) campestris) in wood packaging and its establishment in at least three states (Krishnankutty, et al. 2020a; also see the discussion in my recent blog here).
Astoundingly, data indicate that 97% of wood packaging infested with pests bears the stamp certifying that the wood has been treated according to the requirements of ISPM#15 – and hence should be pest-free (Eyre et al. 2018; CBP interception data). In other words, the presence of the stamp is not a reliable indicator of whether the wood has indeed been treated nor that it is pest-free. Scientists have speculated for years why this is the case. ALB’s new arrival provides an impetus to finally answer this question and to ensure policy reflects the answer.
What Federal Agencies Are Doing to Better Prevent Introductions
In contrast to such a comprehensive approach, this is what changes are under way.
CBP strengthened its enforcement in November 2017. The agency’s total “enforcement actions” increased by 400% from 2017 to 2018 (Sagle, pers. comm). The 2019 data show decreases, in absolute numbers, from earlier years in all categories: a 19% decrease below 2010-2018 in average number of shipments intercepted; a 13% decrease in number of shipments intercepted because the wood packaging lacked the ISPM#15 mark; and a decrease of 6% in the number of shipments intercepted that had a quarantine pest (Stephen Brady, CBP, April 2020). However, one year of interception data do not provide a basis for saying whether CBP’s stronger enforcement has resulted in a lower number of shipments in violation of ISPM#15 approaching our shores. Again, I call for APHIS to repeat Haack et al. (2014) study.
Harriger reported that CBP is also trying harder to educate importers, trade brokers, affiliated associations, CBP employees, and international partners about ISPM#15 requirements. CBP wants to encourage them to take actions to reduce all types of non-compliance: lack of documentation, pest presence in both wood packaging and shipping containers, etc.
APHIS has not altered its long-standing policy of allowing an importer to rack up five violations over a 12-month period before imposing a penalty. Instead, APHIS has focused on “educating” trade partners to encourage better compliance. For example, APHIS worked with Canada and Mexico – through the North American Plant Protection Organization — to sponsor workshops for agricultural agencies and exporters in Asia and the Americas
APHIS also planned to host international symposia on wood packaging issues as part of events recognizing 2020 as the International Year of Plant Health. These symposia have been postponed by travel and other restrictions arising from the coronavirus pandemic.
The Broader Significance of Continuing Wood Packaging Problems
The premise of the international phytosanitary system – the Agreement on the Application of Sanitary and Phytosanitary Standards (SPS Agreement) and the International Plant Protection Convention (IPPC) – is that importing countries should rely on exporting countries to take the actions necessary to meet the importing countries’ plant health goals. The ISPM#15 experience undermines the very premise of these international agreements.
If we cannot clean up the wood packaging pathway – which involves boards or logs that are, after all, already dead – it bodes poorly for limiting pests imported with other commodities that are pathways for tree-killing pests – especially living plants (plants for planting). Living plants are much more easily damaged or killed by phytosanitary measures, so ensuring pest-free status of a shipment is even more difficult. (A longer discussion of the SPS Agreement and IPPC is found in Chapter III of Fading Forests II, available here.
SOURCES
Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)
Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (2014) Effectiveness of the International Phytosanitary Standard ISPM No. 15 on Reducing Wood Borer Infestation Rates in Wood Packaging Material Entering the US. PLoS ONE 9(5): e96611.
Krishnankutty, S.M., K. Bigsby, J. Hastings, Y. Takeuchi, Y. Wu, S.W. Lingafelter, H. Nadel, S.W. Myers, and A.M. Ray. 2020a. Predicting Establishment Potential of an Invasive Wood-Boring Beetle, Trichoferus campestris (Coleoptera:) in the United States. Annals of the Entomological Society of America, XX(X), 2020, 1–12
Krishnankutty, S., H. Nadel, A.M. Taylor, M.C. Wiemann, Y. Wu, S.W. Lingafelter, S.W. Myers, and A.M. Ray. 2020b. Identification of Tree Genera Used in the Construction of Solid Wood-Packaging Materials That Arrived at U.S. Ports Infested With Live Wood-Boring Insects. Commodity Treatment and Quarantine Entomology
Leung, B., M.R. Springborn, J.A. Turner, E.G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. The Ecological Society of America. Frontiers of Ecology.org
Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory
USDA APHIS interception database – pers. comm. January 2017.
USDA APHIS press release dated September 12, 2018
U.S. Department of Agriculture, Press Release No. 0133.20, January 27, 2020
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
We know the dire threats to Hawaiian forests from pathogens. Some threaten the most widespread tree – ohia. Others are insects threatening trees and shrubs in the remnant dryland forests.
The forests of smaller islands of the Pacific also appear to be facing severe threats – although I have been unable to find information on the current situation.
Guam and its Neighbors
The forests of Guam, Palau, and others in the Western Pacific are among those threatened.
They are geographically isolated and hard to reach, but that distance has not protected them from biological invaders. Their predicament illustrates the dominant role of global movement and trade in spreading pests. In this case, it’s mostly trade in ornamental plants.
These islands have unique flora and fauna. And true to invasive species experts’ expectations, they are vulnerable to bioinvaders. Guam’s most famous invasive species is the brown tree snake (Boiga irregularis), which over a few decades eradicated many bird species and the only native terrestrial mammal, the fruit bat.
Less known, but equally damaging, have been a group of insects that are decimating Guam’s native forest flora.
The most widespread arboreal species in the forests of Guam and neighboring islands is the Micronesian cycad, Cycas micronesica. Its range is Micronesia, the Marianas Group including Guam and Rota Islands; and several of the western Caroline Islands, e.g., Palau and Yap (Marler, Haynes, and Lindstrom 2010).
These forests have already absorbed severe habitat destruction as the sites of fierce fighting in World War II and – in some cases – construction of large military bases. Still, cycads were the most common species in the forest as late as 2002 (Moore, A., T. Marler, R. Miller, and L. Yudin. Date uncertain).
The Worst Pest: Asian Cycad Scale
The most severe current threat to the cycads are introduced insects, especially the Asian cycad scale Aulacaspis ysumatsui.
The cycad scale is native to Southeast Asia. It was first detected on Guam in 2003, when officials noticed that cycads planted near hotels had begun to die. However, this scale had already been spreading thanks to the trade in ornamental cycads. It was detected in Florida in 1996, on Hawai`i in 1998. It continued to spread rapidly in the western Pacific: to Rota in 2007, Palau in 2008 (University of Guam 2012). By late 2019, the scale had spread globally – numerous islands and neighboring mainland areas in the Caribbean (including Puerto Rico and US Virgin Islands), several US states in the Southeast, California, and Taiwan (Moore, Marler, Miller, and Yudin. Date uncertain.) and South Africa. (vanWilgen, et. al. 2020) Also, see the map prepared by CABI.
In every case, the scale has apparently been spread on nursery stock. It is difficult to contain by standard phytosanitary measures – visual inspection – because the scale is tiny and hides deep in the base of the plant’s stiff leaves and other crevices. (Marler and Moore 2010)
By 2005 the scale was killing the native cycad on Guam. Within four years, the millions of C. micronesica on Guam were reduced by more than 90% (Marler, T.E. and K.J. Niklas. 2011). The last time cycads on Guam reproduced in any significant number was in 2004 (Marler and Niklas 2018).
The severe impact of the scale was so rapid that the International Union for Conservation of Nature and Natural Resources (IUCN) changed its listing of C. micronesica from “near threatened” in 2003 to “endangered” in 2006. (IUCN Red List of Threatened Species Online 2008).
Scientists have made several attempts to introduce a biocontrol agent. However, the most promising – the lady beetle Rhyzobius lophanthae – has failed to control the scale, despite having become virtually ubiquitous on Guam. The beetle is too big to reach the significant proportion of scale insects living in small cracks and voids within the plant structures. Evidence from another cycad species indicates that the beetles also don’t prey on scale insects living beneath trichomes (fine hairlike structures on the leaves) or on parts of the plant close to the ground. (Moore, Marler, Miller, and Yudin. Date uncertain.).
Attempts to introduce a second biocontrol organism – the parasitoid wasp Aphytis lignanensis – were stymied by the presence of R. lophanthae (Moore, Marler, Miller, and Yudin. Date uncertain).
Micronesian cycad photo by Lauren Gutierrez
Other Invasive Species Attacking Cycads
The cycad blue butterfly (Chilades pandava) was detected in 2005 and spread throughout Guam within months (IUCN 2009). Also, it’s been found on Saipan (1996) and Rota (2006). The butterfly is native to southern Asia from Sri Lanka to Thailand and Indonesia. High populations can cause complete defoliation of new foliage. Repeated defoliations can kill the plant. Cycads on Guam are particularly vulnerable because the scale has already caused loss of most of their leaves. Butterfly larvae are often protected by ants (Anonymous).
On cultivated plants the butterfly can be controlled by microbial insecticides containing Bacillus thuringiensis kurstaki (Moore). Scientists at the University of Guam are exploring use of injected insecticides (Moore). They have found an egg parasite, but parasitism levels are low. Any biocontrol agent targetting larvae would have to contend with the ants (Anonymous).
A longhorned beetle (Dihammus (Acalolepta) marianarum) and a snail (Satsuma mercatorius) are also feeding on the cycads (Marler 2010).
The Indo-Malayan termite Schedorhinotermes longirostris was detected in 2011. The termites weaken the cycad stems, which are then toppled by feeding by introduced deer. The termites are also damaging the cycad’s reproductive structures (megastrobili). Termite attacks on cycads surprised scientists since cycads do not form true wood. The termite had probably been introduced recently because, as of 2011, it had been detected only near the Andersen Air Force Base airport (Marler, Yudin, and Moore 2011).
More Isolated – but Still Overrun
Scattered across the Pacific are groups of atolls, including Palmyra and Rose.
Despite their distance from other islands, they have all been visited by mariners for centuries. As a result, they have non-native species, including insects that attack trees.
Pisonia tree forest – Wikimedia
The tree most affected is pisonia – Pisonia grandis.
The principal insect is another scale, Pulvinaria urbicola. There are some reports that the scale is farmed by ants; species mentioned include several introduced species such as the yellow crazy ant, Paratrechina longicornis.
The scale is probably from the West Indies. Once it reached the Pacific, it might have been distributed to additional islands on seabirds, which travel long distances between the atolls.
The scale’s impact is unclear.
At first, in the mid-2000s, impacts seemed dire. It was reported to be causing widespread tree death on Palmyra and Rose atolls, islands around northeastern Australia, in the Seychelles, and possibly in Tonga.
However, in 2018, scientists reported that eradication of rats on Palmyra Atoll had resulted in an immediate spurt of reproduction of a tree. Numbers of “native, locally rare tree” seedlings (possibly but not explicitly said to be Pisonia grandis) jumped from 140 pre-eradication to 7,756 post-eradication (in 2016). The study made no mention of the scale.
Rose Atoll has only one small island (6.6 ha) with vegetation. Before 1970, it was dominated by Pisonia grandis, but by 2012, there were only seven trees on the island. Several possible causes of this decline have been suggested. Other than the scale, suggested causes include storms, drought, rising sea level / saltwater incursion, and imbalance of bird guano-derived nutrients in the soil. [All information about Rose Atoll is from Peck et al., 2014)
A survey carried out in April 2012 and November 2013 detected 73 species of arthropods from 20 orders on Rose Island, including nine ant species (all but one non-native). Two of these ants – Tetramorium bicarinatum and T. simillimum – were detected tending the scales on Pisonia.
The survey found no evidence of natural enemies of the Pulvinaria scales.
The scientists tested treatment of Pisonia with the systemic insecticide imidacloprid. This treatment apparently reduced scale populations considerably for several months, but then they began to build up again.
In contrast to Palmyra, Polynesian rats (Rattus exulans) were eliminated from Rose Atoll in 1990–1991 – so their role in destroying the trees had ended 20 years before the study. What does the continued decline of the Pisonia trees in subsequent decades suggest for the future of Pisonia trees on Palmyra?
I have sought updates on the tree-pest situations on Guam and the other Pacific islands, but my queries have not received a reply.
CABI November 2019. Aulacaspis yasumatsui (cycad aulacaspis scale (CAS)) or the Asian cycad scale. https://www.cabi.org/isc/datasheet/18756 (was formerly Commonwealth Agricultural Bureaux (CAB) International; now apparently just uses acronym)
Marler, T.E. pers. comm. August 15, 2012
Marler, T.E. 2010. Cycad mutualist offers more than pollen transport. American Journal of Botany, 2010; 97 (5): 841. Viewed as materials provided by University of Guam, via EurekAlert; accessed 6 August, 2012.
Marler, T., Haynes, J. & Lindstrom, A. 2010. Cycas micronesica. The IUCN Red List of Threatened Species 2010: e.T61316A12462113. http://dx.doi.org/10.2305/IUCN.UK.2010-3.RLTS.T61316A12462113.en Accessed 22 April, 2020.
Marler, T.E., and A. Moore. 2010. Cryptic Scale Infestations on Cycas revoluta Facilitate Scale Invasions. HortScience. 2010; 45 837-839. Retrieved August 6, 2012 from www.eurekalert.org
Marler, T.E. and K.J. Niklas. 2011. Reproductive Effort and Success of Cycas micronesica K.D. Hill Are Affected by Habitat. International Journal of Plant Sciences, 2011; 172 (5): 700. Viewed as materials provided by University of Guam, via EurekAlert; accessed 6 August, 2012.
Peck, R., P. Banko, F. Pendleton, M. Schmaedick, and K. Ernsberger. 2014. Arthropods of Rose Atoll with Special Reference to Ants and Pulvinaria urbicola scales (Hemiptera: Coccidae) on Pisonia grandis trees. Hawaii Cooperative Studies Unit. University of Hawaii. Technical Report HCSU-057 December 2014
vanWilgen, B.W.,J. Measey, D.M. Richardson, J.R. Wilson, T.A. Zengeya. Editors. 2020. Bioinvasions in South Africa. Invading Nature. Springer Series in Invasion Ecology 14.
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm These reports do not include details on the pest situation on the Pacific islands (including Hawai`i).
As I noted last November, the premise of the international phytosanitary system – the Agreement on the Application of Sanitary and Phytosanitary Standards (SPS Agreement) and the International Plant Protection Convention (IPPC) – is that importing countries should, and can, rely on exporting countries to take the actions necessary to meet the importing countries’ plant health goals. However, the experience with the International Standard on Phytosanitary Measures (ISPM) #15 and wood packaging casts doubt on this premise.
Exporters are not reliably ensuring the cleanliness of their wood packaging, putting American forests at risk. Indeed, some experts have concluded that continuing to implement ISPM#15 at current levels could triple the number of non-native wood-boring insects introduced into the U.S. by 2050 (Leung et al. 2014).
Too many shipments carry wood packaging that bears no ISPM#15 stamp. And too many pieces of wood packaging arrive with the ISPM#15 stamp, yet are not reliably pest-free. If we cannot clean up this pathway – which involves boards or even logs that are, after all, already dead — it bodes poorly for limiting pests imported with other commodities that are pathways for tree-killing pests – especially living plants (plants for planting). Living plants are much more easily damaged or killed by treatments than the dead wood used in packaging – so ensuring pest-free status of a shipment is even more difficult. (A longer discussion of the SPS Agreement and IPPC is found in Chapter III of Fading Forests II, available here.
Here are the problems – and the latest evidence.
ALB larva in piece of wood packaging material
Too Many Shipments with Pest-Infested Wood Packaging Are Reaching the Country
My information on Customs and Border Protection (CBP) interceptions comes primarily from Kevin Harriger (see full reference at end of the blog). I will note when it comes from other sources.
In November 2019, Kevin Harriger reported that over the past three years, CBP detected a regulated pest, on average, in 30% of the wood packaging the agency intercepted because it was not compliant with ISPM#15. Non-compliance is defined as wood packaging that either lacks an official mark or is infested by a quarantine pest, or both.
From this and previous reports, I have 10 years of CBP interception data – from 2020 – 2019. These data thus begin four years after the U.S. began implementing ISPM#15 (in 2006) and 11 years after the U.S. began requiring China to treat wood packaging accompanying its exports (in 1999).
Over the period 2010 – 2018, CBP intercepted an average of 3,183 shipments with non-compliant wood packaging each year. On average, 2,100 (66%) of these shipments lacked the required ISPM#15 mark. A live quarantine pest was found in an average of 794 (25%) shipments. (There was some overlap in the categories).
In 2019, CBP intercepted a total of 2,572 non-compliant shipments (Stephen Brady, CBP, April 2020). Those lacking the ISPM#15 mark number 1,825 (71%). Shipments in which a live pest was found numbered 747 (29%).
The 2019 data show decreases, in absolute numbers, from earlier years in all categories: a 19% decrease below 1010-2018 average of shipments intercepted; a 13% decrease in number of shipments intercepted because the wood packaging lacked the ISPM#15 mark; a decrease of 6% in the number of shipments intercepted that had a quarantine pest. It is too early to say whether CBP’s stronger enforcement approach launched in November 2017 has resulted in a lower number of shipments in violation of ISPM#15 approaching our shores.
There has been a dispute about which categories of packaging are most likely to be infested. The categories are pallets, crates, spools for cable, and dunnage (wood used to brace cargo and prevent it from shifting). The CBP data available to me and the study by Krishnankutty et al. (2020b – see full reference at the end of this blog) shed no light on that issue.
What is the actual number of infested containers approaching our shores? We know that CBP inspects, on average, 2% of incoming containers – so the above interception data reflect a small percentage of probable true approach rate.
The first issue is, how many containers arrive here?
I have been unable to find data for 2019 – much less 2020, when the media report that import volumes have crashed. Until recently, import volumes had been rising. According to a U.S. DOT report to Congress (see reference at the end of this blog), 25 U.S. maritime ports received 24,789,000 loaded shipping containers (measured as TEU – 20-foot equivalent) in 2018. The number of incoming containers had increased at the top three ports – Long Beach, Los Angeles, and New York / New Jersey – between 3% and 7% since 2016.
However, APHIS told me in November 2019 that CBP reports that only about 13 million loaded containers enter the country every year by rail, truck, air, or sea. While I can’t yet explain the discrepancy, one possible explanation is that DoT counts 40-foot containers as two 20-foot containers.
(Of course, pests introduced to Canada also threaten North America’s forests. Canada received fewer than 5 million containers via maritime trade in 2016 (Asbil pers. comm. 2018).
Two decade-old estimates of the proportion of incoming containers that hold wood packaging (Haack et al. 2017, Meissner et al. 2009) allow me to estimate the risk associated with these incoming containers. Meissner et al. found that 75% of maritime containers have wood packaging. Haack et al. estimated that the wood in 0.1% of those containers was infested. Applying these two factors, I conclude that as many as 18,590 of incoming containers in maritime trade could have been transporting a woodborer in the regulated families (Cerambycids, Buprestids, Siricids). I am hesitant to apply the calculation to CBP’s estimate because I don’t know how many of the 13 million containers entered by sea. However, if I assume that the same percentage of wood packaging applied to all the CBP-counted containers, I conclude that 9,750 of those containers held infested wood packaging – still a significant number.
The actual approach rate might be less – or more! Haack et al. (2014) did not include imports from China in their calculations. Given the history of interceptions, it appears probable to me that a recalculation of the approach rate that included China would probably raise the overall proportion.
Furthermore, 11 years have passed since Haack and Meissner made their calculations. During that time, ISPM#15 has been amended to make it more effective. The most important change was restricting the size of bark remnants that may remain on the wood. I have asked several times that APHIS commission a new analysis of Agriculture Quarantine Inspection Monitoring data to determine the pest approach rate before and after the CBP action in order to determine whether the more aggressive enforcement has led to reductions in non-compliant shipments at the border.
By comparing Dr. Haack’s estimate (see above) with the CBP data, I estimate that Customs is detecting and halting the importation of 4 – 8% of the shipments that actually contain pest-infested wood. Since CBP inspects only about two percent of incoming shipments, the higher detection rate demonstrates the value of CBP’s program to target likely violators – and deserves praise. But it is obviously too low a “catch” rate to provide an adequate level of protection for our forests.
ISPS#15 Is Not Helping to Target Inspections
So – ISPM#15 still allows too many pests to arrive at our shores. Is ISPM#15 at least helping phytosanitary agencies target inspections? No, because both U.S. and European data demonstrate that a high proportion of shipments containing infested wood pieces bore the ISPM#15 stamp. Phytosanitary agencies cannot rely on the presence or absence of the stamp to indicate the pest risk level.
U.S. data:
During the period 2010-2015, CBP found that an average of 95% of pest-infested shipments bore the ISPM#15 mark (Harriger). Unfortunately, CBP data from more recent years don’t provide this breakdown.
In the past two years, CBP inspectors have repeatedly found pests in dunnage bearing the ISPM#15 mark.
Krishnankutty et al. (2020b) analyzed wood packaging from 42 countries of origin intercepted by CBP over six years (April 2012 – January 2018). They found that 87% of the interceptions bore the ISPM mark.
I blogged earlier about the velvet longhorned beetle (Trichoferus (=Hesperophanes) campestris) This pest, like others, has reached our shores and entered the country both before and after implementation of ISPM#15. The predictable result is that VLB is established in three states and has been detected in 14 others plus Puerto Rico (Krishnankutty, et al. 2020a). Apparently we have been lucky that this one isn’t as damaging as so many are!
European data:
For Europe, see Eyre et al. (2018). They concluded that the ISPM-15 mark was of little value in predicting whether harmful organisms were present.
This is alarming and we need to understand the reason – How much is caused by fraud? How much is caused by failure of treatment – either intrinsic weakness or incorrect application? APHIS researchers have found that larvae from wood subjected to methyl bromide fumigationwere more likely to survive to adulthood than those intercepted in wood that had been heat treated (Nadel et al. 2016).
Krishnankutty et al. (2020b) query whether the 2009 requirement that wood be debarked might be less effective in countering insect species that require bark only in the early stages of larval development. Half of the species intercepted in hardwood shipments (e.g., Anoplophora glabripennis, Phoracantha recurva) might fit this profile. They also appear to pose a higher threat since they are polyphagous and known to infest healthy hosts. While some of the softwood-inhabiting species also require bark, they not known to infest living trees and only a quarter were classified in the high-risk group. The Mech et al. 2020 finding that no wood-borers that specialize in conifers posed a high risk appears to support these different impacts.
Krishnankutty, et al. (2020b) also note the risk from pallet recycling. The wood might occasionally be infested by dry-wood borers. One puzzling example was wood packaging shipped from Brazil and bearing a Brazilian ISPM#15 stamp that was infested with a larva of T. campestris (VLB). This is an Asian species not recorded as being present in South or Central America. The authors speculate that the pallets were recycled in Brazil after inadequate treatment in their original places of manufacture.
Of the 17 wood borer species intercepted in hardwoods, three have reproducing populations in the U.S.: A. glabripennis, Phoracantha recurva and T. campestris. Krishnankutty et al. (2020b) say that they are unaware of any of the non-native buprestids and siricids intercepted in softwood SWPM being established in the US. (One Siricid that is established, Sirex noctillio, was not detected in the wood packaging analyzed in this study.)
What Can Be Done to Slow or Eliminate this Pathway?
CBP inspectors
CBP strengthened enforcement of ISPM#15 in November 2017. CBP’s enforcement actions increased by 400% from 2017 to 2018 (John Sagle, CBP, pers. comm). CBP has also expanded its outreach to shippers and others involved in international trade with the goal of reducing all types of non-compliance – lack of documentation, pest presence, etc. in both wood packaging and shipping containers. The outreach includes awareness campaigns targetting trade, industry, affiliated associations, CBP employees, and international partners (Harriger).
Certain countries have a long-standing record of non-compliance with ISPM#15 – as seen in interception records.
Haack et al. 2014 – Italy was the country of origin for most wood borers intercepted 1985 – 2000.
Haack et al. 2014 – the top 5 countries in the 2003 – 2009 period were Mexico (33.7%), Italy (14.2%), Canada (13.4%), Netherlands (4.4%), China (4.1%).
APHIS’ interception database for FY2011-2016 (provided to me) showed Mexico, China, Italy, and Costa Rica had the highest numbers of interceptions.
Krishnankutty et al. (2020b) found the highest numbers of interceptions came from Mexico, China, and Turkey.
These numbers reflect in part the huge volumes of goods imported from both Mexico and China. But China and Italy stand out for their poor performance. (The U.S. does not regulate – or inspect! – wood packaging from our third-largest trade partner Canada.)
Officials know which individual companies within these countries have a history of non-compliance. For example, 21 of the interceptions on wood packaging made from Populus trees in China (53%) were associated with stone, ceramic, and terracotta commodities. Anoplophora glabripennis was intercepted six times in Populus originating from a single wood-treatment facility in China (Krishnankutty et al. 2020b).
How reduce risk to U.S. forests?
Over the past year or two, I have suggested the following actions:
USDA APHIS join Bureau of Customs and Border Protection in penalizing violators.
Citing the need for setting a higher “level of protection”, APHIS & the Canadian Food Inspection Agency (CFIA) should prepare a risk assessment to justify adopting more restrictive regulations. The new regulations should prohibit use of packaging made from solid wood – at least from the countries with records of high levels of non-compliance (listed above).
USDA Foreign Agriculture Service (FAS) should assist U.S. importers to determine which suppliers reliably provide compliant wood packaging.
USDA FAS and APHIS should help importers convey their complaints about specific shipments to the exporting countries’ National Plant Protection Organizations (NPPOs; departments of agriculture).
APHIS should increase pressure on foreign NPPOs and the International Plant Protection Convention more generally to ascertain the reasons ISPM#15 is failing and to fix the problems.
APHIS should fund more studies and audits of wood packaging to document the current efficacy of the standard, including an urgent update of the Haack study of pest approach rate.
The international standard has demonstrably failed to provide a secure method to evaluate the pest risk associated with wood packaging accompanying any particular shipment. The presence of the stamp on pieces of wood packaging does not reliably show that the wood is pest-free.
The situation is even worse re: movement of plants for planting.
SOURCES
Asbil, W. Canadian Food Inspection Agency, pers. comm. August 2018.
Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)
Haack, R. A., K. O. Britton, E. G. Brockerhoff, J. F. Cavey, L. J. Garrett, M. Kimberley, F. Lowenstein, A. Nuding, L. J. Olson, J. Turner, and K. N. Vasilaky. 2014. Effectiveness of the international phytosanitary standard ISPM no. 15 on reducing wood borer infestation rates in wood packaging material entering the United States. Plos One 9:e96611.
Harriger, K. Executive Director for the Agriculture Programs and Trade Liaison office, Department of Homeland Security Bureau of Customs and Border Protection (CBP), presentations to the Continental Dialogue on Non-Native Forest Insects and Diseases, over appropriate years. https://continentalforestdialogue.org/events/
Krishnankutty, S.M., K. Bigsby, J. Hastings, Y. Takeuchi, Y. Wu, S.W. Lingafelter, H. Nadel, S.W. Myers, and A.M. Ray. 2020a. Predicting Establishment Potential of an Invasive Wood-Boring Beetle, Trichoferus campestris (Coleoptera:) in the United States. Annals of the Entomological Society of America, XX(X), 2020, 1–12
Krishnankutty, S., H. Nadel, A.M. Taylor, M.C. Wiemann, Y. Wu, S.W. Lingafelter, S.W. Myers, and A.M. Ray. 2020b. Identification of Tree Genera Used in the Construction of Solid Wood-Packaging Materials That Arrived at U.S. Ports Infested With Live Wood-Boring Insects. Commodity Treatment and Quarantine Entomology
Leung, B., M.R. Springborn, J.A. Turner, E.G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. The Ecological Society of America. Frontiers of Ecology.org
Mech, A.M., K.A. Thomas, T.D. Marsico, D.A. Herms, C.R. Allen, M.P. Ayres, K.J. K. Gandhi, J. Gurevitch, N.P. Havill, R.A. Hufbauer, A.M. Liebhold, K.F. Raffa, A.N. Schulz, D.R. Uden, & P.C. Tobin. 2019. Evolutionary history predicts high-impact invasions by herbivorous insects. Ecol Evol. 2019 Nov; 9(21): 12216–12230.
Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory
Nadel, H. S. Meyers, J. Molongoski, Y. Wu, S. Lingafelter, A. Ray, S. Krishnankutty, A. Taylor. 2017. Identification of Port Interceptions in Wood Packing Material Cumulative Progress Report, April 2012 – June 2017
USDA APHIS interception database – pers. comm. January 2017.
USDA APHIS press release dated September 12, 2018
U.S. Department of Agriculture, Press Release No. 0133.20, January 27, 2020
Wu, Y., S.M. Krishnankutty, K.A. Vieira, B. Wang. 2020. Invasion of Trichoferus campestris (Coleoptera: Cerambycidae) into the United States characterized by high levels of genetic diversity and recurrent intros. Biological Invasions Volume 22, pages1309–1323(2020)
Yemshanov, D., F.H. Koch, M. Ducey, K. Koehler. 2012. Trade-associated pathways of alien forest insect entries in Canada. Biol Invasions (2012) 14:797–812
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
