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 the USDA 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