National Plant Protection Offices (NPPO) around the world frequently publish notifications through the World Trade Organization of new, or changes in, their phytosanitary import requirements and regulations for seeds. USDA APHIS also publishes notifications in the Federal Register and often provides ASTA draft copies prior to official postings for comments. ASTA monitors these notifications closely and submits official comments through proper channels. ASTA solicits input from its members by sending notices to the Phytosanitary Committee, Vegetable Technical Subcommittee, Emerging Diseases Subcommittee, and divisions as appropriate, and maintains a database of notices out for comment, ASTA official comments, and resulting regulations once finalized.
International Standard Setting
ASTA has aggressively pursued international organizations such as NAPPO (North American Plant Protection Organization) and IPPC (International Plant Protection Commission) to develop and adopt international phytosanitary standards. International standards create a predictable trade environment as well as a level playing field for how different countries regulate seed shipments, and provide a basis for challenging regulatory actions when they are not justified according to these standards. NAPPO membership consists of Canada, Mexico, and the US, and current IPPC membership stands at 178 countries. In 2013 NAPPO adopted RSPM 36, “Guidelines for Seed Movements” (link to NAPPO standard). This standard has already had a major impact as Mexico recently published new changes to its phytosanitary import requirements based largely on this standard (link to Mexico regulation changes). The IPPC has begun work on development of the new international seed standard with the development of specifications (link) and establishment of an expert working group (EWG) that is charged with developing the standard (link to EWG). ASTA has partnered with ISF to develop position and information documents for the EWG that represent global seed industry consensus on what are the issues that need to be addressed and included in the standard (link to these documents).
National Seed Health System (NSHS)
The National Seed Health System (NSHS) is a program authorized by USDA-APHIS and administered by the Iowa State University Seed Science Center to accredit both private and public entities to perform certain activities needed to support the issuance of Federal phytosanitary certificates for the international movement of seed. Activities for which entities can obtain accreditation include:
- Laboratory seed health testing: laboratory-based program to test for plant pathogens in seeds;
- Phytosanitary (growing season field) inspection: disease inspection of plants grown to produce seed in the field, nursery, or greenhouse;
- Seed sampling: sampling seeds that requires laboratory seed health testing; and
- Visual inspection: visual inspection of seed shipments at exporter’s facility prior to issuance of phytosanitary certificates.
Through the NSHS, new testing and diagnostic methods are incorporated into the accreditation program to maintain the program on the cutting edge of technology. The NSHS also serves as a resource for pest risk assessment and phytosanitary resolution whenever disputes arise that disrupt the international movement of seed.
ASTA works with sister seed associations to organize and sponsor phytosanitary workshops to address issues and needs of ASTA members. For example, ASTA has sponsored two cross border workshops with the Mexican Seed Trade Association AMSAC (El Paso, 2010; Nogales, 2012) and a workshop on organic seed (Merida, 2011). ASTA and AMSAC are currently in the process of organizing another cross border workshop at Mexicali for the last week in September 2013. ASTA is also helping the Asia and Pacific Seed Association (APSA) organize an Asian regional workshop on pest risk assessment that will be held in early 2014.
Emerging Issues: Brazil Normative 36
Brazil represents a large market for US companies for commercial vegetable and grass seed species. Brazil has been in the process of changing its phytosanitary import requirements for commercial seed quantities. In 2011 and again in 2012 Brazil published proposed new regulations – Brazil Normative 36 – that, if adopted, would have severely restricted, if not prevented, commercial seed imports. ASTA partnered with the US government and numerous seed associations including ABRASEM (Brazil Seed Trade Association), SAA, and ISF to develop comments to Brazil’s proposal, and as a result, Brazil postponed implementation of Brazil Normative 36 until December 2013. In 2012, Brazil received over 200 comments to its last proposed rule. Brazil has indicated that in July 2013 it will publish an amended rule for comment based on comments received with the goal of putting it into force in December 2013.
Emerging Issues: Vietnam Pest Risk Assessment Requirements
Many ASTA member seed companies export a diverse number of seed species to Vietnam including vegetable, grass, forage, maize, and rice. Most of this seed is exported in small quantities to meet niche market needs, and as seed for research and breeding purposes. Vietnam authorities recently informed the US government that, beginning in 2014, it will require pest risk assessments (PRAs) to be completed for all seed species to be exported before import permits will be issued. The process to develop and complete PRAs is complex and involves providing detailed information to APHIS for the preparation of the document, followed by review/approval by Vietnam. ASTA is working with USDA APHIS to develop a process for completing these PRAs in time for the 2014 shipping season.
Emerging Issues: Phytosanitary Changes in Other Countries
ASTA closely monitors changes in phytosanitary import requirements of other countries. Countries communicate changes through the USDA, WTO notices, import permits, and indirectly through arbitrary shipment rejections. Working closely with USDA APHIS and Foreign Agricultural Service, ASTA seeks to eliminate technically unjustified trade barriers, most of which are related to phytosanitary. Recently ASTA has provided information to APHIS and FAS in response to changes in market access for vegetable seed to Yemen, a WTO notice filed by Ecuador for soybean and broccoli seed, and South Korea’s proposed tomato seed import requirements.
Food Safety (FS)
The 2006 outbreak of E.coli O157:H7, associated with spinach production in California, has drawn closer scrutiny to seed as a possible source of infection. Although never proven scientifically, seed remains a concern for many as a possible source for human pathogens such as E. coli, Salmonella, and others. Seed used for vegetable production under field conditions continues to post negligible risk for initiating outbreaks of human pathogens. The highest risk for the seed industry is seed that is used for the production of sprouts. ASTA maintains a capability to respond rapidly to outbreaks of human pathogens associated with vegetables through its Food Safety Pathogen Working Group (FSPWG). This WG routinely monitors outbreaks, research, and proposed state and federal legislation that may implicate seeds; reviews and updates the ASTA Statement on Field and Greenhouse Planted Seeds and Human Pathogens; and communicates relevant information to the ASTA membership. The FSPWG also maintains a database of published research papers on the ASTA website. The FSPWG is currently reviewing the Food and Drug Administration’s proposed Food Safety Modernization Act which will potentially impact the vegetable seed industry, in particular, seed to be used for the production of sprouts.