[BULBS-L] Importing Bulbs and Seeds

WDA aley_wd@mac.com
Mon, 26 Jan 2009 01:24:40 PST
The numbers you request of DHS inspections refer to articles of fruits and vegetables and cut flowers.
Propagative plant material goes to a Plant Inspection Station. I find it ironic that what started off as providing information about being aware of the import regulations to legally trade plant material internationally for members of this group. Which has turned into the justification to bypass the system because you can get away with bypassing the system because it's so overloaded to care about small importers like members of this group. Except some are actually nursery owners who sell and buy plant material commercially.
I currently do not engage in the business of buying and selling plant material in the international market. I have an import permit and I make every effort to ensure that my purchases comply with the permit. 
The government assumes that the price of getting caught for a large plant broker is not worth their risk consequently when an exporter fails to meet the requirements the importer pays for that failure. Individuals who believe that the law of averages and the plant pest pathways do not apply to them are often willing to take on that risk. What do they have to fear? The believe that they are too small for the Government to care about what they do? After-all it wouldn't be on their plant material since individually they are smarter than the government hacks who can't get a job in the real world. I guess if the question your friend brought up about inadequacy of inspectors in The Czech Republic and since they are not part of that process, then the only experience would be based upon the work they  have observed in their own work place. Usually false phytos are the result of individuals bypassing their own system - for a variety of reasons, usually financial. It is not that the government lacks the ability to inspect, rather that the government lacks the ability to prevent false documents.
When it comes to 5% or 100% of commodities being inspected. I will not give you a number because there is no way to estimate it. Some people I've met do a real good job at what they do. Because they believe in what they do. Some people have priorities elsewhere. The result is the perception of how important the problem really is.
As people who like rare and unusual plant material, I believe we have a responsibility to make sure that the possibilities for the exchange of domestic plant pests is maintained to a minimum. There is always a risk.
When an inspector looks at a shipment we assume that they have been trained to some degree to recognize what should not be there. The Phyto offers a degree of certainty that apparently no pests are present. 

Within any system out of 100% the ends of the curve are where the deviations tend to be observed. For most of the sampling it complies with the objective. When PPQ inspects the inspectors follow sampling protocols, hyper-geometric sampling it's referred to. 

Lets face it, do you really want he government to inspect 100% of every shipment that comes into the USA? Because if you thought it was a back log now just imagine how long it would take to get the job done with smaller government and more inspections. TNC wants all plant imports to be placed into a mandatory 2 year post entry program similar to New Zealand's program.

What I am advocating is that as individuals who like rare and unusual plants, we should be aware of the rules and regulations so our plants are not the ones stopped for lack of documentation. Have a certain level of responsibility to ensure that we do not become part of the movement of alien plant pests. Because a North American native or introduced pest would be viewed as an alien plant pest in another country.
As a group I believe that we should hold ourselves to a high level of compliance because we do value those plants that are not commonplace in our own environments. 
Justifying the reason's why one should be able to get around they system becomes more of part of the problem than part of the solution.

Actually PPQ focuses it's resources not on where the largest volume of imports are but on the largest  and most frequent source of plant pests and the potential for introduction of those pests.
And it's not our money. It's the US tax payers money.

Last time I checked it's rather expensive paying for two wars and bailing out the economy. So who will be paying for all of these services to inspect? Probably in the future it will be all importers. Universally what is now a free service will probably have a fee.  Imagine if every import permit had a $300 fees associated with it and every phytosanitary certificate actually reflected the cost of issuing it?  And every new plant pest introduction's clean up effort was placed on the individual who introduced the pest.
Then ask how would that be enforced? Perhaps any shipment lacking in the right documentation or not paying the fee would be destroyed or refused entry into the USA.
This group is part of the international movement of plant material. Often locally grown and pretty much organic with minimal IPM standards. A domestic pest in one country becomes an alien pest in another. Commercial growers focus on regular pesticide applications and plant material common enough to have minimal pests associated with it. Where do you think the pest risk is?
I can guarantee you that at least one person within the PPQ chain of command somewhat at the level of effecting change to the regulations is participating with this group. Take advantage of the resources at your disposal.

In all honesty for regulatory officials no international trade is the best exclusion policy. Then no plants need be inspected, no pests introduced and anyone caught smuggling would be held accountable. But that is not the world we live in, nor how we regulated trade. I guess I'd like to see members of this group state that they have mastered the red tape and systems to ensure that they are not the ones who introduce plant pests. But then maybe I am assuming too much from plant collectors that they would actually accept a statement that the phyto is not worth the paper it's written on. Because if that was true we would be shutting down industries. Just look at the New Zealand cut flower movement into California. First interception of LBAP and the entire industry was forced to comply with a higher level of red tape.

The information about how to do this is available, today more than ever before. Just google it and chances are you'll find the information. The hard part for most people is reading regulations because they are cumbersome and full of legal stuff. Too complex to understand. Most people don't even take the time to read their own permits. That is based on the call I receive to the surprise that their shipments out of all the people who import is being destroyed and it's unfair that they are singled out for being non compliant when everyone else is getting away with it.

Just be aware of the rules and regulations and don't assume that you are so important and outside the possibility of being part of the problem that you'll not get caught eventually. Last I checked this is a public forum and anyone can participate. If you want to be anonymous don't list your private information, and if you do and you brag about how you've bypassed the system. Don't be surprised if a State or Federal Officer knocks at your door to ask you a few questions. You don't see petty thieves bragging about what they get away with on the internet do you? How do you suppose enforcemnt officials gather information, be aware of what is written on a public forum it doesn't go away when you hit send and it's hard to recall back.

It only takes one person to create a movement and the strength of the movement can create change. As plant collectors in a public forum we should collectively be worried about those individuals who do not advocate to the legal method of plant importation. If we police ourselves then there is less tendency for the government to do it for us. I for one do not want to have my narcissus bulbs die away because of a plant pest native to the origins of the plant material. Nor would I want my neighbor to introduce plant pests across the fence because it's cheaper and easier to bypass the system. I certainly would not buy from a nursery that advocates by passing the system. But that's just me. One person.

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