International shipping

WDA aley_wd@mac.com
Wed, 25 Feb 2009 19:53:38 PST
On shipping.
There is a school of thought within the Investigative Enforcement Service- IES for short, they are the APHIS detectives if you will and Department of Homeland Security also known as DHS and probable a few Plant Protection and Quarantine -PPQ Officers who believe that imposing penalties is an effective method of gaining compliance. I can't speak for everyone within the system and how they may view a shipment. I had mentioned this last month. There have been instances that civil penalties were levied against commercial importers because the exporter failed to meet the import requirement.
From an old school regulatory approach. Some of us believed that loss of plant material was sufficient deterrent for not obtaining appropriate documentation such as a phytosanitary certificate. Currently about 160 countries are signature to the International Plant Protection Convention. Where they all meet the standard for issuing the documents as required by the international standards.

To date I have not heard nor observed small shipments as a problem- like I said it was commercial. But that should not take away from exercising caution and informing your exporter the necessity of having the correct paperwork to ensure you receiving a shipment,


On a lighter note I did speak with the current director of the Plant Inspection Stations this morning about the mail shipping issue and how to work with the Headquarters US Postal Service USPS-Management. In short, Animal Plant Health Inspection Service -APHIS is in dialog with the mail service and at the Headquarters level they may have an option that will honor the existing Memo of Understanding-MOU. The discussions have been going on for about 18 months and  he feels confidant that a compromise can be garnered from USPS in the near future.

As faar as translations go. if the document are translated and the information is correct to the point that the appropriate documents are included within the shipments then everyone wins. The International Plant Protection Convention- IPPC makes every attempt to have documents in several languages and based upon a memo I saw the other day our administrator Cindy Smith is encouraging options that help with the regulatory and compliance within International trade.

If NARGS has the documents available on their web page I can forward the link to the appropriate staff Officer for review and see if it can be formalized if that is a goal of the NARGS.

A note to Mike, and on Richard's comment. I'd say that in these dire times underpaid staff may be tempted to loose postage. of this I'm at a loss as to say the appropriate thing- akin to taking coffee mess change I guess. But on a proactive side. having a letter that states what you are doing and how much postage your going to include is a record of sorts. There is not an easy work around on this issue.

On the label. This became an issue with the last administration, another post 9-11 activity. APHIS was charged by the American public to make the documents more accountable.
Which is also the level two access of the e-permits.
For our foreign counter parts, USA has been at code orange for almost three years now and we still need to practically strip search to get on a plane. I'm not sure if some of the precautions will ever go away.
It doesn't mean that you should not engage in trade of plant material, just that you may have to think about what's happening and be more business like and accountable.
At least from the inside out, I am taking all suggestions into account and for the time being I have some access to the changes proposed to the the plants for planting regulations and operations.
For the most part I can overlook the occasional  references to my Nazi, thieving, plant destroying, satanic and animal references of lineage and try to find solutions to some of the problems.
I have said it in the past, when organized groups speak with a unified voice often elected officials will listen, If the trade of plant material is important to you then you should find a way to make that known. I am somewhat limited in my ability to going to elected officials or appointed governmental management and making recommendations or suggestions, but on behalf of an organization that represents a voice that may not be so easily overlooked,
you'd be surprised at how much your collective voice can have reverberations within the halls of government and nothing stops a private citizen from contacting a secretary or undersecretary with valid suggestions, it is however appropriate to the delivery of the message. This is alas colored from my US perspective.
I've tried to go through all of the emails that were posted in the last 12 hours and respond. 
My apologies to our non US counterparts that this seems to be taking up a lot of concern and my overworked brain that slips into jargon way too easily. But on a brighter note if any of this  helps to send small parcels of plant material safely and within international agreements to customers to generate good will or income then that is not such a high price to pay in the long run.

Bill









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