Latest requirements (small lots of seed)

ken isaac via pbs pbs@lists.pacificbulbsociety.net
Fri, 01 Oct 2021 08:04:51 PDT
>
>
> Date: Thu, 30 Sep 2021 12:42:25 -0400
> From: John Willis <willis@fred.net>
> To: Pacific Bulb Society <pbs@lists.pacificbulbsociety.net>
> Subject: [pbs] Latest requirements
> Message-ID: <4CD48DE2-D397-482D-BF0D-69E1C15984D5@fred.net>
> Has anyone tried to get through the latest revision to the small lots of
> seeds permitting process?  Im stuck on the page that wants you to attach
> articles to the application?
> I don?t understand how this would work with seed exchanges.
> My latest application was voided because you now need to use this new
> efile portal which doesn?t seem to work for small lots of variable seeds
>
>
>
John,
As others said, use the secret words:  "All Eligible taxa:"  and
"Various approved countries:"  Amend your application using the old system
(see below) to put those words in your application.
It's a frustrating process for the PPQ587, "small lots of seed," using the
old process, APHIS  ePermits.  Maybe the new one is better?
Problems?  Here is the APHIS USDA help email address, and they are quick to
respond (within a day for me.)
plantsforplantingpermits@usda.gov

As you said, the website now quotes:
"APHIS eFile is the new permitting system for Plants and Plant Products.
Click here to access eFile: https://efile.aphis.usda.gov/"
  .
But, it also says you can use the old  ePermits system to "amend" any
existing application, and this was quick, easy and painless for me to do in
July.
I initially thought I would just import one species, but found later I
wanted far more freedom.  I sent APHIS/USDA a question:
ME:  "How can I modify my application to say "all eligible taxa" instead of
specifically "hippeastrum sp."
APHIS/USDA:  "Please apply for a permit amendment to change the articles
for import."
( I agree with another comment that the term "articles" is confusing in
relation to the small lots of seed permitting process, and "species" would
be far more understandable as we are dealing only in seed, but the term
"articles" in their permitting process covers the whole agricultural scope
of the USDA- plants, plant products, animals, animal products, foodstuffs,
dirt, living organisms & pathogens, etc.)

So, you might be able to go back in now and 'amend' it to add the magic
words!  I did this as I originally listed just one seed, and went back and
amended it to say:
All Eligible taxa:
Various approved countries:
I didn't specify a port

It was approved a day later.
I've attached a screenshot below showing my amended permit application, and
the final amended permit. (I've never tried an attachment to PBS- I'm sure
it will be scrubbed?)

WHY NOT MAKE EVERY PERMIT "ALL  ELIGIBLE TAXA"  from "ALL ALLOWED COUNTRIES
to start with?
Yeah, Why get approval from the wife specifically for a "strawberry
milkshake," when the more generic approval for "any available milkshake" is
so much more liberating when I get to the Shake Shack and look at the menu?
APHIS.USDA <http://aphis.usda.gov/> explains it this way:
"list the seed species and countries from which you want to ship each
species. If the list of species is long, you may enter “eligible taxa”. By
using this option, you are accepting responsibility for determining the
eligibility of the seeds. The Permit Unit cannot tell you if the species
are eligible for importation if you do not list them. A permit is issued
for taxa that are admissible with no restrictions beyond the port of entry
inspection. If port of entry inspectors find prohibited or restricted seeds
in your shipment, they will seize and destroy the ineligible kinds."

So, when you list the species and country on your import permit, you get
approvals for those listed and the port should just inspect them without
arguing if they are approved or not.  When using the more general "All
approved Taxa" from "Various approved countries," the responsibility is all
on you, and the risk could be seed destruction at a port!  Here is what
they say we must assure:
"The seed is not restricted under the Not Authorized Pending Pest Risk
Analysis (NAPPRA) category in the Plants for Planting Manual; is not of any
Federal noxious weed species; does not require an additional declaration on
a phytosanitary certificate; does not require treatment; is not a parasitic
plant...  (etc!!!) "

Or, just check the maual of approved import plants!  Here is a link to the
PDF of the approved plants manual:
https://aphis.usda.gov/import_export/plants/…

see my attached current permit wording, and my amendment that changed it
that way screenshot
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