The risk analysis process examines the plant pests and diseases that are known to be associated with a commodity, identifies those pests that are likely to remain on the commodity upon importation into the United States, and evaluates the mitigations that may be required to avoid, reduce, or eliminate the risk of pest introduction into the United States. APHIS conducts risk analyses in accordance with International Standard for Phytosanitary Measures No. 11, “ Pest Risk Analysis for Quarantine Pests,” and its supplements, set by the International Plant Protection Convention.
The risk assessment is an analysis of the plant pests and diseases known to be associated with the commodity in the country of origin. The risk assessment identifies the pests likely to remain on the commodity upon importation into the United States if certain safeguards are not established. A risk assessment is drafted using the information provided by the NPPO in accordance with 7 CFR 319.5, scientific literature, operational information and experience, and consultation with entities both within and outside APHIS. In some cases, the risk assessment may only be a list of pests present in that country and that are known to affect the commodity under review. In other cases, the risk assessment may further analyze each pest that could be harmful if introduced into the United States and may include options that could be used to avoid, reduce, or eliminate the risk of pest introduction associated with the importation of the commodity. These options may include procedures such as phytosanitary inspection and certification; pre-export requirements such as growing season inspection; treatment; limited origin; port of entry inspection; treatment at destination, in transit or at the point of entry; post-entry quarantine; post-entry measures such as specific end-use requirements or limited distribution; prohibition of entry of specific commodities from specific origins; or a combination of these or other options (i.e., a systems approach).
The risk management analysis evaluates the mitigations that may be required to avoid, reduce, or eliminate the risk of pest introduction that could be associated with the importation of the commodity.
Drafting a Risk Assessment
APHIS prepares a draft risk assessment or pest list based on the information provided by the NPPO and other available scientific and technical information. The risk assessment focuses on determining the pests associated with the commodity at its origin that may be introduced into the United States by the commodity’s importation. The determination of risk is based on the likelihood and consequences of introduction for the pests of concern. Subject matter experts, producers, academics, and scientists in the United States and other countries may be consulted during this process. The draft risk assessment or pest list does not include measures to mitigate pest risk since risk management is conducted after completion of both the stakeholder and country consultations. The time it takes us to prepare a risk assessment or pest list varies depending on the availability of information and our workload. Risk assessments for fruits, vegetables, or plants for planting are added to the list of in-progress PPQ pest risk analyses at the next update of the lists.
Reviewing the Risk Assessment
When we complete a draft risk assessment or plant pest list, it undergoes internal Agency review. We may make changes to the risk assessment or pest list based on this internal review.
APHIS makes draft risk assessments or pest lists for plant and plant product commodity import requests available for a 30-day review by stakeholders prior to the country consultation process on the Stakeholder Risk Assessment Consultation website. To participate in the stakeholder consultation process, please subscribe to the APHIS Stakeholder Registry and select the following topics:
By doing this, you will automatically receive notification from the Stakeholder Registry when risk assessments or pest lists are available for stakeholder consultation. During the consultation period, you will find the risk assessments or pest lists and additional information on the Stakeholder Risk Assessment Consultation website.
During the consultation period, we also provide a copy of the risk assessment or pest list to the subject country in preparation for the formal country consultation process.
Note: Your comments will be considered and may result in changes to the risk assessments or pest lists. However, we are unable to provide you with individual feedback regarding your comment. Please note that you will have additional opportunities to provide comments on our risk assessments or pest lists when the respective proposed rules or notices are available for comment in the Federal Register.
After the completion of the stakeholder consultation process, we send the risk assessment or pest list and possible mitigation options to the NPPO of the exporting country for review and comment. This allows the NPPO to provide APHIS with feedback regarding the pests listed in the risk assessment or pest list and the feasibility of the proposed risk management options. If the risk assessment or pest list was revised as a result of comments received from stakeholders, we will include the revisions in the documents presented for country consultation.
If the NPPO agrees with our risk assessment or pest list and mitigation options, we will prepare the risk management document.
If the NPPO has comments on our risk assessment or pest list and mitigation options, we will review the comments, modify the documents if necessary, and prepare the risk management document.
Upon completion of both the stakeholder and country consultations, APHIS will draft a risk management document (RMD) that lists specific measures to mitigate the pest risk posed by each pest listed in the RMD and prevent the introduction and establishment of the pest in the United States. For each measure, we indicate the reason it was selected and provide evidence that it is effective and supported by scientific and technical information.