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Animal and Plant Health Inspection Service
U.S. Department of Agriculture

Citrus Nursery Stock Summary of Comments

Protocol for Interstate Movement of Citrus Nursery Stock from Areas Quarantined for Citrus Canker, Citrus Greening, and/or Asian Citrus Psyllid

Summary of Comments received in March 2019 and APHIS’ Responses

Question: Do the requirements for interstate movement differ based on the final destination of the nursery stock (e.g. residential versus commercial)? 

Response: No. The requirements are the same regardless of the plant’s destination and ensure clean trees for both commercial producers and residential owners. 

Comment: The protocol should clearly state that all plants in a facility that has a confirmed detection of citrus canker must be destroyed.  

Response: APHIS cannot state this in the protocol because states may allow producers to move or sell plants within the quarantine area in which the facility is located.  

Comment: The pre-shipment treatment interval should be changed from 30 days to 10 days. 

Response: APHIS did not make this change because we do not have scientific information that shows that shortening the pre-treatment interval would not impact risk.  

Comment: Using different testing requirements for different types of propagative materials creates burden on nursery owners. 

Response: APHIS supports using the least burdensome requirements that adequately protect American agriculture and natural resources. This is why, in response to stakeholders’ concerns in 2018, APHIS changed the protocol for testing requirements to be based on risk. This change resulted in reduced testing requirements for low-risk material. APHIS recognizes that this may require nursery owners to implement a tracking system for different types of materials. APHIS inspectors will assist nursery owners by helping them determine the most efficient inspection and testing strategy under the new requirements.  

Comment: Recommend modifying requirements based on state of origin. 

Response: APHIS cannot modify the requirements based on state of origin because the citrus nursery stock protocol is a national protocol intended to provide clean nursery materials to commercial producers as well as homeowners throughout the United States. APHIS bases the protocol on national standards for production practices and not individual state standards. States may have additional requirements for diseases or pests not regulated at the Federal level. 

Comment: Seed is a low-risk material that should not need to originate from a state certified seed source tree. 

Response: Although seed is generally considered low risk, the central tenet of the protocol is to "start clean and stay clean" by using a systems approach that is verified through inspection and testing. To maintain the integrity of the systems approach, all propagative material must be traceable to a clean source, including seed. 

Comment: The requirement for five feet of space between walls and plants in section II of the protocol is too burdensome.

Response: APHIS supports this change and has modified the protocol to state that nursery owners must provide adequate space between walls and plants that allows access for inspectors. This change specifically requires that all plants within all structures must be arranged so that inspectors will have access to the plant material and there is space between all interior and exterior walls and plants.  

Comment: Consider a strategy of removing trees infected with citrus canker and allowing movement of remaining material.

Response: APHIS is not aware of any scientific information that would support this strategy. Therefore, we have not changed the requirements. 

Comment: The detection of an Asian citrus psyllid (ACP) in a facility does not necessarily pose a risk, and if a huanglongbing (HLB) positive tree is found within a facility, it should be removed and nursery owners should be able to test remaining trees until no HLB is detected. 

Response: Detections of ACP or HLB within a facility indicate a failure of the systems approach and violate the central tenet of the protocol to start with clean material and keep it clean. The citrus nursery stock protocol is a systems approach as defined by the International Plant Protection Convention in which multiple layers of risk mitigation measures reduce risk to a tolerable level. Under the protocol, the facility must reset with clean material and implement an intact systems approach to be eligible to ship interstate. 

Comment: Consider allowing movement between non-contiguous quarantine areas.  

Response: The type of movement described is considered interstate movement, and it is currently allowed under the requirements of the nursery stock protocol. 

Comment: The language in the protocol is unclear.

Response: APHIS agrees that certain sections of the protocol are unclear. We have revised the language in several sections. In Section I, we:

  • Clarified that all mother and scion trees must come from certified clean stock. 
  • Indicated that safeguards have to be in place through the entire movement process. 
  • Clarified the right of inspectors to have reasonable access to facilities as a requirement for participation.  

In addition, we:

  • Changed the title of each section to indicate which regulatory tool is used to ship articles in that section. 
  • Changed the phrase “risk assessment” to “critical control point assessment” throughout the document to reflect the intent of the assessment. 
  • Added a new section for Eligibility for Shipment in sections III and V so that all the requirements for shipment are now located in one section of the protocol.
  • Revised the formatting to enhance readability.
  • Clarified the testing interval for mother/scion trees in an HLB-quarantined area.
  • Added definitions from 7 CFR §301 to improve accessibility to the information.
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