RMD-11-02: Pest Risk Management Document for Deregulation of Heterodera glycines Ichinohe (Soybean Cyst Nematode)

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As described by the International Plant Protection Convention (IPPC), Pest Risk Analysis (PRA) includes three stages: initiation, pest risk assessment and pest risk management. Initiating the PRA process involves identifying pests and pathways of concern and defining the PRA area. Pest risk assessment provides the scientific basis for the overall management of risk. Pest risk management is the process of identifying and evaluating potential mitigation measures which may be applied to reduce the identified pest risk to acceptable levels and selecting appropriate measures.

This Risk Management Document (RMD) includes a summary of the findings of a pest risk assessment and records the pest risk management process for the identified issue. It is consistent with the principles, terminology and guidelines provided in the IPPC standards for pest risk analysis.

Table of Contents

Executive Summary

As described by the International Plant Protection Convention (IPPC), Pest Risk Analysis (PRA) includes three stages: initiation, pest risk assessment and pest risk management. The Risk Management document (RMD) is part of the pest risk management and communication stage. This RMD includes a summary of the findings of a pest risk assessment and records the pest risk management process for the identified issue. Consultation on the RMD, from a range of potentially affected stakeholders, is a key step prior to the approval and implementation of regulatory changes to the status of a pest.

Heterodera glycines, the soybean cyst nematode, is currently on the List of Pests Regulated by Canada. Schedule II of the Plant Protection Regulations restricts the domestic movement of soybean seed for propagation, soybean harvesting equipment, machinery, soil and any other thing suspected of being infested with the pest. To prevent the introduction of H. glycines, the Canadian Food Inspection Agency (CFIA) regulates imports of soybean seed, potatoes, root crops, and soil and soil-related matter, alone or in association with plants. Soybean cyst nematode has been considered one of the most destructive pests of soybean. Soil is the primary pathway for the movement of this pest. Plant commodities, farm equipment and natural means such as, water, air and birds, also move infested soil.

The Pest Risk Assessment conducted by the CFIA in 2010 for H. glycines determined that the overall risk of the pest was "low" and supported the possibility of deregulation. In Canada, surveys have detected this nematode in most Ontario soybean producing counties, since the first detection in Kent County in 1987. Heterodera glycines infested counties account for about 75% of the soybeans produced in Ontario and one half of the total Canadian soybean production. The limitation in enforcing domestic regulations and movement restrictions, along with lack of movement compliance, may have been a contributing factor to the spread of the pest to new areas in Ontario.

The biology of H. glycines indicates that cryptic spread is ongoing both within the province of Ontario and potentially to other regions. The United States of America (USA) has not regulated this pest since 1972, either at the federal or state level, because domestic regulations and movement restrictions were unsuccessful in preventing the spread. The nematode has been effectively managed through the use of best management practices, including crop rotation with non-host crops and planting resistant soybean varieties.

Risk management consideration was given to the following:

  1. The challenges in enforcing domestic movement regulations to prevent spread of the pest from infested areas;
  2. The lack of control over the natural spread of the pest;
  3. Due to discrepancy over strict import requirements versus limitations in enforcing domestic movement requirements, Canada faces challenges in meeting its obligations under the IPPC;
  4. Limitation of soil surveys to map the distribution of the pest; and,
  5. Highly expensive and resource intensive quarantine measures that need to be enforced if status quo is to be maintained.

After consultation and due consideration of stakeholder feedback, the CFIA is deregulating H. glycines in Canada and communicating the decision through this RMD. The deregulation is not expected to cause any significant market access issues, as most of Canada's trading partners, including the USA, have never regulated or have already de-regulated this pest.

1.0 Purpose

To deregulate Heterodera glycines Ichinohe, the soybean cyst nematode, in Canada.

2.0 Scope

This pest risk management document pertains to Canada's policies (plant import and domestic movement) to address the risks from H. glycines.

3.0 Definitions

Definitions for terms used in the present document can be found in the Plant Health Glossary of Terms.

4.0 Background

Heterodera glycines is currently on the List of Pests Regulated by Canada. Under Schedule II of the Plant Protection Regulations, soil or compost material, soybean harvesting equipment, machinery and any other thing suspected of being infested with the pest, including soybean (Glycine max) seed for propagation, that is transported from an area of infestation identified pursuant to Section 16 of the Plant Protection Regulations to any other area of Canada requires a Movement Certificate.

In Canada, H. glycines has been regulated for more than three decades. The following Canadian Food Inspection Agency (CFIA) Plant Health Directives include requirements that regulate imports to prevent the entry of H. glycines into Canada or prevent its spread, through infested soil, within Canada:

5.0 Pest Risk Assessment Summary (2010)

Heterodera glycines has been considered one of the most destructive pests of soybean. Wrather and co-workers (2001) reported that, both in Canada and the USA, yield loss due to H. glycines was higher than that caused by any other pest or pathogen of soybean. Yield loss to this nematode is an ongoing issue in regions where the pest is not effectively managed through the use of crop rotation with non-host crops, and the use of appropriate resistant soybean varieties.

Soil is the primary pathway for the movement of this pest. The spread of H. glycines via soil associated with crops, commodities, seed, horticultural plants, machinery, footwear etc., is primarily human mediated. Cysts can also move via the feet of birds and other wildlife; via water (e.g. flooding) and wind, suggesting that the pest will eventually spread to all soybean production areas in North America.

Since its first detection in Kent County, Ontario in 1987, the pest has been detected in soybean fields of several counties in Ontario including Essex, Elgin, Huron, Haldimand, the Municipality of Chatham-Kent, Lambton, Middlesex, Norfolk, Oxford, the United Counties of Prescott-Russell, Brant, Regional Municipality of Niagara, Northumberland, the City of Ottawa, the Regional Municipality of Peel, Perth, the United Counties of Stormont, Dundas and Glengarry, and City of Kawartha Lakes. Heterodera glycines infested counties account for about 75% of the soybeans produced in Ontario and one half of the total Canadian soybean production. In 2009, a single cyst was detected in a soil sample from the Rural Municipality of South Norfolk in Manitoba. However, a more intensive follow-up survey of the same field in 2010 did not confirm the presence of the pest.

Domestic movement restrictions of soil from H. glycines infested areas have been difficult to enforce due to the wide geographic area of the infested counties in Ontario, the lack of knowledge of movement activities and compliance of growers to the movement of regulated articles, which includes equipment and agricultural commodities associated with infested soil. The expanding range of H. glycines in Ontario attests to the continuous spread from infested counties to other areas. The pest, since its reported first detection in Ontario, has been controlled through effective best management practices, which include development and use of H. glycines resistant soybean varieties through industry- government partnerships. The H. glycines resistant soybean varieties are grown throughout the soybean production areas of Ontario.

Prior to 1972, United States Department of Agriculture's (USDA) domestic quarantines for H. glycines contained provisions that were equivalent to, if not more stringent than, those contained in current Canadian regulations relating to H. glycines. Despite this, the USDA abandoned their federal quarantines in 1972 as they had proven ineffective in limiting the spread of H. glycines, due in part to limitations in enforcement, lack of compliance with regulatory requirements, and natural means of spread of the pest to new areas. The pest is considered widespread in the soybean production areas of the USA.

In the absence of USA regulation, H. glycines will continue to spread undetected to new areas of the USA, and repeatedly into Canada via established pathways of introduction. New infestations have almost certainly occurred, but will not be reported until populations build to detectable levels. In North Dakota, it was estimated that H. glycines had been present for 5 to 7 years before the symptoms in the field led to detection by soil tests (Bradley et al., 2003).

Given that numerous states of the USA could be infested and remain unregulated, that soil surveys are of limited sensitivity, and that some H. glycines positive counties in Ontario are not currently regulated; current Canadian regulations and practices are unable to prevent further spread of this pest. The challenges in enforcing strict domestic movement requirements versus the rigorous enforcement of import control on host material are inconsistent with Canada's obligations under the World Trade Organization – Sanitary and Phytosanitary Measures (WTO-SPS).

6.0 Risk Management Considerations

6.1 International Standards for Phytosanitary Measures and Canada's Obligations

The IPPC has been identified as the international phytosanitary standard-setting authority by the WTO. The IPPC Standard for Phytosanitary Measures (ISPM) No. 19, Guidelines on Lists of Regulated Pests (2003), requires that pests regulated by National Plant Protection Organizations meet the criteria for either quarantine pests or regulated non-quarantine pests.

To be considered a quarantine pest according to the IPPC's definition, an organism must be "a pest of potential economic importance to the area endangered thereby and not yet present there, or present but not widely distributed and being officially controlled". In 2001, the Interim Commission on Phytosanitary Measures approved Guidelines on the Interpretation and Application of the Concept of Official Control for Regulated Pests (see Supplement No. 1 in ISPM No.5). These guidelines include, among other elements, that measures be mandatory and that domestic and import requirements should have equivalent effect.

Thus, for Canada to comply with WTO and IPPC guidelines and continue to regulate H. glycines as a quarantine pest on imports, it would have to strengthen significantly the enforcement of domestic movement restriction from any infested area in Canada.

7.0 Pest Risk Management

7.1 Considerations

7.1.1 Domestic Movement Regulations

In Ontario, the soybean production area is expanding and the distribution of the nematode is widespread. The limitation in enforcing domestic regulation, along with lack of movement compliance, may have been a contributing factor to the spread of the pest to new areas in Ontario. The recent case of H. glycines in Manitoba is a good example which reiterates the challenges in enforcing domestic movement regulations over a wider area. The single cyst detection was in a field well outside the flood zone of the Red River, and on a site where there was no record of previous soybean production. Thus, the likelihood of the pathway of introduction of H. glycines to this site may have been the seed from an infested field or spread of infested soil using agricultural equipment from other fields where soybeans are produced. However, it is noted that further cysts were not detected during a follow-up intensive survey of that particular field in Manitoba.

7.1.2 Spread by Natural Pathways

Natural pathways, such as wind, water and birds, also contribute to the spread of the nematode to new areas. These natural pathways and the spread cannot be controlled by regulations and enforcements. The continuous spread of the pest in Ontario to new production areas though cryptic, could be attributed to these natural pathways. The Manitoba soybean production area is in the Red River valley, which is contiguous with the production areas of Minnesota and North Dakota, where H. glycines has been reported within 300 km of the border. Considering the potential for annual flooding in this area it is very likely that H. glycines has spread into the soybean production areas of Manitoba along the Red River. Similarly, H. glycines has been reported in Eastern Ontario in 2008 and is likely present in the neighbouring soybean production area extending down the St. Lawrence valley.

7.1.3 Soil Surveys

In order to effectively regulate H. glycines in Canada, additional extensive surveys would be required in order to determine the current distribution of the pest in soybean production areas. Soil surveys, which are highly resource-intensive exercises, would never fully describe the true distribution of this pest, given its biology and pathways of spread. It is reported that the population of the pest has to build to a detectable level before it can be confirmed by soil surveys.

7.1.4 Enforcement Requirements on Infested Fields

To maintain the regulated status of H. glycines, containment measures would then have to be implemented by the CFIA that would parallel the current measures in place to contain the two species of potato cyst nematode that are present in Canada, Globodera pallida and G. rostochiensis, as per the Golden Nematode Order, SOR/80-260 (Saanich, British Columbia) and Golden Nematode Infested Places Order (Quebec).

Quarantine measures would include:

  1. Immediate issuance of notice of quarantine or equivalent regulatory order;
  2. Categorization of lands in the infested zone, as infested, exposed and adjacent. All these categorized lands will be placed under quarantine;
  3. Restriction on the production of all host and minor hosts of H. glycines;
  4. Prohibition on movement of soil and equipment associated with infested soil;
  5. Prohibition on movement of plant and plant parts with infested soil;
  6. Restriction on the movement of equipment and plant material from other category fields in the quarantine area;
  7. Restriction on movement of grains intended for other end uses; and,
  8. Establishment of various compliance agreements for facilities handling regulated plant and plant parts originating from regulated areas.

It would be prohibitively costly and resource intensive to implement such a rigorous regulatory program and it would severely impact most soybean seed growers and those agricultural sectors, such as equipment operators in Ontario, that move soil, either intentionally or unintentionally.

7.2 Proposed Approach

The CFIA considered the different risk management options presented in Appendix A.

After due consideration of the advantages and disadvantages of each option and feedback from stakeholders, the CFIA decided on the de-regulation of H. glycines all across Canada.

7.2.1 Impact on Exports and Imports

The de-regulation of H. glycines in Canada is not expected to have any impact on market access based on the current requirements of trading partners.

Freedom from soil in exports of seed and grain from Canada addresses the phytosanitary concerns of trading partners for this pest. The costs of implementing stricter quarantine measures, combined with the lack of control over natural spread of H. glycines, make an investment in strengthening a regulatory program questionable in terms of benefit to stakeholders, particularly when market access for soybeans is not an issue and the pest is managed by growers through current crop management practices.

Once deregulated, Canada can remove phytosanitary requirements on the import of soybean seed, as well as potatoes (seed, table and processing) from some states of the USA, which are currently regulated for the presence of soybean cyst nematode. This is crucial in complying with the existing obligations under the WTO and IPPC.

8.0 Risk Management Decision

8.1 Consultation

The initial Risk Management Discussion document, proposing the recommended option of deregulating H. glycines all across Canada, was circulated for stakeholder consultation in February 2011 and stakeholder feedback was received. While stakeholders from other provinces expressed support for deregulation of H. glycines, stakeholders from Quebec and Manitoba preferred continued regulation of H. glycines. Further, in December 2011, a Question and Answer document was distributed, which addressed specific concerns raised by stakeholders. Further discussions with concerned Quebec and Manitoba stakeholders were conducted in summer of 2012 to better understand their position, address specific concerns and provide timeline for the implementation of the deregulation of H. glycines.

There was a concern from Manitoba and Quebec that the proposed deregulation will introduce H. glycines in their soybean growing areas, where this pest has not been reported yet. During the consultation, the CFIA emphasized that all imports of seed and grain are required to be free of soil, as soil is the primary pathway for introduction of H. glycines.

The mandate of the CFIA is to prevent the introduction of pests/pathogens and to protect the agricultural resource base of Canada. The current status of H. glycines, widespread presence in Ontario, is such that it needs to move from being a quarantine pest to a management pest. It was also noted that despite the presence of H. glycines, the soybean acreage in Ontario has been increasing over the last two decades, which is largely attributed to the use of best management practices involving the development and use of H. glycines resistant soybean varieties.

The discrepancy between Canada's strict import requirements and inconsistent enforcement of domestic regulations for H. glycines can be perceived as unjustified discrimination or a disguised restriction on international trade of some plant commodities. This makes Canada vulnerable to WTO challenges from trading partners.

8.2 Decision

Heterodera glycines no longer fits the definition of a quarantine pest.

By way of this Risk Management Document, the CFIA is announcing the deregulation of H. glycines in Canada. As of November 25, 2013, the CFIA will not enforce the import regulations related to H. glycines. The CFIA will not be enforcing the Schedule II of the Plant Protection Regulations (PPR) pertaining to the domestic movement restriction of H. glycines infested material. The risk-based decision was made considering several factors, including the low risk of the pest, the utilization of H. glycines best management practices, and discrepancy in domestic and import regulations. Soil is a prohibited substance and all imports are required to be free of soil.

The implementation of the de-regulation of H. glycines would require that relevant plant health import directives be amended to remove reference to requirements for freedom from H. glycines or revoked. The Automated Import Reference Systems (AIRS) will also be updated to reflect the deregulation of H. glycines.

As part of the overall regulatory review process, the CFIA will work towards the removal of H. glycines from the Schedule II of the Plant Protection Regulations and the List of Pests Regulated by Canada.

9.0 References

Bradley, C, Nelson, B, Helms, T. 2003. Soybean cyst nematode reported in North Dakota. North Dakota State University. August 28, 2003.

Canadian Food Inspection Agency (CFIA). 2006. Directive 94-17: Plant Protection Import Requirements for soybean seed. CFIA, Ottawa, ON.

Canadian Food Inspection Agency (CFIA). 2008. Directive 95-26: Phytosanitary requirements for soil and related matter, alone or in association with plants. CFIA, Ottawa, ON.

Canadian Food Inspection Agency (CFIA). 2009. Directive 98-01: Import Requirements for seed potatoes and other potato propagative material. CFIA, Ottawa, ON.

Canadian Food Inspection Agency (CFIA). 2010. Directive 94-26: Plant protection import requirements for edible roots for consumption or processing. CFIA, Ottawa, ON.

Canadian Food Inspection Agency (CFIA). 2010. Directive 96-05: Import Requirements for Potatoes, potato parts and potato by-products. CFIA, Ottawa, ON.

Golden Nematode Infested Places Order

Golden Nematode Order 2010 (SOR/80-260)

International Plant Protection Convention (IPPC). 2001. Report of the Third Interim Commission on Phytosanitary Measures. 2001. Secretariat of the International Plant Protection Convention, Food and Agriculture Organization of the United Nations, Rome, Italy.

International Plant Protection Convention (IPPC). 2006. International Standards for Phytosanitary Measures 1 to 27 (2006 edition). Secretariat of the International Plant Protection Convention, Food and Agriculture Organization of the United Nations, Rome, Italy.

International Plant Protection Convention (IPPC). (updated annually). ISPM No. 5 Glossary of Phytosanitary Terms. Secretariat of the International Plant Protection Convention, Food and Agriculture Organization of the United Nations, Rome, Italy.

Plant Protection Regulations (SOR/95-212)

Pest Risk Assessment. 2010. Evaluation of import pathways for the soybean cyst nematode. Plant Health Risk Assessment Unit, CFIA, Ottawa, ON.

World Trade Organization (WTO). 1995. Agreement on the Application of Sanitary and Phytosanitary Measures - PDF (90.6 kb).

Wrather, J.A., Stienstra, W.C. and Koenning, S.R. 2001. Soybean disease loss estimates for the top ten soybean-producing countries in 1998. Canadian Journal of Plant Pathology 23 (2): 122-131.

Appendix A – Pest Risk Management Options

The following table discusses three pest risk management options considered, with the advantages and disadvantages listed for each.

Options Advantages Disadvantages

Status quo: Regulated Pest Status of Heterodera glycines

Retain H. glycines in the List of Pests Regulated by Canada

AND

Schedule II of Plant Protection Regulations on Restricted Movement Within Canada.

AND

Implement official control measures if H. glycines is found in a new area.

Control over import of seeds, potatoes and associated soil.

Control over Domestic Movement of seed, and soil associated with seed, potato tubers, horticultural root crops, plant material, farm machinery and equipment etc.

Authority to respond to positive finds and implementing official control measures.

Authority to contain the pest by enforcing mitigation measures at point of origin, if from an infested area.

Already present in large areas and numerous soybean production counties of Ontario.

No control over natural pathways of pest introduction, such as:
Wind,
Floods,
Birds, etc.

More resources needed to enforce domestic movement restrictions.

Potential additional costs to the growers to follow quarantine measures.

Additional costs in establishing and maintaining compliance agreements to handle regulated plant and plant parts from regulated areas

Potential additional costs to equipment operators (e.g. cleaning costs).

Potential for negative impact on trading partners and trading relationships due to continued oversight of imported commodities.

Potential for WTO challenges from trading partners over discrepancy in domestic and import regulations, if domestic regulations are not enforced

Declare Ontario as "infested area" and continue regulation of H. glycines in rest of Canada

Retain H. glycines in the List of Pests Regulated by Canada

AND

Schedule II of Plant Protection Regulations on Restricted Movement Within Canada.

AND

Make changes to Schedule II of Plant Protection Regulations on Restricted Movement from Ontario to the rest of Canada.

AND

Implement official control measures if H. glycines is found in a new area.

Authority to respond to positive finds at a location outside Ontario and implement official quarantine measures.

Quarantine measures would include:

  1. Declaring Ontario as a "soybean cyst nematode-infested area".
  2. Immediate issuance of notice of quarantine or equivalent regulatory order.
  3. Categorization of lands in the infested zone, as infested, exposed and adjacent. All these categorized lands will be under quarantine.
  4. Restriction on production of all host and minor hosts of H. glycines.
  5. Restriction on movement of soil and equipment associated with infested soil.
  6. Restriction on movement of plant and plant parts with infested soil.
  7. Restriction on the movement of equipment and plant material from other category fields in the quarantine area.
  8. Restriction on movement of grains intended for other end uses.

Control over import of seeds, potatoes, horticultural root crops and associated soil into Canada except Ontario.

Requirement on procurement of seed and seed potatoes intended for planting outside Ontario, from a field or area free of H. glycines

Control over Domestic Movement of seed, and soil associated with seed, potato tubers, horticultural root crops, plant material, farm machinery and equipment etc., from Ontario to the rest of Canada.

Better preparedness through official surveys, in soybean production areas outside Ontario.

Domestic movement restrictions apply from Ontario to rest of Canada.

No control over natural pathways of pest introduction, such as:
Wind,
Floods,
Birds, etc.

Potential impact on trade from Ontario

More resources, potential partnerships with provinces and service providers needed to:

  1. Apply potential quarantine measures.
  2. Enforce domestic movement restrictions.
  3. To conduct extensive annual surveys.

Potential additional costs to the grower/regulated field owner when quarantine measures implemented: restriction on sale and movement of equipment, cleaning costs etc.

Potential impact on soybean and potato seed producers in Ontario.

Additional costs in establishing and maintaining compliance agreements to handle regulated plant and plant parts from regulated areas.

Potential additional costs to Ontario equipment operators, like cleaning costs.

Potential for negative impact on trading partners and trading relationships due to more stringent oversight of imported commodities.

Potential for WTO challenges from trading partners over discrepancy in domestic and import regulations, if domestic regulations are not enforced.

De-regulate H. glycines across Canada

Remove H. glycines from the List of Pests Regulated by Canada

AND

Remove H. glycines from Schedule II of the Plant Protection Regulations on Domestic Movement Within Canada

Meet international obligations to IPPC, WTO-SPS, by adopting a harmonized approach to imports and domestic policies.

No additional resources and costs for enforcement of regulations pertaining to H. glycines.

No additional requirements and costs, related to H. glycines certification, for exporters to Canada.

No domestic movement restrictions for commodities and equipment associated with H. glycines.

Unrestricted movement between H. glycines infested counties/provinces, states in the USA and the rest of Canada.

Soil – The most significant pathway for movement of H. glycines is regulated in imports.

No authority to regulate H. glycines on imports.

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