RMD-13-04: Consolidated Pest Risk Management Document for pest plants regulated by Canada
Appendix 10B: Risk Management Considerations for Paspalum dilatatum (Dallis grass)
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- Potential Mitigation Measures for Natural Means of Dispersal
- Potential Mitigation Measures for Intentional Introduction Pathways
- Potential Mitigation Measures for Non-intentional Introduction Pathways
Potential Mitigation Measures for Natural Means of Dispersal
According to Allison (2009) it is unlikely that natural dispersal will allow the species to enter Canada, as established populations are in the southern states.
Potential Mitigation Measures for Intentional Introduction Pathways
Plants for Planting excluding Seed
Paspalum dilatatum is not reported to occur in Canada, and no evidence was found that it is cultivated in Canada. Paspalum dilatatum, as an ornamental plant, is not available in Canada (CNLA 2009).
Previous imports
The CFIA requires a Permit to Import, with the scientific and common names, for all plants and propagative material from origins other than the continental U.S. (CFIA 1997; CFIA 2009). Some plants from the continental U.S. also require a Permit to Import as listed in CFIA (2009). The CFIA has not issued a Permit to Import for Paspalum dilatatum plants in the past three years (CFIA internal data).
Potential risk mitigation measures
Non-regulatory measures
Currently, no specific non-regulatory measures are required.
Regulatory measures
Regulate Paspalum dilatatum as a quarantine pest under the Plant Protection Act and add this species to the List of Pests Regulated by Canada.
- This will require that importers of material from regions other than the continental U.S. specify the scientific name when applying for a Permit to Import plant and propagative material;
- This will require that the scientific name be provided on the Phytosanitary Certificate for all plants and plant products exported to Canada from the continental U.S.
- Refuse to issue Permits to Import for plants of Paspalum dilatatum Footnote 1.
Trade Implications
As Paspalum dilatatum is mainly used for pasture and soil retention in tropical and subtropical regions and is not cultivated in or imported into Canada as plants or seed, the regulation of Paspalum dilatatum is not expected to have a significant impact on trade.
Cost-effectiveness and Feasibility
CFIA plant health programs are already in place to prevent the entry of prohibited plant materials. Measures under the Plant Protection Act are already in place for other pests regulated by Canada (CFIA 2009).
Seed
Previous imports
Seed of new crop species, such as field crops, can be imported without a Permit to Import or a Phytosanitary Certificate. There is no regulatory policy or application process in place to adequately control these imports.
Potential risk mitigation measures
Regulate Paspalum dilatatum as a Class 1 prohibited noxious weed under the Weed Seeds Order of the Seeds Act Footnote 2.
- This species meets the definition for a Class 1Footnote 3 species under the Weed Seeds Order.
- All imported and domestic seed lots must be free of prohibited noxious weed seeds. Imported seed lots require a certificate of analysis stating Paspalum dilatatum is absent from the seed lot before it can be imported.
Regulate as a quarantine pest under the Plant Protection Act. Add this species to the List of Pests Regulated by Canada(CFIA 2009) in order to:
- Prevent the importation, movement, and cultivation of this species in Canada. Currently, seed of many new crop species, such as field crops, can be imported without a Permit to Import or a Phytosanitary CertificateFootnote 4.
- Enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spread Footnote 5.
Regulatory actions under the Plant Protection Act could include the following:
- Prohibit importation of Paspalum dilatatum seed and refuse to issue Permits to Import for seed of Paspalum dilatatum. The only exceptions would be for the importation of devitalized seed and the importation of seed or preserved specimens for scientific research purposes by recognized herbaria and research facilities Footnote 6.
Require importers of plant material from the non-continental U.S. to apply for a Permit to Import with scientific name specified.
- Seed of horticultural plants is not within the scope of CFIA's unpublished, draft directive on plants for planting (D-08-04). Therefore phytosanitary requirements must be specified either in a revision of D-08-04 (CFIA 2008) or in a new regulatory policy directive.
Sufficient information about the use of Paspalum dilatatum as a potential crop does not exist. If the proponent, located in Canada, needs to collect more information about the plant (e.g. to generate data for a determination of environmental safety), then confined research trials under Part V of the Seeds Regulations could be authorized by the Plant Biosafety Office.
Trade Implications
- The regulation of Paspalum dilatatum, is not expected to have a significant impact on trade.
- Regulation may facilitate seed trade with countries where Paspalum dilatatum is listed as a serious or principal weed (Australia, Philippines, Brazil, Columbia, the former Soviet Union and Taiwan (Holm et al. 1991))
Cost-effectiveness and Feasibility
The CFIA Seed Program is already in place to prevent the entry of prohibited noxious weeds.
Field Crops Not Intended for Propagation
Previous imports
Based on the information available in the CFIA's Import Permit System, two import permits have been issued, in 2003 and 2007, for various dried plant specimens from the genus Paspalum. Import permits were issued under section 43 and were for research purposes only.
Risk mitigation measures
Regulate Paspalum dilatatum as a quarantine pest under the Plant Protection Act and add this species to the List of Pests Regulated by Canada in order to:
- Prevent the importation, movement, and cultivation of this species in Canada.
- Enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spread Footnote 7.
Regulatory requirements under the Plant Protection Act could include one or more of the following:
- A Permit to Import indicating specific import requirements and conditions for the handling and use of the commodity. It is the importer's responsibility to apply for and obtain the permit.
- End uses would have an impact on risk mitigation measures. For example, Paspalum dilatatum imported for milling (grinding) into flour would have lower risk than that coming in for direct use as pastured/rangeland animal feed. For milling, risk mitigation measures would include: proper disposal of anything removed from Paspalum dilatatum prior to the milling process and the milling itself. The same is true of Papalum dilatatum imported for processing into feed (pelleting, crushing, etc.). Papalum dilatatum imported for human consumption or direct feeding to livestock would have greater risk and would require treatment to render the grain unviable. Treatments, where applicable, such as heat (i.e. where heat would not compromise quality of grain for intended end use), grinding, pelletizing could be used prior to import or post-entry.
- All risk mitigation measures for Paspalum dilatatum must also take into consideration requirements/measures for pests other than plants (e.g. pathogens and insects).
Trade implications
As there is no identified usage of Paspalum dilatatum as as non-propagative product (food, ornamental, decorative) there will be no impact on trade.
Cost-effectiveness and Feasibility
CFIA plant health programs are already in place to prevent the entry of prohibited plant materials. Measures under the Plant Protection Act are already in place for other pests regulated by Canada (CFIA 2009).
Potential Mitigation Measures for Non-intentional Introduction Pathways
Field Crops Not Intended for Propagation
Previous imports
- The total value of grain commodities (corn, soybean, rice, canola, cereals) imported in 2008 from states where Paspalum dilatatum is present was over $1 billion (Industry Canada, 2009).
- Sixty-three percent of U.S. corn imported into Canada came from states where Paspalum dilatatum is present.
- The total value of soybeans imported from the U.S. in 2009 was $170.9 million. Approximately $5.5 million (3%) came from states where Paspalum dilatatum is present.
Potential risk mitigation measures
Regulate Paspalum dilatatum as a quarantine pest under the Plant Protection Act and add this species to the List of Pests Regulated by Canada (CFIA 2009) in order to:
- Prevent the importation, movement, and cultivation of this species in Canada.
- Enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spread Footnote 8.
Regulatory actions under the Plant Protection Act could include one or more of the following:
- Exporters could be required to provide a Phytosanitary Certificate with or without an Additional Declaration stating freedom from Paspalum dilatatum.
- Recognition of Pest Free Areas – if Paspalum dilatatum can be shown to be absent in the country/state/region from which the field crop product was propagated, then risk is negligible and additional phytosanitary requirements may be waived.
- A Permit to Import indicating specific import requirements and conditions for the pest status, handling and use of the commodity could be required. It is the importer's responsibility to apply for and obtain the permit Footnote 9.
- Provisions for importation of grain contaminated with Paspalum dilatatum for research, processing, industrial or educational uses under a section 43 permit on a case-by-case basis.
- Phytosanitary measures may be waived for those commodities that have been treated or processed such that the risk of introduction of Paspalum dilatatum has been reduced to an acceptable level. End uses impact risk and may therefore impact required risk mitigation measures. For example, field crop commodities containing Paspalum dilatatum imported for milling (grinding) into flour would have lower risk than that coming in for direct use as pastured/rangeland animal feed. For milling, risk mitigation measures would include: the milling itself and proper disposal (incineration, grinding or deep burial) of anything removed from the commodity prior to the milling process. The same is true of field crop commodities imported for processing into feed (pelleting, crushing, etc.). Commodities imported for human consumption or direct feeding to livestock would have greater risk and could require treatment to render the grain unviable. Treatments, where applicable, such as heat (i.e. where heat would not compromise quality of grain for intended end use), grinding, pelletizing could be used prior to import or post-entry.
- All risk mitigation measures for field crop commodities containing Paspalum dilatatum must be taken with consideration for requirements/measures for pests other than plants (e.g. pathogens and insects).
Trade implications
- Not controlling import and spread of the species may result in infestations of field crops for export; market access for Canadian commodities could be compromised.
- Exporting countries may have to devote resources towards inspection and issuance of Phytosanitary Certificates. Laboratories in foreign countries will need to be able to identify seeds of Paspalum dilatatum. Exporters will need to ensure freedom of Paspalum dilatatum in field crop shipments, otherwise CFIA can refuse import.
Cost-effectiveness and Feasibility
- Measures under the Plant Protection Act are already in place for other pests regulated by Canada (CFIA 2009).
- The seeds of Paspalum dilatatum can be identified by trained analysts.
Seed
Previous imports
In 2008 the total value of seeds of forage plants imported from the U.S. was $6.68 million. Sixty-three percent of those imports ($4.23 million) came from states where Paspalum dilatatum is present (Industry Canada 2009). See appendix 10C. The probability of the weed seeds contaminating seed lots is unknown. The seed has not been reported as a contaminant in the marketplace of imported seed lots coming into Canada. There is risk associated with Paspalum dilatatum because it is commonly used as a forage crop, for pasture in cultivated subtropical areas, and it is also a serious weed in turf and golf courses in the southern states.
Potential risk mitigation measures
Regulate Paspalum dilatatum as a prohibited noxious weed (Class 1) under the Weed Seeds Order of the Seeds Act Footnote 10.
- All imported and domestic seed lots must be free of prohibited noxious weed seeds. Imported seed lots would require a certificate of analysis stating Paspalum dilatatum is absent from the seed lot before it can be imported
- This species meets the definitions for Class 1 species under the Weed Seeds Order.
Regulate Paspalum dilatatum as a quarantine pest under the Plant Protection Act and add this species to the List of Pests Regulated by Canada (CFIA 2009) in order to:
- Prevent the importation, movement, and cultivation of this species in Canada.
- Enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spread Footnote 11.
Regulatory actions under the Plant Protection Act could include one or more of the following:
- Exporters could be required to obtain a Phytosanitary Certificate stating freedom from Paspalum dilatatum.
- Exceptions may be made for the importation of preserved specimens for scientific research purposes by recognized herbaria and research facilities and the importation of seed for research in containment facilities.
- Could negotiate phytosanitary agreements to certify imports from pest free areas and/or recognize noxious weed certification in countries or states of origin.
Trade implications
Exporting countries currently devote resources towards inspection of seed lots and issuance of Phytosanitary Certificates when required. Laboratories in foreign countries will need to be able to identify seeds of Paspalum dilatatum within a seed sample. Exporters need to ensure freedom of Paspalum dilatatum in seed lots, otherwise CFIA can refuse import.
Cost-effectiveness and Feasibility
- The CFIA Seed Program is already in place to prevent the entry of prohibited noxious weeds. The CFIA monitors compliance with the Canadian standards through the Marketplace Monitoring Program Footnote 12.
- There are 320 species of Paspalum in the warm regions of the world (Watson and Dallwitz, 1992 onwards), so there will always be identification issues. However, Paspalum dilatatum is identifiable by trained personnel. Training will be necessary for laboratory analysts.
Hay and Straw
Previous imports
- The total value of hay and straw imports was approximately $5.5 million in 2008; 98% of this value came from the U.S. (Industry Canada 2009).
- Between 2004 and 2008, about 8% of hay and straw imports came from states where Paspalum dilatatum is present.
- The level of risk associated with imports of hay and straw into Canada is relatively low as the volume of importation from states where Paspalum dilatatum is present is low.
Potential risk mitigation measures
Regulate Paspalum dilatatum under the Plant Protection Act as a quarantine pest by placing it on the List of Pests Regulated by Canada in order to:
- prevent the importation, movement, and cultivation of this species in Canada.
- enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spread Footnote 13.
Regulatory actions under the Plant Protection Act could include:
- Require importers to obtain a Phytosanitary Certificate with or without an Additional Declaration stating freedom from Paspalum dilatatum.
- A Permit to Import indicating specific import requirements and conditions for the pest status, handling and use of the commodity could be required. It is the importer's responsibility to apply for and obtain the permit.
- For hay or straw intended for use as a biofuel stock, heat treatment or pelletization could be required.
Trade implications
- The impact of the obligation to obtain an Import Permit and Phytosanitary Certificate is expected to be low, as only 8% of imported hay and straw comes from states where Paspalum dilatatum is present.
- Exporting countries will need to devote resources towards inspection of hay and straw commodities and issuance of Phytosanitary Certificates. Inspectors in foreign countries need to be able to identify seeds of Paspalum dilatatum that could be associated with hay and straw. Exporters need to ensure freedom of Paspalum dilatatum in hay and straw, otherwise CFIA can refuse import.
Cost-effectiveness and Feasibility
This measure is already in place for other pests regulated by Canada. Minor costs will be incurred for identification training for inspectors.
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