RMD-13-04: Consolidated Pest Risk Management Document for pest plants regulated by Canada
Appendix 14B: Risk Management Considerations for Solanum elaeagnifolium (silverleaf nightshade)
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- Values at Risk
- Potential Mitigation Measures for Natural Means of Dispersal
- Potential Mitigation Measures for Intentional Introduction Pathways
- Potential Mitigation Measures for Non-Intentional Introduction Pathways
Values at Risk
Several crops are affected by Solanum elaeagnifolium worldwide, the most important being cereals (wheat, sorghum and maize), alfalfa (lucerne) and cotton. In Australia and the U.S., wheat production losses have been as high as 50%. A 2007 survey of farmers in Australia showed that Solanum elaeagnifolium has spread across the wheat belt of Victoria, New South Wales and South Australia. On average, the total farm cost for the weed was $1,730 (AUD) per year for control and $7,786 (AUD) per year in production losses (Kidston et al. 2006). Sorghum losses have ranged from 4-10% under optimal moisture conditions (CAB International, 2007; Sforza and Jones 2007).
The amount of land in each province in hardiness zones 5-9 that are planted with the species most affected by Solanum elaeagnifolium. The Province of Ontario has the greatest amount of crop area that could be impacted. In 2008, Ontario counties in hardiness zones 5 and 6 produced approximately 12 million bushels of wheat (OMAFRA, 2009) Maize production was approximately 48 million bushels in 2008 in Ontario counties (OMAFRA, 2009). Sorghum production in the respective provinces is considered marginal. A total of 22 hectares of organic sorghum was produced in Canada in 2005, with 15 hectares originating from provinces where Solanum elaeagnifolium could establish (Macey 2006).
Type of Commodity (Pathways) |
Introduction | Previous Imports | Potential Risk Mitigation Measures | Trade Implications | Cost Effectiveness & Feasibility |
---|---|---|---|---|---|
Seed | Intentional | No data available |
| Market loss for exploring countries would be minimal | Seed Program already in place |
Seed | Unintentional (as a contaminant) | This species has not previously been recorded in imported and Canadian seeds samples Level of risk is high since maize and forage plants originate primarily from areas where this species is present |
|
|
|
Field crops not intended for propagation | Unintentional | 300,000 tonnes of wheat, sorghum, maize and soybeans from countries with Solanum eleagnifolium were import in 2008 | Regulate under the PPA | Potential for reduction or loss of some import markets for Canada if physanitary requimrents can not be met. | Resources will be needed for marketplace monitoring |
Hay and Straw | Unintentional | Hay and straw imports were around $13 million in 2008 (harvested frequently and before weeds produce fruit) | Regulate under the PPA | Regulation of this species will safeguard trade of hay and straw with US, Potential reduction of import markets in Canada | Resources will be needed for CFIA marketplace monitoring |
Vehicles and Used Farm Machinery | Unintentional | Considerable volume of vehicles cross US and Canadian border Information not available on imports of used farm machinery | Enforcement of Directive 95-96: Phytosanitary requirements for soil and related matter, alone or in association with plants | ||
Nursery Stock with soil | Unintentional | In 2008, 73% of all nursery stock imports came from countries where this species is present | Regulate under the PPA | Potential reduction in import market for Canada if exporting countries cannot meet requirements | Phytosanitary certificate are currently issued by exporting countries for nursery stock. |
Manure | Unintentional | Data is unavailable | Bagged, composted manure regulated by Health of Animals Regulations. There are currently no standards for fresh manure. | No trade implications | If heating process makes weed seeds inviable, the n this would be a cost effective measure. |
Livestock | Unintentional | Risk associated with livestock pathway is relatively low | It is not feasible to implement mitigation measures for this pathway at this time. |
Potential Mitigation Measures for Natural Means of Dispersal
Natural dispersal of Solanum elaeagnifolium seeds by birds, animals or water could cover great distances and this represents a possible pathway of entry into Canada. Currently, populations of the plant in Washington are in counties at the southern margins of the state (USDA-NRCS, 2009). Washington State carries out eradication of Class A weeds as required by law (NWCB, 2009). Oregon and Idaho also have programs to eradicate noxious weeds (ODA, 2009; ISDA, 2005). If these programs are effective, the risk of natural dispersal as a pathway into Canada will decrease.
Since Solanum elaeagnifolium is currently at the southern margins of bordering states, an early detection and rapid response (EDRR) program should be employed such as the framework established in British Columbia. The Invasive Plant Council of BC has approved an EDRR framework that describes the process, steps and stakeholders involved in carrying out an EDRR system in the province (IPCBC, 2007). Early detection can be made possible with the use of atlases already available such as E-flora BC (Klinkenberg 2008) that inventory native, non-native and invasive species.
Potential Mitigation Measures for Intentional Introduction Pathways
Although sources indicate Solanum elaeagnifolium is not currently being sold as an ornamental plant in Canada (CNLA, 2009), further research found two Internet sites with seeds of Solanum elaeagnifolium for sale. While these companies indicate that they will ship to Canada, it is unknown how often, if any, seeds have been brought into Canada through this pathway. The potential for intentional introduction of Solanum elaeagnifolium into Canada is low.
Seed
Previous imports
None known. There is no data available specific to imports of Solanum elaeagnifolium.
Potential risk mitigation measures
Regulate Solanum elaeagnifolium as a prohibited noxious weed (Class 1) under the Weed Seeds Order of the Seeds Act Footnote 1.
- This species meets the definitions for Class 1Footnote 2 species under the Weed Seeds Order.
- All seed lots sold or imported into Canada must be free of prohibited noxious weed seeds. Imported seed lots would require a certificate of analysis stating Solanum elaeagnifolium 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 Certificate.
- Enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spread Footnote 3.
Regulatory actions under the Plant Protection Act could include the following:
- prohibit importation of Solanum elaeagnifolium seed. 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 government research facilities Footnote 4.
- 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 the CFIA's draft directive D-08-04 on plants for planting (CFIA 2008). Therefore phytosanitary requirements will be specified under a new regulatory directive or D-08-04 will be revised .
Sufficient information about the use of Solanum elaeagnifolium 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 field trials under Part V of the Seeds Regulations could be authorized by the Plant Biosafety Office.
Trade Implications
- Currently, there is not a large market for Solanum elaeagnifolium seeds in Canada, so market loss for exporting countries will be minimal.
- Lack of Canadian regulation could lead to establishment of Solanum elaeagnifolium in Canada, which could compromise market access for Canadian commodities to those countries that regulate Solanum elaeagnifolium. Worldwide, it is a quarantine pest in Belarus, Russia, and Ukraine, and is controlled under noxious weed legislation in Australia and South Africa (EPPO, 2007). In Europe, it is included on the European and Mediterranean Plant Protection Organization (EPPO) list of species recommended for regulation as quarantine pests by member countries (EPPO, 2009).
Cost-effectiveness and Feasibility
- The CFIA Seed Program is already in place to prevent the entry of prohibited noxious weeds. Verification of compliance is carried out through the Seed Marketplace Monitoring Program Footnote 5.
- No additional staff will be required at the CFIA Plant Health and Biosecurity Permit Office to regulate the species. Applications to import are reviewed by officers on a regular basis.
Potential Mitigation Measures for Non-Intentional Introduction Pathways
Field Crops Not Intended for Propagation
Previous imports
The total volume of wheat, sorghum, maize and soybeans Footnote 6 imported in 2008 from countries where Solanum elaeagnifolium is present was approximately 300,000 metric tonnes (Appendix 14C; Statistics Canada, 2009). The majority of these imports (99.5%) came from infested U.S. states (Industry Canada, 2009).
Potential risk mitigation measures
Regulate Solanum elaeagnifolium 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 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 Solanum elaeagnifolium.
- Requirement for an import permit issued by the CFIA indicating specific import requirements and conditions for the pest status, handling and use of the commodity. It is the importer's responsibility to apply for and obtain the permit Footnote 8.
- Recognition of Pest Free Areas– if Solanum elaeagnifolium 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.
End uses have an impact on risk and may, therefore, affect required risk mitigation measures. Phytosanitary measures may be waived for those commodities that have been treated or processed such that the risk of introduction of Solanum elaeagnifolium has been reduced to an acceptable level.
All risk mitigation measures for field crop commodities containing Solanum elaeagnifolium must be taken with consideration for requirements/measures for pests other than plants (e.g. pathogens and insects).
Trade implications
- 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 Solanum elaeagnifolium. Exporters will need to ensure freedom of Solanum elaeagnifolium in field crop shipments, otherwise CFIA can refuse import.
- Potential for reduction and or loss of some import markets for Canada should exporting countries be unable to meet proposed phytosanitary requirements.
- Not controlling import and spread of Solanum elaeagnifolium may result in infestations of field crops for export; if the importing country prohibits this species, market access for Canadian commodities could be compromised. Canada exported around $2 billion worth of wheat, sorghum and maize in 2008; approximately $733 million of exports went to states in the U.S. that regulate Solanum elaeagnifolium (Industry Canada, 2009).
- Canadian regulation will facilitate trade with those countries and states which have established regulatory control of Solanum elaeagnifolium. Worldwide, it is a quarantine pest in Belarus, Russia, and Ukraine, and is controlled under noxious weed legislation in Australia and South Africa (EPPO, 2007). In Europe, it is included on the European and Mediterranean Plant Protection Organization (EPPO) list of species recommended for regulation as quarantine pests by member countries (EPPO, 2009).
Cost-effectiveness and Feasibility
- Resources will be needed by CFIA for marketplace monitoring and sampling, inspector training, and communication material development.
- Solanum elaeagnifolium seeds can be readily screened out of grain lots due to the relatively large size (2-3 mm wide and 2-2.5 mm) and distinctly smooth surface and hilum (R. Wang – National Seed Herbarium, personal communication). Prior to export, grain can be cleaned to remove contaminant seeds.
- Field inspections or laboratory testing in the exporting country could be used to ensure freedom from Solanum elaeagnifolium.
Seed
Previous imports
- The Seed Science and Technology Section of the CFIA Saskatoon laboratory maintain a record of contaminants through the marketplace monitoring of domestic and imported seed. Solanum elaeagnifolium has not previously been recorded in imported and Canadian seed samples.
- The total value of seeds of maize and forage plants (alfalfa, clover, fescue, kentucky blue grass, rye grass and timothy grass) imported from countries where Solanum elaeagnifolium is present was approximately $89 million and the total value was approximately 35 million kilograms in 2008 (Appendix 14D; Statistics Canada, 2009). This represents about 54% of the total value of these commodities imported in 2008 (Industry Canada, 2009).
- The level of risk associated with imports of seed of maize and forage plants into Canada is relatively high since they originate primarily from areas where Solanum elaeagnifolium is present. Ninety percent of total imports of these seeds came from the U.S. (including states where Solanum elaeagnifolium is currently absent; Industry Canada, 2009), so the risk of introduction will increase if the range of the plant increases to states where it is currently absent.
Potential risk mitigation measures
Regulate Solanum elaeagnifolium as a prohibited noxious weed (Class 1) under the Weed Seeds Order of the Seeds Act.
- This species meets the definitions for Class 1 species under the Weed Seeds Order.
- All imported or domestic seed lots must be free of probhibited noxious weed seeds. Imported seed lots would require a certificate of analysis stating Solanum elaeagnifolium is absent from the seed lot before it can be imported.
Regulate Solanum elaeagnifolium as a quarantine pest under the Plant Protection Act and add this species to the List of Pests Regulated by Canada in order to:
- Enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spread.
- Prevent the importation, movement, and cultivation of this species in Canada.
Regulatory actions under the Plant Protection Act could include one or more of the following:
- Exports could be required to provide a Phytosanitary Certificate with or without an Additional Declaration stating freedom from Solanum elaeagnifolium.
- Requirement for seed from infested areas to be allowed entry into Canada only after the importer obtains a CFIA issued import permit indicating specific import requirements and conditions for handling and use of the commodity. Prior to permit issuance, a facility inspection by CFIA and verification of importers ability to meet permit requirements may be required
- Negotiate phytosanitary agreements to certify imports from pest free areas and/or recognize noxious weed certification in countries or states of origin.
Trade implications
- Regulation of Solanum elaeagnifolium under the Seeds Act and Plant Protection Act will facilitate seed trade with the 19 U.S. states where Solanum elaeagnifolium is regulated as a noxious weed. It will also facilitate trade with Belarus, Russia, China, Ukraine, Australia and South Africa where it is a quarantine pest. Canada exported approximately $61 million worth of alfalfa, clover, fescue, Kentucky blue grass, rye grass and timothy grass seed in 2008 to the states and countries where Solanum elaeagnifolium is regulated.
- Exporting countries will need to devote resources towards inspection of seed lots and issuance of phytosanitary certificates. Laboratories in foreign countries will need to be able to identify seed of Solanum elaeagnifolium within a seed sample. Exporters will need to ensure freedom of Solanum elaeagnifolium in seed lots, otherwise CFIA can refuse import.
- There is potential for reduction and or loss of some import markets for Canada if exporting countries are unable to meet proposed regulatory requirements.
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 9.
- Seed of Solanum elaeagnifolium can be easily identified by trained analysts (R. Wang – National Seed Herbarium, personal communication) .
- Prior to export, seed is typically cleaned to remove contaminant seeds. Solanum elaeagnifolium seeds can be readily screened out of seed lots due to the relatively large size (2-3 mm wide and 2-2.5 mm) and distinctly smooth surface and hilum (R. Wang – National Seed Herbarium, personal communication).
Hay and Straw
Previous imports
- The total value of hay and straw imports was around $12 million in 2008; 91% of this value came from countries and states where Solanum elaeagnifolium is present (Appendix 14E; Industry Statistics Canada, 2009).
- Between 1999 and 2004, high quantities (an average of around $10 million per year) of hay and straw were imported from countries and states where Solanum elaeagnifolium is present (Statistics Canada, 2009).
- Between 1999 and 2004, high quantities of hay and straw (an average of $9.5 million per year) were imported from Washington and Oregon, where Solanum elaeagnifolium is present. This represents the majority of hay and straw imported into Canada. Since 2004, imports of hay and straw have remained relatively constant (Industry Canada, 2009).
- Although imports of hay and straw into Canada originate primarily from areas where Solanum elaeagnifolium is present, the level of risk associated with this pathway may be low if harvest occurs frequently and before the weeds produce fruit, which usually occurs from the end of spring until the fall (EPPO 2007).
Potential risk mitigation measures
Regulate Solanum elaeagnifolium 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.
Regulatory actions could include one or more of the following:
- Exporters could be required to obtain a Phytosanitary Certification with or without an Additional Declaration stating freedom from Solanum elaeagnifolium.
- Requirement for an import permit 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.
- Recognition of Pest Free Areas – if Solanum elaeagnifolium 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.
- Requirement for heat treatment or pelletization for hay or straw intended for use as a biofuel stock.
Trade implications
- Regulation of Solanum elaeagnifolium will safeguard trade of hay and straw with the 19 states that regulate Solanum elaeagnifolium. Canada exported $4.5 million worth of hay and straw in 2008 to states where the weed is regulated as a noxious weed.
- Exporting countries may have 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 berries and seeds of Solanum elaeagnifolium that could attach themselves to hay and straw. Exporters need to ensure freedom of Solanum elaeagnifolium in hay and straw, otherwise CFIA can refuse import.
- Potential for reduction in and or loss of some import markets for Canada if exporting countries are unable to meet proposed regulatory requirements. Since 98% of hay and straw imports come from the U.S., and the majority from states where Solanum elaeagnifolium is invasive, there could be significant market losses of this commodity if Canadian regulations cannot be met.
Cost-effectiveness and Feasibility
Resources will be needed by CFIA for marketplace monitoring and sampling, inspector training, and communication material development.
Vehicles and Used Farm Machinery
Previous imports
- A considerable volume of vehicles cross the U.S.-Canada border every year.
- Information is not available on the volume of imports of used farm machinery.
Potential Risk mitigation measures
Enforcement of the Directive 95-26: "Phytosanitary requirements for soil and related matter, and for items contaminated with soil and related matter" (Canada, 2008).
- In 2003, the Canada Border Services Agency (CBSA) assumed responsibility for the initial import inspection services in respect to the Acts and Regulations administered by the CFIA to the extent that they are applicable at Canadian border points. The inspection of goods that may be contaminated with soil are among the responsibilities that were transferred to the CBSA in 2003. The Food, Plant and Animals Programs Section of the CBSA is currently finalizing its Standard Operating Procedures (SOP) concerning the "Inspection of Imported Goods Potentially Contaminated with Soil." This SOP provides the CBSA's Border Services Officers with formal procedures for the inspection and disposition of goods that may be contaminated with soil, including used agricultural machinery and vehicles.
- Vehicles and farm machinery should be thoroughly checked for berries and root fragments of Solanum elaeagnifolium, especially if originating from infested areas.
Nursery Stock with Soil
All parts of the root of Solanum elaeagnifolium are capable of forming shoot buds; root fragments only 1 cm long retain the ability to sprout. In addition, sections of taproot can remain viable for up to 15 months (Boyd et al., 1984; Parsons and Cuthbertson, 2001). Root fragments of Solanum elaeagnifolium can contaminate soil in imported nursery stock and establish if planted in suitable growing conditions.
Previous imports
- The total value of imports of nursery stock was around $173 million in 2008 Footnote 10. Approximately 73% of this value came from countries where Solanum elaeagnifolium is present, with 64% coming from the continental U.S. (Industry Canada, 2009). While soil from the non-continental U.S. is prohibited as per Directive D-95-26: Phytosanitary requirements of soil and related matter, alone or in association with plants, soil associated with nursery stock from the continental U.S is permitted in some cases. All but 2 states (of the 28) infested with Solanum elaeagnifolium exported nursery stock to Canada; Florida, Oregon, California and Washington exported the highest value of nursery stock at around $98 million value. It is not possible to determine the amount of nursery stock from the continental U.S. arriving with soil.
- The level of risk associated with this pathway is unknown. One reference (EPPO, 2007) made a statement that ornamental plants are a possible pathway for this species, but it is unknown how often ornamental plants are contaminated with Solanum elaeagnifolium.
Potential Risk mitigation measures
Regulate Solanum elaeagnifolium under the Plant Protection Act as a quarantine pest and add it 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.
Regulatory actions could include one or more of the following:
- Addition of Solanum elaeagnifolium to D-95-26 Phytosanitary requirements for soil and related matter, alone or in association with plants Appendix 2: Additional declarations required for shipments from the U.S. All soil and related matter in association with plants requires a phytosanitary certificate stating freedom from pests named in this appendix.
- Requirement for importers to obtain a phytosanitary certificate with or without an Additional Declaration stating freedom from Solanum elaeagnifolium.
- Requirement for nursery stock imported from areas infested with Solanum elaeagnifolium to be allowed entry into Canada only after the importer obtains a CFIA issued import permit indicating specific import requirements and conditions for pest status, handling and use of the commodity. Prior to permit issuance, a facility inspection by CFIA and verification of importers ability to meet permit requirements may be required. It is the importer's responsibility to apply for and obtain the permit.
- Recognition of pest free areas; if the exporting country shows Solanum elaeagnifolium to be absent from the country/state/region from which the nursery stock is produced, then risk is negligible.
Trade implications
- Potential for reduction in and or loss of some import markets for Canada should exporting countries be unable to meet proposed regulatory requirements. Since a large proportion of nursery stock comes from infested areas of the U.S., there could be significant market losses of this commodity if Canadian regulations cannot be met.
- The exporting country may have to devote resources toward inspection of pest-free areas of production and the issuance of Phytosanitary Certificates. These measures are currently in place for other pests regulated by Canada.
Cost-effectiveness and Feasibility
Phytosanitary certificates are currently issued by exporting countries for nursery stock and exporting countries currently comply with the phytosanitary requirements set out in D-95-26, including pest-free areas of production.
Manure
Previous imports
Data is unavailable to determine the total values of manure imports.
Potential risk mitigation measures
- Bagged, composted, manure may be imported according to the Health of Animals Regulations (HAR), s. 46.1 and manure may be imported according to the HAR, s. 46.1 if accompanied by an official export certificate from the U.S. and if heated to a minimum of 77 degrees centigrade for at least 7 days. It is possible that this heating process may make any weed seeds inviable at time of entry, in which case, the risk associated with this pathway would be negligible.
- There are currently no standards in place for the import of fresh manure, but it is uncertain whether this is transported across the border. Most manure and fertilizer is allowed entry into the country if deemed acceptable by the CFIA Animal Health Directorate.
- More information is required to determine if the regulations currently in place for manure would prevent viable seeds from entering the country.
Trade implications
No trade implications are expected since regulations are already in place for manure.
Cost-effectiveness and Feasibility
If the heating process does make weed seeds inviable, this provides a cost-effective measure for the manure pathway.
Livestock
Previous imports
- Between 2004 and 2008, approximately 11,400 live horses, asses, bovine animals, swine, sheep and goats for reproduction were imported into Canada from countries where Solanum elaeagnifolium is present. The majority of these animals were horses (CFIA internal data).
- The risk associated with the livestock pathway is relatively low due to the small number of animals for reproduction being imported into Canada from places where Solanum elaeagnifolium is established. In addition, berries of Solanum elaeagnifolium can be toxic to cattle and the plants will not be eaten unless there are no other food sources available (EPPO 2007).
Potential risk mitigation measures
It is not feasible to implement mitigation measures for this pathway at this time.
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