RMD-13-04: Consolidated Pest Risk Management Document for pest plants regulated by Canada
Appendix 5B: Risk Management Considerations for Crupina vulgaris (common crupina)
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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
No values at risk were identified.
Potential Mitigation Measures for Natural Means of Dispersal
The natural dispersal of the achenes would remain fairly local as the seeds fall close to the parent plant and dispersal by wildlife occurs only over short distances. These methods of dispersal are difficult to control. No specific mitigation measures are proposed for natural means of dispersal of Crupina vulgaris.
Potential Mitigation Measures for Intentional Introduction Pathways
Transport of plant parts by tourists and recreational users
A potential intentional pathway for the introduction of Crupina vulgaris is due to the appearance of the achenes. They are tapered and slightly iridescent, and with their stiff bristles at the wide end, somewhat resemble dry flies used for fishing.
Previous imports
It is not possible to assess the quantity of achenes that enter Canada for fly fishing, but it is most likely small.
Risk mitigation measures
Increase public awareness of the regulation and the risk posed by this plant and distribute awareness material at border crossings to the public. This is not considered effective by itself if the risk is high, but is a viable action if the level of risk is low.
Trade implications
As most imports of this type are non-commercial, there would be no trade implications.
Cost-effectiveness and Feasibility
A public awareness campaign is the most feasible option, whereas inspection would be very disruptive, difficult to implement, and expensive.
Potential Mitigation Measures for Non-intentional Introduction Pathways
Hay and Straw
Previous imports
- The total value of hay and straw imports from 2006 to 2008 was over $ 44 million; over 84% of this value came from the U.S. (Industry Canada, 2009).
- During the same period, large quantities of hay and straw (about $31 million value) were imported from Washington and Oregon while smaller amounts were imported from Idaho and California (just over $111,000), all states where Crupina vulgaris is present. This represents the majority of hay and straw imported into Canada. Since 2002, imports of hay and straw have remained relatively constant (Industry Canada, 2009).
- The level of risk associated with imports of hay and straw into Canada is moderate to high. The majority of hay and straw shipments do not originate from counties in Washington and Oregon where Crupina vulgaris is present. However, a smaller amount of imported hay and straw does originate in the infested areas of Idaho and California. The associated risk will increase if Crupina vulgaris continues to spread. As Crupina vulgaris is found not only in range land but also non-crop disturbed areas such as field edges and roadsides, land use changes such as road building and increased recreational use will increase the risk of spread.
Potential risk mitigation measures
Regulate Crupina vulgaris under the Plant Protection Act as a quarantine pest by adding it to the List of Pests Regulated by Canada. This will:
- Enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spreadFootnote 1.
- Require exporters to obtain a Phytosanitary Certificate with or without an Additional Declaration stating freedom from Crupina vulgaris. (Note: Recognition of Pest Free Areas – if Crupina vulgaris can be shown to be absent in the area from which the field crop product was propagated, then risk is negligible and additional phytosanitary requirements may be waived.)
Additional requirements may include:
- A Permit to Import 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.
- For hay or straw intended for use as a biofuel stock, heat treatment or pelletization could be required.
Trade implications
- Regulating Crupina vulgaris as a quarantine pest would align Canada with the U.S. where this species is already on their Regulated Pest List.
- This measure will facilitate trade of hay and straw with the states of California, Oregon and Washington, where Crupina vulgaris is regulated.
- NPPOs of exporting countries will need to devote resources towards inspection of hay and straw commodities and issuance of Phytosanitary Certificates. Most straw and some hay from the four U.S. states where Crupina vulgaris is present currently requires phytosanitary certification. Inspectors in exporting countries need to be able to identify seeds of Crupina vulgaris that could attach themselves to hay and straw. NPPOs of the exporting country need to ensure freedom of Crupina vulgaris in hay and straw, otherwise CFIA can refuse import.
- Since most of hay and straw imports come from the U.S., and the majority from California, Oregon, Idaho and Washington where Crupina vulgaris is considered invasive, there could be significant market losses of this commodity if it is found to be contaminated.
- The U.S. could object to the new requirements, necessitating negotiation.
Cost-effectiveness and Feasibility
Regulation under the Plant Protection Act is already in place for other pests regulated by Canada. Minor costs will be incurred for training of inspectors for weed identification. Costs may be incurred during the negotiation of requirements with the U.S. or other affected trading partners.
Seed
Previous imports
Between 2004 and 2008, an average of $42 million worth of seed was imported into Canada from the four US states where Crupina vulgaris occurs.
Risk mitigation measures
Crupina vulgaris seeds are not likely to contaminate seed as it does not tolerate cultivation and would not be prevalent in crop fields, although it can become established along field edges. However, it also matures earlier than crop plants and the achenes are easily removed by screening due to its bristly pappus. Seeds suspected of being contaminated with Crupina vulgaris could be re-cleaned to remove the contaminant seeds.
Crupina vulgaris is listed as a Class 1 prohibited noxious weed in the Weed Seeds Order Footnote 2, and therefore, due to current regulations and requirements under the Seeds Act, imported seed is unlikely to be a pathway.
Other options include regulating Crupina vulgaris as a quarantine pest under the Plant Protection Act. Adding this species to the List of Pests Regulated by Canada (CFIA, 2009) would:
- 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 spreadFootnote 3.
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 Crupina vulgaris.
- 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
NPPOs of exporting countries and seed certification agencies currently devote resources towards inspection of seed lots and issuance of Phytosanitary Certificates. Laboratories in foreign countries will need to be able to identify seeds of Crupina vulgaris within a seed sample. Exporters need to ensure freedom of Crupina vulgaris in seed lots, otherwise CFIA can refuse import.
Field Crops Not Intended for Propagation
Included in this section are cereal grains, oilseeds, pulses, forage, and new crops not covered under the Seed section above.
Previous imports
Between 2004 and 2008, an average of $1.7 million worth of field crops not intended for propagation were imported into Canada from the four U.S. states where Crupina vulgaris occurs.
Risk mitigation measures
Crupina vulgaris seeds are not likely to be a contaminant as they do not tolerate cultivation and would not be prevalent in crop fields, although Crupina vulgaris can become established along field edges. However, it also matures earlier than crop plants and the achenes are easily removed by screening due to its bristly pappus. Grain suspected of being contaminated with Crupina vulgaris could be re-cleaned to remove the contaminant seeds.
Livestock
Previous imports
- The total value of sheep and cattle imports varies widely by year. Live sheep imports ranged from $30,244 in 2004 to $2,106,614 in 2006 (Industry Canada, 2007). Live cattle imports have ranged from $3 million in 2004 to $267 million in 2000 (Industry Canada, 2007).
- Between 1999 and 2008, almost 260,000 sheep, goats, and cattle were imported from the four states where Crupina vulgaris is present (CFIA, internal data).
Potential risk mitigation measures
Regulate Crupina vulgaris under the Plant Protection Act as a quarantine pest by placing it on the List of Pests Regulated by Canada. This would:
- Enable inspectors to take appropriate action for the purposes of eradicating the pest or preventing its spread Footnote 4.
- Require importers to obtain certification stating freedom from Crupina vulgaris.
Trade implications
- NPPOs of the exporting countries would need to devote resources towards inspection of livestock commodities. Inspectors in exporting countries would need to be able to identify seeds of Crupina vulgaris that could attach themselves to livestock. Exporters would need to ensure freedom of Crupina vulgaris on livestock, otherwise CFIA could refuse import.
- Since almost all imports of livestock come from the U.S., including California, Oregon, Washington and Idaho where Crupina vulgaris is invasive, there could be significant market losses of this commodity if it is found to be contaminated.
Cost-effectiveness and Feasibility
- The regulation of Crupina vulgaris on livestock is not considered feasible. Inspection of livestock for Crupina vulgaris achenes would be disruptive, difficult to implement, and expensive.
- This measure is not currently in place for other plant pests regulated by Canada. Substantial costs would be incurred if an inspection system for invasive plant seeds on livestock were to be implemented.
Raw Wool and Raw Skin
Previous imports
- The total value of sheep and goat raw wool imports was around $3.05 million in 2008; 76% of this value came from U.S. (Industry Canada 2009).
- Between 1997 and 2006, significant quantities of raw wool and raw skins were imported from California, where Crupina vulgaris is present.
Potential risk mitigation measures
No measure is required:
- The vegetative matter is removed from commercial wool by carbonization Footnote 5.
- Raw wool and raw hides imported into Canada from all countries require CFIA inspection. They must be free from feces, blood, ectoparasites and dirt (plant and plant parts are considered to be dirt) or they will be refused entry (Health of Animals Act, Directive AHPD-DSAE-2001-1-1 (CFIA 1990)). No further measures are considered necessary.
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" (CFIA 2010).
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.
Trade implications
- Exporting countries will need to devote resources towards inspection of used vehicles and farm machinery. Inspectors in exporting countries need to be able to identify seeds of Crupina vulgaris that could attach themselves to used vehicles and farm machinery. Exporters need to ensure freedom of Crupina vulgaris, otherwise CFIA can refuse import.
- The number of used vehicles and farm machinery imported from all states where Crupina vulgaris is present is unknown; however, there could be significant market losses of this commodity if it is found to be contaminated.
Cost-effectiveness and Feasibility
As vehicles and used farm machinery are already required to be free from soil, this would address one of the likely sources of Crupina vulgaris contamination, resulting in no additional costs. However, ensuring that used vehicles and farm machinery are free from Crupina vulgaris achenes not in association with soil would require additional resources and training as well as renegotiating the Memorandum of Understanding (MOU) between CFIA and CBSA.
Used Recreational Equipment and Clothing
Previous imports
It is not possible to assess the quantity of used recreational equipment and clothing that enters Canada, but it is most likely significant.
Risk mitigation measures
Increase public awareness of the regulation and the risk posed by this plant and distribute awareness material at border crossings to the public. This is not considered effective by itself if the risk is high, but is a viable action if the level of risk is low.
Trade implications
As most imports of this type are non-commercial, there would be no trade implications.
Cost-effectiveness and Feasibility
A public awareness campaign is the most feasible option, whereas inspection would be very disruptive, difficult to implement, and expensive.
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