RMD-13-04: Consolidated Pest Risk Management Document for pest plants regulated by Canada
Appendix 2B: Risk Management Considerations for Alopecurus myosuroides (slender foxtail)

• 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

Alopecurus myosuroides is considered the most serious weed of winter cereals in Europe, reducing crop yield (CAB International 2007). Alopecurus myosuroides will most likely have the greatest impact on crops in Ontario, where winter wheat is produced. In 2008, approximately 650,000 tonnes (or 24 million bushels) of winter wheat were produced in the southwestern Ontario counties of Chatham-Kent, Essex and Lambton where Alopecurus myosuroides could potentially occur. This represents almost a quarter of winter wheat production in Ontario (OMAFRA 2009). Between the year 2000 and 2004, the average value of winter wheat production in Ontario was $250 million per year (OMAFRA 2009). Other crops that could be affected (to a lesser extent) by Alopecurus myosuroides in the respective counties include oats and barley with production values of 5,300 tonnes (85,000bu and 2,400 tonnes (112,000bu respectively in 2008 (OMAFRA 2009).

Potential Mitigation Measures for Natural Means of Dispersal

Wind is the main natural means of dispersal for Alopecurus myosuroides, but only over short distances. Given the current range, wind dispersion is an unlikely pathway for entry into Canada (Allison 2009); thus, no mitigation measures for natural means of dispersal are required at this time.

Potential Mitigation Measures for Intentional Introduction Pathways

No intentional introduction pathways were identified (Allison 2009). Alopecurus myosuroides is not available in Canada as an ornamental plant (CNLA 2009). Although no mitigation measures are currently needed, this pathway will still be regulated under the Plant Protection Act if this species is placed on the List of Pests Regulated by Canada and the Seeds Act if placed on the Weed Seeds Order.

Potential Mitigation Measures for Non-intentional Introduction Pathways

Field Crops Not Intended for Propagation

Previous imports

• The total value of cereal grain commodities that have winter varieties (wheat, rye, barley, and other unmilled cereals) imported in 2008 was approximately $39 million or 8.8 million metric tonnes. Approximately $7.7 million or 1.9 tonnes worth of imports were from countries where Alopecurus myosuroides is present (Statistics Canada 2009). See Appendix 2C for a breakdown of HS codes and values of each commodity originating from countries where Alopecurus myosuroides is present. No data were available on imports of winter cereal varieties.
• The level of risk associated with imports of cereal grain into Canada is relatively low since the majority of imports (82%) originate from areas where Alopecurus myosuroides is absent (Statistics Canada 2009).

Potential risk mitigation measures

Regulate Alopecurus myosuroides 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 1}.

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 Alopecurus myosuroides.
• 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.
• Provisions for importation of grain contaminated with Alopecurus myosuroides for research, processing, industrial or educational uses under a section 43 permit on a case-by-case basis.
• Recognition of Pest Free Areas – if Alopecurus myosuroides can be shown to be absent from the country/state/region from which the field crop product was propagated, then risk is negligible and additional phytosanitary requirements may be waived.

• Note: End uses impact risk and may therefore impact 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 Alopecurus myosuroides has been reduced to an acceptable level.
  Combine harvesting equipment may blow a certain proportion of the weed seeds out of the grain during harvest due to their small size and low weight. It has been speculated that this may be up to 100%, but no study has been done (K. Allison, personal communication). The seeds may enter Canada in field crops not intended for propagation; a study examining the efficacy of removal during harvest should be done.

Trade implications

• Since a relatively small value of grain imports originate from areas where Alopecurus myosuroides is present, reduction and or loss of import markets if exporting countries are unable to meet proposed phytosanitary requirements would be low.
• Regulation of Alopecurus myosuroides under the Plant Protection Act will facilitate future exports of grain (average value of $1.6 million per year over the past 10 years; Industry Canada 2009) to the State of Washington, where Alopecurus myosuroides is regulated.
• Not controlling import and spread of the species may result in infestations of field crops (e.g. winter wheat) for export; if the importing country prohibits that species, Canadian market access could be compromised.
• Exporting countries may have to devote resources toward the inspection of grain commodities and the issuance of phytosanitary certificates.

Cost-effectiveness and Feasibility

• Resources will be needed by CFIA for marketplace monitoring and sampling, inspector training, and communication material development.
• Grain contaminated with Alopecurus myosuroides could be re-cleaned to remove the contaminant seeds. Alopecurus myosuroides seeds can be readily screened out of grass seed lots as the size of the seeds are 4.5-7.5 mm (Hubbard 1968). The seeds are readily identifiable by trained analysts. This should be done in the exporting country.

Seed

Previous imports

• The Seed Science and Technology Section of the CFIA Saskatoon laboratory maintains a record of contaminants through the marketplace monitoring of domestic and imported seed. Alopecurus myosuroides has been recorded in 5 imported grass seed samples in the past 9 years.
• The total value and quantity of grass seed commodities (Kentucky bluegrass, timothy, ryegrass and fescues) imported in 2008 from countries where Alopecurus myosuroides is present was approximately $22 million and 11 million kilograms respectively (Appendix 2D; Statistics Canada 2009). This represents 84% of the total value of grass seeds imported into Canada. The highest proportion of seed was imported from the states of Oregon and Washington with values of $17 million (9 million kilograms) and $4.4 million (2 million kilograms) respectively. The total value of imported grass seed has increased between $6 and $8 million over the last 5 years (Industry Canada 2009).
• The level of risk associated with imports of grass seed into Canada is relatively high since they originate primarily from areas where Alopecurus myosuroides is present.

Potential risk mitigation measures

Regulate Alopecurus myosuroides as a prohibited noxious weed (Class 1) under the Weed Seeds Order of the Seeds Act ^{Footnote 2}.

This species meets the definitions for Class 1 ^{Footnote 3} species under the Weed Seeds Order.

All imported and domestic seed lots must be free of prohibited noxious weed seeds. Imported seed lots would require a certificate of analysis stating Alopecurus myos uroides is absent from the seed lot before it can be imported.

Regulate Alopecurus myosuroides 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 4}.

Regulatory actions 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 Alopecurus myosuroides.
• Requirement for an import permit indicating specific import requirements and conditions for the pest status, handling and use of the commodity. A section 43 import permit will be required for the importation of devitalized seed, preserved specimens for scientific research purposes by recognized herbaria and research facilities and the importation of seed for research in containment facilities.
• Recognition of Pest Free Areas – if Alopecurus myosuroides can be shown to be absent from the country/state/region from which the seed was harvested, then risk is negligible and additional regulatory requirements may be waived.
• Recognition of foreign government phytosanitary noxious weed certification in countries or states of origin may allow for additional phytosanitary requirements to be waived.

Trade implications

• Lack of Canadian regulation could compromise market access for Canadian commodities to those countries that regulate Alopecurus myosuroides, should this species become established in Canada.
• Regulation of Alopecurus myosuroides under the Seeds Act and Plant Protection Act will facilitate seed trade with the State of Washington, where Alopecurus myosuroides is regulated as a noxious weed. The value of grass seed exported to Washington in 2008 was low at approximately $960, 000 (Industry Canada 2009).
• There is potential for reduction and or loss of some import markets for Canadians if exporting countries are unable to meet proposed phytosanitary requirements. This loss will be significant as a large proportion of seed imports originate from countries where Alopecurus myosuroides is present.
• Exporting countries 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 Alopecurus myosuroides within a seed sample. Exporters may need to ensure freedom of Alopecurus myosuroides 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 5}.
• Seed contaminated with Alopecurus myosuroides could be re-cleaned to remove the contaminant seeds. Alopecurus myosuroides seeds can be readily screened out of grass seed lots as the size of the seeds are 4.5-7.5 mm (Hubbard 1968). The seeds are readily identifiable by trained analysts and can be separated from seeds of other Alopecurus species. This should be done in the exporting country.

Hay and Straw

Previous imports

The total value of hay and straw imports was around $13 million in 2008; 98% of this value came from the U.S. (Industry Canada 2009).

• Between 2004 and 2008, high quantities of hay and straw (an approximate average value of $11.1 million per year) were imported from Washington and Oregon, where Alopecurus myosuroides 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). Consult Appendix 2E for a detailed breakdown of hay and straw imports for the last 3 years.
• The level of risk associated with imports of hay and straw into Canada is relatively high since they originate primarily from areas where Alopecurus myosuroides is present.

Potential risk mitigation measures

Regulate Alopecurus myosuroides 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 6}.

Regulatory actions could include one or more of the following:

• Exporters could be required to obtain a Phytosanitary Certificate with or without an Additional Declaration stating freedom from Alopecurus myosuroides.
• Requirement for an import permit 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.
• Recognition of Pest Free Areas – if Alopecurus myosuroides can be shown to be absent from the country/state/region where the hay or straw was produced, then risk is negligible and additional phtyosanitary 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 Alopecurus myosuroides under the Plant Protection Act will address the potential export of hay and straw (value of approximately $3.6 million in 2008; Industry Canada 2009) to the State of Washington, where Alopecurus myosuroides is regulated.
• 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 seeds of Alopecurus myosuroides that could be associated with hay and straw. Pre-harvest field inspections may be the most feasible option to ensure pest freedom. Exporters need to ensure freedom of Alopecurus myosuroides in hay and straw, otherwise CFIA can refuse import.
• Since 98% of hay and straw imports come from the U.S., and the majority from the state of Washington where Alopecurus myosuroides is invasive, there could be significant market losses of this commodity if it is found to be contaminated.

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, alone or in association with plants" (CFIA 2008).

In 2003, the Canada Border Services Agency (CBSA) assumed responsibility for the initial import inspection services in respect of the Acts and Regulations administered by the CFIA to the extent that they are applicable at Canadian border points. The inspections of goods that may be contaminated with soil are among the responsibilities that were transferred to the CFIA in 2003. The Food, Plant and Animals Programs Section of the CFIA is currently finalizing its Standard Operating Procedures (SOP) concerning the "Inspection of Imported Goods Potentially Contaminated with Soil." This SOP provides the CFIA'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.

• Previous
• Table of Contents
• Next