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RMD-13-04: Consolidated Pest Risk Management Document for pest plants regulated by Canada
Appendix 15B: Risk Management Considerations for Zygophyllum fabago (Syrian bean-caper)
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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
As described in Section V, natural dispersal is a possible pathway; however there is a high level of uncertainty regarding this. The species is regulated in Washington and Idaho and populations have been controlled. Therefore, risk mitigation measures will not be suggested.
Potential Mitigation Measures for Intentional Introduction Pathways
Plants for Planting Excluding Seed
Intentional introduction for planting is the most likely pathway for entry of Zygophyllum fabago into Canada, as it can be used as a medicinal herb or as a flavoring.
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 2008, 2009). Some plants from the continental U.S. also require a Permit to (CFIA 2009).
Based on the information available in the CFIA's Import Permit System, Import Retrieval System, and information compiled at the CFIA's Import Service Centres, Zygophyllum fabago has not been recently imported into Canada.
Potential risk mitigation measures
- a) Use sterile cultivars if they exist. The efficacy of this measure is unknown. The CFIA has never received an application to import sterile cultivars of Zygophyllum fabago.
- b) Encourage voluntary cessation of the sale of Zygophyllum fabago. Voluntary cessation is not effective by itself, but could support other measures.
- c) Increase public awareness of the risk posed by this plant, publish a factsheet online, and distribute awareness material to garden centers, botanical gardens, gardeners associations, horticulture industry groups, etc. This measure is not considered effective by itself, but could support other measures.
- d) Allow sale of Zygophyllum fabago with special conditions such as not to be grown close to natural areas and mandatory control of adventives. Allowing sale with special conditions is not considered effective because once the plant is grown in private gardens, CFIA does not have adequate resources to monitor.
- e) Regulate Zygophyllum fabago under the Plant Protection Act as a quarantine pest in order to:
- Prohibit the importation of plants of Zygophyllum fabagoFootnote 1.
- Require importers of material to specify the scientific name when applying for a Permit to Import plant and propagative material.
- Require the scientific name to be provided on the Phytosanitary Certificate for all plants exported to Canada.
For species intended for large scale cultivation in Canada:
- f) Zygophyllum fabago can proliferate in coarse mineral substrates contaminated with heavy metals and studies are being conducted to assess its potential use in phytoremediation (Lefèvre et al. 2006). Nothing indicates that Zygophyllum fabago is currently cultivated in Canada, but there may be an interest in the future.
- g) The commercial cultivation of Zygophyllum fabago as a crop requires conditions in order to mitigate risks to food, feed, or other environmental risks. Example conditions include geographic limitations or reproductive isolation. Regulation of Zygophyllum fabago as a New Crop under Part V of the Seeds Regulations could be explored.
- If Zygophyllum fabago is regulated under the Plant Protection Act, no market losses are expected since there is no known current trade of this species in Canada.
- Regulation of Zygophyllum fabago under the Plant Protection Act could facilitate the export of Canadian greenhouse and nursery plants, seed and grain to countries that currently or will in the future prohibit Zygophyllum fabago by maintaining country/area freedom.
Cost-effectiveness and Feasibility
- If Zygophyllum fabago is regulated, additional staff would not be required at the CFIA Plant Health Permit Office to regulate the species. Applications for Permits to Import are reviewed by officers on a regular basis. Enforcement of the prohibition to import would require importers to specify full scientific names on their applications for permits to import, instead of only the genus name, as is often the case currently. This requirement is already in place (see CFIA Directive 97-04; CFIA 2008), but Permit Office staff may need to spend some time communicating this requirement to importers.
- CFIA Plant Health inspection staff will need to be trained to identify Zygophyllum fabago.
Websites list seeds of this species for sale as a medicinal herb (CFIA, 2009), but it is difficult to know the level of interest in the plant in Canada.
Potential risk mitigation measures
Regulate Zygophyllum fabago as a prohibited noxious weed (Class 1) under the Weed Seeds Order of the Seeds ActFootnote 2.
- This species meets the definitions for 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 Zygophyllum fabago is absent from the seed lot before it can be imported.
Regulate 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. 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 spreadFootnote 5.
Regulatory actions under the Plant Protection Act could include the following:
- Prohibit importation of Zygophyllum fabago. 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.
- 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 draft directive D-08-04 on plants for planting (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 Zygophyllum fabago 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.
- If Zygophyllum fabago seeds are regulated under the Weed Seeds Order of the Seeds Act, no market losses are expected since there is currently no known trade of Zygophyllum fabago seeds in Canada.
- There may be an impact on the importation of other Zygophyllum spp. as foreign NPPOs will need to identify Zygophyllum fabago seeds as well as any other Zygophyllum species listed on Phytosanitary Certificates.
Cost-effectiveness and Feasibility
- The CFIA Seed Program is already in place to prevent the entry of prohibited noxious weeds.
- There should be no difficulties in detection and identification of seeds (Allison 2009).
Potential Mitigation Measures for Non-intentional Introduction Pathways
Zygophyllum fabago is "thought to have been imported to the United States at the turn of the century in contaminated alfalfa seed" (Davison and Wargo 2001).
- The Seed Science and Technology Section of the CFIA Saskatoon laboratory maintains a record of contaminants found through marketplace monitoring of domestic and imported seed. Zygophyllum fabago has not been recorded in imported or Canadian seed samples.
- From 2006-2008, an average of approximately $3.9 million and 779,000 kilograms per year of alfalfa seed was imported from countries where Zygophyllum fabago is present (Table 33; Statistics Canada 2009). This represents approximately 78% of total alfalfa seed imported between 2006 and 2008 (Industry Canada, 2009).
Import data for Alfalfa seed originating from countries where Zygophyllum fabago (Syrian beancaper) is present.
Although a large percentage of imported alfalfa seed originates from areas where Zygophyllum fabago is present, the level of risk associated with this pathway is relatively low since the species is not a common weed of agricultural fields (CFIA 2009). No imports are coming from countries in the weed’s native range, which would be the most likely source of contaminated alfalfa seed.
|U.S. - Idaho||4,772,722||1,580,344||2,799,074|
|U.S. - California||421,346||649,464||197,474|
|U.S. - Washington||26,447||404,826||199,382|
|U.S. - Montana||7,709||10,583||18,097|
|U.S. - Idaho||955,171||327,406||440,995|
|U.S. - California||114,149||166,799||43,479|
|U.S. - Washington||5,457||80,165||45,398|
|U.S. - Montana||971||2,158||5,275|
Source: Statistics Canada 2009
Potential risk mitigation measures
Regulate Zygophyllum fabago as a prohibited noxious weed (Class 1) under the Weed Seeds Order of the Seeds Act Footnote 6.
- This species meets the definitions for Class 1 Footnote 7 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 Zygophyllum fabago is absent from the seed lot before it can be imported.
Regulate Zygophyllum fabago 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 spreadFootnote 8.
Regulatory actions under the Plant Protection Act could include one or more of the following:
- Exporters may be required to provide a Phytosanitary Certificate with or without an Additional Declaration stating freedom from Zygophyllum fabago.
- 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 pest status, handling and use of the commodity. Prior to permit issuance, a facility inspection by CFIA and verification of the importer's ability to meet permit requirements may be required.
- Recognition of foreign government phytosanitary noxious weed certification in countries or states of origin may allow for additional phytosanitary requirements to be waived.
- Regulation of Zygophyllum fabago under the Seeds Act and Plant Protection Act will safeguard seed trade with the five U.S. states (Idaho, California, Nevada, Oregon and Washington) where Zygophyllum fabago is regulated as a noxious weed. Canada exported approximately $23.7 million worth of alfalfa seed in 2008 to these states (Industry Canada, 2009).
- 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 seed of Zygophyllum fabago within a seed sample. Exporters will need to ensure freedom of Zygophyllum fabago 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 phytosanitary 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.
- The seeds of Zygophyllum fabago are easily identified by trained seed analysts (Allison 2009).
Vehicles and Used Farm Machinery
Root fragments can sprout to form new plants (Davison and Wargo, 2001). It is possible that root fragments could be transported on equipment. Since Zygophyllum fabago is not a common weed of agricultural fields, this is considered a low-risk pathway.
- 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 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 has developed 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.
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