Proposed changes to the plant protection requirements for importing earthworms into Canada for commercial purposes

To enhance alignment with plant health risks and compliance with international plant protection principles, the Canadian Food Inspection Agency (CFIA) is proposing to update its requirements for importing earthworms for commercial purposes by:

• defining the list of approved earthworm species by whether they are present in the Canadian environment
• removing plant protection requirements for importing aquatic earthworms
• using the same list of approved earthworm species for all origins
• requiring a permit to import earthworms from the continental United States (US)

Background

Earthworms may present a threat to Canada's agricultural, forestry and natural environments in which they are not present. They may be pests themselves or be pathways for the entry of parasites and diseases due to their potential of carrying soil (for example, in their guts).

Earthworms are imported into Canada for commercial purposes such as for use as bait and for vermicomposting. The CFIA enforces requirements under the Plant Protection Act to mitigate risks to plant health that are presented by these activities (for ex., impact on nutrient cycling patterns in soil).

Import requirements concerning earthworms are provided in the CFIA's plant protection directive D-12-02. Appendix 1 to D-12-02 lists terrestrial and aquatic earthworms that may be commercially imported into Canada from specified origins, along with import requirements.

Earthworms that are approved for importation from the continental US are those that are present in at least four Canadian provinces. If the origin is one of the 16 US states infested with a soil-borne micro-organism quarantine pest, the earthworms must undergo a cleansing period of at least 15 days before shipment to Canada.

Only one species is listed in Appendix 1 as approved for import from outside the continental US. Shipments must be certified by the exporting country to confirm the identity of the specimens and purity of the shipment, and that cleansing was undertaken.

The US Department of Agriculture's requirements are similar to Canada's. The US allows one species from countries other than Canada, provided that the country is free from foot-and-mouth disease and that cleansing was undertaken to remove soil from their bodies.

Considerations

a. General

Earthworms are considered beneficial organisms in some environments. However, the introduction of new species may disrupt the nutrient cycle in environments that have evolved without or with other earthworms.

Contrary to terrestrial earthworms, aquatic earthworms do not appear to pose either a direct or indirect threat to plants. The removal of aquatic earthworms from plant protection requirements should not adversely affect plant health.

Lowering the threshold for approving earthworms for import – from being present in at least four provinces to only being present in the Canadian environment – presents a risk to the environment if earthworms are imported and released into new areas.

However, the CFIA does not control the in-country spread of earthworms. No measures are in place to control either their intentional (for example, through trade) or accidental (for example, with the movement of soil) spread in Canada. As such, the broadening of the list of approved species should not change the level of risk to the environment.

b. Continental US versus elsewhere

Earthworms may carry soil in their gut, presenting a pathway for the introduction of certain soil-borne quarantine pests. Earthworm cleansing is required for all origins, with the exception of US states that are not infested with a quarantine pest that is a soil-borne microorganism.

The invasiveness of earthworms of the same species does not appear to differ across countries of origin. Provided that the soil pathway is addressed, allowing the same approved earthworms from all countries should not increase risk to plant health in Canada.

The CFIA maintains the ability to review import proposals on a case-by-case basis. As needed, additional conditions may be put in place by the CFIA to mitigate identified risks.

Allowing the same approved species from all countries could impact exports. Restrictions may be placed on earthworms from Canada.

c. Permit to import from the continental US

The Plant Protection Act and Regulations require that permits be obtained to import things that are or could be pests or infested with pests. The CFIA may issue permits with conditions to mitigate risks to plant health. Failure to comply with conditions may lead the CFIA to take enforcement actions.

Permits are currently not required to import approved earthworms from the continental US. Conditions for import are specified in directive D-12-02 and the CFIA's Automated Import Reference System. Because permits are not required, this presents compliance and enforcement challenges under the Plant Protection Act and Regulations.

It is internationally recognized that soil, even in small amounts, may harbour plant pests. The entry and establishment of soil-borne pests may have serious impacts on Canada's plant resources and on its access to export markets.

To increase the strength and enforceability of plant health measures, the CFIA plans to require a permit in order to import approved earthworms from the continental US. Permits will be valid for three years, and will specify conditions informed by the US state of origin or production.