National Plant Board

Plant Quarantine, Nursery Inspection, and Certification Guidelines

Appendix J

Interstate Origin Inspection

I. Purpose

This appendix is intended to complement and accompany the National Plant Board’s Plant Quarantine and Nursery Inspection Program Guidelines for the purpose of fostering a clear understanding of the concept and elements of interstate origin inspection and its role in plant quarantine and nursery inspection.

II. Concept and Role

The interstate origin inspection program concept focuses on 1) the performance of plant quarantine or nursery stock inspection requirements at the point of origin in the shipping state, and 2) acceptance by the receiving state regulatory officials of the inspection as equivalent to any inspection they might make of the contents of the shipment upon arrival at the premises of the consignee.

Chiefly, the role of an interstate origin inspection program is pest risk mitigation; but, a facilitator role also is involved in that pest inspection can be made effectively and more efficiently where the shipment is assembled; and delays associated with holding and inspection at the consignee’s location can be eliminated. Orderly marketing is enhanced when an interstate origin inspection program can be implemented and effectively administered.

III. Elements

Two sets of elements are presented to address the differences between interstate origin inspection programs for plant quarantine (phytosanitary) and nursery stock pest cleanliness standards. However, they are not mutually exclusive and can be combined as needed.

A. Plant Quarantine (Phytosanitary)

1. Identifying the pest(s) covered – The pest(s) covered must be specifically identified because the criteria for what constitutes a quarantine pest are distinctly different from those for “quality” pests. Furthermore, there are differences of economic impact and importance among pests that would meet the criteria for quarantine pests (See Appendix E).

2. Identifying the federal, state, or local pest prevention organization – Part of the risk associated with an origin inspection program relates to the capability and motivation of the governmental agency that must be relied upon to administer it at origin. Administrators must fully understand what is involved with pest prevention in the United States (See Appendix A) and be committed to its effectiveness both in its own best interests as well as those of the receiving state(s). This includes basing decision-making on scientific and biological considerations and keeping political considerations in the background. Indeed, political factors are involved and play a role in many phytosanitary decisions, but they must not be the overriding factors. Administrators must know and be committed to complying with the National Plant Board Plant Quarantine and Nursery Inspection Guidelines.

3. Selecting Shippers for Participation – As a minimum, the following criteria should be used to evaluate and select shippers to participate in a plant quarantine interstate origin inspection program:

a. Good Shipping Record – At least a six-month shipping record of good compliance with quarantine requirements. “Good” compliance means proper identification and phytosanitary certification of shipments, very low incidence of pest interceptions, no shipping of prohibited commodities, and compliance with other receiving state requirements.

b. Production Area Pest Management – A system of pest control including pest exclusion, inspection (and/or testing), and treatment (as required) should be in place with someone responsible for them and held accountable for their effectiveness.

c. Hosts Shipped – Extremely good hosts for quarantine pests might be excluded from the interstate origin inspection program unless an effective commodity treatment is available and used to prevent infestation; or pests can be excluded during production, packing, and shipping.

d. Commitment – The participating shipper must be committed to compliance with quarantine requirements. The economic advantages that will accrue must not be the motivating factor and the program administrators should interview all potential candidates and inspect the growing/shipping facilities to ascertain that the candidate is both capable of satisfying the requirements and willing to do so. The pest situation in the growing/shipping area together with the shipping record will be two good indicators of this.

4. Agreement – A three party agreement should be executed. The shipping state agency should be made responsible and accountable for administering the program locally and for monitoring the operations of the shipper to assure compliance. The shipper should be made responsible for pest exclusion, monitoring, treatment, record-keeping for treatments and shipping, and the proper use of special certificates. The receiving state should be responsible for working with the origin state agency to administer the program, monitoring, prompt reporting of any deviations, and taking corrective actions. A model agreement accompanies this appendix as Attachment A.

5. Certificates – The use of a special certificate (See part IV of this appendix) or some other form of documentation should be authorized by the receiving state to indicate to carriers and receivers that its quarantine requirements have been met and that the stock need not be held for inspection upon arrival at the premises of the consignee. One person should be designated by the participating shipper as responsible and accountable for the proper use of the special certificate or other documentation specified in the agreement.

6. Corrective Actions – The agreement should specify what action(s) will be taken upon the discovery of violations; and provide for suspension or revocation in cases of repeated violations, change of ownership, or other such critical factors.

B. Nursery Inspection

1. Identifying what is covered – Programs can be developed to cover a wide range of quality pests or just a particular class of pests of special concern to the receiving state. Typically, the pest(s) listed will relate to the receiving state’s nursery stock pest freedom and other standards. For example, if a state is concerned about nematode pests on nursery stock for farm planting, nematode pests could be specifically targeted. Other standards might include such things as plant quality, identification, and labeling requirements; plant grades; and plant registration and certification.

Plant materials subject to quarantine may be excluded and covered by the previously described plant quarantine interstate origin inspection program; or covered by special provisions. As stated at the outset of this appendix, it is possible to “marry” plant quarantine and nursery inspection interstate inspection programs to meet both sets of needs.

2. Identifying the federal, state, or local pest prevention organization – In most cases, these organizations will be the same as those that administer plant quarantine programs. However, there are situations where two different organizational units or branches are involved, typically with a common administrator. In any case, the same criteria would apply in determining whether an agency is capable and willing (properly motivated) to effectively administer a nursery stock interstate origin inspection program.

3. Selecting Shippers for Participation – The criteria specified for a plant quarantine interstate origin inspection program should be applied together with any special considerations associated with nursery inspection such as current licensing and authorization to use the origin state’s nursery inspection certificate.

4. Agreement – A nursery stock interstate origin inspection certificate also will be a three party agreement with the same entities as for plant quarantine, except that different governmental units might be involved. The areas of responsibility also will be the same. However, certain tests, inspections and tolerances for pests may be included; and the action(s) that would be taken upon the discovery of a violation should not be as severe as those for plant quarantine violations.

5. Certificates – A special interstate origin inspection certificate should be authorized for use by the participant as a means of letting carriers and consignees know that the receiving state’s requirements have been met and that the shipment need not be held for inspection upon arrival. One person should be designated by the participant as responsible and accountable for the proper use of that certificate.

The plant quarantine interstate origin agreement model that is attached (Attachment A) serves equally well as a model for a nursery inspection agreement.

IV. Interstate Origin Inspection Program Certificates

A. Format – The following format and color scheme is exclusively reserved by the NPB and should not be used except on shipments that are not required to be held upon arrival at destination (carrier terminal or premises of the consignee) pursuant to a formally approved interstate origin inspection or other preclearance program as described in this appendix.

__________________________

(Name of State)/(Name of State)

INTERSTATE ORIGIN INSPECTION/PRECLEARANCE

NURSERY STOCK CERTIFICATE

No.___________________ (White area)

This plant material or nursery or premises from which this shipment was made has been inspected pursuant to an (Name of State)/(Name of State) origin inspection/preclearance agreement and found to be in compliance with its terms.

THIS SHIPMENT NEED NOT BE HELD

BY THE CONSIGNEE FOR

AGRICULTURAL INSPECTION IN

(Green area) (NAME OF STATE)

(Date optional)

Issued by: (Name of State and address) and (Name of State and address)

_____________________________

B. Authorization – Program participants should be formally authorized to use the Interstate Origin Inspection/Preclearance Nursery Stock Certificate. Attachment B is the recommended format for authorizing use.

C. Use on Commercial Shipments – No interstate nursery stock certificate or interstate origin inspection/preclearance nursery stock certificate shall be used:

1. On any shipment of nursery stock that is not in compliance with National Plant Board pest freedom standards and an interstate origin inspection/preclearance agreement.

2. On any shipment of nursery stock any portion of which was grown by a nursery not eligible to use such nursery stock certificates, unless such portion of the shipment is duly inspected by a state nursery inspection program representative and found to meet National Plant Board pest freedom standards and the terms of the origin inspection/preclearance agreement.

3. By any person other than the shipper to whom it is issued.

4. On any shipment of nursery stock for which movement is restricted by a specific quarantine unless also accompanied by the required quarantine (phytosanitary) certificate or permit, or as specifically approved in an interstate origin inspection/preclearance program agreement.

D. Use on Noncommercial Shipments – State governmental nursery inspection agency representatives may affix an interstate nursery stock certificate on noncommercial shipments of plants not subject to quarantine restrictions which they inspect and find to be in compliance with National Plant Board nursery stock pest freedom standards. No special agreement is required for this use.

Appendix J (Attachment A)

Model Interstate Origin Inspection/PreClearance Agreement

(Name of State) AND (Name of State)

INTERSTATE ORIGIN INSPECTION AGREEMENT

NO. (Official State Name Abbreviation followed

by OI – License, registration number, or sequential number)

1. Nursery Name and Mailing Address 2. Shipping Address

3. Kind(s) of Approved Nursery Stock 4. Authority

The (Name of State) Department of Agriculture hereby approves (Name of Firm) to make shipments into (Name of State) of the stated kinds of plant materials which may be released without holding for destination inspection. This approval does not preclude inspection and sampling or testing at the discretion of the (Name of State) Department of Agriculture, and rejection as a consequence of the findings of that inspection and/or test(s). (Name of Firm) is authorized to use the (Name of State)/(Name of State) Origin Inspection Certificate as shown on the attached “Authorization for Use of (Name of State)/(Name of State) Origin Inspection Certificate”.

This approval and authorization is made subject to compliance with the following requirements. (Name of Firm) shall:

1. Maintain a growing season and post-harvest pest control program approved and monitored by the (Name of State) and meet all pest freedom standards outlined by the (Name of State) Department of Agriculture. (Name of State) Department of Agriculture will supply the grower/shipper with information describing the aforementioned pest control program and pest freedom standards.

2. Assign a person(s) to be responsible for growing season and post-harvest pest control and quality control monitoring.

3. Implement a pest quality control program that includes post-packing and pre-shipment checks of finished products and the correction of any problems relating to pests, proper identification of shipment contents or compliance with the requirements of the agreement discovered prior to shipment or upon arrival in (Destination State).

4. Ship only plant material named in this agreement. Plant materials not initially approved under this agreement may be added in a memorandum between the (Name of State Department of Agriculture) and the (Name of State Department of Agriculture).

5. Affix to each carton in the shipment a (Name of State)/(Name of State) Origin Inspection Certificate obtained from the (Name of State) Department of Agriculture and approved by the (Name of State) Department of Agriculture.

6. Maintain a chronological record of all shipments to (Name of State) receivers and, upon request, make such records available to officials of the (Name of State) Department of Agriculture and/or the (Name of State) Department of Agriculture. The record shall include the kind(s) and quantity of each kind of plant material shipped, the date of shipment, and the name of the consignee.

7. Comply with all of the following special requirements:

a. Assure that only eligible commodities are packed in cartons bearing interstate origin inspection certificates. Particular note should be given to the fact that the shipment from (Name of State) of (commodity) is prohibited under (give statute).

b. Assure that plant materials purchased or otherwise obtained from outside sources are inspected and rendered free of pests listed by the (Name of State) Department of Agriculture as quarantine pests; and are essentially free of pests that are treated as quality pests pursuant to established standards.

c. Assure that all cartons shipped bear the following:

1. Name and address of the approved grower/shipper;

2. Name and address of person (or his or her agent) to whom the shipment is being sent;

3. Name of the county, state, or territory where the contents were grown;

4. A statement of the contents;

5. The statement, “May be opened for agricultural inspection”.

8. Comply with all other requirements the (Name of State) Department of Agriculture deems necessary to assure compliance with (Name of State) pest freedom standards.

9. Designate one person to be responsible for assuring compliance with all of the requirements of this agreement.

Upon the discovery of a quarantine pest in the grower/shipper’s shipment in (Name of State), the (Name of State) Department of Agriculture will commence an investigation of the cause(s) of the infestation, work with (Name of Firm) to take corrective action, and notify the (Name of State) Department of Agriculture of the results. These actions will be completed within 10 calendar days, unless shipments using the interstate origin inspection/preclearance certificate have been suspended.

Noncompliance with the requirements stated herein may result either in suspension or revocation of authorization to use the origin inspection certificate. Otherwise, this agreement shall remain in force until revoked by either the (Name of State) Department of Agriculture or by the (Name of State) Department of Agriculture or the ownership and management of (Name of Firm) changes. Revisions to this agreement may be made by memorandum as necessary to include, delete, or modify requirements.

_________________ ________________

(Name of Firm) (Name of State)

Ownership/Management Department of Agriculture

_________________ ________________

(Name of State) Effective Date

Department of Agriculture

Appendix J (Attachment B)

AUTHORIZATION FOR USE

OF

(NAME OF STATE)/(NAME OF STATE) ORIGIN INSPECTION CERTIFICATE

NO. (Official State Name Abbreviation followed

by OI – License, registration number, or sequential number)

(Name of Firm) (Name of Firm)

(Address of Firm) (Address of Firm)

This authorization to use (Name of State)/(Name of State) Inspection certificates is issued concurrent with (Name of State) and (Name of State) Origin Inspection Agreement No. (Official State Name Abbreviation followed by OI – License, registration number, or sequential number). It is subject to revocation or suspension in accordance with provisions of the Origin Inspection Agreement. This certificate is not transferable either to location or ownership. Use is limited to those kinds of plant materials specified in the Origin Inspection Agreement.

This certificate may not be reproduced. For additional copies of this certificate, contact the (Name of State) Department of Agriculture at (Phone Number).

________________________________________________________

(NAME OF STATE)/(NAME OF STATE) ORIGIN INSPECTION CERTIFICATE

FOR INTERSTATE SHIPMENTS

NO. (Official State Name Abbreviation followed WHITE

by OI – License, registration number, or sequential number)

This plant material or nursery or premises from which this shipment was made has been inspected pursuant to an (Name of State)/(Name of State) origin inspection/preclearance agreement and found to be in compliance with its terms.

GREEN THIS SHIPMENT NEED NOT BE HELD BY THE

CONSIGNEE FOR AGRICULTURAL INSPECTION IN (NAME OF STATE)

Issued by: (Name of State Department of Agriculture and Address)

Issued __________________________

Effective Date

_________________________

Signed __________________ Signed_____________________________

(Name of State Department (Name of State Department of Agriculture) of Agriculture)