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The purpose of National Plant Board (NPB) policy formulation and issuance is to:
- Assign responsibility for carrying out the principles and practices of the NPB’s constitution and bylaws.
- Provide a basis for development of procedural guidelines for the NPB’s organizational, personnel and financial affairs.
- Bring about an understanding of international, federal, state and local pest prevention and plant health issues and programs.
- Establish guidelines for international, federal, state and local pest prevention and plant health program operations.
- Provide recognized authority, consistent with applicable laws, under which action is to be taken and to minimize the possibility of unauthorized action.
- Facilitate decisions and promote consistency of interpretation and application of laws, regulations, policies, guidelines, and principles across organizational lines and over time.
- Provide a record to guide future policy formulation and issuance and serve as a framework for policy revisions that appear to be desirable on the basis of experience.
1.1.2 Key Policy Elements
The key elements of NPB policy formulation and issuance are as follows:
Formation of a standing NPB Policy Committee consisting of two representatives of each of the four regional plant boards with responsibility for ensuring compliance with the requirements of this policy statement, ongoing review of existing policy, and drafting, or soliciting drafts of, new policies.
1. Collaboration with the National Association of State Departments of Agriculture (NASDA) to:
a. Help ensure inter-organizational policy consistency.
b. Provide input to NASDA policy-making relative to plant pest prevention and plant health issues, programs and trade.
3. Solicitation of input from other interested and affected parties prior to the issuance of new or revised policy.
The Policy Committee shall, in advance of official adoption, develop an orderly means of determining and considering, fairly and impartially, the views of organizations or persons who must apply, or who will be affected by, a particular NPB policy
In developing the means for obtaining and considering the views of interested and affected parties, the Policy Committee should consider the following:
a. Appropriate organizations, individuals, or special consultative groups to be tapped for suggestions and opinions and whether they adequately represent those interested and affected.
b. The methods to be used to solicit suggestions and opinions such as personal contacts, conference calls, questionnaires, or requests for written comments.
c. Periodic evaluation of the effectiveness of the methods used for contacting interested and affected parties.
4. Ensuring consistency with applicable laws, regulations, other established relevant policies, and the rules (constitution and bylaws) that govern the NPB.
In considering this key element of NPB policy formulation and issuance, the Policy Committee should evaluate the degree to which policies:
a. Are built around and related to the laws, regulations, etc. that are imposed by higher or outside authority.
b. Possess sufficient content to minimize the need for consulting other documents or applicable laws, regulations, etc.
5. Formulation, as needed, of appropriate procedures and instructions for implementing NPB policies, for submission to the officers and Board of Directors for approval and issuance to the membership.
To the extent that prescribed procedures or other detailed instructions are necessary for the uniform and consistent application of NPB policies, the Policy Committee shall ensure that these procedures or instructions truly do facilitate the application of relevant policy by making certain that they are:
a. Easily located and used by being conveniently keyed, cross-referenced, or otherwise linked-up with relevant policy statements.
b. Simple, but complete and flexible enough to permit full and effective application consistent with frequency of use, the number of persons or entities affected, and the volume of activity involved.
6. Publication of policies:
a. Policies shall be issued and maintained in a simple and orderly manner so that they are easy to find and use.
b. Approved policy statements shall be made available promptly to all NPB members and other interested and affected parties.
From time to time it is advantageous to invite special speakers to the National Plant Board (NPB) annual meetings in order to properly address certain topics. Occasionally it might be necessary that the NPB reimburse these invited special speakers for expenses incurred. Also, other situations may arise when individuals may be reimbursed for travel costs incurred by the NPB. The following shall be guidelines for reimbursement of such expenses:
1.2.2 Key Policy Guidelines
The following shall be guidelines for reimbursement of such expenses:
- If the speaker would not normally be eligible for reimbursement from the agency or organization which he or she represents.
- If the speaker’s expenses cannot be covered by funds provided by another agency or organization.
- The NPB budget must be in such condition that reimbursement can be provided without jeopardizing normal cash flow.
- Reimbursement for expenses must be approved by the NPB Executive Committee prior to the finalization of the agenda.
- Receipts for expenses incurred should include air travel receipts, motel receipts, and any other receipt for individual expenses over $20.00. Meals, taxi, etc. need not be documented with receipts when under $20.00.
- All documentation for reimbursement should be sent directly to the NPB Secretary- Treasurer as soon as possible after the annual meeting.
- Travel expenses for the NPB President may be paid by the NPB when the President’s state cannot or will not cover expenses. Such reimbursement shall comply with paragraphs 3, 5 and 6 above.
- Travel expenses for NPB members who travel at the request of or in lieu of the NPB President shall be paid by the NPB when the members’ state cannot or will not cover expenses. Such reimbursement shall comply with paragraphs 3, 5 and 6 above.
Each year each regional plant board may nominate a National Plant Board (NPB) member for the National Association of State Departments of Agriculture (NASDA) Honor Award and the American Association of Nurserymen sponsored Entomological Society of America (ESA) Distinguished Achievement Award in Regulatory Entomology. An information package in support of each regional board’s nominee is reviewed by the NPB Executive Committee and the NPB’s nominees are selected.
1.3.2 Key Policy Guidelines
The following guidelines shall be followed regarding this process:
- 1. The NPB President shall provide guidelines for each award to each regional plant board chairman approximately 30 days prior to the regional plant board’s annual meeting.
- Each regional plant board may nominate a NPB member for each award.
- The regional plant board chairman or his designee(s) shall be responsible for providing personal data packages in support of the regional board’s nominee to the NPB President on or before June 1.
- The NPB President shall duplicate the data packages and submit them to the NPB Executive Committee by June 7.
- Each NPB Executive Committee member shall review the data packages and submit a recommendation to the NPB President by June 21.
- The NPB President shall tally the recommendations and submit the NPB’s nominees to the appropriate agency (ESA, NASDA) for further consideration.
- In the event that the NPB President is a regional plant board nominee paragraphs 4 and 5 shall be handled by the NPB Vice President.
- The NPB’s nominees shall be announced during the NPB annual meeting.
The National Plant Board (NPB) has a “Quarantine and Nursery Standards Committee” (QNSC). The QNSC developed, and the NPB subsequently adopted, “Plant Quarantine, Nursery Inspection, and Certification Guidelines” (Guidelines).
The declared purposes of the Guidelines are to:
- Clarify the elements of pest prevention (Appendix A of the Guidelines).
- Establish the objectives and bring about an understanding of plant quarantine and nursery regulatory programs in the United States.
- Identify the purposes and uses of enforcement mechanisms (Appendix B of the Guidelines).
- Facilitate consistency of interpretation and application across organizational lines and over time.
- Serve as a framework for policy and law revisions that appear desirable on the basis of experience.
As indicated by the foregoing purposes, the Guidelines contain extensive plant pest prevention and plant health information, some of which becomes dated and in need of review, evaluation and revision to ensure coverage of relevant issues or topics and consistency with the development of related national and international standards and new initiatives or programs.
It is the policy of the NPB to ensure the continued effectiveness and relevance of its Guidelines by creating a close and definite link between the Guidelines and current and future plant pest prevention and plant health policies.
In order to achieve these ends, the NPB reaffirms that the Guidelines are for the use of federal, state and local plant pest prevention and plant health officials to:
- Facilitate and govern the identification of quarantine pests, identify pest harm, and assess pest risk.
- Identify pest risk mitigation methods and develop, implement, and manage pest risk mitigation strategies, including quarantines, origin inspection, pre-clearance, pest-free areas, special permits, and compliance agreements.
- Facilitate uniformity in pest prevention and orderly marketing decision- making and action among federal, state and local regulatory officials.
- Provide a basis for pest prevention program review and evaluation.
- Establish an approach to settling disputes over the propriety of pest risk mitigation strategies imposed by state and local regulatory officials.
Further, it is the NPB’s policy that:
- These guidelines shall be distributed to all NPB members; the United States Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine (USDA-APHIS-PPQ), the USDA-APHIS International Services, the USDA Forest Service, the US Department of Interior, and other interested and affected parties.
- The Guidelines be reviewed and updated every two years. The updating and distribution of these guidelines shall be the responsibility of the QNSC.
- Each state plant regulatory agency is responsible for following the Guidelines, providing copies of them to its staff, and providing relevant staff training.
The United States Department of Agriculture (USDA) maintains a list of noxious weed pests. A number of weed pests on the list already exist to a varying extent within the United States. Some are quite common in occurrence.
Many National Plant Board (NPB) member state agencies also maintain noxious weed pest lists, as well as noxious weed pest lists as seed lot contaminants.
Confusion and conflicting positions occur when applicants for federal permits to move a federally listed noxious weed are submitted to states for review and approval or denial.
It is the policy of the NPB to foster development of a federal noxious weed regulation that addresses pest risk, invasiveness and distribution. Accordingly, a federal noxious weed regulation should:
- Set forth the criteria that shall be used by the USDA in determining the invasiveness of any plant species proposed for import, intercepted in quarantine shipments, or detected within the United States.
- Specify that invasive weed pests known not to occur in the United States are federal foreign noxious weeds and prohibited entry.
- Specify that invasive weed pests of limited distribution, or of wide but not general distribution, are federal domestic noxious weeds and interstate movement is restricted.
- Provide for the approval of state pest prevention, suppression or control programs for invasive weed pests that are known not to occur in an area thatwould be harmed by introduction, colonization and establishment.
While many non-native species have proven to be beneficial, it has been clearly demonstrated (U.S. Congress, Office of Technology Assessment, 1993, Harmful Non- Indigenous Species in the United States, OTA-F-565, Washington, D.C., 391 pp.) that numerous other non-native, invasive plant/pest species have caused billions of dollars of damage to the nation’s agriculture, environment and economy. These species have radically interfered with the production of crops and timber and the interrelationships of other living organisms in both aquatic and terrestrial ecosystems; reducing biological diversity by eliminating some species and threatening and endangering others.
There is a direct, close relationship between pest occurrence and freedom and agricultural productivity and profitability, farm product quality and affordability, and domestic and international marketability. The U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine (USDA-APHIS-PPQ) and state and local departments of agriculture have, for more than 100 years, developed and administered laws, regulations, policies and programs aimed at preventing the harm that serious, non-native, invasive plant and plant pest species can cause to agriculture, the environment and our economy.
Due primarily to environmental concerns, President William Jefferson Clinton issued an executive order providing for coordinated efforts to prevent the harm serious, non-native, invasive plant/pest species can cause. Internationally, a Biodiversity Convention and Biodiversity Protocol have been developed to frame and guide environmental protection efforts relevant to serious, non-native, invasive plant/pest species
It is the policy of the National Plant Board (NPB) to foster and support federal, state and local government, private industry, private organization, and private citizen collaboration and cooperation to:
- Prevent the harm that serious, non-native, invasive plant and plant pest species can cause to the nation’s agriculture, environment and economy.
- Ensure that pest prevention and suppression decisions are risk-based.
- Ensure that pest risk mitigation strategies that are adopted will provide an acceptable level of agricultural, environmental and economic protection consistent with established global, national, regional, and state standards.
Accordingly, it is the NPB’s policy to support development of a non-native, invasive plant and plant pest species management plan that includes the following elements:
- Risk analysis.
- Survey, detection and exclusion at ports of entry and the interior of the country.
- Accurate and timely diagnostics.
- Distribution survey for each discovery of an incipient infestation.
- Eradication of incipient infestations when feasible.
- Scientific support through research and development of new detection, exclusion, diagnostic, and eradication methods.
- Public outreach.
- Clear organizational roles, responsibilities and linkages.
Concerning survey and detection, USDA-APHIS-PPQ should expand its own efforts to include state-by-state pest detection strategies, detection plan development and implementation protocols. Such an effort would be a natural extension of existing cooperative ties with the states and would greatly enhance the USDA’s own efforts. USDA-APHIS-PPQ should pursue contracting with state pest detection agencies to put such a system in place at the earliest possible date. Currently, $40 million is proposed for the FY 2002 budget for this purpose. The NPB, with its existing close ties to USDA-APHIS-PPQ, should coordinate these efforts among the states.
Further, it is the NPB’s position that management of non-native, invasive plant and plant pest species, that cannot be eradicated and are causing serious harm to the nation’s agriculture, environment and economy, should be aggressively pursued through the appropriate jurisdictional federal agency, or agencies, and state cooperators. Research to find new techniques and tools to more effectively deal with these species should be a strong component of these management efforts.