Comment from Richard D Gaskalla, Florida Department of Agriculture, Division of Plant Industry

March 13, 2006 Regulatory Analysis and Development USDA, PPD, APHIS, Station 3A-03.8 4700 River Road, Unit 118 Riverdale, Maryland 20737-1238 Reference: Federal Register Docket No. 05-059-1 Importation of Baby Corn and Baby Carrots from Zambia The Florida Department of Agriculture and Consumer Services would like to take this opportunity to formally offer the following comments regarding the proposal to amend the fruits and vegetables regulations to allow the importation into the continental United States of fresh, dehusked immature (baby) sweet corn and fresh baby carrots from Zambia: The Pest Risk Analysis (PRA) titled ?Importation of Baby Carrot, Daucus carota L. spp. sativus, from Zambia into the Continental United States? evaluated the risk of introducing into the United States, the root-knot nematode Meloidogyne ethiopica which can inhabit the tissues of the imported carrots. APHIS has mitigated the risk of introducing this pest into the United States by requiring a visual inspection of carrots grown at each production site and by requiring a phytosanitary certificate issued by the Zambian authorities, coupled with the fact that M. ethiopica has not been reported in Zambia. However, we would also like to point out that M. ethiopica has been already introduced from Africa into the Americas where this pest has become established in Chile. In Chile, M. ethiopica has become a major pest of grapevine causing serious crop losses for the Chilean grape industry. We would like to remind APHIS that another root-knot nematode introduced from Africa into the Americas is Meloidogyne mayaguensis which is now present in the United States (Puerto Rico and Florida). Docket No. 05-059-1 Importation of Baby Corn and Baby Carrots from Zambia March 13, 2006 Page Two Many root-knot nematode species such as M. acronea, M. Africana, M. decalineata, M. kikuyensis and M. megadora occur in the African continent. Additionally, many other species remain undescribed. Information about the geographical distribution and host range of these African root-knot nematodes is lacking. Therefore, we cannot support this proposed amendment unless the required field inspections include an annual laboratory analysis of both soil and root samples taken from the carrots and the soil of the production area. In the event regulated nematodes of quarantine significance are detected, shipments of carrots from these production sites would be denied. We would hope that the lack of information about a pest would never provide good reason for relaxing plant pest exclusionary measures or for simply avoiding the implementation of appropriate actions. We certainly welcome the opportunity to offer comments on the proposed amendments to the baby corn and baby carrots regulations to allow the importation into the continental United States from the Zambia. Sincerely, CHARLES H. BRONSON COMMISSIONER OF AGRICULTURE Richard D. Gaskalla Division Director RDG/ch