Comment from Richard D Gaskalla, Florida Department of Agriculture

February 27, 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. 05-068-1 Importation of Peppers from the Republic of Korea 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 peppers from the Republic of Korea under certain conditions: In reviewing the proposed amendments we could find no consideration of the possibility that the recently identified Pepins mosaic potexvirus could be transported into the United States on finished pepper crop from the Republic of Korea. We understand that at the present time, it is not known for certain whether Capsicum is a host of the virus, but other members of the Solanaceae family are such as potato, tobacco and many weeds. The virus is transmitted by contact, thus the fruit for market could easily serve as a vector. Additionally, it now appears that new strains of the virus may already be forming and, therefore, adapting to a wider host range. The Pest Risk Analysis (PRA) titled ?Importation of Fresh Paprika Pepper Fruit (Capsicum annuum L. var. annuum) from the Republic of Korea into the Continental United States? (August 2005) evaluates the risks associated with the importation of peppers into the continental United States from South Korea. Docket No. 05-068-1 Importation of Peppers from the Republic of Korea Page Two The PRA only treats the fungus Monilinia fructigena as a risk and on the face of it, this makes sense since the organism is present in Korea, but doe not occur in the United States. However, Korea has both M. fuctigena and M. fructicola; with the latter being common in the United States. Both are typical brown rot organisms that are extremely difficult to distinguish from one another. To distinguish M. fructigena from M. fructicola requires that the organism be observed at least in culture under laboratory conditions. Any brown rot symptoms observed on imported peppers would require careful and thorough diagnosis to insure the proper pathogen is identified. The PRA admits that currently ?No treatment is available for the pathogens?. Until these pest risk issues are properly mitigated, we cannot support this proposed amendment to allow importation into the continental United States of peppers from the Republic of Korea. We certainly welcome the opportunity to offer comments on the proposed amendments to the fruits and vegetables regulations to allow the importation into the continental United States of peppers from the Republic of Korea. Sincerely, CHARLES H. BRONSON COMMISSONER OF AGRICULTURE Richard D. Gaskalla Division Director RDG/ch