Comment from Eric D Weinert, CW Hawaii Pride

I am owner and manager of CW Hawaii Pride, LLC, the world?s first irradiator built to meet USDA APHIS quarantine regulations to protect mainland agriculture from harmful tropical pests. Since we opened our doors in August of 2000, we have spent over $1 million dollars on payroll and have treated over 30 million pounds of tropical fruit. I am in favor of fair trade. However, I have several concerns with the proposed rule ( 7 CRF Parts 305 and 319 docket No APHIS-2006-0040 ) that would allow importation of fruit from Thailand. 1. It is not clear from the proposed rule if an American citizen USDA APHIS PPQ officer will be on site in Thailand to monitor the treatments. I believe this is critical because only by being on site can one assure proper treatments. Inspectors receiving shipments in the mainland US must trust the documentation as it is impossible to tell by examining the fruit if the fruit has or has not been treated with irradiation. The Japanese insist on Japanese inspectors in Hawaii to monitor papaya shipments to Japan, and we too should insist on American inspectors in Thailand to monitor irradiation treatments. Our facility is governed by a compliance agreement with our local APHIS PPQ port director. USDA APHIS personnel are on site daily and inspect each lot treated. They open boxes from every lot to verify commodity and to look for insects not covered in the treatment protocol. They also approve and sign the paperwork to verify that each lot was treated with the proper dose guarantying that the minimum dose was achieved and the maximum absorbed dose was not reached. Finally each the quantity of cartons in each lot is accounted for, as well as uniquely identified by number clearly marked on each carton. Please write into the rule the requirement for an American USDA APHIS officer to be on site, and not leave it to the vagaries of their compliance agreement. 2. I was surprised that several insects were not listed as being of concern to Hawaii tropical fruit growers. Specifically, there are three insects that we know of, which were not even mentioned. Two mites which affect longan, Aceria longona and Aceria dimocarpi, are definitely in Thailand and would adversely affect Hawaii production if introduced. Another mite, Aceria litchi is not mentioned and it affects lychee production. Hawaii has a mite, Eriophyes-litchii, which was cause for the Florida litchi growers to successfully lobby to prohibit the importation or distribution into the State of Florida Lychee grown in Hawaii and treated with irradiation. The same should be true for Hawaii, these fruits should be prohibited from importation or distribution into the State of Hawaii. Not even mentioning these insects in the initial APHIS proposed rule calls into question what other insects could have been omitted on the other fruits that would cause harm to Hawaii. 3. The fungus mentioned for both the lichii and mango are of concern to Hawaii. While we agree that the probability for introduction is low in the mainland US (except Florida) that is not the case in Hawaii. Firstly one cannot inspect for the presence of fungus. Secondly, it is highly likely (Hilo rains over 180 inches per year) that someone could discard the skin or seed of an infected fruit and that through direct water transmission affect a growing area, as mango and lychee trees are widely distributed throughout the State of Hawaii in nearly every neighborhood. 4. I do not know how decisions are made with regard to economic impact, but importation of cheap rambutan into Honolulu will adversely affect our rambutan industry. In 2005 the industry treated for export to the mainland over 600,000 pounds of Rambutan. I assume their production for the local market exceeded that amount. This past month, in the middle of our lychee season, Honolulu produce merchants imported, cheap Lychee from Taiwan, heat treated, dipped in acid to blanch the brown fruit to white, then dyed red to appear familiar to Hawaii consumers. Although not even close to the quality of our locally grown (golf ball size, super sweet) Kaimana lychee, produce merchants stopped all shipments from Hawaii Island to Oahu, causing growers to stop picking and the fruit fell rotten to the ground. Cheap rambutan being imported into Hawaii will surely crush the local rambutan industry. 5. Although Hawaii is a State within the United States of America, it is often treated worse than a foreign country. That is the case with regards to Mangosteen, where Hawaii farmers have waited over six years to receive a Pest Risk Assessment, the first step in otherwise and still lengthy process of obtaining permits for sending our fruit to our own country. It leaves a sour taste for us in Hawaii to have APHIS approve shipment from Thailand before fellow Americans. I have long argued that Hawaii needs to be granted special status with preference over foreign countries to obtain permits quickly. Hawaii is a high cost niche market producer and as such must move quickly to recognize and capture markets. Such is the case for dessert guavas. We have several varieties that eat like the best apples one has ever tasted, and small acreages have been planted. Yet, facing years, and never knowing when or if treatments will ever be approved, attracting investment capital becomes difficult. The resources are already in place, PBARC research facility in Hilo, the electronic fruit irradiator, diverse growing climates, and entrepreneurial farmers. The big hurdle is the commitment from APHIS to approve timely treatment protocols. Please consider granting Hawaii special status with precedence over foreign countries for rule making like the one considered here. Sincerely, Eric Weinert