Comment from Richard Gaskalla

To Whom It May Concern: The Florida Department of Agriculture and Consumer Services’ Division of Plant Industry (FDACS’ DPI) has reviewed the Federal Register Docket Number APHIS- 2008-0050, “USDA Proposes to Allow Papaya Imports from Colombia and Ecuador” and offers the following comments. Often overlooked in proposals of this nature that involve systems approach protocols to achieve phytosanitary standards is the need for assurance that there is, and will continue to be, proper regulatory oversight. Has there been a site visit to verify compliance standard oversight? Will there be periodic reviews of the regulatory framework of the exporting countries for this specific program? While the pest mitigation standards may be defendable on paper, we have concerns over the details of these applications in practices in the field. Keeping fallow fruit and fruit that is more than half ripe removed will be difficult to maintain, subject to interpretation, and therefore, will increase pest infestation risks. How is this practice going to be actually carried out? Has research been done on the fruit flies present in the petitioning countries to help assure when the fruit is actually susceptible? What fruit fly lures will be used? Based on the above mentioned concerns, the FDACS’ DPI requests that this proposal not go forward pending further evaluation. Sincerely, Richard Gaskalla, Director Division of Plant Industry Florida Department of Agriculture & Consumer Services PO Box 147100 Gainesville, Florida 32614-7100 (352) 372-3505, Ext. 107 gaskalr@odacs.state.fl.us