Comment from Wayne Dixon

The Florida Department of Agriculture and Consumer Services/Division of Plant Industry has reviewed Docket No. APHIS-2008-0060 regarding the importation of Hass avocadoes from Mexico into the Commonwealth of Puerto Rico and other changes. We support the recommendation to allow this movement of Hass avocadoes under the current systems approach that has been in place to allow for the movement of this fruit into all states within the United States. The systems approach has been working for the Michoacan region as it has had an opportunity to run for a few years now without any resulting pest issues occurring in any U.S. states. Our scientists have reviewed the current situations concerning Anastrepha species of fruit flies as well as for the Mediterranean fruit fly. Hass avocadoes are poor hosts for Anastrepha species that are present in the Michoacan region and the Mediterranean fruit fly is not present in that region. Concerning the language used regarding the assignment of an approved designee to conduct sampling of avocados to replace language that required the Mexican NPPO to select, cut, inspect and certify that the Hass avocados are free from pests. It is indicated that the use of approved designees in situations such as this is consistent with the International Plant Protection Convention’s International Standard for Phytosanitary Measures No. 20 which describes a system that NPPO’s can use to authorize entities to act on their behalf. This system also includes procedures to determine the competency of designees, performing audits and if need be how to withdraw authorization. The FDACS/DPI supports this change in language but stresses the importance in reviewing the criteria that will be utilized by the Mexican NPPO to choose a designee for these purposes.