August 12, 2008
María de Lourdes Guerrero Reyes, Economist
Subdirector of Integration
lguerr@economia.gob.mx
SE, SIC, DGIB
Insurgentes Sur 1940-2, Col. Florida
Delegación Álvaro Obregón, C. P. 01030
Teléfono 01 55 52 29 61 11, Fax 01 55 52 29 65 08
Mexico, D. F.
Mexico
Docket No. APHIS-2008-0066, Notice of Availability of a Pest Risk Analysis for
Importation of Guavas from Mexico into the United States.
To Whom It May Concern:
The Government of Mexico, through the México Secretaría de Economía (SE,
Economy Secretary), Industry and Commerce Subsecretary (SIC), General
Direction of Basic Industries (DGIB) has reviewed Docket No. APHIS-2008-
0066, “Notice of Availability of a Pest Risk Analysis for Importation of Guavas from
Mexico Into the United States” and offers the following comments in response to
the announcing the availability of your pest risk analysis for public review and
comment.
This document identifies and evaluates risks and discusses known risk
mitigations and provides a pest risk analysis that evaluates the risks associated
with the importation into the United States, of fresh guava fruit from Mexico.
Having identified the pest risks involved in the importation of guava fruit from
Mexico, the document proceeds to a discussion of risk management options.
The proposed importation of guava fruit from Mexico, if approved, would be
regulated by an amendment to the existing fruits and vegetables regulations,
these outlines the phytosanitary measures that Animal and Plant Health
Inspections Service (APHIS) will require if the proposed importation of guavas from
Mexico is approved and documents the evidence used by APHIS to conclude that
these measures will effectively prevent the introduction of quarantine pests.
APHIS proposes that guava fruit from Mexico may be imported into the United
States only under the following conditions:
(1). The fresh guava fruit must be imported in commercial consignments as
defined in 7 United States Code of Federal Regulations (CFR) 319.56-2.
(2). The fruit must be irradiated with a minimum absorbed dose of 400 Gy and
follow requirements of 7CFR parts 305.31 and 319.56.
(3). Each shipment of fruit must be inspected by the Mexican National Plant
Protection Organization (NPPO) inspectors and be accompanied by a
Phytosanitary Certificate (PC) issued by the Mexican NPPO certifying that the
fruit received the required irradiation treatment. The PC must also include an
Additional Declaration (AD) that states:
"The fruit in this shipment was treated by irradiation with a minimum absorbed
dose of 400 Gy, inspected in and found free of Oligonychus biharensis,
Oligonychus psidium, Mycovellosiella psidii, Pestalotiopsis psidii and
Sphaceloma psidii."
(4). Each shipment is subject to port-of-entry inspection and must be found free
of: Oligonychus biharensis, Oligonychus psidium, Mycovellosiella psidii,
Pestalotiopsis psidii and Sphaceloma psidii.
In addition to these specific measures, the fresh guava fruit would be subject to
the general requirements listed in 319.56-3 that are applicable to the importation
of all fruits and vegetables.
Based on that analysis, we believe that the application of one or more designated
phytosanitary measures will be sufficient to mitigate the risks of introducing or
disseminating plant pests via the importation of guavas from Mexico.
These measures will prevent plant pests from being introduced into and spread
within the United States. The process for approving the importation of that
commodity can be safely imported subject to one or more of the designated
phytosanitary measures.
A combination of measures in a systems approach is most feasible, will be
adequate to reduce risk of their introduction into the United States. The
specification and implementation of measures, as would be present in an
operational work plan, are the scope of both countries (APHIS and the NPPO of
Mexico will jointly develop it).
It is correctly noted, that you have completed a pest risk assessment to identify
pests of quarantine significance that could follow the pathway of importation into
the United States and, based on that pest risk assessment, have prepared a risk
management analysis to identify phytosanitary measures that could be applied to
the commodity to mitigate the pest risk.
In summary, the document Importation of Guava, Psidium guajava, from Mexico
into the United States A Pathway-initiated, Commodity Risk Analysis June 2008,
makes it clear a reliable systems approach of effective mitigation can be
considered for safe importation of Mexican guavas into the U.S.
After reviewing all the public submissions you will receive, we will hope that,
considering the highest standards to the evaluation, that concluded that guavas
can be safely imported into the United States from Mexico using one or more of
the designated phytosanitary measures, we will get your announce in a
subsequent notice, that you will begin issuing permits for importation of fresh
guava fruit from Mexico into the United States subject to the requirements
specified in the risk management analysis.
We believe that, the phytosanitary requirements will result in the effective removal
of the pests of concern from the pathway identified by the pest risk analysis for
the importation of fresh guava fruit from Mexico.
We consider that the entry in your country of guava fruit from Mexico, it will
constitute a fort incentive to increase the market for Mexican products, to foment
the productions, exports and the commercial flows from guava-producing Mexican
States.
For these reasons, we agree and we supported the proposal, also we are thankful
that the pest risk analysis for Importation of Guavas From Mexico Into the United
States, has concluded to determine the regulations measures that you are due to
apply to the guavas coming from Mexico.
Sincerely,
JOSÉ GUADALUPE SÁENZ SOLÍS
GENERAL DIRECTOR OF BASIC INDUSTRIES
jsaenz@economia.gob.mx
Martha Aurora Berzosa Olivares
Area Director
mberzosa@economia.gob.mx
Comment from José Sáenz Solís, General Direction of Basic Industries
This is comment on Notice
Notice of Availability of a Pest Risk Analysis for Importation of Guavas From Mexico Into the United States
View Comment
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