Comment from Wayne Dixon

To Whom It May Concern: The Florida Department of Agriculture and Consumer Services’ Division of Plant Industry (FDACS/DPI) has reviewed Federal Register Docket No. APHIS-2009-0086 concerning the importation of Shepherd’s Purse with roots from the Republic of Korea. The proposed change to recommend entry of Shepherd’s purse with roots based on a systems approach which includes the growing of the plant material in areas free from the four listed ectoparasitic nematodes (Hemicycliophora koreana, Paratylenchus pandus, Rotylenchus orientalis and Rotylenchus pini) is sufficient to safeguard both agricultural and native plant materials in Florida. However, the Pest Risk Assessment fails to mention any safeguarding measures against endoparasitic nematodes that would potentially follow the pathway into the United States. These endoparasitic nematodes include lesion nematodes (Pratylenchus thornei and other unidentified Pratylenchus species), the rice root nematode (Hirschmanniella imamuri), new races of the soybean cyst nematode (Heterodera glycines) and the root knot nematodes (Meloidogyne spp.). FDACS’ DPI recommends that the roots be removed prior to entry of Shepherd’s purse from the Republic of Korea into the United States or that the systems approach include the Shepherd’s purse be grown in areas that are certified free of the above mentioned endoparasitic nematodes. Sincerely, CHARLES H. BRONSON COMMISSIONER OF AGRICULTURE Dr. Wayne N. Dixon Acting Director ----------------------------- Division of Plant Industry Florida Department of Agriculture and Consumer Services email: dixonw@doacs.state.fl.us Phone: 352.372.3505 ext. 107 Cell: 352.258.0812 Fax: 352.955-2300 ------------------------------ Division of Plant Industry, FDACS PO Box 147100 (1911 SW 34th Street) Gainesville, FL 32614-7100 (32608)