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CPM 2010/INF/19

COMMISSION ON PHYTOSANITARY MEASURES

Fifth Session

Rome, 22-26 March 2010

Compiled Member Comments on Annexes to ISPM 28 on Irradiation treatments (CPM2010-02-Annex 5-9)

Agenda Item 9.2.5 of the Provisional Agenda

1.The Secretariat compiled comments received in advance of CPM-5 on the draft ISPM on Annexes to ISPM 28 on Irradiation treatmentsfrom the following members:

Annexes to ISPM 28 on Irradiation treatmentsforCONOTRACHELUS NENUPHAR, CYCLAS FORMICARIUS ELEGANTULUS, EUSCEPES POSTFASCIATUS, GRAPHOLITA MOLESTA, AND GRAPHOLITA MOLESTA UNDER HYPOXIA

Japan

COSAVE

Chile

Argentina

Brazil

Bolivia

Uruguay

Paraguay

R. Korea

Australia

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CPM 2010/INF/19

Advanced comments prior to CPM-5 on Annex 2 of CPM 2010/2

ANNEX to ISPM 28:2009: Irradiation treament for conotrachelus nenuphar, Cyclas formicarius elegantulus, Euscepes postfasciatus, grapholita molesta, and grapholita molesta under hypoxia

As of 10th March 2010

The following are comments received according to guidelines given in the document CPM 2010/2. The Secretariat has compiled the comments, as provided by members, in the order of the text. This document is provided for information and the final version will be distributed at the CPM-5 meeting.[1]

No. / 1. Section / 2. sentence/
row/indent, etc. / 3. Type of comment / 4. Proposed rewording / 5. Explanation / 6. Country
1 / GENERAL COMMENTS / About the footnote included in all treatments, during the process to adopt international standards under special process, performed at CPM -4, a number of contracting parties indicated that, while endorsing approval of eight drafts, wording on the footnote might need to be improved and it was suggested the issue should be forwarded to the SC for further consideration.
Also during CPM - 4, the CPM underlined its agreement with an statement, inline with ISPM No. 28, that established among other issues that:
...“When considering phytosanitary treatments for submission to the TPPT, NPPOs and RPPOs should consider factors such as the effects on human health and safety, the impact on the environment and the quality and intended use of the regulated article.”.....
On the other hand, ISPM No. 28, at the end of item 3 “Requirements for Phytosanitary Treatments”, establishes that for the purpose of this standard, phytosanitary treatments should fulfill the following requirements:
- be effective in killing, inactivating or removing pests, or rendering pests infertile or for devitalization associated with a regulated article.
The level of efficacy of the treatment should be stated (quantified or expressed statistically). Where experimental data is unavailable or insufficient, other evidence that supports the efficacy (i.e. historical and/or practical information/experience) should be provided.
- be well documented to show that the efficacy data has been generated using appropriate scientific procedures, including where relevant an appropriate experimental design. The data supporting the treatment should be verifiable, reproducible, and based on statistical methods and/or on established and accepted international practice; preferably the research should have been published in a peer-reviewed journal.
- be feasible and applicable for use primarily in international trade or for other purposes (e.g. to protect endangered areas domestically, or for research).
- not be phytotoxic or have other adverse effects.
There is then, a clear requirement in ISPM No. 28 about the need to ensure the absence of phytotoxicity and adverse effects on the product, that has to be supported by evidences and bibliography, what is not the case for all host species.
The footnote has to be reconsidered also for treatments adopted during CPM IV. / ARGENTINA
BOLIVIA
BRAZIL
CHILE
PARAGUAY
URUGUAY
COSAVE
2 / GENERAL COMMENTS / Object to adopt Cylas formicarius elegantulus and Euscepes postfasciatus / R Korea
3 / GENERAL COMMENTS / Object to adopt Cylas formicarius elegantulus and Euscepes postfasciatus / R Korea
4 / specific COMMENTS
5 / 1. ISPM 28:2009 Conotrachelus nenuphar
6 / 1. Title
7 / 1. Adoption
8 / 1. Scope of the treatment / Footnote / Substantive / The scope of the IPPC treatments does not include issues related to pesticide registration or other domestic requirements for approval of treatments. Treatments also do not provide information on specific effects on human health or food safety, which should be addressed using domestic procedures prior to the approval of a treatment. In addition effects on product quality have not been considered for all hostsare considered before their international adoption. Phytotoxicity and other effects on the quality of other hosts species should require additional evaluation and were not considered specifically in relation to these treatments.There is no obligation for a contracting party to approve, register or adopt the treatments for use in its territory. / -The quality of the product after treatment is highly relevant and information regarding its phytotoxicity and other effects on the quality of regulated articles should be provided according ISPM No. 28 to evaluate if the phytosanitary treatment is feasible and applicable.
-Extrapolation regarding efficacy of the treatment do not cover the effects on the quality of the product.
-It is not appropriate to state in a footnote that effects on the product quality are considered before their international adoption, because there is noinformation supporting that irradiation treatments wereevaluated for all hosts of each pest considered. / ARGENTINA
BOLIVIA
BRAZIL
CHILE
PARAGUAY
URUGUAY
COSAVE
9 / 1. Other relevant information / Added text / Technical / − Irradiated adults are very unlikely to survive for more than one week,
post irradiation, and they are therefore less likely to be robust or to spread than non-irradiated adults / Robustness is not a necessary concept. / ARGENTINA
BOLIVIA
BRAZIL
CHILE
PARAGUAY
URUGUAY
COSAVE
10 / 1. Other relevant information / Para 2 / editorial / Despite the treatment, live irradiated adults may be present in a consignment. However, theAlthough the treatment may result in the presence of irradiated adults, the following factors…. / The treatment is not responsible for the presence of live adults in the consignment. / Australia
11 / 1. Treatment description
12 / 1. References
13 / 2. ISPM 28:2009 Cyclas formicarius elegantulus / Substantive (objection of adoption) / This annex does not solve the problem of irraidated adult which was raised in last consultation.
There may be no data about how long adult (from irradiated larvae or irradiated pupae or irradiated adult itself) of Cyclas formnicarius elegantulus can survive. This may mean the adults (from irradiated larvae or irradiated pupae or irradiated adult itself) and eggs, larvae, and pupae from the adult which do not have any sign of irradiation treatment, can be found after clearance in the consignment and other related things for an extended period. This may cause big burden to importing countries to prove the insect is not established in the countries.. / R Korea
14 / 2. Title
15 / 2. Adoption
16 / 2. Scope of the treatment / Footnote / Substantive / 2.The scope of the IPPC treatments does not include issues related to pesticide registration or other domestic requirements for approval of treatments. Treatments also do not provide information on specific effects on human health or food safety, which should be addressed using domestic procedures prior to the approval of a treatment. In addition effects on product quality have not been considered for all hostsare considered before their international adoption. Phytotoxicity and other effects on the quality of other hosts should require additional evaluation and were not considered specifically in relation to these treatments.There is no obligation for a contracting party to approve, register or adopt the treatments for use in its territory. / -The quality of the product after treatment is highly relevant and information regarding its phytotoxicity and other effects on the quality of regulated articles should be provided according ISPM No. 28 to evaluate if the phytosanitary treatment is feasible and applicable.
-Extrapolation regarding efficacy of the treatment do not cover the effects on the quality of the product.
  • It is not appropriate to state in a footnote that effects on the product quality are considered before their international adoption, because there is noinformation supporting that irradiation treatments wereevaluated for all hosts of each pest considered.
/ ARGENTINA
BOLIVIA
BRAZIL
CHILE
PARAGUAY
URUGUAY
COSAVE
17 / 2. Treatment description
18 / 2. Other relevant information / Add new sentence / Editorial / Add the following new sentence after 1st paragraph;
Although the treatment may result in the presence of irradiated adults, the following factors may affect the likelihood of adults being found in traps in importing countries:
-Adults are rarely (if ever) present in shipped fruit because the insect pupates off the fruit;
-Irradiated adults are very unlikely to survive for more than one week post irradiation, and they are therefore less likely to be robust or to spread than non-irradiated adults / To be consistent with the other relevant information of “Conotrachelus nenuphar”
(In the response of Korea’s formal objection, it is necessary to describe these factors may affect the likelihood of adults being found in traps in importing countries) / JAPAN
19 / 2. References
20 / 3. ISPM 28:2009 Euscepes postfasciatus / Substantive
Object to adopt / This annex does not solve the problem of irraidated adult which was raised in last consultation.
There may be no data about irradiated adult (from irradiated larvae or irradiated pupae or irradiated adult itself) of Euscepes postfasciantuscan survive how long. This may mean the adults(from irradiated larvae or irradiated pupae or irradiated adult itself) and eggs, larvae, and pupae from the adults which do not have any sign of irradiation treatment, can be found after clearance in the consignment and other relevant things for a extended time. This may cause big burden to importing countries to prove the insect is not established in the countries.. / R Korea
21 / 3. Title
22 / 3. Adoption
23 / 3. Scope of the treatment / Footnote / Substantive / 3.The scope of the IPPC treatments does not include issues related to pesticide registration or other domestic requirements for approval of treatments. Treatments also do not provide information on specific effects on human health or food safety, which should be addressed using domestic procedures prior to the approval of a treatment. In addition effects on product quality have not been considered for all hostsare considered before their international adoption. Phytotoxicity and other effects on the quality of other hosts should require additional evaluation and were not considered specifically in relation to these treatments.There is no obligation for a contracting party to approve, register or adopt the treatments for use in its territory. / -The quality of the product after treatment is highly relevant and information regarding its phytotoxicity and other effects on the quality of regulated articles should be provided according ISPM No. 28 to evaluate if the phytosanitary treatment is feasible and applicable.
-Extrapolation regarding efficacy of the treatment do not cover the effects on the quality of the product.
  • It is not appropriate to state in a footnote that effects on the product quality are considered before their international adoption, because there is noinformation supporting that irradiation treatments wereevaluated for all hosts of each pest considered.
/ ARGENTINA
BOLIVIA
BRAZIL
CHILE
PARAGUAY
URUGUAY
COSAVE
24 / 3. Treatment description
25 / 3. Other relevant information / Add new sentence / Editorial / Add the following new sentence after 1st paragraph;
Although the treatment may result in the presence of irradiated adults, the following factors may affect the likelihood of adults being found in traps in importing countries:
-Adults are rarely (if ever) present in shipped fruit because the insect pupates off the fruit;
-Irradiated adults are very unlikely to survive for more than one week post irradiation, and they are therefore less likely to be robust or to spread than non-irradiated adults / To be consistent with the other relevant information of “Conotrachelus nenuphar”
(In the response of Korea’s formal objection, it is necessary to describe these factors may affect the likelihood of adults being found in traps in importing countries) / JAPAN
26 / 3. References
27 / 4. ISPM 28:2009 Grapholita molesta / Footnote / Substantive / 4.The scope of the IPPC treatments does not include issues related to pesticide registration or other domestic requirements for approval of treatments. Treatments also do not provide information on specific effects on human health or food safety, which should be addressed using domestic procedures prior to the approval of a treatment. In addition effects on product quality have not been considered for all hostsare considered before their international adoption. Phytotoxicity and other effects on the quality of other hosts should require additional evaluation and were not considered specifically in relation to these treatments.There is no obligation for a contracting party to approve, register or adopt the treatments for use in its territory. / -The quality of the product after treatment is highly relevant and information regarding its phytotoxicity and other effects on the quality of regulated articles should be provided according ISPM No. 28 to evaluate if the phytosanitary treatment is feasible and applicable.
-Extrapolation regarding efficacy of the treatment do not cover the effects on the quality of the product.
  • It is not appropriate to state in a footnote that effects on the product quality are considered before their international adoption, because there is noinformation supporting that irradiation treatments wereevaluated for all hosts of each pest considered.
/ ARGENTINA
BOLIVIA
BRAZIL
CHILE
PARAGUAY
URUGUAY
COSAVE
28 / 4. Title
29 / 4. Adoption
30 / 4. Scope of the treatment
31 / 4. Treatment description
32 / 4. References
33 / 5. ISPM 28:2009 Grapholita molesta under hypoxia
34 / 5. Title
35 / 5. Adoption
36 / 5. Scope of the treatment / Footnote / Substantive / 5.The scope of the IPPC treatments does not include issues related to pesticide registration or other domestic requirements for approval of treatments. Treatments also do not provide information on specific effects on human health or food safety, which should be addressed using domestic procedures prior to the approval of a treatment. In addition effects on product quality have not been considered for all hostsare considered before their international adoption. Phytotoxicity and other effects on the quality of other hosts should require additional evaluation and were not considered specifically in relation to these treatments.There is no obligation for a contracting party to approve, register or adopt the treatments for use in its territory. / -The quality of the product after treatment is highly relevant and information regarding its phytotoxicity and other effects on the quality of regulated articles should be provided according ISPM No. 28 to evaluate if the phytosanitary treatment is feasible and applicable.
-Extrapolation regarding efficacy of the treatment do not cover the effects on the quality of the product.
  • It is not appropriate to state in a footnote that effects on the product quality are considered before their international adoption, because there is noinformation supporting that irradiation treatments wereevaluated for all hosts of each pest considered.
/ ARGENTINA
BOLIVIA
BRAZIL
CHILE
PARAGUAY
URUGUAY
COSAVE
37 / 5. Treatment description / Added text / Technical / − Irradiated adults are very unlikely to survive for more than one week,
post irradiation, and they are therefore less likely to be robust or to spread than non-irradiated adults / Robustness is not a necessary concept. / ARGENTINA
BOLIVIA
BRAZIL
CHILE
PARAGUAY
URUGUAY
COSAVE
38 / 5. Other relevant information / Add new sentence / Editorial / Add the following new sentence after 1st paragraph;
Although the treatment may result in the presence of irradiated adults, the following factors may affect the likelihood of adults being found in traps in importing countries:
-Adults are rarely (if ever) present in shipped fruit because the insect pupates off the fruit;
-Irradiated adults are very unlikely to survive for more than one week post irradiation, and they are therefore less likely to be robust or to spread than non-irradiated adults / To be consistent with the other relevant information of “Conotrachelus nenuphar”
(In the response of Korea’s formal objection, it is necessary to describe these factors may affect the likelihood of adults being found in traps in importing countries) / JAPAN
39 / 5. References