SECTION VI Regulatory Aspects © 2000 by CRC Press LLC 1 CHAPTER 9 Quarantines and Regulations, Pest Risk Analysis, and International Trade Robert P. Kahn, Gary L. Cave, John K. Greifer, and Edwin Imai CONTENTS 9.1 Introduction 306 9.2 Pest and Pathogen Exclusion 307 9.2.1 Regulatory Concepts 307 9.2.1.1 Legal Basis 307 9.2.1.2 Biological Aspects 309 9.2.1.3 Geographical Basis 309 9.2.2 Pathway Analysis 310 9.2.2.1 Background 310 9.2.2.2 Exports as a Pathway 311 9.2.2.3 Imports as a Pathway 311 9.2.3 Quarantine 7CFR319.56, Fruits and Vegetables 312 9.2.3.1 Approval of Permit Applications 312 9.2.3.2 Disapproval of Permit Applications 312 9.2.3.3 Inspection 313 9.3 Pest Risk Analysis 314 9.3.1 Introduction 314 9.3.1.1 International Trade and Plant Pest Risk 314 9.3.1.2 International Standards 315 9.3.1.3 APHIS and Risk Assessment as Defined by the SPS Agreement 315 9.3.2 APHIS Risk Analysis Principles 316 9.3.2.1 GATT Consistent 316 9.3.2.2 Science Based 316 9.3.2.3 Well Documented 316 © 2000 by CRC Press LLC 2 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION 9.3.2.4 Flexible 316 9.3.2.5 Open to Review 317 9.3.3 Components of the APHIS Risk Analysis Process 317 9.3.3.1 Risk Assessment 317 9.3.3.2 Overview of the Risk Assessment Process 317 9.3.4 Philosophical Aspects of Pest Risk Assessment 322 9.3.4.1 What Risk Assessments Can and Cannot Achieve 322 9.3.4.2 The Philosophical Balance Between What Risk Assessments Can and Cannot Achieve 323 9.3.5 Trade Risk Analysis and the Future 323 9.4 The Interaction of Plant Quarantine and International Trade 324 9.4.1 Introduction 324 9.4.2 Background 324 9.4.2.1 Agricultural Trade Relations Prior to the Uruguay Round 325 9.4.2.2 Tokyo Round, GATT 325 9.4.2.3 Uruguay Round, GATT 326 9.4.2.4 North American Free Trade Agreement (NAFTA) 326 9.4.3 Sanitary and Phytosanitary (SPS) Measure, GATT 326 9.4.3.1 Emergence of an SPS Regime 326 9.4.3.2 Basic Rights 327 9.4.3.3 Harmonization 328 9.4.3.4 Relation to the International Plant Protection Convention (IPPC) 328 9.4.3.5 Components 330 9.4.4 Summary 334 References 335 9.1 INTRODUCTION* The movement of articles in international trade is subject to a wide spectrum of rules, regulations, policies, and/or guidelines implemented by parliaments or gov- ernment agencies of various nations. These agencies include customs, public health, marketing, food and drug, narcotic enforcement, environmental protection, and plant health/plant quarantine. The principal objective of plant quarantine activities is the exclusion of exotic, quarantine significant plant pests and pathogens along man- made pathways. Exclusion is an environmentally sound method of control because if the entry of these organisms is prevented, the need for pesticides, biological control agents, or other integrated pest management activities for eradication, suppression, or containment would not be required. The objectives of this chapter are to discuss: * By Robert P. Kahn. © 2000 by CRC Press LLC QUARANTINES/REGULATIONS, PEST RISK ANALYSIS, INTERNATIONAL TRADE 3 • regulatory, quarantine, and exclusion concepts and activities in general and their application to international trade of fruits and vegetables, • pest risk analysis (PRA) upon which these activities may be based, and • the interaction of quarantine, international trade, and PRA. Plant health or plant quarantine programs in most countries including the U.S. usually have three components: • Exclusion of pests and pathogens of quarantine and economic importance that might be moved along man-made pathways when articles are imported, or the reduction of the risk to an acceptable level in moving such hazardous organisms, • Containment, suppression, and/or eradication of pests and pathogens that may have recently entered along man-made or natural pathways, and • Assistance to exporters of plant products, such as fruits and vegetables, to meet the regulatory requirements of the importing countries. International trade can be considered a two-way street; the exports of one country are the imports of another country. Both countries are concerned with excluding pests and pathogens. Pest risk analysis is often used as a biological tool for deter- mining risk levels leading to promulgation of rules and regulations and deploying resources to protect a country’s agriculture against the entry of exotic, quarantine significant pests and pathogens. The importing country promulgates regulations, develops operating procedures at points or ports of entry, establishes inspection stations at major ports, deploys inspectors at these and other ports of entry, and when resources are limited allocates them to higher risk situations. In essence, regulatory activities and international trade are closely interwoven with pest risk analysis serving as an interface. As discussed later in this chapter, international standards for PRA are in place that will provide the biological justifi- cation for regulatory activities, including the entry status of imported agricultural commodities. 9.2 PEST AND PATHOGEN EXCLUSION* 9.2.1 Regulatory Concepts The legal, geographical, biological, political, social, administrative, and eco- nomic aspects of plant quarantine in general and plant pest and pathogen exclusion in particular have been reviewed in detail (Kahn, 1979, 1991 and references cited therein). In this section, legal, biological, and geographical aspects are discussed in general as they relate to pest risk analysis and international trade in agricultural product. 9.2.1.1 Legal Basis Legislation enacted by Congress and approved by the President gives the Sec- retary of Agriculture broad authority to protect U. S. agriculture from pests and * By Robert P. Kahn. © 2000 by CRC Press LLC 4 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION diseases. Among the legislative acts passed by Congress, which are the legal basis for Animal and Plant Health and Inspection Service (APHIS) programs for agricul- tural imports, are the following: • Federal Seed Act (FSA) of 1939, as amended restricts the entry of agriculture and vegetable seed to insure seed purity and freedom from seeds of certain named weed species. • The Federal Plant Pest Act (FPPA) of 1957, as amended regulates the movement (along man-made pathways) of plant pests. The FPPA is the basis for authority of inspectors to board ships and restrict entry or require treatment of any cargo that may be infected or infested with certain pests or disease agents. Authority is also given for emergency action and promulgation of regulations necessary to prevent spread. • Federal Noxious Weed Act of 1973, as amended restricts the entry of seed deemed to be harmful to agricultural crops, livestock, fish and wildlife resources, public health, irrigation, and navigation. Only seeds of weeds named in the Act are regulated, but some additional weeds are regulated under the FSA. • Plant Quarantine Act (PQA) of 1912, as amended authorizes the Secretary of Agriculture to establish quarantines which restrict or prohibit the entry of host plants, plant parts (such as seeds or fruits) and other products or articles in order to protect U.S. crops from specific pests or disease agents. The regulations that relate to fruit and vegetable imports are found in the Code of Federal Regulations (Anon., 1998), 7CFR 319, Foreign Quarantine Notice, Sub- part 319.56 which • restricts or prohibits fresh fruits and vegetables including herbs from all countries, • restricts frozen fruits and vegetables, and • includes fresh-cut flowers imported for decoration if fresh fruit is attached. Section 9.2 of this chapter is concerned primarily with 319.56, although some of these products are also covered by some other Sub-parts, such as: 319.15 Sugar- cane; 319.24 Corn Diseases; 319.28 Citrus fruits; 319.37 Nursery Stock, Plants, Roots, Bulbs, Seed, and Other Plant Products (including fruits and vegetables capa- ble of propagation, such as potatoes and whole coconuts); and 319.41 Indian Corn or Maize, Broomcorn and Related plants. Of these, 319.56 is used later in this section to illustrate how quarantine affects the importation of agricultural products in general and fruits and vegetables in particular. In the U.S. and 105 other countries, the legal basis for regulatory activities related to agricultural exports is the International Plant Protection Convention (IPPC) of 1951, as amended (Anon., 1952; also see Section 9.4), and administered by the Food and Agriculture Organization (FAO) of the United Nations. Another legal basis for the international trade in agricultural commodities is the General Agreement on Tariffs and Trades (GATT) and its Sanitary and Phytosanitary Measures (SPS) component. Under the SPS portion, FAO has been given the responsibility to develop international standards for pest risk analysis. Member countries (including the U.S.) must be able to biologically justify their regulations and quarantine operations, particularly when they interfere with international trade (see Section 9.4). © 2000 by CRC Press LLC QUARANTINES/REGULATIONS, PEST RISK ANALYSIS, INTERNATIONAL TRADE 5 9.2.1.2 Biological Aspects The biology of a pest or pathogen, i.e., its life cycle, is an essential component of PRA. This in turn is the foundation of biologically justified regulations and regulatory procedures that affect international trade in agricultural products. The life cycle is the sequence of events that takes place from the appearance of one stage of an organism to its reappearance in the next generation. Some disease agents or pests have stages or life forms that enable them to survive the pesticide, as well as biological and/or physical stresses which occur along the various man-made path- ways, and to become established in new areas. Exclusion, as a control strategy, is based on the identity of the organism and knowledge of its life cycle as influenced by environmental stress, including climate, weather, farm practices, natural and man-made pathways, host range, and other factors (Kahn, 1982, 1988, 1991). 9.2.1.3 Geographical Basis The distribution of exotic pests and pathogens in various continents, regions, or countries is the geographic basis of quarantine actions that often impact international trade in agriculture and other commodities. The geographic distribution of pests and pathogens is determined by the ecological range of the organism and its host(s). In addition, due to the rapid transportation of plants and other agricultural products along man-made pathways, the distances most organisms can be moved are much longer and the time required much shorter that the movement along natural pathways. The following are examples of natural pathways: • Vectors, such as fungi, insects, mites, slugs, snails, birds, rodents, and other ani- mals, • Propagules transported passively by storms, air currents, wind, and jet streams, • Propagules transported passively by ocean currents or land surface drainage, • Rain-generated aerosols (splashing may release fungus spores or bacterial cells in an aerosol moved passively by air currents), • Self-locomotion of spores and cells (short-distance spread by bacteria or fungus zoospores’, or the movement of nematodes in water in the soil, often in combination with natural dispersal, • Natural dispersal of infected seed, sometimes assisted by active dispersal of seeds into air currents, followed by passive spread by air currents, wind, or animals. Among the man-made pathways are the following: • Mail containing articles that can harbor pathogens (e.g., infected propagative mate- rials, live cultures of pathogens). • Baggage containing fruits or vegetables for consumption, plant propagative mate- rial, or other articles in relatively small volumes. • Agricultural cargo (e.g., agricultural raw materials, plant propagative materials, commodities in large volumes). © 2000 by CRC Press LLC 6 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION • Non-agricultural cargo (contaminated with pests and pathogens in packing mate- rials, soil, sand, ballast, etc.). • Cargo containers, aircraft, trucks, etc. • Dunnage, crates, and pallets (particularly if made from wood with bark containing plant pathogens or insect including vectors). • Used bagging or packing materials derived from infected plants (e.g., straw, rice hulls). • Unsealed ship’s stores containing infected plant materials that might be brought ashore. • Garbage (which might harbor animal or plant pathogens). • Smuggling (often prohibited fruits, plant propagative materials, live or dormant insects, or pathogen cultures). Plant quarantine regulations, operations, and safeguards are directed toward excluding those exotic organism of quarantine importance: • that do not have an efficient means of natural spread, e.g., scale insects, nematodes, most bacteria, many fungi, and many viruses, but that can infest, infect, or con- taminate plants or plant parts, commodities, or their containers and carriers, and • obscure exotic organisms (e.g., systemic fungi and viruses, insect borers, and larvae), found in fleshy storage organs (bulbs, tubers, etc.), seeds, woody stems, etc., that are not readily detected in samples by inspectors using equipment and facilities available at ports of entry. 9.2.2 Pathway Analysis 9.2.2.1 Background Pathway analysis, which is one of the first steps in initiating a PRA (Section 9.3) is based on the biology of named pests and/or pathogens, their known geographic distribution, and knowledge about the movement of such organisms along the path- ways mentioned in Section 9.2.1. The pathway analysis may be directed either to a named organism(s) or a commodity and all the exotic organisms that could be moved along with the commodity. In this section, emphasis is placed on vegetable and fruit imports and exports moved as commodities along man-made pathways. Biological and environmental data are required to make a meaningful pathway analysis. Many national and state or provincial quarantine services develop files, data sheets, or data banks containing information extracted from scientific or regu- latory literature. In addition, many international organizations, such as the European and Mediterranean Plant Protection Organization, the Food and Agriculture Orga- nization, and the Commonwealth Agricultural Bureau International have compiled computerized information retrieval data bases. The sources of information contain data about the classification and nomenclature of pests and pathogens; life cycle; morphology of the agent; known natural host range; geographical distribution; signs and symptoms, including the parts of plants that are infected such as fruits, seeds, © 2000 by CRC Press LLC QUARANTINES/REGULATIONS, PEST RISK ANALYSIS, INTERNATIONAL TRADE 7 stems, flowers, roots, etc.; whether the pathogen is local or systemic; whether a pest is externally or internally seed-borne; transmission or dispersal; overwintering, over- summering, or dormant stages; methods of detection; and treatments. Scientific literature and data sources have been reviewed (Kahn, 1982, 1988,1991; PPQ,1998; USDA, 1995, and references cited therein). In essence, a pathways analysis answers the question: can named pests and/or pathogens of quarantine significance be moved along the pathway of exported or imported commodities, such as vegetables and fruits that may be transported as cargo in ships, airplanes, vehicles, or by mail? A PRA is a method to determine or estimate the probability or chances that certain named pests and/or pathogens will enter the pathway and become established, and determine the consequences should this event occur (Section 9.3). 9.2.2.2 Exports as a Pathway Generally, most importing countries prohibit commercial shipments of commod- ities unless a permit has been issued (this is specific to the country and commodity in question, as not all countries and not all commodities require import permits). If a country has a quarantine concern, i.e., the potential entry of a pest or pathogen of quarantine significance from a given area, then: • the quarantine service does not issue a permit for that commodity, or • a permit is issued that may prescribe, in addition to inspection upon arrival, treat- ments or other safeguards to be conducted at origin and/or arrival of port of entry. In addition, the shipment must meet all other quarantine requirements of the importing country, as well as requirements of other agencies of that country Under the provisions of the IPPC (Section 9.2.1.1), APHIS has a treaty obligation to assist exporters of plant products to meet the import requirements of signatory nations, including the required pre-shipment inspection which is documented by the phytosanitary certificate (PC). The PC is discussed in detail in Section 9.2.3.2.1. 9.2.2.3 Imports as a Pathway U. S. plant quarantine regulations (Anon., 1998), which cover a wide spectrum of import plants, plant parts, and plant products, have been promulgated to reduce the chances of entry and subsequent establishment of exotic pests and pathogens of quarantine significance on articles moved along the pathway of imports. Most fruits and vegetables are covered by Sub-part 319.56 and some other Sub-parts as men- tioned in Section 9.2.1.1. In general, fruits and vegetables are prohibited unless their entry is authorized under 7CFR319.56. A permit is issued when entry has already been authorized for a particular fruit or vegetable from a specific country or part of a country. The request of a resident or the interest of a foreign government serves to initiate a PRA according to the description in Section 9.3 or one according to PPQ guidelines (USDA, 1995). The PRA for the latter may be conducted by PPQ or by a qualified person selected © 2000 by CRC Press LLC 8 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION by the potential importer who follows the guidelines and develops a PRA that the potential importer submits to PPQ for review. 9.2.3 Quarantine 7CFR319.56, Fruits and Vegetables Quarantine 319.56 and other regulations enable PPQ to establish phytosanitary measures, regulatory actions, and other safeguards to reduce to an acceptable or tolerable level the probability or chances that an exotic pest will enter and become established as a result of the commercial importation of approved fruits and vege- tables. These measures may be stipulated on the import permit or by standard operating procedures at ports (air or maritime) or points (land borders) of entry. In this section, some of the safeguards employed as a means of pest exclusion are discussed. Most of these are environmentally sound procedures for pest control by exclusion or regulatory control. 9.2.3.1 Approval of Permit Applications During the period between 1955 and May 1998, about 4000 permits were issued to allow the importation of fruits and vegetables. In 1997, almost 22% of all permits issued under all plant quarantine regulations were for fruits and vegetables. A survey of PRAs for applications under 319.56 show that the following were among the mitigation measures those required (PPQ, APHIS, 1998). • Inspection only upon arrival. • A mandatory treatment is prescribed. • The commodity must enter from an approved pest-free area as determined by survey and other criteria approved by PPQ for specified pest(s), but the commodity is prohibited from other areas of the country. • A mandatory treatment is required in conjunction with a pest-free area in a given country. • In a country with an approved pest-free area, a mandatory treatment is required if the commodity originates from area in that country that is not pest-free. • A mandatory treatment is required in conjunction with preclearance (Section 9.2.3.3.1). • A mandatory treatment is required in conjunction with a work plan which details how the commodity is to be processed and under what prescribed safeguards. • The commodity must be certified to be free of a specific pest or pathogen. 9.2.3.2 Disapproval of Permit Applications As a result of PRA, some applications to import specific fruits or vegetables from specific countries were disapproved. Among the reasons for disapproval were the following: • No approved treatment is available. • Not from a pest-free area in a country where pest free areas have been approved (Section 9.4.3.5.3). © 2000 by CRC Press LLC QUARANTINES/REGULATIONS, PEST RISK ANALYSIS, INTERNATIONAL TRADE 9 • A PPQ-approved work plan is required as a condition of entry, but pest risk documentation does not show that one was submitted and approved. • The fruit or vegetable was prohibited by – the Food and Drug regulations. (e.g., Piper betel, betel nut); – 7CFR 319.37. (e.g., Berberis spp. barberry); – 7CFR 319.24.(e.g., Zea mays, corn). 9.2.3.3 Inspection Inspection is a mitigation procedure that takes place when a commodity arrives at a port or point of entry in the U.S., including its territories and possessions. Inspection is conducted by a visual examination of a consignment by trained plant quarantine officers. The method of sampling and sampling size is prescribed in operational manuals. Officers look for signs (insect eggs, fungus fruiting bodies, bacterial oozes, etc.) or symptoms (the response of plants to infection or infestation). Phytosanitary Certificates — The phytosanitary certificate (PC) is a safeguard document that not only certifies plant health based on inspection but also certifies the identity of the fruits or vegetables and their geographic origin. The PC is issued by the quarantine service of the exporting country and addressed to the quarantine service of the importing country. The PC should conform to the IPPC model certif- icate. The weight given to the PC by the importing country depends on its past experience with PCs from a given exporting country. Consequently, in recent years most exporting countries strive to uphold the credibility, accuracy, biological sound- ness, and conformity to international standards of their PCs, but this was not always so in the past. Inspections are made by authorized certifying officials (PPQ officers, state or county cooperators). The cooperators must meet specified standards for education, training, experience, and the ability to identify pests and pathogens. The PC certifies that the products have been inspected according to appropriate procedures, and they are considered to be free from quarantine pests, practically free from other injurious pests, and conform to the phytosanitary regulations of the importing country. Some countries also accept state phytosanitary certificates which may certify origin, treatments, active growth field inspections, virus indexing, or other special conditions. The certificate must contain the quantity and name of the product as well as the botanical name, the number and description of the packages, distinguishing marks, and certified origin. Preclearance — Preclearance inspection is a safeguard taken at the origin of the commodity, in conjunction with several other safeguards agreed to by the exporting country and the U.S. PPQ officers work alongside their counterparts in the exporting country. A work plan is developed that spells out the responsibilities of the U.S. and the exporting country. Among the safeguards that may be specified in a preclearance program are one or more the following: pest-free areas, insect trapping, surveys for insects and disease agents, mandatory treatments, and inspection. PPQ may monitor with local inspections during the growing seasons, packing, storing, and shipping of approved fruits and vegetables. © 2000 by CRC Press LLC [...]... 199 5) harmonized with guidelines provided by NAPPO (Anon., 199 3) and FAO (Anon., 199 6a) Pest risk assessment is one of the three stages of a pest risk analysis (Anon., 199 3; Anon., 199 6a): Stage 1 — Initiating the process for analyzing pest risk (identifying pests or pathways for which the pest risk analysis is needed) (Figure 9. 1) © 2000 by CRC Press LLC 14 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL. .. need for vigorous national plant protection programs with the need for an outward-oriented trade policy which increases the export opportunities for domestic producers To a great extent, the 199 4 North American Free Trade Agreement (NAFTA) (Anon., 199 3) and the 199 5 GATT Uruguay Round Agreement provide a framework for balancing the need for health-related protection measures in trade with the need for. .. Press LLC 22 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION which limited their own comparative advantages and trade potential The increasing popularity of market-oriented policies during the 198 0s, along with the growing frustration with global agricultural trade conditions, produced sufficient support for agricultural trade reform The opportunity arose for such reform in 198 6 when countries... Measures, General Agreement on Trade and Tariffs, pp 69- 73 199 4 Anon Guideline for Plant Pest Risk Analysis of Imported Commodities, Version 1.7, Plant Protection and Quarantine, APHIS, USDA, Riverdale, MD, 277 pp., 199 7a Anon International Plant Protection Convention, New Revised Text, FAO Conference at its 29th Session, November, 199 7, FAO, Rome., 197 7b Anon Code of Federal Regulations, Title 7, Agriculture,... Oxford, 198 7 © 2000 by CRC Press LLC 32 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION Drake, J A., T E Flum, G J Wittman, T Voskuil, A M Hoylman, C Cresson, D A Kenney, G R Huxel, C S Larue, and J R Duncan The Construction and Assembly of an Ecological Landscape J Anim Ecol 62: 117-130, 199 3 Elton, C S The Ecology of Invasions by Animals and Plants Methuen and Co., Ltd., London, 195 8... pertinent pest interceptions at U.S ports of entry are reported Step 4 — Pest List — A list of potential quarantine pests associated with the plant species to be imported is compiled (regardless of plant part requested for importation) Step 5 — Identify Quarantine Pests — Quarantine pests (sensu Anon., 199 6b; Anon., 199 6) are identified A determination is then made which of the quarantine pests must... (Crawley, 198 7; Kogan, 199 0; Sailer, 197 8) Even if extensive biological information exists about an organism, many scientists believe that the turbulence of the ecological dynamics precludes any accurate predictions of the future (Drake et al., 199 3; May, 198 7; Porter et al., 198 8) 9. 3.4.2 The Philosophical Balance Between What Risk Assessments Can and Cannot Achieve When conducting risk assessments for regulatory... mitigation measures to reduce risk), and risk communication (the sharing of risk information) (USDA, 199 6) The results of APHIS risk analyses provide well-supported recommendations to APHIS decision makers to help ensure safe trade © 2000 by CRC Press LLC 12 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION 9. 3.2 APHIS Risk Analysis Principles APHIS recognizes that there are various approaches...10 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION Treatments — Among the safeguards for imports are treatments which consist of a chemical or physical processes, or modification of the environment (around the commodity) to eradicate a pest Fortunately, many of the PPQ treatments prescribed are environmentally sound since they involve physical... LLC 26 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION defined in the revised Convention to mean “justified on the basis of conclusions reached by using an appropriate pest risk analysis or, where applicable, another comparable examination and evaluation of available scientific information.”(Anon., 197 7b, Article II) This emphasis on the need to provide technical justification and pest risk . (Anon., 199 3) and FAO (Anon., 199 6a). Pest risk assessment is one of the three stages of a pest risk analysis (Anon., 199 3; Anon., 199 6a): Stage 1 — Initiating the process for analyzing pest risk. (identifying pests or pathways for which the pest risk analysis is needed) (Figure 9. 1) © 2000 by CRC Press LLC 14 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL PROTECTION Stage 2 — Assessing pest. 315 9. 3.2 APHIS Risk Analysis Principles 316 9. 3.2.1 GATT Consistent 316 9. 3.2.2 Science Based 316 9. 3.2.3 Well Documented 316 © 2000 by CRC Press LLC 2 INSECT PEST MANAGEMENT: TECHNIQUES FOR ENVIRONMENTAL