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International plant protection convention
Subjects: contaminating pest and contamination
15_TPG_2014_Dec
Agenda item: 5.1.2
SUBJECT OF THE TPG WORK PROGRAMME :
CONTAMINATING PEST AND CONTAMINATION (2012-001)
(Prepared by Laurence Bouhot-Delduc)
Background
[1]
The Glossary term contaminating pest was added to the List of topics for IPPC standards by the
Standards Committee (SC) in April 2012 based on a TPG proposal. The objective was to review its
definition to make sure that is covers the concepts normally expressed by the term hitch-hiker pest
which was deleted from the Glossary by CPM-7 in 2012.
[2]
Deletion of contaminating pest was proposed by the TPG in February 2013 because:
The definition of contaminating pest is limited to pests carried by a commodity, and does not
cover pests carried e.g. by conveyances.
However, there is a definition of contamination that covers appropriately all cases of
contaminations by pests or regulated articles.
Instead of revising the definition of contaminating pest, it was considered preferable to delete it,
to avoid duplicating definitions.
[3]
However, at the 2013 member consultation many members did not support this deletion because they
consider the term contaminating pest is useful, for example as an equivalent of the term hitch-hiker
pest. Thus they suggested not to delete the term contaminating pest, but rather to review its definition
making it fit with the meaning of hitch-hiker pest, for example extending it so that it covers not only
commodities but also regulated articles such as storage places, conveyances and containers.
[4]
The TPG recognized in February 2014 that: (i) the term contaminating pest is used in practice,
although not commonly in ISPMs; (ii) both contaminating pest and contamination are valid terms,
and; (iii) contaminating pest is easier to use than contamination in some contexts. However, the TPG
believed there is still a need to avoid duplication between the definitions. In addition, other issues have
been raised in relation to contamination. Thus the TPG suggested that contaminating pest be
withdrawn from the draft Amendments to the Glossary (2013), for reconsideration at the next TPG
meeting together with contamination.
[5]
The SC May 2014 agreed with this approach, noting that the TPG should also take account of member
comments made at the 2013 member consultation on contaminating pest.
[6]
Glossary definitions
contaminating pest
contamination
[7]
A pest that is carried by a commodity and, in the case of plants and plant
products, does not infest those plants or plant products [CEPM, 1996;
revised CEPM, 1999]
Presence in a commodity, storage place, conveyance or container, of pests
or other regulated articles, not constituting an infestation (see infestation)
[CEPM, 1997; revised CEPM, 1999]
The definition of contamination uses the definition of regulated article:
regulated article
Any plant, plant product, storage place, packaging, conveyance, container,
soil and any other organism, object or material capable of harbouring or
spreading pests, deemed to require phytosanitary measures, particularly
where international transportation is involved [FAO, 1990; revised FAO,
1995; IPPC, 1997]
International Plant Protection Convention
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15_TPG_2014_Dec (5.1.2)
[8]
Subjects: contaminating pest and contamination
Moreover contamination and infestation are cross-referenced terms, i.e. contamination is more readily
understood in relation to infestation:
infestation
(of
commodity)
a Presence in a commodity of a living pest of the plant or plant product
concerned. Infestation includes infection [CEPM, 1997; revised CEPM,
1999]
[9]
Problems with the existing definitions of contaminating pest and contamination
[10]
Contaminating pest
[11]
The definition of contaminating pest does not adequately reflect the particular implications of the
English term hitch-hiker pest. Thus, at the 2011 MC, some member comments did not support the
deletion of the definition of hitch-hiker pest because the definition of contaminating pest does not
fully deal with the concept of hitch-hiker pest i.e. “moved to another area, on a non-host which may be
an unusual pathway”.
[12]
The definition of contaminating pest does not make a cross-reference to the definition of infestation.
[13]
Contamination
[14]
In the definition of contamination, the wording “pests or other regulated articles” is not correct
because pests are not regulated articles.
[15]
The presence in a storage place, conveyance or container of regulated articles can be normal and thus
does not necessarily constitute a contamination. For example, plants and plant products are regulated
articles that may be present in containers as commodities.
[16]
In the draft ISPM Minimizing pest movement by sea containers, the term contamination is used in a
broader sense than its glossary definition: it covers, for example, organisms other than pests or
regulated articles, such as snails, slugs and snakes. This is not consistent with the Glossary definition
of contamination, but no other term had been found when drafting this standard. However it may be
legitimate in this case to use the term in a specific meaning (broader than the Glossary definition)
applying only to that draft ISPM. One option would be that the existing definition of contamination be
modified so as not to mention “storage place, conveyance or container”, but that this be added between
brackets after the term (as a qualifier). This would allow for the term to be used more broadly in other
contexts.
[17]
Possible solutions
[18]
The TPG noted in February 2014 that the term contaminating pests is not commonly used in ISPMs (it
is only mentioned in ISPM 15:2009 Regulation of wood packaging material in international trade and
ISPM 32:2009 Categorization of commodities according to their pest risk), whereas several other
ISPMs use contamination by pest or contamination of consignments, etc. However, this is not
surprising as before adoption ISPMs were amended to use the term contamination whenever possible.
Draft ISPMs more frequently use the term contaminating pest, and even the term contaminant which
is not defined in the Glossary, e.g.:
the draft ISPM International movement of seeds uses 3 times contaminating pest, 2 times
contamination and 2 times contaminant;
the draft ISPM International movement of used vehicles, machinery and equipment uses 1 time
contaminating pest, 17 times contamination and 7 times contaminant.
[19]
Therefore several solutions seem worth considering:
-
amend the definitions of contaminating pest and contamination,
amend the definition of contaminating pest and simplify the definition of contamination,
add a definition of contaminant.
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International Plant Protection Convention
Subjects: contaminating pest and contamination
(1)
[20]
[21]
15_TPG_2014_Dec (5.1.2)
Proposed revision of the definition of contaminating pest
a) First proposed revision:
A pest that is carried by present in a commodity, storage place, conveyance or
contaminating pest
container and, in the case of plants and plant products, does not infest those
plants or plant products (see infestation)
With this revision, the change is minimum: the definition is extended to “storage places, conveyances
and containers” and a cross-reference is added to the definition of infestation.
b) Second proposed revision:
A pest that is carried by a commodity, conveyance or container, or that is
contaminating pest
present in a storage place, and that, in the case of plants and plant products,
does not infest those plants or plant products (see infestation)
In this revised definition “carried by” is kept for commodities, conveyances and containers which are
moved internationally, and “present in” is used only for storage places.
[22]
With such a revised definition of the term contaminating pest, the concepts expressed by the English
term hitch-hiker pest would be better captured (extension of the definition to storage places,
conveyances and containers), especially in the second definition (use of the wording “carried by”).
However, the definitions of contaminating pest and contamination would be even more redundant.
Indeed, as the definition of contamination takes into account not only pests but also other
contaminants such as soil, both definitions would have to be kept.
[23]
The definition of contamination also needs to be revised.
[24]
[25]
(2) Proposed revision of the definition of contamination
Accidental presence in a commodity, storage place, conveyance or
contamination
container, of pests or other regulated articles, not constituting an
infestation (see infestation)
NB: - This revised definition is not fully satisfactory because the presence of pests is always
accidental, unlike the presence of regulated articles.
- Should it be “presence in or on” (e.g for sea containers)?
[26]
The definition of contamination (with or without revision) theoretically enables the deletion of the
definition of contaminating pest. The term contaminating pest could be still be used as a derived form
of contamination. However, at the 2013 MC many members did not support the deletion of
contaminating pest because they consider this term is used in practice, particularly as an equivalent of
the English term hitch-hiker pest whose definition was deleted from the Glossary in 2012.
[27]
However, the definition of the term contamination could be simplified so that the definitions of
contaminating pest and contamination are less redundant.
[28]
[29]
(3) Simplification of the definition of contamination
a) First proposed simplification of the definition of contamination:
Accidental presence in a commodity, storage place, conveyance or
contamination
(of a commodity)
container, of pests or other regulated articles, not constituting an
infestation (see infestation)
NB: This revised definition is not fully satisfactory because the presence of pests is always accidental,
unlike the presence of regulated articles.
The addition of the qualifier (“of a commodity”) would make the definitions of contaminating pest and
infestation more symmetrical. Moreover it would allow to use the terms contamination and
contaminant with their general meaning, for example for the contamination of sea containers by
invasive alien species.
International Plant Protection Convention
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15_TPG_2014_Dec (5.1.2)
Subjects: contaminating pest and contamination
b) However, if a definition of contaminating article were added in the Glossary, the definition of
contamination could be even more simplified.
[30]
Proposed addition of a definition of contaminating article:
[31]
contaminating article A regulated article that is accidentally carried by a commodity, conveyance
or container, or that is accidentally present in a storage place.
NB: Should “unintentionally” be used instead of “accidentally” in this definition?
[32]
Second proposed simplification of the definition of contamination:
[33]
Presence in a commodity, storage place, conveyance or container, of
contaminating pests or other regulated contaminating articles, not
constituting an infestation (see infestation)
NB: Is it grammatically correct to use the wording “presence” instead of “presence in”?
contamination
[34]
With such a simplification the definitions of contaminating pest and contamination would be much
less redundant, so both definitions could be kept without duplication.
[35]
Third proposed simplification of the definition of contamination (combining the two first
simplifications):
contamination
(of a commodity)
Presence in a commodity, storage place, conveyance or container, of
contaminating pests or other regulated contaminating articles, not
constituting an infestation (see infestation)
[36]
As well as for the second simplification proposed, the definitions of contaminating pest and
contamination would be much less redundant, so both definitions could be kept without duplication.
As well as for the first proposed simplification of the definition of contamination, the addition of the
qualifier (“of a commodity”) would make the definitions of contaminating pest and infestation more
symmetrical. Moreover it would allow to use the terms contamination and contaminant with their
general meaning, for example for the contamination of sea containers by invasive alien species.
[37]
A last solution would be to define the term contaminant in the Glossary.
(4)
Proposed addition of a definition of contaminant
A pest or a regulated article that is accidentally carried by a commodity,
conveyance or container, or that is accidentally present in a storage place, and
whose presence on plants or plant products does not constitute an infestation
(see infestation).
NB: This definition is not fully satisfactory because the presence of pests is always accidental, unlike
the presence of regulated articles.
Contaminant
[38]
[39]
The proposed definition of the term contaminant merges the definitions of contamination and
contaminating pest, and thus it theoretically enables to delete those two definitions. However it would
prevent to use the term contaminant with its general meaning (e.g. for invasive alien species
contaminating sea containers).
Proposal
[40]
To be discussed by the TPG, noting that:
If the definition of contaminating pest were deleted, the concepts expressed by the English term
hitch-hiker pest would be partly lost.
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International Plant Protection Convention
Subjects: contaminating pest and contamination
15_TPG_2014_Dec (5.1.2)
-
[41]
If the definition of contamination were deleted, the symmetry between the definitions of
infestation and contamination would be lost, whereas the wording “infestation or
contamination” is often used in ISPMs.
- Even if it is preferable to avoid duplicating definitions, it seems more important to clearly
define the fundamental concepts of the IPPC in the Glossary.
Taking this into account, two main solutions seem especially worth considering.
(1)
Simple revision of the definitions of contaminating pest and contamination
contaminating pest
contamination
[42]
A pest that is carried by a commodity, conveyance or container, or that is
present in a storage place, and that, in the case of plants and plant products,
does not infest those plants or plant products (see infestation)
Accidental presence in a commodity, storage place, conveyance or
container, of pests or other regulated articles, not constituting an
infestation (see infestation)
This is the simplest solution and these amendments constitute the minimum to be done, because the
revised definitions of contaminating pest and contamination would be more correct. However with the
revision of the definition of contaminating pest, the two definitions would be even more duplicating.
Moreover the revised definition of contamination would not be fully satisfactory because the presence
of pests in commodities is always accidental, unlike the presence of regulated articles.
(2) Revision of the definition of contaminating pest and simplification of the definition of
contamination
[43]
With the addition of the qualifier (“of a commodity”) for the definition of contamination, the
symmetry between the cross-referenced terms infestation and contamination would be reinforced.
Moreover this would allow to use the terms contamination and contaminant with their general
meaning, for example for the contamination of sea containers by invasive alien species.
a) First proposal for the simplification of the definition of contamination
contaminating pest
contamination
(of a commodity)
[44]
A pest that is carried by a commodity, conveyance or container, or that is
present in a storage place, and that, in the case of plants and plant products,
does not infest those plants or plant products (see infestation)
Accidental presence in a commodity, storage place, conveyance or
container, of pests or other regulated articles, not constituting an
infestation (see infestation)
This solution would not avoid some duplication between the definitions of contaminating pest and
contamination. Moreover the revised definition of contamination would not be fully satisfactory
because the presence of pests in commodities is always accidental, unlike the presence of regulated
articles.
b) Second proposal for the simplification of the definition of contamination
A pest that is carried by a commodity, conveyance or container, or that is
present in a storage place, and that, in the case of plants and plant products,
does not infest those plants or plant products (see infestation)
contaminating article A regulated article that is accidentally carried by a commodity, conveyance
or container, or that is accidentally present in a storage place.
Presence in a commodity, storage place, conveyance or container, of
contamination
(of a commodity)
contaminating pests or other regulated contaminating articles, not
constituting an infestation (see infestation)
contaminating pest
International Plant Protection Convention
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15_TPG_2014_Dec (5.1.2)
Subjects: contaminating pest and contamination
[45]
This solution would largely avoid duplication between the definitions of contaminating pest and
contamination, but would require the addition of a definition of the term contaminating article in the
Glossary.
[46]
The TPG is invited to consider the solutions envisaged.
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International Plant Protection Convention