Letter: DoA explains import rules for Christmas trees


I refer to your editorial of Nov. 5 (“Red tape strangles Cayman’s supply of Christmas trees”), which contained factually inaccurate information, which is misleading to the public and cast the Department of Agriculture (DoA) in an unfair and unfavorable light.

It is the job of the DoA to safeguard the plant health of the Cayman Islands (agriculture, horticulture and environment) and to mitigate the risk of introduction of pests of quarantine importance. This is a regulatory responsibility under the Plants (Importation and Exportation) Law and the National Conservation Law that we take very seriously. Essentially, it is our mandate to safeguard these Islands and prevent the importation and introduction of quarantine pests and other invasive species, while striving to strike the appropriate balance between protection and trade facilitation.

To offer some background, in 2015 the Department’s Inspectors noticed an increase in the interceptions of live pest specimens in shipments of Christmas trees. The situation continued in 2016. However, in both years this was linked to imports from one geographical region only. Although internationally accepted standards allow for return or destruction of infested shipments, in both instances the Department opted to work with importers to treat the trees post-entry, to eliminate the pest threat. Despite halting imports from the region that was the source of infested trees in the previous years, in 2017 live specimen samples were found in every shipment inspected. In total, 61 live specimen samples were collected and sent off island to experts for taxonomic identification. Of these, sixteen samples contained pests of or potentially of quarantine importance, including several known to be serious pests of agricultural crops and 10 which have never previously been recorded in the Cayman Islands. Again, recognizing the importance of the shipments to importers and the public, the Department opted for post-entry treatment, and after expending over 82 hours of inspectors’ time, was able to successfully eliminate the pest risk and release the trees.

Based on the experience of 2017 and following extensive consultations with other regulatory authorities in the Caribbean, the Department updated its Conditions for the importation of fresh Christmas trees in May 2018, which were in turn shared with importers at a meeting on June 5, 2018.

The Editorial stated that, “Officials’ initial idea was to require growers, in Canada, to spray the trees before they are shipped to Cayman. The only problem is that the spray DoA wanted growers to use is banned in Canada. (How could the DoA not be aware of this? Anyway, why are they advising the use of a poison that has been banned in a large first-world country like Canada?)”

This is simply not true; at no time did the Department require such a treatment. The Conditions provided an either or option; that is, either post-harvest fumigation, which would be guaranteed to eliminate any pest in the shipment, or conduct a pre-harvest treatment three to six weeks before harvest using a mixture of approved pesticides. The Department was and is fully aware that Canada no longer uses the fumigant in question. However the United Sates does and as it is the only fumigant that would eliminate virtually all pests without killing the trees, leave no residue on the fumigated product and is still used in international trade, it was provided as an option, particularly for potential imports from the U.S. In the case of Canada exporters, they could avail themselves of the alternative of a pre-harvest treatment.

Additionally, as some specific insects and diseases are known to be difficult to control with pesticides, and given the feedback from exporters in Canada that they inspect their fields and select trees for export only from fields free of these listed pests, an additional requirement for a declaration certifying that the trees were harvested from fields free of these listed pest was included in the import conditions.

In July 2018, the DoA received feedback from the exporters that the Canadian authorities would not certify the fields to be free of the listed pest and hence would not sign the necessary phytosanitary certificates required for export. In light of this and on consultation with the Regional Plant Protection Organization (RPPO) for the Caribbean, the Department decided to modify the conditions to remove the requirement for certification of harvest from pest-free fields. These revised conditions were circulated to both USDA-APHIS and CFIA (Canadian authorities) and after review (which took time) both authorities agreed the conditions were acceptable and the required phytosanitary export certificates could be issued.

The updated conditions were not a “workaround” as described by the Compass editors but a carefully reviewed and considered decision, because the preferred condition could not be certified to by the authority of the exporting country; its removal would facilitate trade while maintaining an acceptable level of risk mitigation.

The Department again met with importers on Aug. 16, 2018 to apprise them of the updated conditions. The actual treatment requirements remained unchanged from June 2018. The change in August did not add any additional conditions for exporters to meet and simply removed an inspection and certification requirement that would have had to be met at the time of harvest in October.

It is unfortunate that the Compass editorial team chose to publish an editorial based on hearsay without checking and verifying the facts with the Department of Agriculture. Further, to imply that necessary and internationally accepted phytosanitary regulations endorsed by the World Trade Organization (WTO), the Food and Agriculture Organization (FAO) and the International Plant Protection Convention (IPPC) as the appropriate mechanism for assuring safe trade in fresh agricultural and plant products are merely “red tape” seems to indicate a lack of appreciation for science-based regulatory decisions designed to protect countries from the movement of invasive pest species.

The potential economic and environmental impacts of invasive pests are real and serious. In Turks and Caicos, a new scale insect introduced via Christmas trees is decimating their native “pineyard” ecosystem, and with no effective control available could well lead to the complete loss of their native pine. Many insects are polyphagous and non-host specific, and what may not be a pest in its native country may become one in a new environment. In the United States, a 1999 Cornell University study estimated that invasive species cost that country US$123 billion a year in economic losses.

As stated previously, trying to maintain the appropriate regulatory balance between protection and trade facilitation is a complex and ever-changing challenge, and one that the Department of Agriculture takes very seriously. Despite its small size and limited staff, rather than failing in this goal, as the editorial implies, the Cayman Islands Department of Agriculture has on multiple occasions been recognized regionally for its accomplishments and its professional standards with regard to the implementation of Sanitary and Phytosanitary regulatory measures.

I hope that the facts stated above have given you a different perspective on the issue of the Christmas tree shortage, and that it will inform your reporting moving forward. I am happy to meet with you to clarify or further explain the DoA’s position. Thank you for your time.

Adrian R. Estwick
Director of Agriculture

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