Lesson 2: Pest Risk Analysis

Topic 3: Pest Risk Management

In this topic, we review the steps in completing the pest risk management stage of PRA.

Objectives:

  • Recall the process for completing the pest risk management stage of PRA.

If you determine from the pest risk assessment report that the risks of pest introduction are too high, you will need to make a targeted plan for managing these risks and mitigating the potential consequences. This third stage of PRA is called pest risk management.

Definition from ISPM 5:

“the analytical process of identifying, evaluating, and recommending pest risk management options.” —ISPM 5

Just as you analyzed the risks and consequences of pest introduction in the pest risk assessment stage, you need to analyze the pest risk management options. This process can also be undertaken as a re-evaluation exercise to update and modify current mitigation measures. This should be done regularly as new pest information and mitigation methods become available. As you begin the process of identifying and weighing your pest risk management options, recall these principles of pest risk management analysis and practice by reviewing the terms below:

  • Necessity: Countries have the sovereign right to protect themselves but must demonstrate that potential risk justifies the need for protection.
  • Managed risk: NPPOs must realize zero risk is not achievable and adopt a policy of managed risk based on an accepted level of risk.
  • Minimal impact: Always choose the least restrictive measures possible that will least impede trade.
  • Non-discrimination: Policies should not discriminate between trading partners who face similar risks.
  • Technical justification: When risk management requirements are not based on international standards, they must be justified through PRA.
  • Modification: PRA needs to be modified without delay when new information becomes available.

Rational relationship is not described as a principle in either the IPPC or the SPS Agreement and is not spelled out in an ISPM. However, it has become a central issue in many legal systems and plays an important role in risk management. Before selecting a risk management plan, you must be able to sufficiently answer two questions:

1. Does the measure under consideration actually mitigate the risk?
For instance, a fumigation or irradiation treatment that is effective against insect pests may not be appropriate for weed seeds (as pests of a commodity). If so, the measure would have no rational relationship to the risk if required as a treatment against weed seeds.

2. Is the strength of measure proportional to the risk?
The magnitude of the risk and the strength of the measure applied to mitigate the risk are on “sliding scales.” Higher risks require stronger measures, and lower risks require weaker measures. For example, a treatment designed for internal-feeding pests (higher risk) may be too strong against external-feeding pests and/or contaminating pests (lower risk).

Keeping these principles in mind, let’s now review the process and information needed to perform analysis of pest risk management options.

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As a risk manager, you will need to do the following:

  1. Read and understand the risk assessment. Are the risks unacceptably high to the point where mitigations are needed?
  2. Identify appropriate risk management options based on the risk assessment. Find out all the options that could mitigate your specific risks from the assessment.
  3. Evaluate options by seeking information on the efficacy, feasibility, and impacts of each option. You will need to be sure the mitigation options will effectively reduce or eliminate the threat.
  4. Document the level to which the risk is reduced by each option or combination of options.
  5. Re-examine and compare the risk assessment in light of the risk management options chosen.
  6. Consider if other options leading to an equivalent reduction in risk are available.
  7. Demonstrate the added effect of each option on the level of risk reduction.
  8. Report your management recommendations to the appropriate NPPO officials.

As you work through the previous steps, consider the three primary categories of risk mitigation measures:

  1. Mitigations: Measures that have a direct effect on pests to reduce their numbers or survivability (e.g., treatments such as fumigation, irradiation, chemicals).
  2. Safeguards: Measures that promote phytosanitary security by reducing probability of pest escape or contamination, entry, or establishment (e.g., pest-proof packages, shipping season spread over time, prohibition).
  3. Processes: Measures that do not reduce risk by themselves but support or improve the effectiveness of risk management (e.g., inspection, certification).

Often your recommendations will need to include implementing more than one of these options in order to achieve an acceptable level of reduced risk. The three most common measures used for risk management are prohibition, inspection, and treatment. Prohibition is the highest level of protection, but is the most difficult to justify. Inspection, treatments, and other common management options covered in the SPS course will be reviewed in the next lesson.

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After carefully weighing and considering your pest risk management options, you must create a final PRA report including the pest risk assessment findings and pest risk management recommendations with rationale.
According to ISPM 11, these are the main components that should be included in the final PRA report:

  1. Purpose of the PRA
  2. Pest, pest list, pathways, PRA area, endangered area
  3. Sources of information
  4. Conclusions of risk assessment
    • Categorized pest list
    • Probability
    • Consequences
  5. Risk management
    • Options identified
    • Options selected

All of this information must be included in order for the NPPO to make justified phytosanitary regulatory decisions. Remember that all regulatory decisions must not only be based on the PRA report, but also comply with SPS principles of transparency, consistency and equivalence.

Pest risk management is the last stage of conducting a PRA. For more information regarding pest risk management, please review Module 6: Pest Risk Management.

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