Systems Approach to Nursery Certification (SANC)

SANC Elements Manual for Systems Approach to Nursery Certification (SANC)

A systems approach for the certification of nursery stock is an audit-based certification program designed to reduce pest risk associated with the movement of nursery stock. In order to implement an audit-based system, participating nursery/greenhouse operations must comply with certain conditions for the systems approach strategy meeting the goals of: 1. Maintaining health and quality of end product, 2. Reducing the spread of plant diseases and pests, 3. Reducing the incidents of quarantine violations, 4. Reducing industry costs associated with regulatory action (stop sales, plant destruction) and pesticide applications, and 5. Reallocation of resources where needed.

While every nursery operation is unique and there is no “one size fits all,” the level of participation SANC will vary and can be tailored to each nursery/greenhouse operation. At a minimum, a systems approach for the certification of nursery stock requires the nursery/greenhouse operation to: 1) conduct routine scouting/pest management, 2) provide adequate training for employees to ensure compliance with requirements of a systems approach, 3) keep accurate records and 4) conduct a risk assessment of the nursery operation. Participation in the systems approach to nursery certification (SANC) by nursery/greenhouse operations is on a voluntary basis.

The purpose of the SANC Operations Manual is to provide industry and state regulatory agencies with an overview of the major operational elements of a systems approach to nursery certification. Information in this manual will allow nursery/greenhouse management to evaluate the systems approach and determine if participation in SANC is desired. The SANC Operations Manual provides a list of common hazards and critical control points found in nursery/greenhouse operations and suggested best management practices to mitigate these hazards. Nursery/greenhouse operations that choose to participate in SANC can use this manual as a guide in the development of those best management practices which will enable them to meet the goals and requirements of SANC.

SCOUTING/PEST MANAGEMENT Scouting which is conducted on a regular basis provides for the early detection of plant pests and nutrient and water abnormalities which in turn prevents the establishment and spread of plant pests and reduces time and costs associated with controlling the pests.

Current regulatory inspections are typically conducted once during the growing season and/or at the time of shipment, thus providing the inspector with only a “snapshot in time” of pest conditions in the nursery. Scouting conducted at regular intervals by nursery/greenhouse employees ensures stock is monitored throughout the growing season and allows staff to focus inspections during those times when pests/pathogens are most prevalent.

Scouting also serves a critical role in the control of plant pests and associated costs. Routine scouting enables staff to treat at the onset of an infestation rather than after the pest has become established. Early detection and early treatment will likely result in reduced treatment costs and increased treatment success (i.e., control, eradication) since the infestation/infection will be detected when it is smaller and easier to manage.

Successful scouting and pest management requires adequate training of staff to recognize plant pests and

SANC Elements Manual v.9 7/2013 Page 1 of 10 diseases and identify treatment recommendations. Documentation of scouting through the use of established recordkeeping procedures verifies that scouting occurred and was conducted at appropriate times and provides a record of plant pest problems.

TRAINING Management and employees should be provided adequate training so they understand their role and responsibilities in SANC. Employees must understand that they are the first line of defense in preventing the introduction and spread of plant pests. Training should include all elements of both the systems approach protocol and the nursery/greenhouse operations manual.

RECORDKEEPING Recordkeeping is essential in order to document that established SANC procedures are followed. Proper recordkeeping will verify that all requirements of the systems approach protocol and nursery operation manual are completed in a timely manner. In addition, recordkeeping provides essential trace-back and trace-forward documentation. Recordkeeping requirements will vary depending on the hazards, CCP’s and BMP’s identified, but should include, at a minimum, scouting activities and training records.

RISK ASSESSMENT The risk assessment of nursery/greenhouse operations will identify both the operational areas which have the unintended potential to cause harm to plant products (hazard) and the mitigation measures to address those hazards. In order to implement a successful systems approach protocol, the nursery/greenhouse operation must include at least two independent measures (see Framework for a Systems Approach to Nursery Certification); one of these measures should include routine scouting.

SANC requires identification of hazards and critical control points followed by implementation of best management practices to effectively reduce the risk associated with the specific hazard. Hazards are defined as any area of nursery/greenhouse operations which have the potential to cause harm to the plant products by contamination or introduction of plant pests. A critical control point (CCP) is any point, step or procedure at which controls can be applied and the hazard prevented, eliminated or reduced to an acceptable level. Best management practices (BMPs) are those measures which are implemented at a CCP to prevent, eliminate or reduce the risk associated with the specific hazard.

Example: If irrigation water is considered a risk for spreading plant pathogens, then water meets the definition of a hazard. If the water source is an irrigation pond, the CCP for the water hazard could be the pond since this is the point at which controls could be established to reduce the risk associated with irrigation water. The measures (BMP) to address this hazard could include regular monitoring/testing for the presence of pathogens in the pond water or implementation of a routine treatment schedule.

The best management practices (BMPs) included in this manual are provided as suggestions. There are likely other BMPs which may be more appropriate for the individual nursery and will better facilitate management of identified hazards. Researchers, industry and the National Plant Board have collaborated in the development of a set of general BMPs (SANC BMP companion document) to support this process. The nursery/greenhouse management, in cooperation with the state regulatory agency will develop the BMPs necessary for each CCP for incorporation into the nursery/greenhouse operations manual.

Conducting a risk assessment requires identification of the areas of the nursery/greenhouse operation (hazards) which have an increased risk of the introduction of plant pathogens and pests. Common hazards which have a high degree of risk for the introduction of plant pests include, but are not limited to the following core hazards: I. Water II. Surface Areas, Equipment and Tools III. Incoming Shipments IV. Cull Piles, Composting Areas, Debris V. Containers VI. Media

I. Hazard - Water: Proper water management can prevent the spread of plant pathogens and resulting diseases. Irrigation water should be free of pathogens in order to reduce the risk of spread of plant diseases associated with various water sources. Water which is from an irrigation pond may contain pathogens as runoff from production areas is likely to drain into the pond thus spreading pathogens from infected plants. Well water or water from a municipal system will likely have a lower risk than irrigation water of containing pathogens. In addition, the type of irrigation system used by the nursery and timing of irrigation play an important role in the spread of disease as overhead irrigation increases the chance of splash, ponding, leaf wetness, etc.

Hazard: Irrigation Water CCP: Recycled Irrigation Water 1. Responsibilities of the Place of Production A. Training Staff will receive training to include proper testing and treatment procedures for irrigated water and associated record keeping requirements B. Pest Management Program (Best Management Practices) i. Water Monitoring - Test irrigation water on routine basis for pathogens of concern ii. Water Treatment - Treat irrigation water on routine basis. (e.g., chlorine, sand filtration, settling ponds) C. Internal Verification i. Test treated and non-treated irrigation water at least once per week ii. Test well and/or municipal water at least once per month iii. Designate staff responsible for treating, testing and monitoring of irrigation water D. Traceability Record keeping requirements include type of type of testing and frequency, specific test protocols, targeted pathogens, type of treatment and frequency, personnel conducting the treatment and monitoring, training conducted 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Inspections to verify compliance with testing and monitoring requirements to include water testing to verify results, audit of testing/treatment records and training records

Hazard: Standing Water CCP: Irrigation Practices – Measures to ensure plants are not overwatered 1. Responsibilities of the Place of Production A. Training Staff will receive training on irrigation procedures (frequency, duration, etc.), visual monitoring, proper use of moisture monitoring devices, and record keeping requirements B. Pest Management Program (Best Management Practices) i. Use of water moisture monitoring devices ii. Conduct visual monitoring on routine basis. Establish procedures for reporting overwatering C. Internal Verification Use of moisture monitoring devices on systematic basis (e.g., daily, weekly, monthly)

SANC Elements Manual v.9 7/2013 Page 3 of 10 D. Traceability Recordkeeping requirements include irrigation schedules, monitoring records, type of monitoring devices used, personnel conducting testing/monitoring, and training 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual inspections to verify proper irrigation practices (presence/absence of excess water). Audit of moisture monitoring device records and irrigation schedule records

Hazard: Extended Periods of Leaf Wetness CCP: Irrigation Practices - For overhead irrigation, steps to reduce leaf wetness period. 1. Responsibilities of the Place of Production A. Training Staff will receive training on irrigation practices (frequency, duration, etc.), visual monitoring, proper use of moisture monitoring devices, and recordkeeping requirements B. Pest Management Program (Best Management Practices) Develop irrigation schedule (i.e., early morning) to enhance leaf drying C. Internal Verification Conduct visual monitoring on routine basis. Establish procedures for reporting overwatering/extended leaf wetness periods D. Traceability Recordkeeping requirements include irrigation schedules, monitoring records, personnel conducting monitoring, and training 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Conduct visual inspections of plants for symptoms of extended leaf wetness periods. Audit of irrigation schedule records and training records

Hazard: Standing Water CCP: Nursery Layout/Growing Areas 1. Responsibilities of the Place of Production A. Training Staff will receive training on conducting visual monitoring for areas of standing water, use of raised beds/benches, weed mat, etc. B. Pest Management Program (Best Management Practices) i. Install gravel, weed mat or other approved substrate (not bare soil) ii. Grade nursery in a manner which will provide proper water drainage iii. Use of raised beds or benches to allow water to drain properly and prevent plants from sitting in excess water iv. Bury drainage pipe to enhance water drainage C. Internal Verification Conduct visual monitoring for standing water on routine basis D. Traceability Recordkeeping requirements include map of nursery to include water drainage, installation date and location of weed mats, raised benches and other mitigation devices 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual inspections to verify proper drainage of runoff throughout nursery; Inspections to verify use of raised benches and weed mat (when applicable); Audit of weed mat installation records (when applicable)

II. Hazard - Surface Areas, Equipment and Tools: Plant pathogens can inadvertently be transmitted through exposure to contaminated plant benches/tables, equipment and tools. Proper and routine sanitization practices can eliminate the spread of pathogens.

Hazard: Surface areas of container stock CCP: Plant Rotation Procedures 1. Responsibilities of the Place of Production A. Training Staff will receive training on importance of sterilization, methods, recordkeeping requirements B. Pest Management Program (Best Management Practices) i. Greenhouse benches/surfaces and propagation containers are cleaned and sterilized between uses ii. Leaf debris is removed between rotations/crops. This can be accomplished by flaming/burning, sweeping or raking debris, or laying down fresh weed matt, etc. Maintain record of all actions to destroy/remove debris between rotations C. Internal Verification Monitor to verify sterilization has occurred (disinfectant is used, debris is removed/destroyed). Assign sterilization and monitoring responsibilities to different staff members. D. Traceability Recordkeeping requirements include dates, methods and personnel conducting sterilization; training of staff 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Audit of records to verify sterilization is completed and staff is trained

Hazard: Surface areas of container stock CCP: Exclusion procedures for soil/weeds from production areas 1. Responsibilities of the Place of Production A. Training Staff will be trained on risks associated with native soils, weeds, etc. Staff will be trained on appropriate methods to clean equipment of native soils, exclude soils from greenhouses, and weed treatment requirements B. Pest Management Program (Best Management Practices) i. Establish sanitation procedures to keep greenhouses free of native soils and outside equipment. ii. Establish procedures to treat and/or exclude weeds from and adjacent to greenhouses and plant production areas; grass or other cover crop is maintained and kept mowed. C. Internal Verification Establish monitoring schedules to ensure greenhouses are free of native soil; establish mowing or herbicide application schedules for areas adjacent to greenhouses and plant production areas D. Traceability Recordkeeping requirements include dates, methods and personnel cleaning equipment; herbicide applications; training of staff 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency

SANC Elements Manual v.9 7/2013 Page 5 of 10 Visual inspection of greenhouses and areas adjacent to greenhouses/plant production areas. Audit of records to verify sterilization is completed, herbicide applied, and staff is trained

Hazard: Equipment/Tools CCP: Sanitization of Equipment/Tools 1. Responsibilities of the Place of Production A. Training Staff will be trained on risks associated use of contaminated equipment and tools; methods for cleaning equipment and approved methods and required sterilization intervals B. Pest Management Program (Best Management Practices) i. Machinery, tools, cutting knives, heavy equipment are appropriately washed (remove visible soil from surface) and sanitized between each use ii. Equipment is cleaned and sanitized before moving from areas known to be contaminated with pests or pathogens C. Internal Verification Monitor to verify cleaning and sterilization has occurred (disinfectant is used, equipment is clean). Assign cleaning/sterilization and monitoring responsibilities to different staff members D. Traceability Recordkeeping requirement to include sanitation schedules for equipment, greenhouse benches, surfaces, debris removal, etc. Training sessions for nursery staff is documented 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual inspection of equipment/tools. Audit of records to verify cleaning and sterilization is completed, and staff is trained

III. Hazard - Incoming Shipments: Preventing the introduction of infected plant material is the first line of defense for introduction of plant pests. Outside sources of plant material presents a high risk of infection as these plants may appear healthy upon arrival. Good sanitation practices associated with the introduction of nursery stock can lessen the chance of disease establishment.

Hazard: Incoming (Buy-In) Shipments CCP: Delivery Trucks 1. Responsibilities of the Place of Production A. Training Staff will be trained on cleaning and sanitization procedures for delivery trucks for both incoming and outgoing plant shipments; recordkeeping requirements for all cleaning and sanitization activities B. Pest Management Program (Best Management Practices) Sanitation of Delivery Trucks - Interior and exterior of delivery vehicles are clean and sanitized between shipments to reduce the potential for buildup of pathogens and pests C. Internal Verification Monitor to verify cleaning and sterilization has occurred (disinfectant is used, equipment is clean). Assign cleaning/sterilization and monitoring responsibilities to different staff members D. Traceability Recordkeeping requirement to include disinfectant used, dates, delivery trucks, personnel, training 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual monitoring of delivery trucks to verify cleaning/sterilization occurred. Audit of sterilization records

Hazard: Incoming (Buy-In) Shipments CCP: Shipping and Receiving Areas of Nursery/Greenhouse Operation 1. Responsibilities of the Place of Production A. Training Designated receiving area should be clearly marked. Staff should be trained on procedures for cleaning receiving areas between shipments and disposal of debris and soil B. Pest Management Program (Best Management Practices)  Designated receiving area for all incoming plants  Receiving area should be a smooth surface such as asphalt or concrete or other appropriate surface.  Receiving area must be cleaned between deliveries and shipments and kept free of plant and soil debris. Debris and soil left behind after plant loading or unloading is collected and disposed of properly (landfill, burning or complete composting). C. Internal Verification Visual monitoring of receiving area to ensure area is cleaned between shipments and debris is disposed of properly. D. Traceability Recordkeeping requirement to include documentation for destruction of debris and soil left behind between shipments. 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual verification of designated receiving area, appropriate surface. Audit of records for destruction of debris and soil, staff training.

Hazard: Incoming (Buy-In) Shipments CCP: Incoming Nursery Stock 1. Responsibilities of the Place of Production A. Training Nursery staff will receive training in the following areas:  Symptoms of plant pests and pathogens of regulatory concern  Symptoms and unacceptable levels of disease/pests caused by established (quality) pests and pathogens  Appropriate management and/or eradication measures  Procedures/requirements to reject loads  Importance of quarantine procedures  Procedures when pests and pathogens or regulatory concern or quality pests are detected in quarantined plants (to include treatments, cull procedures)  Importance of and procedures for segregation of high risk plants  Recordkeeping requirements for all incoming stock (source nursery, date, etc.) to ensure ability for trace back and trace forward B. Pest Management Program (Best Management Practices)

SANC Elements Manual v.9 7/2013 Page 7 of 10 i. Inspection of Incoming Stock - Plants are inspected prior to (when possible) and during unloading. Unacceptable or suspect stock is not allowed onsite and is rejected and returned ii. Quarantining of incoming stock - Incoming nursery stock is placed under quarantine for at least 30 days and monitored for symptoms. Nursery staff is trained to recognize symptoms of plant pests/pathogens of regulatory concern, unacceptable levels of disease/pests caused by established pests/pathogens, and appropriate management and/or eradication measures iii. Inspection following 30 day quarantine period - Recently purchased plant material should be inspected on a routine basis (following the 30 quarantine period and on regular basis afterwards) iv. Segregation of plants - High risk plants should be grouped to minimize the spread of disease (alternate blocks of high risk host plant material to reduce the chance of spread from one block to another and keep all high risk host plants together rather than comingling and thus infecting more blocks and more plants) C. Internal Verification Visual monitoring of incoming shipments. Quarantine areas are established and inspected on weekly basis. High risk plants released from quarantine area are segregated and monitored D. Traceability Record of inspection of incoming plant shipments to include date of arrival, source nursery, rejected loads, etc. Records of quarantined plants to include arrival date, inspection dates, personnel, inspection results. Inspection records of plants released from nursery’s quarantine to include date, results of inspection, treatments. Current maps of nursery layout indicating quarantine areas, plant segregation areas, etc. Incoming plant records to include source nursery, date, location in nursery. Pesticide application records are maintained 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual confirmation of quarantine areas; segregation of high risk plants. Audit of records for inspection, treatments, nursery layout map

IV. Hazard - Cull piles, composting area, debris: Stock which is culled could contain plant pathogens which can spread to production areas via workers or water run-off from the cull/composting areas. In addition, plant debris from infected nursery stock is a source of plant pathogens and should be removed in order to eliminate exposure.

Hazard: Cull piles and composting area CCP: Location of cull piles/composting areas 1. Responsibilities of the Place of Production A. Training Staff will be trained on risks associated with contaminated cull piles and composting areas and methods to prevent the spread of pathogens from these areas B. Pest Management Program (Best Management Practices) i. Locate cull/composting areas away from soil, soil mixing areas, and growing beds ii. Locate cull/composting area away from high traffic areas iii. Water run-off from cull piles flows away from plant production areas or runoff must be contained to prevent contamination of plant production areas as well as media and container storage areas iv. Compost is managed to ensure plant pests are not viable C. Internal Verification Monitor to verify that water run-off flows away from plant production areas. Monitor areas to ensure staff and equipment avoid compost/cull areas when possible. Compost pile is rotated to maintain adequate temperatures. Internal temperatures of compost pile is monitored D. Traceability Recordkeeping requirements include map of nursery indicating compost areas/cull piles and water drainage from these areas. Recordkeeping of compost piles monitoring and rotation, identification (source, block, number) of culled plants. Staff training on compost monitoring, rotating and avoidance of compost/cull areas 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual monitoring of compost/cull areas. Audit of records to include verification of map of nursery, compost monitoring records and staff training

V. Hazard: Debris from infected plants: Plant debris which remains between crop rotations can be a source of plant pathogens and steps should be taken to remove this debris in order to prevent the spread of disease to uninfected stock.

Hazard: Debris from infected plants CCP: Handling of plant debris 1. Responsibilities of the Place of Production A. Training Staff will be trained on risks associated with residual plant debris and will be trained on accepted methods of debris removal and recordkeeping requirements B. Pest Management Program (Best Management Practices) Removal of leaf debris between rotations/crops. This can be accomplished by flaming/burning, sweeping or raking debris, use of fresh weed matt, etc. C. Internal Verification Monitor to verify plant debris is properly managed between rotations/crops and per nursery protocols D. Traceability Recordkeeping requirement to include documentation of destruction of plant debris between rotations. Record staff training on destruction requirements and risks associated with residual plant debris 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual monitoring of plant production areas to verify absence of plant debris. Audit of plant debris destruction records and staff training records

VI. Hazard - Containers: Used containers can be a source of plant pathogens and steps should be taken to prevent the use of these containers from spreading disease to uninfected stock.

Hazard: Containers CCP: Procedures for Treatment and Storage of Used Containers 1. Responsibilities of the Place of Production A. Training Staff will be trained on risks associated with reusing plant containers and accepted methods of cleaning and sterilization, recordkeeping requirements B. Pest Management Program (Best Management Practices) i. Used containers must be cleaned of all debris and properly sanitized before re-use.

SANC Elements Manual v.9 7/2013 Page 9 of 10 ii. Potting containers must be stored in a clean area away from compost and cull piles and native field soil C. Internal Verification Visual monitoring to ensure used pots are stored away from compost/cull areas and properly cleaned D. Traceability Recordkeeping requirement to include cleaning and sterilization schedules for used containers. Training for staff on sterilization techniques is documented 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual monitoring of used container storage area and presence/absence of clean used pots during potting. Audit of cleaning/sterilization records of used pots

VII. Hazard - Media: Potting media should be handled and stored in a manner that will prevent media from becoming infected with plant pathogens.

Hazard: Media CCP: Storage and Handling of Potting Media 1. Responsibilities of the Place of Production A. Training Staff will be trained on the proper methods of handling and storing media and methods of sanitizing boots and equipment B. Pest Management Program (Best Management Practices) i. Potting mix and potting mix components must be stored in a clean container or on a clean surface away from compost and cull piles and native field soil ii. Runoff from compost and cull piles must be diverted or prevented from contaminating potting mixes and components iii. Nursery staff sanitizes boots and equipment before walking in soil media mixing or storage area. C. Internal Verification Visual verification that all media is stored in clean area and away from water runoff D. Traceability Recordkeeping requirement includes documentation of sterilization records and training for staff. Nursery layout map to indicate media storage area, cull/compost areas, and water runoff 2. Compliance Monitoring - Responsibility of Issuing Regulatory Agency Visual monitoring of location of media storage areas and water runoff. Audit of sterilization and staff training records