64 GERMINATION.CA JANUARY 2019 risk to a level consistent with the pest risk involved. While ISPM 38 addresses the harmonization barrier to international seed movement, it does not provide a solution to the ever-increasing demands for phytosanitary certifica- tion. One approach proposed to the IPPC by several countries, including Canada this past fall, is to create a risk-based systems approach. NPPOs of exporting countries could accredit seed companies based on compliance with the overall system. The com- pliance would be tested via routine audits of the production facilities. The accreditation arising from a compliant production system would form the basis for phytosanitary certification, serving as an alternative to the current individual consignment certification. Substituting sampling and testing for an accreditation and systems’ approach can also resolve issues around the movement of small lots of seed. The implementation of ISPM 38 and a corresponding systems approach would facilitate more effi- cient global trade without compromis- ing the rigour that is associated with the Canadian regulatory process. CANADA’S SEED INDUSTRY is a global enterprise, with imports of approximately $600 million and exports of roughly the same value to over 100 countries worldwide. Of those countries, 34 imported more than $1 million in Canadian seed in 2017. These numbers are expected to increase as Canada executes more free trade agreements and companies conduct their business internationally to a greater extent. In conversations about trade, the administrative side of things is often omitted. For anyone who engages in trade, however, it is often the first thing said. Trade cannot occur without the administrative tasks associated with ensuring import requirements are met. In the case of seed, phytosanitary certificates are the passports for the destination countries, but as trade continues to increase so do import requirements. This makes the task of issuing phytosanitary certifi- cates by certifying officials in exporting and re-exporting countries a daunting one. The increase strains National Plant Protection Organization (NPPO) resources like the Canadian Food Inspection Agency (CFIA). Further exacerbating the difficulty is the lack of harmonization between different NPPOs. These factors present a signifi- cant impediment to the international movement of plants and plant products, including seed. To improve global seed movement, an interna- tional phytosanitary measure was introduced by the International Plant Protection Convention (IPPC) in April of 2017. The mission of the IPPC is to prevent the intro- duction and proliferation of plant pests. World Trade Organization (WTO) members like Canada should base their phytosanitary measures on international standards developed within the framework of the IPPC, which are legal internationally binding agreements. The adopted standard, entitled ISPM 38 on the International Movement of Seeds, is intended to provide detailed guidance to harmonize phytosanitary measures for seeds for planting. ISPM 38 encourages NPPOs to share phytosanitary information and consider equivalent phytosanitary measures to fulfill requirements. An exam- ple of the latter would be to use an alternative chemical treatment if the one required by the importing country is not available in the exporting country. Companies that produce and move seed often use quality management systems and best practices to manage phytosanitary risks. ISPM 38 recognizes that these seed production practices, when combined under a systems approach (ISPM 14), can manage phytosanitary HERE'SHOWTOENABLEMOREEFFICIENTTRADE Claudio Feulner, CSTA Regulatory Affairs and Policy Coordinator CSTA / SEEDINNOVATION.CA / ISPM 38 HELPS FACILITATE INTERNATIONAL MOVEMENT OF SEED “INCONVERSATIONSABOUT TRADE,THEADMINISTRATIVE SIDEOFTHINGSISOFTEN OMITTED.”