January 25, 2021 | Susan Napier-Sewell

USDA Permit Violation Results from Shipping Oversights

USDA permit conditions were not followed for international shipment.

Recently a research collaborator shipped USDA (United States Department of Agriculture) regulated material from a location in Canada directly to a Pacific Northwest National Laboratory (PNNL) researcher in Richland, Washington, who was not a USDA permit holder.

The package should have been sent to a Plant Protection and Quarantine (PPQ) Inspection Station first, then addressed to the appropriate USDA permit holder at PNNL. Thus, the USDA permit protocol was not thoroughly employed or followed through.

Additionally, a prepaid domestic shipping label, to get the shipment from the inspection site to the final destination, should have been included. These oversights represent USDA permit violations.

Details of USDA permit shipping violations

The PPQ Plant Inspection Station in Seattle, Washington, inspected and verified the entry of the package into the U.S. The shipment originated from Canada and contained materials with bacteria and fungi to be analyzed at Pacific Northwest National Laboratory (PNNL).

The shipment was sent under a PNNL PPQ Permit to Move Live Plant Pests, Noxious Weeds, and Soil and was improperly addressed directly to PNNL. U.S. Customs and Boarder Protection redirected the package to the PPQ Plant Inspection Station in Seattle as required for entry into the U.S. Upon inspection of the package, the following violations were found:

• The package was addressed to a PNNL researcher who was not the permit holder.
• The package was addressed to the final destination, rather than a PPQ Plant Inspection Station as required. The package should have been sent to the port designated on the permit.
• Payment for further transit was not contained as required. A prepaid domestic shipping label to get the shipment from the site of inspection to the final destination should have been included.

While PNNL staff provided the USDA shipping protocol information to the collaborator, it was not followed by the collaborator. As the USDA permit holder, PNNL holds responsibility for communicating and assuring regulated materials are properly shipped. In reviewing the USDA shipping protocol, it was recognized that the information was not completely clear. PNNL staff worked to clear up the protocol confusion, then added the requirement to send PNNL a photo of the ready to ship package to provide verification that the proper shipping labels have been applied.

Lessons Learned

-Regulated USDA material originating in foreign countries should first
be sent to a PPQ Plant Inspection Station, then shipped to an appropriate USDA permit holder using a prepaid domestic shipping label.

-You must contact the USDA SME (subject matter expert) or your ECR (Environmental Compliance Representatives) for help with USDA shipping regulations.

-Depending on the location of origin (foreign or domestic sites), soils, certain plants, plant pests, and microbes can be regulated by the

-International packages sent to the U.S. must be accompanied by a USDA APHIS (Animal and Plant Health Inspection Service) permit,
a Red & White shipping label, a shipping manifest and two air waybills (one international, one domestic).

-A detailed procedure has been developed to assure that international collaborators ship USDA regulated material properly to

This Lesson Learned is courtesy of OPEXShare, the U.S. Department of Energy, and originates from the Pacific Northwest National Laboratory (PNNL).

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Accidents, Investigations, Process Safety
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