W-2.2
Risk Analysis, Vol. 36, No. 5, 2016 DOI: 10.1111/risa.12477
A Regional Decision Support Scheme for Pest Risk Analysis
in Southeast Asia
T. Soliman,1,∗ A. MacLeod,2 J. D. Mumford,3 T. P. L. Nghiem,1 H. T. W. Tan,1
S. K. Papworth,1 R. T. Corlett,4 and L. R. Carrasco1
A key justification to support plant health regulations is the ability of quarantine services to
conduct pest risk analyses (PRA). Despite the supranational nature of biological invasions
and the close proximity and connectivity of Southeast Asian countries, PRAs are conducted
at the national level. Furthermore, some countries have limited experience in the develop-
ment of PRAs, which may result in inadequate phytosanitary responses that put their plant
resources at risk to pests vectored via international trade. We review existing decision support
schemes for PRAs and, following international standards for phytosanitary measures, pro-
pose new methods that adapt existing practices to suit the unique characteristics of Southeast
Asia. Using a formal written expert elicitation survey, a panel of regional scientific experts
was asked to identify and rate unique traits of Southeast Asia with respect to PRA. Subse-
quently, an expert elicitation workshop with plant protection officials was conducted to verify
the potential applicability of the developed methods. Rich biodiversity, shortage of trained
personnel, social vulnerability, tropical climate, agriculture-dependent economies, high rates
of land-use change, and difficulties in implementing risk management options were identi-
fied as challenging Southeast Asian traits. The developed methods emphasize local South-
east Asian conditions and could help support authorities responsible for carrying out PRAs
within the region. These methods could also facilitate the creation of other PRA schemes in
low- and middle-income tropical countries.
KEY WORDS: Biosecurity protocol; expert elicitation; expert evaluation; invasive alien species
1. INTRODUCTION
The introduction and spread of invasive species
is a major worldwide concern that has been regulated
by international agreements since 1878.(1) According
1Department of Biological Sciences, National University of Singa-
pore, Singapore, Republic of Singapore.
2Ofice of the UK Chief Plant Health Officer, Defra, Sand Hutton,
York, UK.
3Centre for Environmental Policy, Imperial College London,
London, UK.
4Xishuangbanna Tropical Botanical Garden, Chinese Academy of
Sciences, Menglun, Mengla, Yunnan, China.
∗Address correspondence to T. Soliman, Department of Biologi-
cal Sciences, National University of Singapore, 14 Science Drive
4, Singapore, 117543, Republic of Singapore; tariq.soliman@
cipdpro.co.uk.
to the World Trade Organization, countries can
use plant health regulations to restrict trade only
if justified by a science-based pest risk analysis
(PRA). FAO(2) defines a PRA as ‘‘the process of
evaluating biological or other scientific and economic
evidence to determine whether an organism is a
pest, whether it should be regulated, and the strength
of any phytosanitary measures to be taken against
it.’’ The International Standards for Phytosanitary
Measures (ISPMs) are the official reference for
PRA.(3) Complying with these international stan-
dards is obligatory for developing an internationally
acceptable PRA.
As the PRA concepts described by the
ISPMs are generic in nature, countries and
904 0272-4332/16/0100-0904$22.00/1 C© 2016 Society for Risk Analysis
Pest Risk Analysis in Southeast Asia 905
intergovernmental bodies have developed decision
support schemes (DSSs) to improve their applicabil-
ity. Although these DSSs differ in sophistication and
details, they all follow the ISPMs of the International
Plant Protection Convention (IPPC). For instance,
the European and Mediterranean Plant Protection
Organization (EPPO) DSS for PRA(4) is one of the
most detailed schemes for species-initiated PRAs.
The scheme has two complementary annexes on
habitat categories and environmental impacts. It is
available on paper and as a digital version that incor-
porates advanced techniques to analyze pest risks.
On the other hand, the Canadian scheme(5) uses a
much simpler pathway-specific approach based on a
matrix that combines dependent risk elements. Other
pathway-specific schemes are those of Australia,(6)
New Zealand,(7) and the USA.(8,9) The Australian
and New Zealand schemes have sections that com-
bine plant and animal risk analysis in a common
scheme. The Australian scheme uses risk matrices
to determine the joint probability of entry, estab-
lishment, and spread through a sequence combining
the risk elements. In contrast, the American scheme
adds individual independent probability scores to
drive the probability of introduction (i.e., entry,
establishment, and spread). In both schemes, the
overall risk score is then calculated by a risk matrix
rule that integrates the score for impact magnitude
and the score for probability of pest introduction.
PRAs in Southeast (SE) Asian countries vary
in the characteristics of their regulatory systems,
capacity, and enforcement. Some countries, such as
Laos, have a limited implementation of PRA, while
others, such as Malaysia, Indonesia, and the Philip-
pines, have higher levels of implementation. For
instance, according to the IPPC, in 2009–2010 the
numbers of PRAs completed and documented in
Indonesia, the Philippines, Thailand, and Vietnam
were 57, 17, 12, and 42, respectively. In contrast,
other countries, such as Cambodia, Laos, and Myan-
mar, did not report any PRAs in 2009.(10) Insufficient
capacity building, and a shortage of qualified staff
and financial resources, present major challenges
for SE Asian national plant protection organizations
when producing international standard PRAs.(10)
Inadequate PRAs place SE Asian countries at a dis-
advantage in trade negotiations with other countries
and put their domestic resources at risk.
In the last decade, several studies have reviewed
and enhanced the practice of PRA, but these studies
have been limited to high-income countries.(11–14)
Most suggest incorporating computerized
quantitative techniques, where appropriate, to
improve the consistency and reduce the uncer-
tainty of risk estimation.(12,15–17) These quantitative
techniques are highly demanding in terms of data,
interpretive skills, time, and effort even in high-
income countries. At the same time, rudimentary
qualitative analyses can be challenged by trading
partners.(2) Practical PRA schemes that are scien-
tifically rigorous, consistent with the ISPMs, and
relevant for routine use are needed, especially in
low- and middle-income countries. Such schemes
could also be used in higher income countries where
demand for faster delivery of PRA is increasing. This
is consistent with the comment in ISPM 2 stating
“a PRA does not necessarily need to be long and
complex. A short and concise PRA may be sufficient
provided justifiable conclusions can be reached after
completing only a limited number of steps in the PRA
process.”(2) In SE Asia it is especially important
to have an efficient and effective PRA process as
countries must work with a limited PRA budget.(18)
Invasive pests pose risks that often extend
beyond national boundaries.(19) For instance, the
golden apple snail (Pomacea canaliculata) that was
initially introduced into cement tanks, managed
ponds, and backyard soil pits in the Philippines
later spread to Indonesia, Malaysia, Thailand, and
Vietnam.(20,21) It spread rapidly through irrigation
ditches and public waterways to the rest of the
region. Other examples of exotic pests that have
spread widely in SE Asia are the fruit fly Bactrocera
cucurbitae, the lepidoptera Helicoverpa armigera
and Plutella xylostella, and the psyllid Heteropsylla
cubana.(22) PRAs in SE Asia are conducted at the
national level,(18) which has advantages, such as
the ability to reach a rapid consensus without the
delays that would result from intergovernmental
negotiation on common plant health policies and
related regulatory activities at the regional level.
However, given the supranational nature of inva-
sive pest spread, the proximity and connectivity
of SE Asian countries, and the heterogeneity in
the resources available for PRAs, a regional-scale
PRA scheme could generate more effective and
efficient preventive and control strategies(23) to
better support national plant health responsibilities.
SE Asia has a unique economic, ecological, and
social nature, and a regional DSS should account for
these special traits. However, it is unclear what these
traits are and how a newly developed regional DSS
should differ from existing schemes in high-income
settings. Furthermore, the low number of recent
906 Soliman et al.
international journal articles on the determinants of
pest invasion success in SE Asia and the scarcity of
research on PRA in the region reveals the need for
eliciting knowledge from experts who specialize in
biological invasion research in SE Asia.(19) The final
adoption of any regional PRA scheme would be the
responsibility of the many national authorities and
their regional plant protection organizations.
Here we develop an independent proposal for a
regional PRA scheme by adopting parts of existing
DSSs and adapting them to the unique traits of SE
Asia. Two expert panels were consulted to (i) iden-
tify the characteristics of SE Asia that should be ac-
counted for in a regional PRA, and (ii) demonstrate
the operation of the proposed PRA.
2. MATERIALS AND METHODS
2.1. Expert Elicitation
2.1.1. Regional Scientific Panel
A panel of regional experts was asked in a
formal written expert elicitation survey to identify
and rate unique traits of the SE Asian region.
Potential experts were individuals with expertise
in biological invasions and an understanding of SE
Asia as a receptor environment for invasive species.
Accordingly, the following roles were identified:
(1) academics with knowledge of PRA in SE Asia,
(2) public-sector employees acquainted with PRA
(e.g., pest risk analysts working in national plant
protection organizations), and (3) private-sector em-
ployees acquainted with PRA (e.g., ecologists in con-
sultancies and nonprofit organizations). The “Pest-
Net,” “aliens-l,” and “PHRA-L” email distribution
lists were used to elicit experts, as was direct contact
with biological invasion experts at the National Uni-
versity of Singapore (Singapore), Instituto Hórus
de Desenvolvimento e Conservação Ambiental
(Brazil), Xishuangbanna Tropical Botanical Garden
(China), University of Potsdam (Germany), and the
plant protection services of Australia, New Zealand,
the United Kingdom, and Singapore. Out of
15 experts directly contacted and the members of the
distribution lists, eight experts participated in this
expert elicitation survey. These experts were asked
to identify and rate the unique traits of the SE Asian
region in a formal written expert elicitation survey.
The questionnaire starts with a general introduction
and motivation, followed by a list of suggested traits
that the experts are requested to rank quantitatively.
Table I. The Importance of Traits Relevant to PRA in the SE
Asian Region
Traits That Make SE Asia
Different from High-Income
Regions with Regard to Pest
Risk Analysis (PRA) Weight (%) SD
Agriculture-dependent economies 54 27
Rich biodiversity 68 35
Shortage of trained personnel 68 22
Social vulnerability 41 22
High rates of land-use change
(particularly deforestation) and
ecosystem degradation (logging,
fire, and hunting)
51 36
Tropical climate 59 36
Difficulties in implementing risk
management options
24 30
SD: Standard deviation.
To enable evaluations of the proposed traits, a
detailed description of each trait was provided in an
annex attached to the questionnaire. Experts were
asked to give a weight between 0 (lowest importance)
and 100 (highest importance) for each trait.
The traits were: agriculture-dependent econo-
mies, shortage of trained personnel, rich biodi-
versity, social vulnerability, high rates of land-use
change and ecosystem degradation, tropical climate,
and difficulties in implementing risk management
options. These traits are represented in the proposed
scheme by adopting and adapting parts of other
PRA schemes. Traits with greater weight were
represented in more detail in the proposed scheme.
After collecting quantitative responses, experts’
opinions were combined using equal weights to cal-
culate the mean and standard deviation for each trait
(Table I). The description and weighted importance
given to the traits were as follows:
(1) Agriculture-dependent economies (weighted
importance 54%). Agriculture is an impor-
tant source of income and foreign currency,
providing a large proportion of employment
capacity in SE Asia. Furthermore, most SE
Asian farmers are classified as subsistence
rather than large-scale farmers. The proposed
scheme should reflect food security vulnerabil-
ities if key crops are attacked by invasive plant
pests.
(2) Shortage of trained personnel (weighted im-
portance 68%). Many SE Asian countries
face serious resource constraints for managing
Pest Risk Analysis in Southeast Asia 907
plant health. Despite funding programs and
support by international organizations, further
capacity building is still needed to produce
qualified plant quarantine officers.(18,24) The
scheme cannot demand highly skilled person-
nel given the low to middle incomes of SE
Asian countries.
(3) Rich biodiversity (weighted importance 68%).
The high biodiversity and endemism of SE
Asia is well recognized.(25) The scheme should
enhance biodiversity protection, since SE Asia
contains several global biodiversity hotspots.
Although there are few records of species ex-
tinction in SE Asia, the increase in species clas-
sified as endangered and susceptible should be
recognized within a PRA system and, where
appropriate, risk mitigation should apply
regionally.
(4) Social vulnerability (weighted importance
41%). In PRA, social vulnerability can be
interpreted as social choices that increase the
vulnerability of the receptor environment to
pest invasion.(26) Social vulnerability includes
cultivation practices by farmers, institutional
interventions, and market practices that could
increase regional vulnerability to invasive
plant pests and diseases.
(5) Land-use change (weighted importance 51%).
Compared to high-income regions, SE Asia
is characterized by higher rates of land-
use change (particularly deforestation) and
ecosystem degradation (e.g., logging, fire, and
hunting). Both deforestation and ecosystem
degradation play a key role in facilitating es-
tablishment and spread of invasions.
(6) Tropical climate (weighted importance 59%).
Compared to temperate regions, tropical cli-
mates can support the survival of invasive
plant pests from very diverse sources and
clades, often throughout the year. Therefore,
the scheme should provide a detailed analy-
sis for potential pest establishment. Risks are
highest for pests from other tropical areas that
are linked to SE Asia by direct transportation
routes.
(7) Difficulties in implementing risk management
options (weighted importance 24%). Struc-
tural obstacles and lack of operational ca-
pability for enforcement relevant to invasive
plant pest introductions may limit the response
to PRAs and their recommended risk reduc-
tion options. The scheme should account for
temporary management options to support the
PRA until permanent measures are success-
fully applied.
2.1.2. Panel of Regional Plant Protection Officials
To validate the traits suggested by the scientific
experts and verify the proposed DSS applicable for
routine PRA use in SE Asia, plant health officers
in the region were consulted through an expert
elicitation workshop. The workshop was held in
Bangkok, Thailand, from 29th July to 2nd August
2013 in conjunction with the project “Beyond Com-
pliance: Integrated Systems Approach for Pest Risks
Management in Southeast Asia” (STDF/PG/328).(27)
Officers from the plant health ministries of Malaysia,
Thailand, Vietnam, and the Philippines, experts from
Imperial College London, Queensland University of
Technology, and the Centre for Agriculture and Bio-
sciences International (CABI), and representatives
from the FAO–IPPC, and the FAO–Asia, and the
Pacific Plant Protection Commission (APPPC) at-
tended the meeting. In total, 20 experts participated
in this expert elicitation workshop. The consulta-
tion started with an introduction to the draft PRA
scheme. It continued with an explanation of how the
scheme was adapted to meet the identified criteria
for SE Asia. Finally, the consultation ended with a
group discussion. Expert opinions were combined
using the behavioral aggregation approach where
experts themselves aggregate judgments on the
validity of the suggested scheme.(28) This is achieved
when the group, following discussion, comes to
an agreement about a particular judgment value.
To avoid group domination by the most confident
and outspoken experts, we encouraged knowledge
sharing, corrected potential biases, and used feed-
back to aid the debate. For instance, we used direct
questions to prompt less confident experts to express
their opinions and expressed contrary opinions to
the suggested points to enrich the discussion.
2.2. Visual Representation of Pest Risk
and Uncertainty
In some PRA schemes, questions to evaluate and
manage pest risk are rated on a qualitative scale
where available rating scores are expressed in de-
scriptive and numerical terms.(5,8) In our approach,
each section of the DSS is rated by the risk analyst
through a two-step process: first, by choosing one or
more ratings, and secondly, assigning an uncertainty
908 Soliman et al.
Magnitude of
impacts
Probability of
introduction
Negligible
Low
Medium
High
LowNegligible Medium High
Pest A
Pest B
Pest C
Pest E
Pest D
Uncertainly level:
Negligible
Low
Medium
High
Fig. 1. An illustrative example for the visualizer graph of overall risk of four different pest cases. The visualizer helps prioritize and compare
pests while supporting further discussion between policymakers. The black dot represents the risk score (probability of introduction and
magnitude of impacts) and the bubble around the black dot represents the level of uncertainty. The size of the bubble does not represent
the range of the level of risk and is intended only to visually reflect the uncertainty of the analysts in their rating. In the example, pest D
presents high probability of introduction, high potential impacts, and negligible uncertainty in the assessment and would thus be prioritized
for risk management. Pest B presents the opposite case with negligible overall risk and low uncertainty, probably not requiring prioritization
for management measures. Pests A, C, and E would need further discussion by policymakers. For instance, although pest A presents high
potential impacts, the probability of introduction is negligible and the opposite situation occurs for E. Pest C presents medium probability
of introduction and potential impacts but there is high uncertainty associated to these estimates.
level to each score. The rating reflects the chosen
level for the risk factor, while the uncertainty rat-
ing reflects the degree of confidence in the rating.
The ratings for the risk elements (e.g., probability
of entry, establishment, spread, and economic im-
pacts) and uncertainty consist of four categories (i.e.,
negligible, low, medium, and high). The overall risk
score for the likelihood of introduction and magni-
tude of impact is calculated as the median of the val-
ues for risk and uncertainty ratings separately (see
Supplementary Online Material (SOM), “Guidelines
for Expressing Overall Risk”).
The risk outcome is represented through a visu-
alizer graph that shows both the risk score for the
likelihood of introduction and magnitude of impact,
plotted by a black dot, and the associated uncertainty
plotted by bubbles around the black dot of size pro-
portional to the uncertainty level (Fig. 1). Given that
the uncertainty scores are qualitative, the uncertainty
bubbles do not represent the range of the levels of
risk. The x-axis on the visualizer graph represents the
likelihood of introduction and the y-axis represents
the magnitude of impacts.
3. RESULTS
3.1. SE Asian PRA Scheme Development
The proposed scheme is composed of seven
main sections in line with the ISPM 11 guidelines.(29)
(1) PRA initiation; risk assessment in terms of (2)
probability of entry, (3) probability of establishment,
Pest Risk Analysis in Southeast Asia 909
Risk
Initiation Entry Spread Establishment Impacts
Risk
Management
Risk Assessment
CFIA EPPO
USDA-
APHIS
Australian
New
Zealand
Shortage of
trained
personnel
Tropical
climates
Land use
change
Social
vulnerability
Rich
biodiversity
Agriculturally-
dependent
economies
Difficulties in
implementing risk
management
options
Traits
PRA
Schemes
Fig. 2. Structure of the developed Southeast Asian scheme and the components of existing schemes that were used to develop the scheme.
The graph is divided into: “traits” that describe the unique characteristics of SE Asia to be accounted for in the scheme; “PRA”: the
different sections of the PRA process; and “Schemes”: existing schemes and how their sections are mapped into the SE Asian scheme.
CFIA: Canadian Food Inspection Agency.
(4) probability of spread, (5) magnitude of potential
economic impacts, and (6) magnitude of potential
environmental impacts; and (7) risk management
(see the SOM). Within each section, there are several
main and subelements for assessors to consider. For
instance, the section “Magnitude of potential eco-
nomic impacts” is divided into two main subsections,
“Direct impacts” and “Indirect impacts.” Within the
subsection “Direct impacts,” there are two elements
to consider: “Crop losses, in yield and quality” and
“Significant increases in costs of production beyond
normal annual fluctuations due to, for instance,
additional control measures and/or costs associated
with surveillance and monitoring (e.g., extra labor
cost).” Additional examples on the sections con-
cerning probability of entry, establishment, spread,
and magnitude of impacts are provided in Table II.
Moreover, we ensured that all the terms used in the
scheme are in line with the glossary of phytosanitary
terms detailed in ISPM 5 and provided detailed
and clear guidelines to explain the steps the analyst
should follow to estimate the final risk outcome.(30)
Shortage of trained personnel was suggested
as the most limiting factor by regional experts, so
we chose the most straightforward existing DSS as
the foundation for the SE Asian DSS, based on a
review of characteristics of existing PRA schemes
(Fig. 2; Table III). We started with the short scheme
previously adapted within a project exploring alter-
native PRA protocols(12) as a base from which to
develop the SE Asian scheme. We complemented
this with other schemes that could represent the
traits important for SE Asia. The EPPO scheme(4)
can capture multiple aspects of potential impacts
for both structural biodiversity and ecosystem
services functionality at the species, community,
and landscape level. As this was the second most
important distinctive trait of SE Asia, the EPPO
scheme was used as the basis for environmental
impacts and risk management. The EPPO scheme
also provides detailed evaluation of all existing
and potential risk management measures for both
exporting and importing countries. The Australian
and New Zealand schemes consider both the scope
(i.e., direct and indirect) and the geographical scale
(i.e., local, district, regional, and national) of impacts,
so they were heavily relied upon to estimate eco-
nomic, environmental, and social impacts. The U.S.
Department of Agriculture Animal and Plant Health
Inspection Service (USDA-APHIS) scheme shows
the factors to consider when assessing potential
entry and establishment of species and procedures
for conducting risk assessments (e.g., data needed
and order of analysis), so was used to represent po-
tential pest entry and establishment, and to provide
supplementary information on risk management.
Several modifications were applied to the
combined scheme to represent SE Asian traits
910 Soliman et al.
Table II. Examples of Some Changes Applied to the Developed Regional Southeast Asian Scheme (the Full Scheme is Available
at the SOM)
Probability of entry
2.3. Survival during transport or storage
Examples of factors to consider are:
a) Speed and conditions of transport and duration of the life cycle of the pest in relation to time in transport and storage
Probability of establishment
2.6. Availability of suitable hosts, alternate hosts, and vectors in the PRA area
Examples of factors to consider are:
a) Whether hosts and alternate hosts are present, how abundant or widely distributed they may be
Probability of spread
2.12. Potential for natural spread
Examples of factors to consider are:
f) The existence of natural barriers to spread of the pest in the PRA area; include variables such as vectors or natural enemies that may
affect the pest’s ability to spread in the PRA area; in SE Asia, distances between islands and modes of transport between them will be
crucial
Magnitude of potential economic impacts
2.18. Indirect economic impacts
For identification and characterization of the indirect effects of the pest in the PRA area or those effects that are not hostspecific, the
following are examples that could be considered:
a) International trade effects, including loss of markets (e.g., export loss), meeting new technical requirements to enter or maintain
markets, and changes in international consumer demand
e) Effect on foreign exchange earnings and poverty rates, if the host crop contributes significantly to the exports
Magnitude of potential environmental and social impacts
2.22. Indirect environmental and social impacts
For identification and characterization of the indirect effects of the pest in the PRA area or those effects that are not hostspecific, the
following are examples that could be considered:
a) Environmental and other undesired effects of control measures (e.g., pesticides); herbicide and insecticide resistance may be developed
in SE Asia owing to use of generics with active ingredients not under patent
d) Significant change in ecological processes (e.g., natural successions; trophic and mutualistic interactions such as the food web,
pollination, or plant-mycorrhizal webs) and the structure, stability, or processes of an ecosystem including further effects on plant species,
erosion, water table changes, increased fire hazard, and nutrient cycling
Table III. Evaluating the Characteristics of Different Pest Risk Analysis (PRA) Schemes
EPPO Canada USA Australia New Zealand
Dominating approach Species/pathway-
based PRA
Pathway-based
PRA
Pathway-based
PRA
Pathway-based
PRA
Pathway-based
PRA
Rating system Descriptive /
numerical
Descriptive /
numerical
Descriptive /
numerical
Descriptive /
numerical
Descriptive /
numerical
Analyzing uncertainty
quantitatively
Yes No No No No
Guidance notes /examples Very detailed Detailed Detailed Detailed Detailed
Complexity High Low Medium Medium Medium
and improve the guidance notes (SOM, Appendix
III). As SE Asian countries are largely agriculture-
dependent economies, we added export loss,
employment loss, reduction in market value of the
affected host, effects on closely related industries,
income reduction, foreign exchange earnings, and
increased poverty rates (SOM, 2.19, points a, b, c,
d, e, and f). Moreover, to represent social vulnera-
bility, we added to the same section the economic
values or market structures that may inflate impacts
(SOM, 2.19, point g). To accommodate the “rich
biodiversity” trait, we extended elements in the
“environmental impact” section, such as reduction
of keystone plant species, reduction of plant species
that are major components of ecosystems (in terms
of abundance or size), reductions of endangered
native plant species, and significant reductions of
plant species of high conservation value (SOM, 2.21,
Pest Risk Analysis in Southeast Asia 911
points a, b, c, and d). Indirect environmental impacts,
such as changes in ecological processes and effects on
plant communities, were also extended (SOM, 2.22,
points b, d, e, f, and g). The “social vulnerability”
and “land-use change” traits were included in the
“cultural practices” element of the “pest establish-
ment” section (SOM, 2.9). The “land-use change”
trait was also included in the “other factors” element
of the “probability of spread” section (SOM, 2.14).
These traits were illustrated by cultivation practices
of farmers and other human activities that promote
establishment and spread. “Tropical climate” was
included in point 2.8 “suitability of environment”
of the “probability of establishment” and in the
introductory phrase of the “probability of entry”
section. In the “risk management” section, the
analyst is requested to suggest a temporary action
that may be used if there is difficulty implementing
longer-term risk management options. This addition
is meant to cover the last identified …
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