FACTORS INCLUDED IN IMPORT RISK ANALYSIS

7.6 FACTORS INCLUDED IN IMPORT RISK ANALYSIS

7.6.1 Assessing Pest Status

Import risk analysis should include evaluation of the potential pest status of a species or a variant of a species (breed, cross-breed, strain, line, variety etc.), whether the variant was derived by natural selection, human-assisted natural breeding, or the use of biotechnology to produce a 'genetically modified organism' (GMO). Submissions to the Review raised concerns about the low priority given to such evaluation in import risk analysis and argued that greater attention was needed to ensure that new species or variants imported into Australia were not likely to become environmental pests. Examples included Bengal cats, Dorper sheep and herbicide-resistant plants. The Review Committee believes that evaluation of potential pest status should be an integral component of import risk analysis of import access requests for species or variants that are exotic to Australia.

7.6.1.1 Pest animal status

Several submissions to the Review argued that import risk analysis must include an evaluation of the potential pest status of new species or variants of animals. In part, this argument rests on the premise that even animals imported into some sort of confinement should be regarded as eventually likely to 'escape', with potential negative consequences for the natural environment. For example, the submission from the National Biodiversity Council argued that 'the presence of exotic species in Australia, in either a quarantine situation or in an artificial habitat, should be regarded as inevitable introductions into habitats which have natural values (i.e. biodiversity values). In other words, escapes from confinement (like gardens, aquaria, cages or fenced-off areas) are inevitable in either the short- or long-term'.

The Review Committee notes that there are models for evaluating the potential pest status of vertebrates (e.g. Bomford 1991) and that quarantine authorities are obliged to refer relevant import proposals to the Environmental Protection Authority for assessment under the Environment Protection (Impact of Proposals) Act 1974. In addition, potential importers should be alerted to the need to consider whether or not an additional permit is required from the Australian Nature Conservation Agency of the of the Department of the Environment, Sport and Territories. In its submission to the Review, the Department of the Environment, Sport and Territories argued that applications for quarantine import permits for animals (and plants) should include a standard paragraph to inform intending importers that they should check with that Department to determine whether an additional permit is required from the Australian Nature Conservation Agency. The Review Committee agrees that quarantine import applications should be amended accordingly.

7.6.1.2 Weediness

Many submissions to the Review expressed concern at the number of introduced plants that have become weeds in Australia. The report that the Review Committee commissioned on weeds demonstrated that such concerns were well founded, with its conclusion that at least 290 plants have become naturalised in Australia during the past 25 years and that the rate of naturalisations is increasing (see Appendix B). The Review Committee noted that the potential environmental impact of imported plants was also of increasing concern in other countries, including New Zealand and the United States.

Several submissions to the Review supported a model for assessing weediness that was commissioned by the Australian Weeds Committee (Pheloung 1995). Submissions from a range of government and environmental groups supported the Pheloung model for determining the weediness of new plant introductions, including the use of a 'permitted' list as the basis for approvals, rather than the use of a 'prohibited list' as practised by AQIS (see Section 8.4.3).
The Review Committee believes that although it will need further development and fine-tuning, the Pheloung model provides a very sound framework — based on risk analysis principles — for determining the weediness of new plant introductions. The Review Committee applauds the action by AQIS in circulating it for public comment in September 1996 in preparation for its ultimate adoption for assessing weediness of proposed new plant introductions.
Recommendation 45: The Review Committee recommends that import risk analysis used by Quarantine Australia include increased consideration of the potential environmental effects of proposed introductions of new species, breeds or varieties of animals and plants or their germplasm, including their propensity to become weeds, vertebrate pests or invertebrate pests in Australia.

7.6.2 Genetically Modified Organisms

A few submissions to the Review commented on the need to ensure that the process of import risk analysis was suitable for considering requests for import of GMOs. The Review Committee believes that the import risk analysis process advocated in this Report is appropriate for and readily applicable to all imports of exotic species or variants of species (breed, cross-breed, strain, line, variety etc.). It considers that this is true whether the variant was derived by natural selection, human-assisted natural breeding, or the use of biotechnology to produce a GMO.

On its import permit applications, AQIS specifically asks if microorganisms are GMOs. As more animal and plant GMOs are developed and they or their products are traded internationally, Quarantine Australia should include this question on all import applications. Identification of animals and plants as GMOs, and of their products as derivatives of GMOs, will enable Quarantine Australia to ensure that this information is considered in its import risk analysis.
Australia is engaged in consultations on the development of a possible protocol on biological safety of GMOs under the Convention on Biological Diversity (see Appendix C for discussion on this Convention). The protocol is likely to consider the international movement of GMOs, including unintentional movement across national boundaries and their possible adverse effects (e.g. on agriculture or the natural environment). It is likely to include provision for an 'advance informed agreement' on the biological safety of GMOs. This agreement would oblige countries that produce or export a GMO to provide relevant information to enable potential importing countries to conduct an import risk analysis on the GMO, including consideration of possible effects on biodiversity. The agreement might also oblige countries that produce or export a GMO to undertake the import risk analysis on behalf of developing countries that request such assistance. The Review Committee supports these developments and believes that Quarantine Australia should work closely with other authorities such as the Genetic Manipulation Advisory Committee to ensure that importing countries are provided with the necessary information or assistance for any GMOs produced in Australia.

7.6.3 Biological Control Agents

Several submissions to the Review raised the issue of the protracted process required for importing agents for evaluation of their potential use in biological control. The submissions agreed that a very thorough consultative process was required for consideration of approval to release such agents into the natural environment. However, they argued that a more streamlined process was both appropriate and feasible for evaluating requests to import such agents into secure premises for testing their potential as biological control agents.

The crux of the argument for a more efficient process for importing potential biological control agents is that the keeping of such imports and the decision process for their import are, as stated in CSIRO's submission to the Review, 'very closely regulated and a frequent source of frustration and delay'. The protracted process and long delays are seen as an unnecessary and expensive disincentive to researchers wishing to import organisms for evaluation as possible biological control agents. This is particularly so given that most organisms evaluated can be quickly eliminated as potential biological control agents (e.g. because studies in appropriately secure facilities prove they are pests or pathogens of indigenous Australian species and not just the target pest species for which control is desired). The Review Committee believes that there is scope for streamlining the process used for approving imports of agents for testing for their potential as biological control agents. For example, testing of agents could be restricted to appropriately secure facilities (under supervision and audit of Quarantine Australia) and applications could be screened by a scientific panel with representatives from government, agricultural groups and environmental groups. A core panel with such representation might be supplemented with additional scientific members with expertise in the particular taxonomic groups of the putative biological control agent or target pest (although neither the core nor supplementary group should include members working for the applicant or proponent of any particular proposed import). The scientific panel should use and apply the principles of risk analysis in its consideration of applications for importing agents for evaluation of their potential as biological control agents.
The Review Committee believes that Quarantine Australia should develop a proposal along these lines for a more efficient approach to importing agents for evaluation of their potential as biological control agents, and submit this for the endorsement of the Standing Committee on Agriculture and Resource Management. In addition, it notes that in its submission to the Review, the Department of the Environment, Sport and Territories recommended that the Australian Nature Conservation Agency and AQIS jointly develop and institute a single permit that would cover all relevant legislation overseen by both parties. This could be included in Quarantine Australia's review of procedures.
The Review Committee wishes to emphasise that it seeks streamlined procedures for importing agents for evaluation of their potential as biological control agents — and not for the subsequent process for approval to release such agents after testing in Australia. A more comprehensive consultative process similar to existing procedures should continue for approval to release biological control agents.
Recommendation 46: The Review Committee recommends that Quarantine Australia develop a proposal for a streamlined process for considering imports of agents into secure premises for evaluation of their potential as biological control agents, and submit this for the consideration of the Standing Committee on Agriculture and Resource Management.

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