Australian Quarantine Review Secretariat Australian Quarantine a shared responsibility
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- Quarantine Security and Transhipment
- 8.10.2 Containers
- Timber and Timber Products
- Dunnage and Packing
- Air Cargo
- Imported Second-hand Farm Machinery
- Sanctions for Non-compliance
8.10 QUARANTINE CLEARANCE OF CARGOThe primary method for screening all imported cargo electronically is through links to ACS electronic information systems. Determination of the profiles used in the screening systems is based on risk analysis principles (see Section 8.5.2.1 on information systems). Cargo clearance involves screening the import to determine risk, clearance of documents (e.g. fumigation certificates), inspection of product (e.g. fresh fruits and vegetables), and treatment if any problems are encountered. Quarantine Security and TranshipmentDuring the public hearings and inspections of quarantine operations, an issue of security of quarantinable items during transportation from the point of arrival (bond) to the designated inspection area was raised with the Review Committee. It was claimed that there have been instances where goods subject to quarantine have been substituted or otherwise interfered with during transport to the final inspection point. From time to time, sticker-type seals have been applied to goods subject to quarantine inspection but these are easily removed and re-applied and do not represent a genuinely secure system. However, there does not appear to be any foolproof system yet devised to overcome this potential security risk. Another security issue brought to the Review Committee’s attention during the public hearings was the alleged lack of procedures for surveillance of produce being transhipped through Australia. For example, the Review Committee was informed that produce was being exported by air from New Zealand to overseas destinations via Australia and was often left without quarantine supervision in cargo sheds, bond stores or on tarmac areas. In other cases, products are further processed under bond in Australia before shipment to their intended destination. The Review Committee understands that quarantine staff are often not informed of the presence of these goods, as they rely on ACS for advice. Because this produce is not destined for Australia, the ACS computer does not flag these items for quarantine inspection. In some cases, the bond stores are located away from airports but the goods are neither subject to quarantine surveillance nor notification from ACS. The Review Committee is concerned with the situation and considers that these gaps in quarantine surveillance must be closed. It encourages Quarantine Australia to examine these shortcomings with a view to developing satisfactory security arrangements for uninspected goods subject to quarantine clearance and produce being transhipped through Australian ports. Recommendation 72: The Review Committee recommends that quarantine security for goods stored or transported under bond be tightened to ensure that the quarantine risks to Australia associated with these goods are appropriately addressed. 8.10.2 ContainersA number of submissions to the Review raised the issue of the dangers posed to quarantine security by the movement of containers between metropolitan areas, before they undergo quarantine clearance. The system, known as landbridging, involves transporting containers from the port of entry to another metropolitan destination. This system is being increasingly used by industry, due to the cost-effectiveness of the process. Under this system, containers can be moved from the port area and transported to a different metropolitan area with the correct commercial documentation but not necessarily with the prior knowledge or approval of AQIS. Very often, this process involves long-distance transport between States through rural areas. From a quarantine perspective, landbridging is an unsatisfactory situation and certainly presents a significant risk — with the possibility of uninspected containers with insect infestations or adhering soil transiting rural areas. Containers originating in countries infected with giant African snail are all inspected on arrival in Australia. In the case of containers going direct to country destinations, AQIS aims to minimise the risk of a chance pest or disease incursion by conducting tailgate inspections of all containers destined for rural delivery. A tailgate inspection involves opening the doors of the container allowing a quarantine officer to conduct a cursory examination of its interior to ensure that there is nothing obvious that might be of quarantine concern (e.g. live insects, infested products, untreated dunnage or packing materials). The external surfaces of containers are also inspected. These inspections are usually undertaken while the containers are on the back of the transporting vehicle. The Review Committee recognises that this inspection procedure represents a compromise between quarantine security and commercial movement of cargo. Container handling has been the subject of a recent internal report (AQIS 1996) that acknowledges the need to work with industry to facilitate speedy cargo clearance. However, the report also highlights the significant risks that this process presents, and proposes measures to reduce or eliminate the problem. The report puts forward a number of options, of which the preferred option — which is also supported by industry — is to maintain current procedures for inspecting containers destined for rural delivery (as well as those coming from giant African snail ports), with the added requirement of lifting rural-bound containers onto container stands, or inspecting the containers on skeletal bed trailers. The report also recommends the introduction of procedures to inspect and to carry out surveillance on all landbridged containers before departure. The Review Committee supports this approach and urges its early implementation. Recommendation 73: The Review Committee recommends that as a minimum, all containers should be subject to thorough external inspection at their port of entry. Timber and Timber ProductsProcedures for inspection of timber and timber products came in for considerable criticism from industry in submissions to the Review Committee and in the follow-up public hearings. Apparent variations in inspection procedures from port to port and delays in clearance of consignments attracted the main criticism. During the Review, a number of importers expressed concern at what they regarded as undue delays in clearance of timber at some ports. However, timber must sit for at least 24 hours before inspection to enable detection of pest infestation through signs of frass (insect excrement). The Review Committee could find no evidence of inspection not being completed within three days of arrival, as per current directives. The Review Committee believes that some imports of timber and timber products may pose a high risk due to the volume and variety of imports and the nature of the pests themselves. Pests of timber and timber products tend to be long-lived with long maturation times, and are difficult to detect during inspection on arrival. Imports of timber and timber products are varied as are the associated risks (e.g. sawn logs with bark are probably high risk, manufactured products such as chopsticks are probably low risk). However, the level of risk of the different types of timber and timber products can only be determined after risk analysis (see Section 8.3.1). Inspection arrangements for timber and timber products need to be reviewed to determine if any new technologies are available for the detection of pests and pathogens. Accreditation of overseas sources that use approved treatment methods should also be investigated (e.g. kiln-dried timber from New Zealand). Only adequately trained officers should undertake timber inspections. Several submissions to the Review expressed concern at the possible incursion of decay and stain fungi on imported timber and timber products. In addition, the commissioned report on forest pests and pathogens noted that although there were no definitive examples of the establishment of decay or stain fungi in Australia during the past 25 years, past experience in Australia and overseas has shown that fungi introduced on timber or dunnage can be very destructive. The report lists a number of such fungi that have been intercepted on arrival of timber imported into Australia and notes that imports of sawn green timber have the potential to introduce pathogenic decay fungi (e.g. those of the genera Armillaria, Echinodontium, Ganoderma, Heterobasidion and Phellinus) and stain fungi (e.g. of the genera Ceratocystis, Fusarium and Ophiostoma) that could lead to significant losses in forestry and forest products. The Review Committee noted that forestry and quarantine officials in both New Zealand and Canada shared these concerns about the risk of introduction of exotic decay and stain fungi of timber and timber products. There is an opportunity for Australia to collaborate with such countries to address this problem through applied research. Such collaboration would be consistent with the principle of keeping problems offshore and undertaking research on pests and diseases of concern, as outlined in Chapter 6 on Offshore Activities. A number of submissions supported some form of quality assurance arrangement whereby importers could arrange for self or third-party inspection and clearance of low risk timber and timber products, subject to audit. The Australian Timber Importers Federation advocated the use of ‘an accredited inspection and fumigation service that could be managed and administered by the timber industry as an in-house responsibility’. The Review Committee supports this initiative, subject to identification of low risk items provided by detailed risk analysis. Recommendation 74: The Review Committee recommends that Quarantine Australia investigate with industry the use of quality assurance arrangements, with an appropriate audit system, for clearing consignments of low risk timber and timber products. Dunnage and PackingApart from its use in the floors and structure of containers, timber is also used as packing for goods carried in containers and for dunnage. While always requiring a declaration from the shipper, changes were introduced in 1995 whereby each consignment entering Australia must be accompanied by a declaration by the importer’s agent stating whether or not it includes timber packing. Although some incidents of false declarations have been identified (with subsequent remedial action such as imposing cost penalties in the form of full inspection of all containers imported by the offending companies), the Review Committee believes more emphasis could be directed to this area. Despite these recent changes, it is still only through random inspections that breaches of these procedures are detected. Because timber used for dunnage is usually of a low grade, the risk of infection or infestation with exotic pests or pathogens would appear to be high. All timber dunnage should therefore be properly treated, fumigated or promptly destroyed. Evidence emerged during site inspections by the Review Committee that would indicate that in some cases insufficient attention is being directed to this risk area. Dunnage control in relation to imported air freight appears to have no clear guidelines or procedures in place and seems to have been given little attention to date. Although the level of dunnage imported with air freight is far less than that with sea cargo ¾ most dunnage is in the form of pallets and packaging ¾ air freight containers are often moved from air cargo bond stores to freight forwarders with little supervision. The Review Committee understands that quarantine control of dunnage at freight forwarders’ premises is not currently in place. At air cargo bond stores, quarantine officers attempt to inspect wooden packaging and dunnage through surveillance activities as part of routine patrols of these areas. With limited time available for such activities, there is often difficulty in examining all cargo to the extent required. The turn-around time for air cargo is of necessity very short, and movement can be difficult to monitor. Consequently, the Review Committee understands that much of the freight and packing leaves the bond store without inspection. The Review Committee believes that Quarantine Australia should review procedures to ensure that appropriate attention is given to dunnage and packing timbers. Recommendation 75: The Review Committee recommends that, as a matter of urgency, procedures for the identification of the presence and type of timber dunnage and packing associated with imports be uniformly implemented across all ports of entry, and that the required quarantine inspection be undertaken. Air CargoThere has been an increase in air freight generally in recent years, with dedicated cargo aircraft arriving in Australia and the regular scheduled airlines themselves increasing freight carrying capacity. Air cargo, a specialised area of the import clearance system, is based on the Air Cargo Automation system, which is accessed by AQIS for quarantine clearance. The Review Committee heard much criticism of this program from industry in both submissions and public hearings, particularly regarding a perceived lack of development of an adequate system of flagging items of quarantine interest and a perceived inconsistency of quarantine procedures between air cargo and sea cargo. This issue is discussed in more detail in Section 8.5.2.1. The Review Committee regards air cargo controls as an area that requires significant and urgent improvement. AQIS has advised the Review Committee that in the determination of new quarantine profiles it was found that the ACS manual screeners release without referral to AQIS about 80% of all screen-free cargo of quarantine concern. This situation is likely to be exacerbated as ACS moves to full electronic screening in early 1997 (see Section 8.5.2.1). Imported Second-hand Farm MachineryThe Minister for Primary Industries and Energy asked the Review Committee specifically to address the issue of imported second-hand and new field-tested agricultural machinery that might be contaminated with soil and seeds. Imports of all such machinery from countries where karnal bunt (a fungal disease of grains) occurs were suspended by the Minister in April 1996, pending a full examination of the situation. As a result, AQIS issued revised guidelines for the inspection of second-hand agricultural machinery. Subsequent Quarantine Operational Notices acknowledged differing inspection procedures in each Australian State and sought to standardise inspection procedures for used agricultural machinery. The revised instructions cover the import of machinery from countries both with and without karnal bunt. After examining the instructions and holding discussions with inspection staff, the Review Committee is satisfied that, if fully observed, the revised instructions should provide a satisfactory framework for inspection, and that with appropriate care and attention to the inspection procedures, the risks associated with the import of second-hand or new field-tested agricultural machinery will be greatly reduced. These arrangements may need to be reviewed after completion of a detailed risk analysis of border programs, as recommended in Section 8.3.1. Recommendation 76: The Review Committee recommends that tightened inspection procedures introduced to address the risk posed by imported second-hand and field-tested agricultural machinery continue until completion of risk analysis of border programs. Sanctions for Non-complianceWhile acknowledging that a number of procedures have already been developed in inspection arrangements to institute forms of sanctions for non-compliance with quarantine regulations, the Review Committee is concerned that these sanctions are mainly directed at remedying the problem once goods have arrived in Australia and are not focused on keeping the problem offshore, as espoused in this Review’s approach to the continuum of quarantine. Mention has already been made of VMS and of the sanctions for continuous re-inspection applying to offending vessels. Reference has also been made of the new arrangements requiring that each cargo consignment be accompanied by a declaration regarding the presence of timber packing materials. Penalties for false or incomplete declarations result in full inspections for a specified period, with consequential additional costs to the importer. Inadequate fumigation of containers can also attract sanctions in the form of non-acceptance of fumigation certificates from overseas companies not complying with quarantine standards. These penalties go some way to reinforcing with importers that Australia will not tolerate continued breaches of its quarantine requirements. However, irrespective of the sanctions applied under these arrangements, the pest or pathogen has still arrived with the consignment and the problem has not been kept offshore. While commending the action already taken to institute and enforce these post-arrival penalties, the Review Committee believes that the further development of sanctions should focus on returning offending consignments to their country of origin and not permitting their entry into Australia. The Review Committee acknowledges that this proposal might be seen in some quarters as harsh, but believes that it is fully in accord with the approach advocated in the continuum of quarantine. While recommending that sanctions be introduced for continued breaches of quarantine import requirements, the Review Committee is also cognisant of the need to reward ‘good customers’, wherever possible ¾ those who go to the trouble and expense of observing Australia’s quarantine rules and continuously prepare consignments in the proper manner. These efforts could be rewarded by the institution of a system of automatic clearance of consignments, with random audit after a predetermined number of favourable inspections. Such a system was observed by the Review Committee while undertaking an investigative tour of quarantine arrangements in Canada. The procedure adopted in Canada is a special clearance system designed to reward importers who have established a history of compliance with Agriculture and Agri-Food Canada’s requirements. Under this system, an importer with a satisfactory compliance history may automatically receive pre-approval for shipments of low risk items. In this way, the importers’ goods are cleared without inspection charges or delays. The program is regarded as quite successful and has met with considerable approval from importers. The Review Committee believes that Quarantine Australia should review this program and consider adopting appropriate elements of it for use in Australia. Recommendation 77: The Review Committee recommends that for general cargo, Quarantine Australia develop and implement a system of sanctions and incentives to encourage compliance with Australia’s quarantine requirements. Directory: SiteCollectionDocuments SiteCollectionDocuments -> Emerging Transport Technologies SiteCollectionDocuments -> Lesson Plan What are smart goals? 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