Australian Quarantine Review Secretariat Australian Quarantine a shared responsibility

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8.4 IMPORT PROTOCOLS

Quarantine policies for the import of live animals, plants and their genetic materials are based on the development of scientific protocols (the term protocol refers to conditions that are or may be, applied to imports). A risk analysis is conducted as part of protocol development. An integral element of this process is a sound knowledge of the pest and disease status in the exporting country, and of the pre-border, border and post-border strategies that can be used to manage risk.

Effectiveness of Current Import Protocols

In attempting to assess the effectiveness of current animal and plant import protocols, the Review Committee commissioned a number of reports on pest and disease incursions in Australia over the past 25 years (see Appendix B). This section of the Report focuses on data from those reports on pest or disease incursions that might indicate there could be shortcomings in import protocols.

The commissioned report on animal pests and diseases identified three incursions of pests or pathogens that were new or not anticipated, and not accounted for in import protocols. The report identified a further three instances of detection of antibody to an exotic disease during post-entry quarantine. Although none of these three incidents involved the presence of disease, each had trade repercussions and illustrates the need for continuous review of protocols.
The commissioned report on plant diseases concluded that the main routes of introduction appear to be legally introduced plant materials (defined as including cuttings, budwood, fruit, leaf waste and dried material) and seeds, which constituted about 41% and 34% of established incursions, respectively. Few plant pathogens that established in Australia during the past 25 years appeared to be associated with imports of whole plants. Exotic plant pathogens that apparently established in Australia during the study period were most commonly associated with fruits and vegetables (34.5%) and nursery plants, ornamentals and flowers (22.5%). When analysed by type of pathogen, fungi (42%) and viruses and viroids (39%) predominated. The Review Committee believes that the data in this report indicate that import protocols for plant materials — especially fruits, vegetables, nursery plants, ornamentals and flowers — need to be reviewed and strengthened.
The commissioned report on weeds concluded that at least 290 exotic species of plants have become naturalised in Australia during the past 25 years (see Appendix B). However, because plants may be present for some time before they are recognised as weeds, many species that have been recorded as naturalised during the study period may have been introduced before 1970. The report concluded that, of those species for which information was available, most had been introduced deliberately — with 65% of the total having been legally introduced as ornamental plants for horticulture. The Review Committee believes that the data in this report indicate that there is a need to strengthen the assessment of weediness in protocols for importing plants, especially of ornamental plants for horticulture (see Section 7.6.1.2).

Fumigation and Treatment of Imported Plant Material

With regard to fumigation, Agriculture Western Australia made the point in its submission that current fumigation treatments appear to be inadequate for addressing all the risks with insects. The submission expressed concern about the efficacy of some treatments required for insect pests found on imported goods. The validity of some overseas fumigation certificates was also questioned in a number of submissions.

It is fair to say that governments and industry are concerned at the validity of overseas certification and at the inadequacy of fumigation and treatment of plant material, particularly cut flowers. For instance, the Review Committee is aware that AQIS recently circulated to all interested parties, a notification list of fumigators from which certification will not be accepted, based on detections of inadequate fumigation treatments.
The Review Committee believes that sanctions should be intensified against importers who continually present consignments with fumigation certificates from agents listed as unacceptable. Merely ordering re-fumigation in Australia — albeit at the importer’s expense — is inconsistent with the principle of seeking to treat potential quarantine concerns offshore whenever possible. The Review Committee believes that where importers have a record of presenting consignments with unacceptable fumigation certificates, the consignment should not be permitted to enter Australia (see Section 8.10.7).
The inspection and treatment of imported plant material was criticised in a number of submissions to the Review Committee. In particular, submissions referred to inadequate fumigation and concerns that the inspection requirements do not match the type of pests that are likely to be found on the product. Consistent with the concept of the continuum of quarantine, the Review Committee is strongly of the view that disease and pest risk should be managed offshore, where possible. There is reduced incentive for exporters to ensure full compliance with import protocols if the option of treatment on arrival is readily available. In particular, the Review Committee shares the concerns expressed in submissions regarding fumigation certification and inadequate treatment of imported cut flowers. Further, the Review Committee believes that quarantine authorities should impose mandatory fumigation at approved and audited premises overseas for cut flowers from sources with an established record of high prevalence of accompanying pests or diseases. Persistent transgressors should be removed from this mandatory requirement only when they can prove to the satisfaction of quarantine authorities that remedial action has been put in place, the revised procedures are effective over a number of consecutive imports, and ongoing compliance can be audited (see Section 8.10.7).
Recommendation 53: The Review Committee recommends that Quarantine Australia impose mandatory fumigation at approved and audited premises overseas for cut flowers from sources with an established record of high prevalence of accompanying pests or diseases.

Seeds

With respect to imports of seeds for sowing, AQIS basically operates a ‘prohibited’ entry system, based on two sets of lists, namely:

· those seeds prohibited by legislation due to their assessed weed threat or other undesirable characteristics ¾ these seeds are listed under Proclamation 86P, commonly referred to as the ‘prohibited weeds list’; and
· those seeds that have restricted entry due to their assessed risk of transmitting seed-borne diseases (i.e. entry is allowed by permit only with defined conditions such as limited import quantities, treatment or a period of growth in post-entry quarantine).
By and large, those seeds not covered by the two lists are permitted entry without an import permit, but are subject to inspection on arrival and treatment, if required. These unrestricted imports, which are ‘automatically approved’ by default, can also include seeds that have not been previously assessed.
As highlighted in Chapter 7 on Risk Analysis and in Section 8.4.1, the Review Committee is strongly of the view that quarantine authorities must take greater account of potential weediness and of seed-borne pathogens via alternative host pathways in determining conditions for managing seed imports. In this regard, the Review Committee believes that it is more appropriate for quarantine authorities to operate an ‘approved’ list for seed imports, based on scientific risk analysis, supplemented by an augmented prohibited list for weeds and for seeds requiring specific permits. Under this approach, seeds that are not on the ‘approved’ list would be prohibited entry until assessed scientifically for quarantine purposes. Publication of the definitive approved and prohibited lists would provide transparency and consistency for Australia’s importers and the community. The Review Committee understands that the proclamations associated with imported seeds are being redrafted to incorporate approved and prohibited lists.
Recommendation 54: The Review Committee recommends that the regulations governing the import of seeds and plant germplasm be based on a permitted list for entry rather than solely the current prohibited list.
The Review Committee is concerned by the inconsistency that currently exists with tolerances for seed contaminants associated with the import of unrestricted seed. Although the tolerance for weed seeds as contaminants in unrestricted seed imports is nil, this applies only to weed seeds identified in Proclamation 86P. There are no constraints on seeds that are not listed on Proclamation 86P — that is, on those seeds that have potential weediness or have not been assessed for weediness. Although the commissioned report on weeds indicates that only 2% of traceable weed incursions entered as contaminants of other imported seed (see Appendix B), the current anomaly with respect to weeds should be addressed by the Review Committee’s recommendation on the development of an ‘approved’ list for seed imports.
Of greater concern is the level of restricted seed allowed as contaminant in bulk imports of unrestricted seed, particularly seed designated for agricultural sowing. By way of illustration, in its submission to the Review Committee, Pacific Seeds noted that ‘sorghum is a restricted species that we can only import through a Quarantine Glasshouse. [However], AQIS does allow seed lots of unrestricted species to be contaminated with up to 35 sorghum seeds per kilogram. Such seeds can … be sown without restrictions such as seed treatment requirements or area freedom’. As reported in a recent review of seedborne diseases of 24 crop genera, ‘the risk of introducing and establishing new diseases through unrestricted bulk imports of seed destined for direct sowing in the field is far greater than that represented by small seed lots grown to second generation seed for release through post-entry quarantine’ (Phillips and Chandrashekar 1994, p. 11). Further, the report on plant pathogens commissioned by the Review Committee concluded that about one-third of established incursions of exotic seedborne pathogens during the past 25 years entered via approved imported seeds (e.g. the recent example of anthracnose of lupins). However, the percentage of these incursions that were transmitted from restricted seeds as a contaminant of unrestricted imports is not known (see Appendix B).
In its submission, Pacific Seeds argued that the difference in treatment between restricted seed imports and tolerances for restricted seed contaminants of unrestricted seed imports is not related to the risk associated with each mode of import — but is based on what was practically achievable with seed screening technologies at the time tolerances were set. For instance, Pacific Seeds compares the nil tolerance for maize as a contaminant against that of 35 seeds per kilogram for sorghum in unrestricted seed imports, noting that ‘the difference in tolerance is we assume because maize being a much larger seed can more easily be graded out of other seeds whilst removing sorghum may be more difficult’. There was no evidence presented during the course of the Review that refuted this assertion. The Review Committee believes strongly that there must be consistency in conditions applying to imports of restricted seeds under permit and as contaminants of unrestricted seeds and that these conditions, including tolerances, should be based on sound scientific grounds.
Recommendation 55: The Review Committee recommends that tolerances for contaminants of imported seeds (including bulk grains) be consistent, equitable and based on scientific risk analysis.
Another apparent inconsistency with respect to imported seeds brought to the attention of the Review Committee related to imports of seeds of certain horticultural crops such as beans, broad beans, peas, sunflowers and garlic for sale as food. In its submission to the Review Committee, the Heritage Seed Curators Association claimed that the direct import of such seeds for sowing incurred relatively expensive quarantine charges — ranging from treatment on entry to growing out in quarantine glasshouses, depending on the particular seed. In contrast, similar seeds imported for sale as food in supermarkets and health stores — although supposedly devitalised by AQIS-approved treatments — could be purchased off the shelf and germinated by members of the Association. The Association claims that its members ‘have found that the germination rate varies between 10 and 60% … for treated bean seed bought off the shelf in a supermarket or healthfood store’. In this regard, AQIS acknowledges that although methyl bromide fumigation may not be as effective as other devitalisation treatments, it is considered adequate for certain bean seed from North America, Europe and New Zealand in view of the low pest and disease risks associated with sourcing from these countries and the intended end use of the seed (i.e. human consumption via the retail trade).
Recommendation 56: The Review Committee recommends that Quarantine Australia undertake regular audits of seeds, bulbs, tubers and other plant material imported for human consumption to ensure that those originating from high risk sources are not viable for propagation.

8.4.4 Sampling methods

The Review Committee became aware during inspections of quarantine operations that inspection staff were applying differing standards to the sampling of plant materials. In some instances, staff seemed unaware of the existence of differing sampling standards and inspection procedures between States and, certainly in the case of fresh fruit and vegetable inspections, also appeared unaware of the general lack of uniform procedures. While acknowledging that standards for inspection of grain imports appear to have a solid and generally uniform base, inspection of other plant materials such as fresh fruit and vegetables do not.

Grains

Most imports of restricted seed (see Section 8.4.3) are permitted entry only in small lots subject to treatment and growth in post-entry quarantine. Only seed produced in quarantine on healthy plants is released to the importer for multiplication. Two exceptions to this are bulk beans (Phaseolus vulgaris) and peas for sowing, which are allowed from certain States in the United States subject to specific requirements. In these cases, samples are drawn in accordance with the International Seed Testing Association’s rules and samples are forwarded to a seed laboratory for analysis. Release is dependent on the outcome of that analysis. All government seed laboratories are accredited by the International Seed Testing Association.

In the case of non-restricted seed, for small consignments (up to 500 g) quarantine inspectors examine the whole consignment using sieves with apertures suitable for the task. Non-restricted seed is inspected to determine the absence of restricted seed, weed seed, fungal fruiting bodies and any other contaminants. Bulk quantities of non-restricted seed, whether bagged or loose, are sampled according to rules set by the International Seed Testing Association. Small retail packets are inspected visually by checking a pre-determined number of packets in accordance with statistical tables.

Horticulture

There are specified inspection sample sizes for imports of cut flowers. However, importers do have the option of a lesser sampling rate if they opt for voluntary fumigation. All consignments must be inspected before fumigation to determine pest status and what fumigation rate must be applied. The Review Committee is aware that AQIS is currently finalising a consultancy for a complete review of all the inspection standards for the import of cut flowers. It is estimated that this review will commence in December 1996 but in the meantime arrangements have been made to implement a number of new procedures to ensure any immediate quarantine concerns are addressed while the review is undertaken. The particular problems associated with the import of cut flowers is discussed in Section 8.4.2.

The differing standards being applied by States to the inspection of fresh fruit and vegetable imports is a matter of concern to the Review Committee. This concern is reinforced by the finding in the report on pest and disease incursions of plant material commissioned by the Review Committee that identifies legally imported fruits and vegetables as being a major route (34%) for introduction of exotic plant pathogens into Australia (see Appendix B).
The Review Committee is aware that for fresh fruit and vegetable imports from Japan, Mexico, New Zealand, Spain and the United States, there is a 600-unit sample taken for each consignment under a sampling requirement set out under specific import protocols. However, inspections may vary because in some States inspection ceases as soon as live pests are found, which may be only half way through the 600-unit sample. This limited inspection has implications in terms of identification of all possible pests in a consignment and application of appropriate fumigation rates to kill pests. For commodities other than those with specific protocols mentioned above, the use of a plant health standard sampling rate is used by some States.
AQIS acknowledges that sampling rates and inspection techniques vary between States and locations, explaining that the variations are due to the time constraints of the inspectors, experience of the inspector and the pressures from importers to release goods or reduce inspection times. Confusion can also exist over required sampling rates as some staff undertake both quarantine and export inspections that can have differing sampling requirements. The Review Committee is aware that AQIS has work in progress to develop a national sampling standard to align export and import requirements, the aim of which is to ensure all States are using standard sample size and inspection techniques.
The Review Committee is strongly of the view that the application of internationally accepted uniform standards for sampling of plant material, particularly fresh fruit and vegetables, is critically important to the prevention of the entry of plant pests and diseases and should be introduced as soon as possible.
Recommendation 57: The Review Committee recommends Quarantine Australia urgently develop and adopt consistent sampling methods and techniques based on internationally accepted scientific procedures.

Foods and Feedstuffs

Due to the substantial overlap between the imported food inspection and the import clearance programs, AQIS began a process of amalgamating the two programs during 1995. The amalgamation has led to the development of a common computer management system, common fees for comparable inspection activities, visits for sampling and clearance purposes by a single officer (except in a minority of specialised cases), co-location of staff from the two programs, and the use of a single dispatch and control system. Both programs require similar background experience and knowledge, and specialist training is available to ensure a smooth amalgamation. The Review Committee commends this management initiative.

The Review Committee acknowledges a late supplementary submission from the Community and Public Sector Union that raised objections to the transfer of existing imported food inspectors to a different public service classification. The Review Committee shares the Union’s view that the imported foods inspection function, as with all inspection activities, should be carried out by persons with appropriate qualifications and experience. However, while acknowledging the concerns of the Union, the Review Committee does not believe that comments on public service position classifications is within its terms of reference.
The Review Committee recognises that the Australia New Zealand Food Authority has responsibility for establishing Australia’s food safety requirements. Toxins and heavy metal contaminants in imported foods for human consumption should thus remain separate from quarantine considerations. However, the Review Committee understands that similar contaminants of imported feed and feed ingredients for animals do not fall within the responsibility of the Australia New Zealand Food Authority or any other Commonwealth agency because such feedstuffs are not for direct human consumption. Given the effect that contaminated feedstuffs ingested by domestic animals could have on Australia’s domestic and international markets, the Review Committee believes that this issue should be taken up by the Australian Animal Health Council for urgent consideration and resolution.
Recommendation 58: The Review Committee recommends that the Australian Animal Health Council should address, as a matter of importance, the issue of unwanted contaminants in imported feedstuffs for animals.

Biological products

Biological products (or biologicals) include, inter alia, microorganisms, vaccines, serum, antiserum, hormones, antibodies, toxins, toxoids, human or animal blood and blood components, products of molecular biology, and therapeutics. AQIS is responsible for assessing applications and issuing permits to import biological products.

The risks associated with importing biological products were highlighted in a number of submissions to the Review Committee. In its submission, Cynamid Websters noted that there are inherent risks in the use of vaccines that are aggravated by the potential risk of inadvertently introducing an exotic disease through imported vaccines or vaccine components. Cyanamid Websters argued that each proposal for importing a vaccine should be reviewed using a formal risk analysis procedure. CSL suggested that fundamental to quarantine is the acceptance that biological imports might be contaminated by adventitious agents with potential for serious harm in the importing country, and thus importing these substances presents a risk to the existing health status.
The Review Committee believes that AQIS acknowledges this risk, in that an increasing emphasis has been placed by AQIS on regulating high volume, medium risk laboratory requisites while higher risk products have either been strictly controlled or prohibited. With extra resources now available to AQIS, high volume, medium risk products are being assessed more thoroughly. The Review Committee understands that assessments are showing that most of these products require only minimal post-import controls.
However, in relation to quarantine border controls there are two major aspects to be addressed for the importation of biologicals and foods. First, there is the range of complex food and biological products that must be assessed, and cannot be easily identified by border staff when they examine the products at entry. Second, many of the products being assessed are part of the international trade, with new products constantly being developed and marketed. This adds to difficulty in identification. Given the vast range of complex products that must be cleared by quarantine staff, a high level of liaison and training must occur.
In its submission to the Review, AQIS acknowledged shortcomings in staff training on imported biological materials and commented that the primary goal of the program is to facilitate imports while maintaining quarantine integrity. Central to this approach is the drafting of new subordinate legislation (a Quarantine Proclamation) to allow for the issue of permits containing conditions for medium and high risk products. However, the proclamation will also allow for the import of low risk products without permits, following publication of the appropriate import conditions in a notice in the Government Gazette. This will permit the targeting of assessment and training resources to high risk products rather than to post-arrival control of low risk products. It will also provide opportunities to devolve permit issue for medium risk products to regional staff. Integral to this plan will be the preparation of manuals for assessors and staff, as well as guidelines for importers. The development of training programs for quarantine staff and upgrading of electronic systems under the Export Import Conditions Database project are also essential. The Review Committee endorses this approach, subject to strong scientific analysis.
Recommendation 59: The Review Committee recommends that Quarantine Australia strengthen training programs on biological products for staff to ensure proper implementation of this border program.

8.4.7 Permits to Import

A number of submissions to the Review Committee raised the requirement that an importer must apply for a permit to import plant material into each State where that material may be required. In particular, the Food and Beverage Importers Association queried the need for this in the light of AQIS being a national organisation. As a matter of principle, the Review Committee believes that permits and protocols should have national application and validity, with individual States applying specific State quarantine requirements separately and independently, so that any differing requirements are transparent.

The Review Committee understands that work is currently under way towards the development of a nationally based permit issuing and tracking system. The Review Committee supports the requests from industry that this costly and time consuming situation be rectified as quickly as possible.
Recommendation 60: The Review Committee recommends that quarantine authorities ensure that a national system for issuing import permits be developed and implemented as soon as practicable.

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Australian Quarantine Review Secretariat Australian Quarantine a shared responsibility

8.4 IMPORT PROTOCOLS

Effectiveness of Current Import Protocols

Fumigation and Treatment of Imported Plant Material

Seeds

8.4.4 Sampling methods

Grains

Horticulture

Foods and Feedstuffs

Biological products

8.4.7 Permits to Import