7.1 INTRODUCTION
Australia's quarantine policy and programs are based on the assessment and management of pest and disease risk in accordance with internationally accepted principles. Risk analysis provides the framework for determining quarantine policy, particularly with respect to consideration of import access requests.
7.1.1 The Mythical 'No Risk' Quarantine Policy
In 1979, the Senate Standing Committee on Natural Resources reported on the adequacy of quarantine and other control measures to protect Australia's pastoral industries from the introduction and spread of exotic pests and diseases of animals and plants. Its report stressed that there is no such thing as a 'no risk' (or 'nil risk' or 'zero risk') quarantine policy, noting that 'the shorthand term "no risk" is widely applied to Australia's quarantine policy. The use of this term is misleading and it is not accepted by the quarantine authorities as an accurate description of quarantine policy. In practice any international trade or travel contains an element of quarantine risk ... A more accurate description of quarantine policy would be the scientific evaluation of acceptable risk' (Senate 1979, p. 4).
Similarly, the Lindsay Review of Australian quarantine requirements concluded that 'a "no risk" policy for Australian quarantine — implying total exclusion — is untenable and undesirable and should be formally rejected. By contrast, the notion of "acceptable risk" is realistic: it reflects the fact that, regardless of the policy of the day, all imports whether or not they are legal inevitably involve a level of risk' (DPIE 1988, p. 27). Furthermore, a subsequent Senate Committee report on the Australian Quarantine and Inspection Service (AQIS) noted that 'risk analysis and risk management underpin many facets of AQIS' work and, during the inquiry, this process emerged as one of the most controversial and consistently misunderstood aspects of AQIS' activities' (Senate 1996, p. 65). The same report reiterated that 'successive reviews of Australia's quarantine services have noted that a policy of "no risk" is not, and never has been, a viable quarantine policy option' (Senate 1996, p. 65).
However, the number of individuals and organisations that continue to advocate a 'no risk' policy remains sufficient for the 1996 Senate Report on AQIS to state that it was 'concerned about the persistence of the view that "no risk" is a viable option for quarantine policy, despite consistent and unequivocal dismissal of this approach by previous reviews' (Senate 1996, p. xi). Even during the course of the present Review, a number of submissions advocated a 'no risk' policy. The Review Committee believes that the continued perception in some quarters that there ever has been or ever can be a 'no risk' quarantine policy for any country — let alone a major agricultural trading nation such as Australia — reflects a fundamental misconception that needs to be corrected in an ongoing awareness campaign. As discussed in Chapter 3, the national quarantine awareness campaign needs to include a focus to increase industry and community understanding of the fact that there is not and cannot be a 'no risk' quarantine policy. The awareness campaign must aim to ensure that all Australians appreciate that natural migrations of vertebrate animals (including birds and fish), invertebrates (including insect pests), plant germplasm (including seaborne seeds and airborne spores), and insects and other pests mean that Australia never has been truly isolated from the rest of the world's flora and fauna (and their associated pests and diseases). Similarly, human-assisted movement of animals and plants (and of their associated pests and diseases) has occurred since the first humans migrated to Australia tens of thousands of years ago.
In more recent times, many pests and diseases undoubtedly failed to establish in Australia during early European settlement. The long sea voyage from Europe meant that on their way out (or soon after arrival) animals or plants infected or infested with significant pathogens or pests died or developed obvious clinical signs and were destroyed. Since the establishment of quarantine services (as outlined in Section 1.6), sound scientific principles have been developed and applied to quarantine to manage the risk of inadvertently importing unwanted exotic pests and diseases with animals and plants (or their products) and passengers and cargo. These principles, such as pre-entry testing and certification, import inspection and post-import quarantine and surveillance, have led to the largely successful management of the pest and disease risks that are unavoidably associated with imports, trade and travel. Indeed, it is the very success of this risk management approach that has led to the misconception in some quarters that Australia has had a 'no risk' quarantine policy.
The application of sound scientific principles to identify and manage the pest and disease risks that are unavoidably associated with imports, trade and travel is part of the process that is now called risk analysis. Although animal and plant health and quarantine authorities worldwide have adopted this approach for many years, it is only in the past 10 to 15 years that it has been recognised formally as part of the emerging inter-disciplinary study known as risk analysis, which has its roots in the physical sciences and engineering rather than biology.
7.1.2 The Terminology of Risk Analysis
Because risk analysis has been recognised only recently as a study or discipline in its own right and has developed from an inter-disciplinary background, there is still some confusion in scientific and popular literature about the precise definition of each of its elements. Several attempts have been made to develop a standardised nomenclature both overseas and in Australia. Such attempts have been made in, for example, animal health (Hathaway 1991, Ahl et al. 1993, Kellar 1993, MacDiarmid 1993, OIE 1994), plant health (IPPC 1995, McNamara 1995) and other disciplines such as environmental science (Beer and Ziaolkowski 1995). In Australasia, Standards Australia and Standards New Zealand have developed a joint standard on risk analysis (SA/SNZ 1994, 1995) and the Australia New Zealand Food Authority released a discussion paper on the application of risk analysis to food safety in September 1996 (ANZFA 1996).
Much of the confusion in the terminology in risk analysis relates to the terms used for the whole process and for each of its elements. For example, some authorities use 'risk management' as the overall term (rather than risk analysis as used in this Report). Others use 'risk analysis' more narrowly as including elements such as risk identification, assessment and evaluation but excluding risk management and communication. The only practical difficulty arising from these variations in terminology is that one needs to be conscious of which set of terms is being used in any particular publication or discipline. Despite variations in details of the terms used, the basic principles are the same across all disciplines.
For the purposes of this Report, risk analysis is used as the overall term to encompass the elements of risk assessment, risk management and risk communication. This approach is generally consistent with that of most authorities working in animal and plant health and quarantine, including the Office International des Epizooties (OIE) and the International Plant Protection Convention (IPPC).
From a quarantine perspective:
· risk assessment is thus the process of identifying and estimating the risks associated with an import and evaluating the consequences of taking those risks;
· risk management is the process of identifying, documenting and implementing measures to reduce these risks and their consequences; and
· risk communication is the process of interactive exchange of information and opinions concerning risk between risk managers and stakeholders.
Quarantine authorities worldwide have long practised all three elements of risk analysis — albeit probably more consciously and comprehensively for the first two elements than the last.
7.1.3 Applying Risk Analysis in Quarantine
Many submissions to the Review recognised that a 'no risk' policy is unachievable and acknowledged that Australian quarantine authorities have always endeavoured to base import policy and procedures on scientifically based assessment and management of pest and disease risks. CSIRO's submission to the Review supported the use of risk analysis in quarantine and stated that 'it is impossible to maintain a no risk quarantine policy and be involved in world trade'. Similarly, the Australian Academy of Science's submission noted that AQIS's quarantine strategy is based on risk analysis and that 'this strategy has been Australia's long standing approach to quarantine and has served well in the past'. The submission from the Grains Council of Australia stated that the Council 'appreciates that a "no risk" policy is unobtainable'. In its submission to the review, the National Farmers' Federation noted that 'freedom to trade is progressively becoming the "default" position: quarantine barriers or import controls must be justified. In this situation quarantine becomes more explicitly a program for managing risk'.
Discussions the Review Committee held with quarantine authorities and agricultural producer groups overseas (in Canada, the Republic of Korea, Japan, New Zealand and the United States) reinforced the fact that scientifically based risk analysis is fundamental to quarantine policy and practice worldwide. The Review Committee believes that Quarantine Australia must continue to use and refine scientifically based risk analysis to develop its quarantine policies and procedures.
Recommendation 33: The Review Committee recommends that Quarantine Australia continue to use and refine scientifically based risk analysis — comprising risk assessment, risk management, and risk communication — to develop its quarantine policies and procedures.
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