Australian Quarantine Review Secretariat Australian Quarantine a shared responsibility
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- 7.2.1 Consultation
- 7.2.2 Priority and Timing
- 7.2.3 Who Undertakes Import Risk Analyses
- 7.2.4 Handling Uncertainty
- 7.2.5 Scope
- 7.2.6 Resources
- 7.2.7 Appeal
7.2 STAKEHOLDER CONCERNSThis section considers concerns raised during the course of the Review on the application of risk analysis in quarantine decision making on import access requests — the process of import risk analysis. Many submissions to the Review raised concerns relating to the way AQIS conducts import risk analysis, particularly regarding consultation, scope and resource requirements. 7.2.1 ConsultationMany submissions sought better consultation on import risk analysis. The need for early and extensive consultation is illustrated by comments such as that of the Tasmanian Salmonid Growers Association, which stated in its submission to the Review that it had 'found the process of the current risk assessment to be subjective, pre-emptive and inadequately resourced'. Some submissions claimed that AQIS issues papers or discussion papers on import access requests were produced too late in the process for meaningful dialogue with industry, which tended to see these papers as merely presenting an outcome that was already decided. Similar criticism has been levelled at quarantine services in other countries; for example, an official of the United States Animal and Plant Health and Inspection Service noted that its approach to import access requests had been characterised by some as 'decide, announce and defend'. In its submission to the Review, the National Farmers' Federation recommended that 'AQIS consult with the scientific and farming communities, to determine what is a range for acceptable probabilities of risk'. The Tasmanian Farmers and Graziers Association stated 'that consultation with industry and States is critical for the development of smooth processes and successful decision making particularly in the area of risk assessment'. Similarly, the Western Australian Farmers Federation argued the need for 'consultative processes to ensure that industry and community groups are appropriately informed and their views taken into account in policy development and program delivery', with consultation to 'include industry and the community in every step of the importing process'. Other submissions also sought greater consultation with industry on what pests and diseases should be considered in an import risk analysis. For example, the submission from the Bureau of Sugar Experiment Stations recommended 'that industry be involved in determining the quarantine status of a pest/disease'. Some groups noted that consultation consumed a considerable amount of their resources, and that provision of more detailed information would be helpful. For example, in its submission to the Review, the Australian Veterinary Association stated that 'parties being asked to comment on import proposals must be given full access to all qualifying data'. 7.2.2 Priority and TimingSome submissions to the Review stated that there was a need for a transparent method of determining the priority that should be given to each import access request. The lack of clear, defined stages and an agreed timetable was a frequent concern raised in submissions and public hearings. Some submissions also noted that particular risk analyses occasionally took a very long time to be completed. 7.2.3 Who Undertakes Import Risk AnalysesSome submissions to the Review queried the capacity of AQIS to undertake independent scientific risk analyses, particularly in highly specialised areas. A few submissions argued that AQIS was compromised by its role in export facilitation and trade, suggesting that this involvement would inevitably lead to trade-offs between import access and access to export markets. 7.2.4 Handling UncertaintySeveral submissions raised concerns about how the risk analysis process handled uncertainty. For example, in its submission to the Review, the National Farmers' Federation recommended that 'risk assessors should err on the side of caution, especially when information is not available'. The Tasmanian Department of Primary Industry and Fisheries noted that 'this inherent uncertainty also puts a premium on consultation to agree on processes'. The application of the precautionary principle in quarantine risk analysis is discussed in Section 7.4.6. 7.2.5 ScopeA number of submissions called for a greater emphasis on possible environmental implications of proposed imports. In its submission to the Review, the Tasmanian Farmers and Graziers Association recommended that 'AQIS accept responsibility [for] and play a role in the protection of the environment from introduced pests and diseases'. Similarly, the Australian Veterinary Association stated that 'possible environmental consequences must be included in all risk assessment procedures for the importation of both animals and plants'. In its submission to the Review, the National Biodiversity Council proposed that 'the protection of Australia's biodiversity by adopting the precautionary principle should be recognised as a "legitimate objective" under the Technical Barriers to Trade Agreement'. Similarly, the submission of the Department of the Environment, Sport and Territories recommended a 'review of AQIS policies and procedures with a view to strengthening AQIS's capacity for transparent assessment of the potential environmental impacts of proposals. This should be explicitly recognised as part of AQIS's charter and expertise'. However, it also noted that 'provided that AQIS establishes a process which is consistent with the avoidance of unjustified discrimination in trade or a disguised restriction on trade, there is ample scope for it to provide protection for the Australian environment'. Some submissions also called for consideration of regional or local consequences of decisions on import access requests. For example, the Tasmanian Department of Primary Industry and Fisheries noted that potential consequences are 'likely to fall very unevenly on different regions of Australia, so safeguarding of minority interests needs careful consideration'. 7.2.6 ResourcesSeveral submissions noted that import risk analysis is a demanding and resource-intensive process. They questioned whether or not there are adequate resources to undertake the number of risk analyses and the amount of consultation involved. For example, the Australian Veterinary Association stated that 'with the increasing number of protocols to consider, there is concern that AQIS is being inundated with requests to export to Australia and does not have adequate resources to deal with these and fully integrate industry responses'. 7.2.7 AppealSeveral submissions to the Review noted that there is no formal mechanism of appeal against any risk analysis decision, raising concerns that AQIS is 'judge, jury and executioner'. These submissions called for a formal appeal mechanism to be instituted. Directory: SiteCollectionDocuments SiteCollectionDocuments -> Emerging Transport Technologies SiteCollectionDocuments -> Lesson Plan What are smart goals? 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