9 JUN 2011
Dr Colin Grant
GPO Box 858
Canberra ACT 2601
Dear Dr Grant
Draft report for the non-regulated analysis of existing policy for apples from New Zealand
I refer to the Draft report for the non-regulated analysis of existing policy for apples from New Zealand and your request for comments by 4 July 2011.
The draft report proposes that the importation of apples from New Zealand be permitted, subject to specific quarantine measures.
The Department of Employment, Economic Development and Innovation (DEEDI) notes that the Biosecurity Australia draft report under consideration addresses only the three pests at dispute (fire blight, European canker and apple leaf curling midge) after the final ruling by the World Trade Organization (WTO) regarding the validity of existing phytosanitary measures required for the import of New Zealand apples. DEEDI also notes that the current draft is based on new scientific information not available at the time of original risk analysis in 2006 and has taken into account the WTO decision.
DEED I notes that the draft report recommends that export of apple fruit produced using New Zealand's standard commercial practices, the Integrated Fruit Production program (IFP), be allowed into Australia without further phytosanitary measures. The draft report relies solely on the use of the IFP to ensure the phytosanitary status of consignments.
DEEDI has reviewed the draft IRA report and agrees that the pre-import measures included in the IFP are currently sufficient to reduce the risk to Australia's appropriate level of acceptance. However, DEEDI is concerned about full implementation of these protocols by New Zealand apple producers. DEEDI's specific comments on ambiguous issues are attached.
Thank you for the opportunity to comment on the draft IRA report. DEEDI will appreciate receiving a response on how the issues raised are to be addressed in any further review leading to the finalisation of this IRA.
If you require any further information regarding this matter, please do not hesitate to contact Dr Abu-Baker Siddique on telephone 07 32251678 or siddique.abu-baker@deedLqld.gov.au.
Department of Employment, Economic Development and Innovation
Department of Employment, Economic Development and Innovation's response to the Draft report for the non-regulated analysis of existing policy for apples from New Zealand
Biosecurity Australia Advice 2011/06 June 2011
3.2.4 Pest management - page 21
The Department of Employment, Economic Development and Innovation (DEEDI) acknowledges that the Integrated Fruit Production program (IFP) is proprietary information, However, DEEDI remains concerned that insufficient detail about the implementation of the IFP is provided in the draft report, The draft report states that the IFP is only a guideline, and that some orchard managers stated that "the immediate pruning of 'shepherd's crooks' was not necessary", If the IFP is to be relied upon as a mitigating measure, surely allparts of the program need to be implemented,
DEEDI also requests further information on the methods to be used to ensure that the IFP has been fully implemented on exported fruit Specifically, will checks be made to ensure that the IFP guidelines for orchard management are followed, and if so by whom?
Apple leaf curling midge management - page 24
In practical terms, the recommendation to make foliar applications of diazinon in apple trees may pose a threat to biocontrol agents targeted at apple leaf curling, Therefore, DEEDI believes that the proposed control strategy may not be adopted by growers who wish to preserve biocontrol of apple leafcurling,
3.4.1 Packing house - page 25
The draft report states that "packing houses will not accept fruit unless spray diary clearance has been received from the Independent Verification Authority (IVA)", No further details are provided about the IVA In particular, DEEDI requests information on the representatives who make up the IVA, and the methods used to "clear" the spray diaries,
4.1.1 Probability of entry - page 30
DEEDI agrees with the 'Moderate' assessment for probability of importation for fire blight pest, however DEED I disagrees with the subsequent assessment of probability of distribution, It is known that the pest can easily survive on imported apples and that there are many suitable hosts in the areas where apples would be sold and consumed, Therefore an assessment of an 'Extremely low' risk of distribution does not appear to be congruent DEEDI suggests that the likelihood of distribution needs to be upgraded to
'Low'. Coupled with this 'Low' likelihood of distribution the overall unrestricted risk estimate would change to 'Low' rather than 'Very low'. As a result the pest does not meet Australia's ALOP, that is, additional risk management measures are required for this pest. This contradicts BA's assessment.
4.1.1 Probability of importation - page 32
Association of the pest with the commodity pathway-calyx infestation In this section, the work of (Hale et al. 1987) is used to set a standard reduction rate for Erwinia amylovora infection of apple fruit calyxes of 93% from immature to mature fruit. This standard rate of reduction is then used throughout the analysis to determine reduced rates of infection in mature apple fruit. The information from Hale et a/. (1987) was collected from a single farm in a single season and may not be generally representative of the level of reduction that occurs. DEEDI strongly suggests that the use of the specific reduction rate of 93% is not warranted based on only one study. The work of Hale et a/. (1987) indicates that significant reductions occur, but thespecific use of 93% in subsequent calculations is not appropriate.
Ability of the pest to survive existing pest management - page 45
In this section, the draft report refers to the use of the IFP or a certified organic program. Only very limited details are provided about the certified organic program. DEEDI requests further information about this program if itis to be used as a mitigating measure in the same way as the IFP.
Distribution of the imported commodity in the PRA area - page 49
Distribution of the imported commodity in the PRA area - page 100
In both sections it was mentioned that the majority (99.8%) of New Zealand apple fruit are exported in retail-ready packaging, indicating that there will be no need for repackaging of fruit in Australia. DEEDI agrees that if such packaging is used this will greatly increase the phytosanitary status of the consignments. However, there is no guarantee that this form of packaging will be used, and no restriction on the amount of fruit that may be imported in bulk containers and then require repacking in Australia. If the use of retail-ready packaging is not mandated as part of the terms of trade, then this cannot be used as a mitigating measure in the import pathway, and more consideration must be given to bulk transport of fruit and repacking in Australian packing houses.
Ability of the pest to move from the pathway to a suitable host - page 54
The draft report states that "the majority of fruit will be imported during autumn and winter, well before host flowering, when hosts are most receptive to infection". DEEDI acknowledges that this is most likely the current intention of New Zealand exporters. However, there is no stipulation in the terms of trade that this must be the case and so this cannot be used as a significant mitigating measure. Market sale patterns change and it is possible that in the future New Zealand may export significant amounts of apples to Australia during spring and early summer. The export of fruit at this time should begiven more consideration in this pathway.
4.3.1 Probability of entry - page 98
Ability of the pest to survive existing pest management The draft report states that "in cooking varieties and immature fruit, fruit infections (Neonectria ditissima) can remain latent and express themselvesafter 3-7 months of storage" but that "New Zealand does not export immature apples or significant volumes of cooking varieties". Once again, markets change and unless it is specifically stipulated that New Zealand is not to export cooking varieties of apple to Australia this cannot be used as a mitigating factor.
5.2.6 Freedom from trash page -126
The draft report states that all apples must be free from trash, but does not provide details on how these inspections will be undertaken. DEEDI respectfully alerts Biosecurity Australia to the fact that trash in bulk containers tends to settle in the bottom of the container, and such trash may not be observed by an inspection of 600 fruit from the top of the container.
BA's proposed pest risk analysis for fire blight, European canker and apple leaf curling midge seems to be heavily based on recommended standard commercial practices in New Zealand orchards and export packing houses. DEEDI fears that if the proposed conditions are not fully complied with and the relevant pests are not detected during import process, then these pests can easily enter and establish in Australia. Since these pests are categorised as very destructive and of concern to many apple growing countries, establishment of these pests in Australia would have significant impact on both production and export markets.