Risk assessment – Fresh leafy vegetables (spinach, silverbeet, celery, lettuce, brussels sprouts, cabbage, Chinese cabbage, kale, bok choy, fennel, basil, mint, leek and coriander) for human consumption into Norfolk Island from mainland Australia

Australia and Norfolk Island biosecurity policy framework

Under the Biosecurity Act 2015, the Australian Commonwealth is responsible for maintaining the plant biosecurity of Norfolk Island. Australia’s biosecurity policies aim to prevent exotic pests from entering, establishing and spreading on the island. Such incursions may threaten Norfolk Island’s unique flora and fauna and, in turn, the tourist and agricultural businesses of the island that depend on a relatively pest-free environment.

The Pest Risk Area to which these conditions apply is the Norfolk Island group. The Norfolk Island group (-29°02’S 167°57’E) is an external Australian territory situated approximately 1400 km due east of Evans Head on the eastern seaboard of the Australian mainland. The biota of this island group is distinct from Australia and other countries. It is comprised of three small islands, the inhabited main island—Norfolk Island, with two smaller uninhabited islands—Nepean Island, 1 km to the south, and Philip Island 6 km to the south. Norfolk and Philip Islands are the weathered remnants of volcanoes on the Norfolk Ridge linking New Caledonia and New Zealand. Soils are uniformly deep volcanic overlying basalt. Norfolk Island is the largest of the Norfolk Island group at 32 km². It has a subtropical climate with an average rainfall of around 1300 mm per year (falling throughout the year but mostly in June and July) and an average temperature range of 12-20 °C in winter and 19-25 °C in summer. Pre-European settlement, vegetation of the island comprised subtropical rainforest consisting primarily of Araucaria heterophylla(Norfolk Island pine). However, this native vegetation has largely been cleared, with remaining vegetation now mostly conserved in Norfolk Island National Park (approximately 462 ha, including Philip and Nepean Islands). The remainder of the island is rural to rural-residential, with cattle grazing and fruit and vegetable production the main land-based rural industries.

The plant biosecurity pest status of Norfolk Island is known due to a recent survey (2012-2014), which provides a comprehensive biosecurity dataset for the whole island.

The biota of Norfolk Island comprises approximately 566 vascular plant species (430 introduced), 116 bird species (including 11 introduced and 66 vagrant species), many invertebrates (more than 1200 species) as well as 10 introduced mammal species and plant pathogens. It is biologically distinct from the rest of Australia (including Tasmania), where the predominant floral species are members of the Myrtaceae family. Norfolk Island does not contain any native Myrtaceae species. Norfolk Island’s isolation means that there are species endemic to this island group, occurring nowhere else in the world, which could be threatened by pest incursions.

The risk analysis process is an important part of Australia’s biosecurity policies. Risk analyses are conducted by the Department of Agriculture, Fisheries and Forestry
by technical and scientific experts. The process enables the Australian Government to consider the risks that could be associated with imported products entering Norfolk Island from the mainland and other countries. If the risks exceed Australia’s (including Norfolk Island) appropriate level of protection (ALOP), risk management measures are imposed to reduce the risks to an acceptable level. The Biosecurity Act 2015defines

Australia’s ALOP as ‘a high level of sanitary and phytosanitary protection aimed at reducing biosecurity risks to a very low level, but not to zero’. This approach is consistent with the World Trade Organization’s (WTO’s) Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement).

Australia expresses its ALOP in qualitative terms. In determining and maintaining the ALOP for Norfolk Island, the scientific risk assessment process cannot take into account the potential economic impact or the effect on market competition caused by importing goods, as this would not be consistent with Australia’s international trade obligations, nor within the remit of the Act.

Policies and import conditions are designed to protect the environment of Norfolk Island by preventing the introduction of exotic pests to the island, thereby keeping biosecurity risks off shore. Products from locations external to the Norfolk Island group need to be free of exotic pests in order to satisfy the conditions for entry into Norfolk Island. However, in considering import conditions for Norfolk Island, the department has determined it will not knowingly take action that would impact, either positively or negatively, on the current biosecurity status of Norfolk Island. The baseline for this position is the 2012-14 Norfolk Island pest and disease survey.

Import conditions for all fresh fruit and vegetables for human consumption into Norfolk Island from mainland Australia

All plants and plant products for human consumption that are to be imported into Norfolk Island are subject to general conditions that must be met. Certain goods may also be subject to specific additional conditions where this is necessary to manage any biosecurity risks not addressed by the general conditions.

In this risk assessment, mainland Australia include all Australian states and territories on the mainland and the state of Tasmania.

General conditions:

Consignments must be free of plant biosecurity risk materials including live quarantine pests, trash and contaminants.
Trash includes any material other than the [fresh leafy vegetables] intended for export, for example splinter, twig, other leaf material, seeds, soil, animal matter/parts or other extraneous material.
Prior to shipping to Norfolk Island, consignments must be verified by appropriate official government inspections, documentation, systems, reporting and certification to be free of any signs of biosecurity risk material. If required, appropriate pre-export measures (such as reconditioning or treatment) must be applied to mitigate the biosecurity risks with appropriate official government checks at the completion of the reconditioning or treatment.
Consignments must be packed in clean and new bags/boxes/containers. Imports are permitted for human consumption only.
Upon arrival on Norfolk Island, consignments are to be presented to the Department of Agriculture, Fisheries and Forestry Biosecurity Officer for inspection and verification prior to release. The presence of any biosecurity risk material will necessitate remedial actions. Remedial action options include: treatment, where this is available, re-export or destruction.

Leafy vegetables:

Risk background

This assessment includes fresh spinach, silverbeet, celery, lettuce, brussels sprouts, cabbage, Chinese cabbage, kale, bok choy, fennel, basil, mint, leek and coriander. These fresh products have been grouped together for the purposes of this assessment because of their similarities in growing characteristics, production methods, and they have similar biosecurity risks that are associated with leafy vegetables. The following common elements support this position:

The biosecurity risks (arthropods and diseases) associated with the products are similar.
The produce must be commercially grown and packed. Standard commercial practices involve several production activities that provide an increased level of biosecurity control. Each step or action undertaken contributes to a reduction in the risk status and forms part of a managed pathway that results in a biosecurity risk status of at least very low level.
Infestable surfaces of the leaves and stems can be readily inspected, including the outer layers of brussels sprouts, cabbages, leeks and lettuce.
Each of the products must be trimmed so that only the edible leaf and stem or leaf base is left, and some products require mandatory washing (as appropriate). Coriander can retain the root (which is also edible) but must be thoroughly washed to remove all traces of soil.
Inspection techniques require any signs of damage, infection or infestation to be examined more closely by cutting the produce open and inspecting thoroughly.

This assessment is informed by published information and extensive import and export history. The information shows that the following pest groups have the potential to be present on Australian fresh leafy vegetables: moth larvae, thrips, mites, aphids, beetles, flies, and some diseases.

This assessment has not attempted to distinguish between pests that are present on the mainland but which may not be present on Norfolk Island. The conditions require that fresh leafy vegetables must be free of all quarantine pests and other biosecurity risk material.

Specific conditions for the importation of fresh leafy vegetables for human consumption from mainland Australia to Norfolk Island under the Biosecurity Act 2015.

A valid import permit is required. Note: the import permit must be obtained from the Department of Agriculture, Fisheries and Forestry prior to the produce arriving in Norfolk Island.
The [produce] must be Australian grown and packed.
Consignments must be commercially packed in clean new packaging. Each consignment must be secured prior to shipment to maintain its quarantine integrity on arriving using a secure packaging option. The packages must be clearly labelled with the kind of produce, the name of the grower or packer, and information that enables verification against accompanying documentation.
The consignment must be free from live quarantine arthropods, visual symptoms of quarantine diseases and other biosecurity risk material.
1. Note: lettuce, cabbage, Chinese cabbage, bok choy, leek and fennel have an additional requirement that the roots must be removed.
2. Note: spinach, silverbeet, kale, basil and mint have an additional requirement specifying leaf and stem only.
Each consignment must be accompanied by certification issued by a state/territory plant health certification authority, or through the Interstate Certification Assurance scheme (where appropriate) certifying that:
1. The [produce] in the consignment has been inspected and meets the conditions for import into Norfolk Island.
Note: Fresh leeks require a further declaration that “the leeks in the consignment have been sourced and packed in an area where onion smut (Urocystis cepulae) and Iris yellow spot virus are not known to occur.”
Upon arrival on Norfolk Island, consignments are to be inspected by a Department of Agriculture, Fisheries and Forestry biosecurity officer prior to release. The presence of quarantine pests and/or biosecurity risk material will necessitate remedial actions. Remedial action options include: treatment, where this is available, re-export or destruction.

A summary of import conditions and commercial production practices, which reflect the demonstrated ability to manage and detect all of the target pests is shown in Table 1 - Managed pathway for fresh table grapes from mainland Australia to Norfolk Island

Leafy vegetables

Managed pathway for the export of fresh spinach, silverbeet, celery, lettuce, brussels sprouts, cabbage, Chinese cabbage, kale, bok choy, fennel, basil, mint and coriander from mainland Australia to Norfolk Island under the authority of the Australian Department of Agriculture, Fisheries and Forestry and the Biosecurity Act 2015.

Target pests: see below

Weed seeds: Actionable

Regulated articles:

Packaging: must be clean and new.
Trash: splinter, twig, leaf material, seeds, soil, animal matter/parts or other extraneous material

**Table 1 - Managed pathway for fresh leafy vegetables from mainland Australia to Norfolk Island**
Pathway element	Target risk/pest	Risk management action	Critical control points	Risk visible [Yes/No]	Verification action	Evidence
Standard commercial practice	Moths, flies, mites, aphids, thrips, beetles, fungi, bacteria, weed seeds	Pest management systems, including crop monitoring, inspection, chemical and/or biological control. Cultivation and weed management. Official survey program for specific pests, where required	Regular inspections Inspections after adverse weather events Recommended spray program and/or biological control program Maintain good sanitation	Yes/No	Staff and supervisor roles and responsibilities Sprays applied per label Training / Expertise	Grower records and spray diaries Supervision
Harvesting	Free of pests and disease	Removal of non-compliant product Product not left exposed to reinfestation	Inspection at harvest	Yes	Staff training / expertise	Quality control
Product grading	Trash and contaminants (including excessive foliage (tops) and roots) live arthropods Rots and disease symptoms Discolouration and deformities Any signs of damage	Visual inspection Removal and isolation of diseased, damaged and infested goods Produce cut and examined as necessary Trimming and washing	Unacceptable product removed by trained staff	Yes	Entity Quality controls and quality assurance processes	Check of grading line, packed produce and cull pile Packing records
Inspection and Certification	Arachnida, Coleoptera, Diptera, Hemiptera, Lepidoptera, Thysanoptera, fungi, bacteria, trash, contamination Other quarantine pests if present	Inspect, reject, treat non-conforming product (as appropriate) Verify official survey records, where required	Produce is free of target pests, trash and contaminants Free of target pests Meet the conditions for import into Norfolk Island. Where required, treatment applied to produce consistent with application standard Rejected goods segregated and identified Packaging is appropriate	Yes	Inspection by Commonwealth, or state or territory plant health certification authority	Plant Health certificate, Phytosanitary certificate, or Plant Health Assurance certificate Treatment certificate, where required
Post entry verification	Biosecurity risk material, including quarantine pests, trash and contaminants	Inspect to ensure import conditions are met Goods are as described and comply with certification	600 unit inspection using standard process	All pests visible Packaging compliance evident Product aligns with certification	Inspection completed by competent officers	Competency assessment against department standard

The photo depicts a visual graphic that explains the biosecurity risks posed by leafy vegetables imported into Norfolk Island from the Australian mainland. The risks are depicted as going from a high risk during production, harvest and packing to a low risk upon export and a very low risk upon import and release. The key depicts the following components: the export pathway, production practices and regulatory steps. The export pathway includes production, harvest, packing, export, import and release. The production pathway identifies production practices including crop management, pest/disease control, weed control, pruning, monitor and spray records and official surveys. The harvest pathway identifies harvest practices including cull non-compliance product, and limit exposure to pest infestation The packing pathway identifies packing practices including washing and brushing, grading, removing infested and infected fruit, inspection and quality checking, packaging and treatment. The export pathway identifies clean, new robust and secure packaging and labelling. The regulatory controls for the export pathway include state and interstate certification assurance inspection, verification that all import conditions are met, certification and rejection of non-compliant goods. The import pathway identifies import practices including packaging clean, new robust, labelling and segregation of goods. The regulatory steps for the import pathway includes inspection by Department of Agriculture and Water Resources The release pathway does not have any production practices or regulatory steps identified. — Figure 1 – diagram showing the biosecurity risks of fresh leafy vegetables from mainland Australia to Norfolk Island and the export pathway, production practices and regulatory steps taken to reduce biosecurity risks to very low.