From: Yew Kwang POH
Sent: Monday, 25 May 2009 4:27 PM
To: BA - Animal Biosecurity Contact
Cc: Astrid YEO
Subject: Biosecurity Australia Advice Notifying The Release Of The Draft Import Risk Analysis Report For Ornamental Finfish With Respect To Iridoviruses
Our Ref: WRB/OFS/L09/044
25 May 2009
Animal Biosecurity Secretariat
Biosecurity Australia
Dear Sir/Mdm
BIOSECURITY AUSTRALIA ADVICE NOTIFYING THE RELEASE OF THE DRAFT IMPORT RISK ANALYSIS REPORT FOR ORNAMENTAL FINFISH WITH RESPECT TO IRIDOVIRUSES
We refer to the draft import risk analysis report for ornamental finfish with respect to iridoviruses (ref 2009/06) notified to stakeholders on 24 Mar 2009.
We have studied the contents of the draft report and would like to raise some concerns and seek some clarifications, as follows:
a) It was mentioned that the diagnostic tests used (e.g. PCR) for purposes of batch testing or demonstration of country, zone or compartment freedom for iridoviruses must be appropriate for the purpose and adequately sensitive, and Biosecurity Australia notes that there are currently no commercial diagnostic tests available for iridoviruses of quarantine concern, but PCR tests have been used experimentally. These PCR tests are currently undergoing optimisation and validation and would be suitable for testing imported fish. We would like to know if the PCR protocol would be made available to all countries for demonstration of country, zone or compartment freedom for iridoviruses, after it has been optimised and validated, in view that there is no available diagnostic
test under OIE Manual of Diagnostic Tests for Aquatic Animals for the iridoviruses of quarantine concern.
b) The report states that in order to fulfil the criteria of being countries, zones or compartments determined to the satisfaction of Australian government authorities to be free of iridoviruses of quarantine concern, the exporting country would need to apply officially to Australia. We would like to know whether countries such as Singapore,that had earlier been approved for export to Australia under a recognised fish health export programme or surveillance, need to make a new application for export of ornamental finfish with respect to iridoviruses of quarantine concern, or can they continue to export under the previously recognised and approved fish health export programme?
c) We would like to confirm that post-import batch testing would be accepted by Australia, if the species are not imported from countries approved by Biosecurity Australia to be free of iridoviruses of quarantine concern? What happens when imported fish are detected with iridoviruses of quarantine concern?
d) We would like to clarify if there is any change in existing quarantine period when the iridoviruses requirements come into effect, ie 14 days pre-export quarantine at premises approved for export of freshwater finfish to Australia?
e) We could not agree with the conclusion drawn in the report under section 5.1 ‘Release assessment’ that the likelihood of release for cichlid and poeciliid iridoviruses is high from imported fish. This is in consideration that there is a lack of data on the prevalence of iridoviruses in cichlids and poeciliids. Also during the survey conducted under the ornamental fish testing project (2006) in which more than 100 cases were investigated and where cichlids, goldfish, gouramis and poeciliids were targeted for diagnostic testing, only four cases were positive for cichlid iridoviruses, and no iridovirus infections were diagnosed from poeciliids. This would indicate that prevalence of iridoviruses was low in cichlids and absent in poeciliids. In the same section, it was also highlighted that no information is available on the prevalence of iridoviruses in cichlids, goldfish, gouramis and poeciliids, with the exception of the studies undertaken by Go et al. (2006). We noted that the risk assessment conclusion of ‘high’ is based only on one factor, that is the volume imported into Australia, and not based on nformation on the prevalence of iridoviruses in cichlids and poeciliids.
f) Under section 60 ‘Risk management’, it was mentioned that Biosecurity Australia has based its evaluation on an assumption that the pathogenic agents of concern are present in the exporting country. Where exporting countries can provide specific data on their own disease status, including evidence to support disease freedom, Biosecurity Australia will reconsider the risk assessment based on that data. We would be grateful if Biosecurity Australia could share with us guidelines for exporting countries to determine disease status in relation to iridoviruses of quarantine concern, in particular the type of data needed to support disease freedom.
We would appreciate it very much if Biosecurity Australia could consider our concerns favourably and clarify the points raised above. As you may be aware, Australia is one of our major trading partners for export of ornamental aquatic animals. We would like to ensure that our exports continue smoothly after the implementation of this new requirement. Please do not hesitate to contact me if my assistance or clarifications are needed.
Thank you
Yours sincerely
Mr Poh Yew Kwang
Head, Ornamental Fish Section
Import & Export Division
for CEO, Agri-Food & Veterinary Authority of Singapore
Poh Yew Kwang | Wildlife Regulatory Branch | Import & Export Division | Agri-Food & Veterinary Authority
Tel 6751 9802 | Fax 6759 5043 | Website www.ava.gov.sg