OFFICE OF THE CHIEF EXECUTIVE
25 Grenfell Street
Adelaide SA 5000
GPO Box 1671
Adelaide SA 5001
Tel (08) 8226 0168
Fax (06) 8226 0320
Our reference: eA59660
Please refer to: 2008/12
14 July 2008
Mr John Cahill
GPO Box 858
CANBERRA ACT 2601
Received 17 JUL 2008
Dear Mr Cahill
Response to Draft Import Risk Analysis Report from Stone Fruit from the USA
Thank you for the opportunity to comment on the recently released Draft Import Risk Analysis for Stone Fruit from the USA (Biosecurity Australia Advice 2008/12 - 29 April 2008).
Please find attached the formal response from Primary Industries and Resources SA (PIRSA). A copy has been previously forwarded electronically to ensure that we meet the deadline for comments and submissions of 27 June 2008.
Should you or your staff have any queries on any of the comments from PIRSA, please do not hesitate to contact Mr David Cartwright, Manager Plant Health Policy on (08) 8226 9825 or via e-mail at: firstname.lastname@example.org
PIRSA Response to: Biosecurity Australia Advice 2008/12 Draft Import Risk Analysis Report for Stone Fruit from the USA
Primary Industries and Resources SA (PIRSA) have considered the recent Draft Import Risk Analysis Report for Stone Fruit from the USA (Biosecurity Australia Advice 2008/12- 29 April 2008).
The following comments are provided following our analysis of the document:
Pest Risk Assessments
Plum pox virus
Strains - From the data provided, it is unclear what strains of PPV have been detected in the affected areas of Pennsylvania, Michigan and New York State. The Dideron strain (D) appears to be the primary strain present however one or more other strains would appear to be present. On page 143 of the document it is stated that: "....nearly all American PPV isolates are PPV D."
Details of any other strains would be useful as this may have a bearing on the potential for seed transmission of the virus should spread of the virus occur into the proposed export production areas.
The Glossary (Appendix C) provides the following definition of Unrestricted risk - "'Unrestricted' risk estimates apply in the absence of risk management measures." Our interpretation of this in relation to the presence of PPV in Pennsylvania, Michigan and New York State is that the URR estimate should be undertaken in the absence of the current quarantine controls. In this instance the probability of importation should be reassessed as Low.
Such a reassessment of the PRA for PPV is likely to yield an unrestricted risk of Very low and thus a requirement for the application of appropriate risk management measures.
The presence of both susceptible hosts, the range of known PPV aphid vectors within Australia and the high potential consequence of the virus highlights the need to continue to take a precautionary approach to the import of potential vectors of the virus including seed, fruit and host propagation material.
Pest Risk Management
Critical that appropriate risk management measures are employed. In relation to Apple Maggot, the difficulty for Australia will be the early detection of an incursion. This is based upon the absence of suitable trapping regimes for Rhagoletis sp generally within the current Australian fruit fly monitoring systems including the National Ports Surveillance program. Australia must be satisfied either that area freedom can be demonstrated or that USDA APHIS can provide details of an effective disinfestation regime for this important pest species.
Plum pox virus
In relation to the assessed HIGH consequences of an incursion of Plum Pox Virus in Australia, it is recommended that the pest risk management measures for any future stone fruit imports from California, Idaho, Oregon and Washington include reference to the continued application of internal quarantine controls within the USA; including fruit, host plant materials and nursery stock (including ornamental hosts). Such controls should also include the maintenance of area freedom within the designated export States based upon both national surveys to detect PPV and on-going monitoring of the proposed production areas by crop scouts trained in the recognition of the virus. Such surveillance should recognise the potential for PPV to be symptomless in some hosts.
Three quarantinable thrips (Frankliniella intonsa, F tritici and Taeniothrips inconsequens) have been identified as part of the Draft IRA process. Given the small size and cryptic nature, the identified thrips species are likely to be difficult to detect on infested fruits. It is therefore recommended that the AQIS inspection processes plus any pre-export inspection by USDA APHIS include the use of stereomicroscopes and / or "magi-lamps" plus suitable supplementary lighting for the examination of the required fruit samples. This should be explicitly stated as part of the subsequent inspection requirements.
Apart from the comments above, the document appears to provide a comprehensive assessment of the risks associated with potential future imports of stone fruit from the US States of California, Idaho, Oregon and Washington.
Primary Industries and Resources SA
Disclaimer: The department received this submission in hardcopy only, which has been converted into an accessible format to meet Australian Government accessibility requirements. While due care was taken to ensure the information was reproduced accurately, the PDF should be considered the original document for official purposes.