Department of Primary Industries & Water
PO Box 46
+61 3 6336 5414 Telephone
27 June 2008
GPO Box 858
CANBERRA ACT 2601
Dear Mr Cahill
Tasmanian Government Submission: Draft IRA Report for Fresh Stone Fruit from western USA
Thank you for your letter of 20 June 2008 confirming arrangements for commenting on the Draft Import Risk Analysis Report for Fresh Stone Fruit from California, Idaho and Washington, April 2008, as per the new regulated IRA process.
Accordingly, please find attached the Tasmanian Government’s submission describing technical issues identified by the government/industry Working Group considering this matter.
The Working Group would welcome an opportunity to discuss, and as necessary, provide further advice as the IRA proceeds to finalisation. As Chair of that Working Group, I would be pleased to receive any inquiries about the submission on (03) 6336 5414 or Cindy.Hanson@dpiw.tas.gov.au.
BIOSECURITY POLICY BRANCH
This submission has been prepared on behalf of the Tasmanian Government by a Working Group comprising staff from the Department of Primary Industries and Water, and a representative of the peak Tasmanian fruit growers’ industry body, Fruit Growers Tasmania. The Working Group was specifically convened because stone fruit from western USA potentially pose a direct biosecurity threat to the prospects of Tasmania’s stone fruit industry, and to other plant industries in this State that might also be affected by pests and diseases associated with the proposed imports.
However, Tasmanian Government believes the potential ramifications of new pests and diseases on stone fruit from western USA entering and establishing in Tasmania, go beyond this State’s stone fruit industries and other enterprises based on plants that could also directly host the pests and diseases concerned.
Our favourable biosecurity status is integral to, and at the heart of, the Tasmanian brand, and hence our ability to maintain and position ourselves as a unique source of a broad range of quality, natural produce and products for discerning national and international markets. Accordingly, a biosecurity threat to any single industry, such as stone fruit, is also a threat to how the whole Tasmanian brand is perceived and valued in the market.
Further, Tasmania’s small size and reliance on primary industries means that even a modest impact on one industry can have relatively greater impacts on the State’s economy and people, than is the case for other larger, more diverse mainland economies.
These characteristics of the Tasmanian situation inform the following comment on the Draft Import Risk Analysis Report for Fresh Stone Fruit from California, Idaho and Washington, April 2008 (IRA).
2. IRA Section 2 - Pest Risk Analysis Method
2.2.1 Pest categorisation
There are a number of pest categorisation decisions about which some additional clarification is required from a Tasmanian perspective. Issues associated with pests excluded from further analysis are described at Attachment A of this submission, which includes some further distributional information from the Tasmanian Plant Pest Database (TPPD), while Attachment B lists some excluded nematodes and pathogens about which Tasmania also has concerns. Please note Attachments A and B do not represent a complete analysis of all organisms identified for categorisation. Further comment is available from the Working Group on request.
1. The Tasmanian Government requests that BA review Appendix A of the IRA against Attachments A and B of this submission, and reconsider its decision to exclude the organisms identified in those Attachments from further analysis. It notes that additional comment about categorisation is available from the Working Group.
2.2.2 Assessment of probability of entry, establishment and spread
The broad issue is that the method for estimating the likelihood of entry, establishment and spread does not have sufficient regard to the kinds of uncertainties that typically attend predictions of complex biological and ecological interactions. We believe this results in a less conservative approach to estimating biosecurity risk against ALOP.
By nature, it is challenging to describe qualitative likelihood clearly and in a way that can be interpreted consistently by all stakeholders. However, applying numerical descriptions in the form of probability ranges to qualitative likelihood categories gives the misleading impression that there is a unique mathematical solution to likelihood, and that uncertainties about how a particular pest might behave or respond in a certain environment can be dealt with by invoking numbers. This approach does not reflect the true complexity of biosecurity risk.
Assignment of probability ranges to qualitative likelihood statements is also problematic because the current probability ranges and associated written descriptions arguably, do not reflect community expectations of acceptable risk. For example, it is possible for ALOP to be met if, in the course of a single year’s trade, risk is the product of a one in twenty chance of entry, establishment and spread, and the pest can be expected to have a moderate impact. It is unlikely that the community would find this a reasonable interpretation of acceptable biosecurity risk. The Lygus bugs and potato bug fall into this category.
2. The Tasmanian Government recommends use of indicative probability ranges to supplement the description of qualitative likelihood should be discontinued for all IRA work, and greater emphasis given to modifying the descriptive definitions, so that when considered against magnitude of impact, community expectations for acceptable risk are better represented.
The problem described above is compounded by the rules used to combine qualitative likelihoods for entry, establishment and spread, to yield an overall L (EES). When the same likelihoods are combined, whether for import and distribution, or entry, establishment and spread, application of the rules gives an estimate that is one class lower (ie. moderate x moderate = low), except in the case of high likelihoods. While the case for this can be made with reference to the current probability ranges, the effect of these rules is that likelihood estimates are always driven down. This is a less conservative approach that is not appropriate, especially in situations of uncertainty.
However, we acknowledge that some means of considering likelihoods collectively is required.
3. The Tasmanian Government recommends a more appropriately conservative approach to estimating likelihood of entry, establishment and spread could be achieved by replacing the current Table 2.2 matrix of rules in the IRA with:
“When two likelihoods are different, the overall likelihood is the lowest of two likelihoods, and when two likelihoods are the same, the overall likelihood is that same likelihood”.
3. IRA Section 3 – Stone Fruit Industry Information
3.2 The Australian stone fruit industry
It is worth describing the Australian stone fruit industry in some detail since it is the sector likely to be most adversely affected, should biosecurity risks potentially associated with USA stone fruit come to bear, although we note it is not the only sector that could be affected (eg. walnuts, oaks bearing truffles etc).
However, gross production and export figures alone do not give a comprehensive picture of what is potentially at risk. Without this, it seems difficult to form any clear idea of the magnitude of potential impact. For example, from the current description, it can be deduced that Tasmania accounts for about 1 per cent of national stone fruit production, and while not stated in the IRA, the implication is that this sector in Tasmania is somewhat insignificant. It follows that any impact upon the stone fruit industry in Tasmania could therefore be expected to be of little importance to this State. This is not true.
Section 2.2 could be used to better illustrate what is at risk by presenting an analysis of the industry in terms of challenges it faces, levels of investment, growth or decline, and the relative importance of that growth or decline to the areas in which it is occurring. We understand figures could be gathered without too much trouble, which could inform a more robust and meaningful industry description, and hence, impact assessment.
For example, of the Tasmanian stone fruit industry, the following can be said:
“Most sectors of the Australian deciduous tree fruit industry are currently experiencing difficulty due to climatic and international trade issues such as reduced international quarantine market access and the higher value of the Australian dollar.
Despite these setbacks, the Tasmanian fruit industry demonstrates a high degree of resilience. It continues to show strong growth through investment of $50 million over the past five years in new orchard planting, packing and processing infrastructure to meet increasing consumer demand for high quality product within Australia and in international markets. The local industry anticipates that a further $50 million will be invested in the Tasmanian fruit industry over the next five years.
Investment in the Tasmanian fruit industry is being driven by the knowledge that financial rewards can be gained by providing premium quality product for the upper end of world markets.
However, the biggest and most positive influence that has attracted recent investment in Tasmania’s tree fruit industry is the opportunity that exists to gain international market access for Tasmanian produce due to Tasmania’s unique quarantine status.
Currently, mainland industry counterparts are excluded from some of the most lucrative markets such as Taiwan and Japan. Combined with adverse climatic conditions, many mainland growers are reported to be investigating moving their established orchard businesses from the mainland to Tasmania.
In recent years the Tasmanian stone fruit industry, particularly cherries, has expanded rapidly. Industry figures show that last season the Tasmanian cherry crop increased by some 60% and a further 20% expansion is expected this season. It is expected that by 2010-2011 the Tasmanian cherry crop will double to a crop in excess of 7000T. Similar growth is also occurring in apricots and apples”.
4. The Tasmanian Government recommends that BA include information in the IRA that describes more comprehensively the industries potentially at risk, to better inform the impact estimates.
4. IRA Section 4 – Pest Risk Assessments for Quarantine Pests
Comments specific to the pest risk assessments are at Attachment C of this submission. Please note Attachment C does not represent a complete analysis of all PRAs in Section 4 of the IRA. Further comment about PRAs for pathogens, for example, is available from the Working Group on request.
5. The Tasmanian Government requests that BA reconsider the pest risk assessments in the IRA against the information provided in Attachment C of this submission. It notes that additional comment about the risk assessments for other pests and diseases is available from the Working Group.
In addition, we make some general observations, mostly in relation to consequence estimates.
Plant life or health impacts
The IRA identifies alternative hosts for the assessed pests and diseases but for several, does not adequately describe some significant distribution patterns of these hosts which could be expected to influence impact, and likelihood of entry, establishment and spread, especially of polyphagous pests. The intensive nature of agriculture that commonly occurs in many fruit growing districts means there is elevated opportunity for significant harm to occur in these areas. For example, many stone fruit orchardists also grow other commercial crops including grape vines, apples and pears, berries including blueberries, olives, rhubarb, potatoes etc. In Tasmania, stone fruit orchards are often adjacent to other commercial farms, orchards, vineyards and so forth. It is predicted that this will become increasingly so as more development occurs around water resources, particularly in areas such as the Derwent Valley, Tamar Valley and Huon Valley.
6. The Tasmanian Government recommends that alternative host distribution should be more clearly characterised in the IRA, and that BA should consider in more detail how host distribution affects the likelihood and consequence estimates, and adjust these accordingly.
Trade impact estimates
The scoring for international trade does not adequately assess, and hence may underestimate, the potential magnitude of impact of some of the pests and diseases. The statement “may impact on trade with overseas markets” is insufficient because it does not identify which markets in particular could be affected, or the potential extent of that impact. For example, in the case of Tasmania, loss of the Taiwan market could be expected to have a dramatic impact. Pests to which the statement “may impact on trade with overseas markets” (or similar) is applied include: Walnut Husk Fly, Apple Maggot, Plant bugs (Hemiptera), Armoured scales, Mealy bugs, Peach twig borer, Leafrollers, filbert worms, Grapholita spp, Thrips, Xylella, Blumeriella, Podosphaera, and Plum Pox.
7. The Tasmanian Government recommends countries that list a pest or disease assessed in the IRA as a pest of quarantine concern, and the Australian jurisdictions that export to those countries, should be clearly identified in the IRA so that likely international trade impacts are more explicitly described. It requests that BA reconsider the scoring for international trade impacts based on this information.
In addition, the IRA generally concludes domestic trade impacts manifest mostly at the local or district levels. However, domestic trade restrictions that could be imposed in the event of an incursion associated with a new stone fruit pest or disease, may well have regional or nationally significant impacts. This is because Australia’s urban fruit markets operate on a national basis around sequences of fruit availability, from early harvests in the northern districts (eg. granite belt, QLD) to late harvests in the south (eg. Tasmania) to achieve supply continuity throughout the year. Supermarkets also operate on a national basis and continually move fruit and vegetables long distances across the country. Therefore it is difficult to see why domestic trade impacts are assessed mostly as significant at local and district levels.
Further, if the new incursion is a polyphagous pest, a potentially wide range of plant products not limited to stone fruit may have to be regulated, which may have regional or national consequences. In Tasmania, the expanding walnut industry to which Walnut husk fly is relevant, is a case in point. In 2005 it sent nuts intended for domestic sale to Vietnam for shelling and canning, prior to reimport to Australia. So, while the product is sold in Australia, its offshore processing means it must meet and is susceptible to international quarantine requirements.
8. The Tasmanian Government recommends that these issues should be clearly identified in the IRA, and that BA should consider how the nationally-integrated character of fruit and vegetable trade affects the consequence estimates, and adjust these accordingly.
Eradication, control impacts etc
Although the IRA states that some of these pests and diseases could be controlled by chemical means if introduced to Australia, it does not name the relevant chemicals. In Tasmania, strict chemical spraying programs are in place to meet the residue restrictions imposed by our major trading partners eg. Japan, USA, Taiwan and Europe. Therefore, although there may be effective chemical treatments for these pests and diseases, Tasmanian growers may not be in a position to use them if they wish to export overseas. Also, we note that some chemicals registered for use in mainland jurisdictions are not registered for use in Tasmania.
Furthermore, one of Tasmania’s main product integrity market advantages is relatively restricted use of chemicals, made possible by our favourable pest status. The introduction of new pests and diseases could require increased chemical usage which could affect pest resistance mitigation strategies, and undermine current sustainability objectives, and values of the Tasmanian orchard industry. In creased chemical use could also be expected to have more far-reaching brand impacts.
9. The Tasmanian Government recommends that the chemicals concerned and current registration status should be clearly identified in the IRA so that it is more apparent whether and in which jurisdictions these chemicals represent feasible control options. Where there are differences, we request BA adjust the indirect impact scoring accordingly.
The low scores for potential environmental impact appear to be based on absence of evidence rather than evidence. We acknowledge the difficulty in predicting environmental impacts of pests and diseases known primarily for their effects in production systems but believe nonetheless that it is insufficient to assign a low score on the basis of ‘no known consequence’.
10. The Tasmanian Government recommends that the IRA should be amended to clearly articulate that low scores for environmental impact are based on assumption, unless potential for impact in the environment has been specifically tested and there is evidence to suggest consequences are likely to be insignificant.
5. IRA Section 5 - Pest Risk Management
We understand that the unrestricted risk estimates take into account commercial production practices in western USA, including post-harvest cleaning and packing. However, we make the following point in regard to those practices and processes.
Peento peaches, which are flat and have to be hand-graded and packed directly from field bins, may well pose different unrestricted risk to other fruit which pass thorough rollers, brushes etc. For example, reliance on multiple graders and packers, and variation between diligence of individual graders and packers may give rise to a greater chance that pests and diseases persist with the fruit, compared with mechanical brushing. The IRA points out the different processing procedures for these peaches but is subsequently silent about whether or not this particular fruit might present a different risk profile.
11. The Tasmanian Government suggests the risk profile of peento peaches should be more fully described and considered in the IRA.
We further note that import conditions cannot be finalised for two of the pests (apple maggot and peach twig borer) for which unrestricted risk exceeds ALOP until after APHIS has submitted additional information about treatment efficacy. Similarly, while methyl bromide is identified as adequate for remedial treatment of thrips, mealybugs and leafrollers detected during visual inspection, APHIS may also propose alternative remedial treatments as long as these provide an equivalent level of protection. Further, additional information in regard to pest free areas, pest free places of production, pest free production sites, and areas of low pest prevalence for Grapholita moths, is invited.
It is not clear whether and what opportunity exists for stakeholders to examine additional information about risk mitigation that may be subsequently submitted by APHIS. If this information is used to inform the development of operational systems for maintenance and verification of phytosanitary status, we observe that this process can be highly unsatisfactory from a consultation perspective. The Tasmanian Government has previously requested drafts of operational plans, only to be advised that while a departmental officer could view and offer comment on those drafts, he or she would not be able to discuss them or any other aspect of operational system development with agency colleagues. The confidentiality requirements around the development of operational plans are clearly a barrier to the ability of jurisdictions to adequately understand and comment upon management of risks identified in the IRA. Until that barrier is removed and the process becomes more transparent, it is difficult for stakeholders to be satisfied that import conditions will reduce unacceptable risks to ALOP.
12. The Tasmanian Government requests that opportunities for stakeholders to review additional risk mitigation information that may be provided by APHIS, is clarified in the IRA. It further recommends that confidentiality constraints surrounding the process for developing operational plans should be reduced so that stakeholders can make meaningful assessments of whether import conditions achieve an acceptable level of risk mitigation against ALOP.