professor shergold - first report
Four-Monthly Report to the Minister for Agriculture, Fisheries and Forestry, the Hon. Tony Burke M.P. on the Implementation of the Callinan Inquiry (No. 1, October 2008)
I have been engaged as an independent expert to provide regular assessments on the implementation of the government’s response to the Equine Influenza Inquiry.
Since appointment in July 2008 I have become well-acquainted with the 38 recommendations of the Callinan Inquiry, the Rudd Government’s positive response and the detailed implementation plan which has been agreed.
I have been kept apprised by the Department of Agriculture, Fisheries and Forestry and the Australian Quarantine and Inspection Service (AQIS) of developments. I have read AQIS’s written summary of the administrative response to each recommendation, as provided to me earlier this month. I have also been copied in to the fortnightly reports prepared by the department for yourself.
On 18 July 2008 I was provided with detailed oral briefing and, following that, given the opportunity to comment on the proposed project management plans. On 3 October 2008 I met and discussed implementation measures with relevant department managers including, in particular, Dr Ann McDonald and Mr Scott Channing (Animal Quarantine Branch, AQIS); Ms Fran Freeman and Mr Cameron Hutchison (Quarantine and Biosecurity Policy Unit, DAFF); and Dr Colin Grant, Dr Mike Nunn and Dr Robyn Martin (Biosecurity Australia). I also had a working lunch with Dr Conall O’Connell (Secretary, DAFF) and Dr Cliff Samson (Executive Director, AQIS).
I have also met with Mr Roger Beale AO on 18 July 2008 to discuss his approach to the review he chaired on biosecurity and, on 3 October 2008, with Dr Hugh Millar (Expert Group member and Victorian Chief Veterinary Officer) and the newly-appointed interim Inspector-General of Horse Importation, Dr Kevin Dunn.
On 5 August 2008 I took the opportunity to watch at first-hand the importation of a group of six ‘shuttle stallions’ arriving from Europe. At Sydney Airport I inspected the conditions on board the aircraft; witnessed the stallions being off-loaded, transported across the airport by tug, corralled and loaded onto trucks; followed them to the Eastern Creek Quarantine facility; saw them offloaded, visually inspected by a veterinary officer and stabled; and finally examined the cleaning of the horse trucks and showering required of the drivers. It gave me a clear understanding of the procedural challenges involved in significantly reducing the risk of equine influenza spreading post-arrival and the new measures being put in place to meet that objective.
It is my considered and informed judgment that the planning of the department’s response to the Callinan Inquiry recommendations, and its implementation through to October 2008 has been of a high standard and undertaken with a necessary sense of timeliness. The documentation of new procedures is of a good quality. I am assured by the level of project management.
Significant resources are being assigned to reducing the risk of a further outbreak of equine influenza to a minimum. Nevertheless it is important to emphasise that no processes, however well delivered, can eliminate the risk of a virus that is endemic in Europe and North America.
A great deal is being done to lower the risks of virus entering Australia and then, potentially, spreading rapidly through respiration by close direct contact between horses and those who handle them. According to the field guide published in 1995 by the Bureau of Resource Sciences, (W.A. Geering et. al. Exotic Diseases of Australia) a horse can excrete the virus for up to 8 days after initial infection, transmit it up to 35 metres by cough and by up to 8 km through windborne spread, with the virus retaining infectivity in the environment for up to 36 hours. While I am comforted by assurances from veterinary officers that this account may be somewhat exaggerated, it emphasises how challenging is the task of eliminating the risk of outbreak in Australia.
The heart of the administrative task is to limit to a minimum contact with horses between their arrival in Australia and the conclusion of their period of quarantine; to reduce the opportunity for horse to horse transmission; and to ensure that those people who do need to be proximate to the horses scrupulously follow procedures to prevent contamination.
It is my view that the processes being established by AQIS meet those objectives. The Standard Operating Procedures, AQIS Instructional Manual and Work Instructions (which were workshopped with AQIS staff on 7 October 2008) are comprehensive. The emphasis on documentation is well-conceived. Nevertheless, careful attention to paperwork will not of itself fully assure stringent adherence to procedures in the field. It is my opinion that the written guidelines, with training, will need to be supplemented by systematic inspection of facilities and operations, both in Australia and overseas. Regular observation of actual practice is imperative.
I set out for your consideration a summary of the progress of implementation measures in the accompanying Attachment.
Aside from providing you with assurance that the administrative processes are giving full effect to the government’s public commitments, I thought it would be of some value to alert you to issues which you may wish to consider going forward.
Too many players?
I have some concern at the range of bureaucratic stakeholders involved in the provision of advice and delivery of initiatives. Apart from my own oversight brief, and the on-going roles of the Quarantine and Biosecurity Policy Unit of DAFF and the Animal Quarantine Branch of AQIS, you have now appointed (as recommended) an interim Inspector-General of Horse Importation for 2 years. Concurrently the Expert Group is focussing on post-arrival measures, especially infrastructure, and will report to you in February 2009, at the same time that Biosecurity Australia will report to you on pre export quarantine (PEQ) and post arrival quarantine (PAQ) measures. Biosecurity Australia is also, of course, undertaking an Import Risk Analysis (IRA) on horse importation which is to be completed by January 2010.
While it would appear that attempts are being made to ensure effective coordination between the different players (e.g. by a member of Biosecurity Australia having an ex-officio role on the Expert Group) there is an ever-present danger of duplication of effort and/or conflict of approach. Bureaucratic silos carry the risk of territoriality. Certainly the manifold range of external stakeholders, many represented on the Horse Industry Consultative Committee, may be confused as to respective roles and lines of authority.
Is an Inspector-General of Horse Importation justified?
My primary role is to provide assurance that the recommendations of the Callinan Inquiry are being implemented. That Inquiry saw the appointment of an Inspector-General as crucial. However, as I examine the extraordinary efforts being put into preventing the entry of equine influenza, I do question whether the overall distribution of resources available for biosecurity may become artificially distorted (a not uncommon outcome in responding to a particular crisis).
I have not had access to the report which Mr Roger Beale AO handed to you on 30 September 2008 although, as indicated above, I have had oral discussions both with Mr Beale and the head of his secretariat, Ms Freeman. Without being privy to the conclusions of the independent panel reviewing Australia’s quarantine and biosecurity arrangements, and based only on my sense of the emphasis necessarily being placed at present on horses, I think that it would be sensible to re-examine the role of the interim Inspector-General of Horse Importation in the light of broader concerns on the inspection and audit of biosecurity operations.
Biosecurity is a highly resource-intensive business. It is apparent that there are significant new requirements necessary to give full effect to the new horse importation procedures: additional staff (including guards); upgraded facilities and more equipment (everything from overalls to disinfectant). The interim daily fee of $165 initially set will not be sufficient to meet the costs which must be borne by the importers of about 600 horses (of which only 10-15 percent are ‘shuttle stallions’ with the capacity to pay their mounting costs).
I anticipate that, by February 2010, when the new cost recovery budget is to be decided, the financial burden to be borne by importers will have risen very significantly – and certainly they believe that to be the likely outcome. Instead of a sudden, sharp hike in fees, you may wish to consider a series of interim steps. I believe it is likely that, as the full costs of the required importation measures become more apparent, that the pressure from importers for the government to consider alternative vaccination processes will increase. It is important to prepare for this eventuality.
It is not surprising that the implementation of proposed new pre-export controls has proved challenging for AQIS. The appointment of Dr Dunn, and his ability to visit key facilities overseas, will help to re-establish trust and goodwill with countries such as the United States, the United Kingdom and Ireland which are somewhat reluctant to comply fully with new arrangements.
The United States, for instance, has proposed an alternative approach to blood sampling of horses. The Callinan Inquiry recommended that during PEQ a blood sample is to be collected, half of which is to be stored in the US and the other half sent to Australia. The US, concerned about the chain of custody, proposed instead that a USDA accredited veterinarian hold the American sample for 30 days.
Construction of showers on American farms and ranches proved another problem. Instead it was proposed that all personnel entering PEQ premises shower beforehand, wear protective outer clothing and footwear used exclusively in the premises and wash their hands and face before handling animals.
These have been agreed as interim measures. On the basis of supportive advice from Biosecurity Australia (5 September 2008, File 2007/25179) I believe that this is an appropriate outcome pending the completion of the horse IRA.
In order to improve security at the Eastern Creek and Spotswood Quarantine Stations the Callinan Inquiry recommended that there be installed, as soon as practicable, a means of electronic surveillance, including closed-circuit television.
I understand that some consideration is now being given as to whether it is better to use scanin/ scan-out security cards. My opinion is that if the Expert Group, reporting in February 2009, think that this (or a combined) approach provides a more effective form of security, that advice should be accepted. The important thing is to implement the substance of the Government’s response to the Callinan Inquiry, rather than to treat each specific action as a biblical truth carved in stone.
A more substantive challenge is likely to be presented by Sandown, a part-time quarantine facility held up as best practice by Commissioner Callinan. The impending problem is whether the facility, operated during the racing seasons by Racing Victoria Ltd, can continue to be maintained by them, particularly given the need to acquire appropriate insurance coverage. I understand that the lease of the operation may also be in doubt. Given the importance of the facility to the opportunity for overseas horses to compete in Australian races, I consider it prudent to develop some policy options as soon as possible.
I have been impressed with the efforts being taken to implement the Government’s response to the recommendations of the Callinan Inquiry and grateful for the professional secretariat support with which I have been provided.
I anticipate that, prior to my second report, I will follow the importation of horses through Tullamarine/Spotswood and hold discussions with a range of external stakeholders including those on the Horse Industry Consultative Committee. I have accepted, in principle, an invitation to undertake a day of farm inspections organised by Thoroughbred Breeders’ Australia. In all instances I will confirm arrangements through your department.
Professor Peter Shergold AC
Attachment: Summary of Progress
Overall, good progress has been made in implementing the Equine Influenza Inquiry Response Project (EIIRP). AQIS has been working closely with Biosecurity Australia, the Quarantine and Biosecurity Policy Unit in the Department of Agriculture, Fisheries and Forestry and industry stakeholders to implement the government’s response, particularly the new biosecurity measures recommended by Commissioner Callinan.
All of the deliverables are on track with a number having been completed ahead of schedule and others well advanced and expected to be completed by their due date. Notable achievements to date have been the revisions to interim quarantine measures by Biosecurity Australia, updated import conditions and AQIS instructional material, the establishment of the Horse Industry Consultative Committee (HICC) and appointment of the interim Inspector General of Horse Importation. Specific information on each of the EIIRP deliverables is provided below.
1FR-1 Updated Quarantine Act 1908
Due: On-going – 1st milestone – Sept 2008
The first milestone has been met. The component of this deliverable relating to the interim fees for horses at government quarantine stations has been completed. The Minister signed the Quarantine Service Fees Determination 2005 on 5 September to give effect to recommendation 38. The fee for thoroughbred stallions temporarily imported into Australia has increased to $165 a day and the fee for all other horses is $65 a day. The new fees came into effect on 1 October 2008.
The review of the Quarantine Act 1908 to ensure it clearly confers all relevant powers to quarantine officers will commence after the Quarantine and Biosecurity Review reports its findings and recommendations.
Several potential areas requiring amendments have already been identified in the Officer Responsible for Horse Importation report to the Executive Director of AQIS (see 3RR-8).
1FR-2 Updated Horse Import Budget
Due: Feb 2010
This deliverable has not commenced and will not do so until a comprehensive fee review of horse imports is completed.
1FR-3 Updated Import Conditions
Due: On-going – 1st milestone - Oct 2008
The first milestone has been met. Initial updates to AQIS import conditions for horses, incorporating recommendations and findings from the Equine Influenza Inquiry report such as horse testing times, blood samples and provision of documentation to AQIS prior to import, have been completed. Permanent import conditions have been updated for horses from the United States, Members States of the European Union, United Arab Emirates, Singapore, Hong Kong and Macau. Only permanent import conditions for horses from Fiji and New Caledonia remain to be updated but these are a lower priority as there have not been any imports from these countries in many years. As at 30 September 2008 permanent and temporary (for racing) import conditions have been updated for imports from Member States of the European Union and Macau. Import conditions for the re-importation of Australian horses have been updated for Hong Kong for Olympic and Paralympic competitors as well as Macau. This represents all countries from which horses are currently being imported into Australia.
On 18 September 2008 Biosecurity Australia announced revised interim quarantine measures for permanent and temporary imports, and re-importation for all countries from which Australia allows horse imports (also refer to 3RR-2). All AQIS import conditions including those mentioned above will be updated to reflect the new interim quarantine measures.
1FR-4 Updated AQIS Instructional Material
Due: On-going – 1st milestone – Jan 2009
This deliverable is on track. Initial updates to all AQIS instructional material relating to the importation of horses has been reviewed and updated in consultation with AQIS regional staff, Biosecurity Australia and industry stakeholders. The updated instructional material has been placed on the AQIS intranet. Further amendments will be made once reviews are underway and if they inform further change.
1FR-5 Other Airports and Ports Arrangements
Due: June 2010
This deliverable is on track. Preliminary discussions on quarantine and biosecurity arrangements for horse imports at airports and ports other than Sydney and Tullamarine airports were held at the first meeting of the AQIS Horse Industry Consultative Committee (HICC) on 30 July 2008. Further discussions will be held at the next HICC meeting on 29 October 2008.
2P-1 Appointed Interim Inspector General of Horse Importation
Due: Sept 2008
This deliverable is complete. The Minister announced the appointment of Dr Kevin Dunn as the interim Inspector General of Horse Importation on 11 September 2008.
2P-2 Appointed Inspector General of Horse Importation
Due: Jan 2009
The Quarantine and Biosecurity Review Panel was tasked to provide specific advice on how an inspector general position should be designed and implemented. The panel submitted its report to the Minister of Agriculture, Fisheries and Forestry on 30 September 2008. The Minister will consider the report in detail before releasing it and providing a government response.
2P-3 Appointed Officer Responsible for Horse Importation
Due: Jun 2008
This deliverable is complete. On 20 June 2008 the Secretary announced Dr Ann McDonald as the AQIS Officer Responsible for Horse Importation. 2P-4 Expert Group Established Due: Aug 2008 This deliverable is complete. An Expert Group chaired by the Commonwealth Chief Veterinary Officer, Dr Andy Carroll, and comprising representatives from the Animal Health Committee, Australian Animal Health Laboratory and Equine Veterinarian’s Association has been established. Biosecurity Australia will be an observer on the Expert Group. At the first meeting of the Expert Group on 5 September 2008 members agreed to their terms of reference and terms of engagement. The Expert Group visited Melbourne from 10-12 October 2008 and met with industry stakeholders, observed the arrival of a shipment of horses and inspected facilities at Melbourne Airport and Spotswood and Sandown Quarantine Stations.
2P-5 Appointed Import Risk Analysis (IRA) Team Leader
Due: Jun 2008
This deliverable is complete. On 20 June 2008 the Secretary announced Dr Mike Nunn as the team leader of the import risk analysis for horse imports.
2P-6 Consultative Arrangements Established
Due: Aug 2008
This deliverable is complete. AQIS has established the Horse Industry Consultative Committee (HICC) comprising representatives from the Australian Horse Industry Council, Australian Racing Board, Equestrian Federation of Australia, Australian Harness Racing, Thoroughbred Breeders Association, Racing Victoria Limited, Australian Veterinary Association, Quarantine and Export Advisory Council as well as major horse importers and airport representatives. The first meeting of the HICC was held on 30 July 2008. The terms of reference for the HICC and meeting minutes are available at: http://www.daffa.gov.au/aqis/about/clients/consultativecommittees/hicc.
The Officer Responsible for Horse Importation held a meeting with state and territory chief veterinary officers (CVOs) on 15 July 2008 to provide an overview of the government’s response to the Equine Influenza Inquiry report and the EIIRP. AQIS agreed to provide regular updates on the implementation of the government’s response to the state and territory CVOs at Animal Health Committee meetings.
2P-7 Appointed and Trained AQIS Personnel
Due: On-going – 1st milestone – Aug 2008
The first milestone has been met. A Horse Import Program has been established in AQIS to implement the EIIRP and manage horse imports on a day-to-day basis. New staff have been appointed and trained in the Canberra office and staffing levels at the quarantine stations were reviewed. Following this review staff levels at Eastern Creek and Spotswood Quarantine Stations have been increased for 2008/09 to manage horse imports in accordance with the updated instructional material. Staffing levels in the Horse Import Program will continue to be monitored to ensure activities and measures required under the instructional material are performed properly.
Soft-copies of AQIS instructional material have been placed on the intranet site and hard copies of all material are located at premises where activities are performed. Staff have been advised where to locate both the soft and hard copies of instructional material. Staff currently undertaking horse importation activities are all trained. They are aware of and understand the updated work procedures. Staff training needs are being continually assessed as instructional material is updated.
2P-8 Trained/Informed Non-AQIS Personnel
Due: On-going – 1st milestone – Oct 2008
The first milestone has been met. AQIS has amended instructional material to make it a condition of entry for all non-AQIS personnel to a quarantine station to report any suspected breaches of quarantine procedures. All non-AQIS personnel entering government quarantine stations are briefed on the new procedures and sign a declaration agreeing to comply with all conditions of entry before they are authorised to enter the quarantine station.
A new work instruction has been completed for security personnel at quarantine stations and quarantine station managers have provided training to all security personnel to inform them of their duties and biosecurity risks.
3RR-1 Pre Export Quarantine Review Report
Due: Feb 2009
Biosecurity Australia has commenced work on this deliverable by conducting visits to the United States, the United Kingdom, Ireland, the United Arab Emirates, Germany, Macau, Hong Kong and Singapore to review pre export quarantine (PEQ) arrangements. Further visits to the United Kingdom and Ireland have been conducted by the Department of Agriculture, Fisheries and Forestry’s Agricultural Counsellors for horses travelling to Australia for the 2008 Melbourne Cup.
3RR-2 Interim Quarantine Measures Review Report
Due: Sept 2008
On 18 September 2008, Biosecurity Australia provided advice to AQIS and stakeholders on amended interim quarantine measures. The quarantine measures have been updated for all countries (excluding New Zealand) from which Australia currently imports horses – including Canada, the European Union, Hong Kong, Macau, Singapore, Switzerland, the United Arab Emirates and the United States. Previous advice was provided to AQIS on amended interim measures on 2 and 9 July 2008 for the United States and the European Union, 30 July 2008 for Macau, 5 August 2008 for Singapore and Hong Kong and 22 August 2008 for Australian horses returning after competing in Olympic equestrian events.
The amendments included specifying equine influenza strains in vaccines, collection of blood samples during pre export quarantine (PEQ), additional equine influenza testing requirements and changes to the operational arrangements during PEQ and post arrival quarantine.
Discussions are continuing with some countries on available equine influenza vaccines containing updated strains and on the timing of testing for equine influenza in PEQ (to ensure this is as close as practicable to the end of the PEQ period).
Biosecurity Australia has not updated the conditions for the importation of horses from those countries from which there have not been imports for some considerable time (i.e. Fiji, New Caledonia, Norfolk Island and Norway).
3RR-3 Post Arrival Quarantine Review Reports
Due: Feb 2009
This deliverable is on track. There are two post arrival quarantine (PAQ) review reports to be prepared. Firstly, an Expert Group will inspect and review facilities at the airports and quarantine stations and provide advice to AQIS on biosecurity containment. Secondly, Biosecurity Australia officers have visited PAQ stations in Sydney and Melbourne and further visits are planned. Where possible joint visits to PAQ stations with the interim Inspector General of Horse Importation, Expert Group and Biosecurity Australia have been arranged.
In relation to the Expert Group PAQ Review Report, an initial meeting of the Group has been held and the terms of reference and terms of engagement have been agreed. To help facilitate the various inspections and reviews to be undertaken a horse importation workshop was held between the Expert Group, interim Inspector General, Biosecurity Australia, AQIS and representatives of the HICC. The various parties agreed on the tasks to be completed and would develop workplans by October 2008.
On 10-12 October 2008 the Expert Group inspected facilities at Tullamarine Airport, Spotswood and Sandown Quarantine Stations. It is anticipated that they will inspect facilities at Sydney Airport and Eastern Creek Quarantine Station in late November.
3RR-4 Import Risk Analysis Review Report
Due: Jan 2010
Dr Colin Grant, Chief Executive, Biosecurity Australia announced the formal commencement of the import risk analysis (IRA) on 30 September 2008. The import risk analysis is to cover the importation of horses from countries and regions from which Australia currently permits such importation. These include Canada, the European Union, Hong Kong, Macau, New Zealand, Singapore, Switzerland, United Arab Emirates and the United States. The IRA will also cover horses from Japan.
Some preliminary work has been undertaken on the IRA and an expert panel has been identified to assist Biosecurity Australia in its consideration of the scientific issues during the risk analysis. The IRA will be led by Dr Mike Nunn, Principal Scientist, Animal Biosecurity. The expert panel will comprise Dr Patricia Ellis (Animal Health Consultant), Dr James Gilkerson (Director, Equine Infectious Disease Laboratory and Centre for Equine Virology, University of Melbourne) and Dr Hugh Millar (Expert Group member and Victorian Chief Veterinary Officer).
3RR-5 Interim Inspector General of Horse Importation’s Report to the Minister
Due: Apr 2009
This deliverable is on track. The interim Inspector General of Horse Importation commenced in his position on 19 September 2008. He advised his initial workplan on 7 October 2008.
3RR-6 Professor Shergold Review Reports
Due: On-going – 1st milestone – Oct 2008
AQIS and Biosecurity Australia provided implementation status reports to Professor Shergold in September and October 2008.
3RR-7 Horse Import Fee Review
Due: Jan 2010
This deliverable has not commenced and will not do so until the reviews and inspections of preexport and post arrival quarantine facilities and operations have been completed in February 2009.
3RR-8 Officer Responsible for Horse Importation Report to Executive Director of AQIS
Due: 24 Sept 2008
This deliverable is completed. Dr Ann McDonald, Officer Responsible for Horse Importation, reported to Dr Cliff Samson, the Executive Director of AQIS on 23 September 2008 advising him of the biosecurity requirements of non-AQIS personnel, the source of those requirements, their compliance, and identified further measures. Dr Samson agreed to all 11 recommendations in the report which will improve AQIS’s ability to enforce compliance with procedures.
4FA-1 Interim and Final Upgrade – Kingsford Smith
Due: 1st milestone – Sept 2008
The first milestone has been met. Interim facilities at Sydney Kingsford Smith Airport have been upgraded with showering facilities installed. This was completed before the first shipment of horses into Sydney after the Equine Influenza Inquiry on 31 July 2008. Further (final) upgrades to facilities at the airport will be dependant on the recommendations of the Expert Group.
4FA-2 Interim and Final Upgrade – Tullamarine
Due: 1st milestone – Sept 2008
The first milestone has been met. Interim facilities at Tullamarine Airport comprising showering facilities and fencing to corral horses have been established. The establishment of these interim facilities was completed before the first shipment of horses into Tullamarine post the Equine Influenza Inquiry on 14 July 2008. Further (final) upgrades to facilities at the airport will be dependant on the recommendations of the Expert Group.
4FA-3 Initial and Final Upgrade – Spotswood
Due: 1st milestone – Sept 2008
The first milestone has been met. Facilities at Spotswood Quarantine Station have been upgraded and include additional showers, an identified isolation stall for horses suffering from contagious or infectious diseases, lockable storage for the chemicals, drugs and equipment and 24 hour security guard presence. Further (final) upgrades to facilities at the quarantine station, including the use of closed-circuit television (CCTV), will be dependant on the recommendations of the Expert Group.
4FA-4 Initial and Final Upgrade – Eastern Creek
Due: 1st milestone – Sept 2008
The first milestone has been met. Facilities at Eastern Creek Quarantine Station have been upgraded and include showers, an identified isolation stall for horses suffering from contagious or infectious diseases, lockable storage for the chemicals, drugs and equipment and 24 hour security guard presence. Further (final) upgrades to facilities at the quarantine station, including the use of CCTV, will be dependant on the recommendations of the Expert Group.
4FA-5 Renewed Leases for QS facilities
Due: 1st milestone - Sept 2008
This deliverable is on track. On 29 May 2008 United Group Services, on behalf of AQIS, advised the lessor of Spotswood Quarantine Station that AQIS would exercise the option to renew the lease for a further two years. On 2 July 2008 the lessor accepted the offer and confirmed that the lease on Spotswood Quarantine Station had been renewed until 1 December 2010.
The government is considering options for Eastern Creek Quarantine Station in the context of the Quarantine and Biosecurity Review Panel’s findings and recommendations. AQIS has an option to renew the lease at Eastern Creek for five years until December 2015. AQIS has until 30 September 2009 to exercise its option to renew the lease.
4FA-6 Approved PEQ facilities
Due: Aug 2009
This deliverable is on track. On 19 September 2008 the Officer Responsible for Horse Importation finalised a process, including checklist, for AQIS approval of pre export quarantine premises. This process has been provided to Biosecurity Australia, the interim Inspector General of Horse Importation and horse importers for comment. The process and checklist will be used to assess all future PEQ premises. As at 31 August, 30 PEQ facilities have received interim AQIS approval, two PEQ facilities failed and five PEQ facilities have insufficient information to allow AQIS to make a determination.