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SUBMISSION TO THE REVIEW OF THE AUSTRALIAN QUARANTINE INSPECTION SERVICE
31 March 1996

1. Executive Summary and Recommendations

Executive Summary

1. Australia's geographic isolation has been long recognised as providing a natural protection from alien diseases for the human population and domestic species on which Australia's primary production depends. This same isolation allowed an unique flora and fauna to evolve, protected from pathogens and competitors from other countries, and therefore vulnerable to potential invaders.

2. The Australian Academy of Science has had a long standing interest in maintaining the integrity of the Australian biota and in protecting the health and prosperity of the country through the exercise of effective quarantine measures. One recent direct contribution to the matter was the conference on exotic diseases, organised jointly by the Academy and ANZAAS and held in Canberra in May 1984. The proceedings were subsequently published as a book, Pests and Parasites as Migrants; an Australian Perspective (Gibbs and Meischke 1985). In 1985, the Academy sponsored a workshop on biological invasions. The proceedings were published as a book, Ecology of Biological Invasions: an Australian Perspective (Groves and Burdon 1986).

3. Until Federation, the Australian colonies were responsible for quarantine within their own borders. The Federal Quarantine Service began operations on 1 July 1909 within the Department of Trade and Customs. The Commonwealth Department of Health was established in 1921, partly as a result of the difficulty experienced by the Commonwealth and the States in coordinating quarantine and health measures to respond to the influenza outbreak of 1919. Subsequently, in the 1920s the regulations were gradually extended to cover a number of animal and plant disease organisms, still under the Department of Health. With the general improvement in hygiene and human health after the Second World War the emphasis in quarantine shifted to animal health. This was recognised formally by the transfer of responsibility to the Department of Primary Industry and, in 1986, by the establishment of the Australian Quarantine and Inspection Service (AQIS).

4. In 1992 the Quarantine and Inspection Advisory Council (QIAC) was established with strong representation of grower and export interests. The Council has encouraged the development of cost recovery and user pays in the financial management of AQIS, reflecting the prevailing interest in ensuring protection of Australia's reputation as a producer of high quality, clean meat and other food products for the growing export markets.

5. Since the publication of the Commonwealth Government's environment policy document Our Country, Our Future, in 1989, there has been a growing awareness of the threats to the native biota from the import of foreign organisms, as well as a growing appreciation of the complex nature of the effects of such incursions. With the great increase in the traffic of people and goods into Australia and the much shorter transit times in aircraft, the risks of inadvertent incursions of serious pest species has increased hugely.

6. These changes, in the perception of the community and in the evidence of increased risk, have brought new obligations for the quarantine services of the country and require new thinking about the management and financing of such services. They require a greater use of, and support for, the scientific expertise in State Government Departments, CSIRO, Museums and the Universities, and organisational and fiscal policies to meet these changes.

7. Central to the Academy's recommendations is the need for the national quarantine authority to attain a balance between short term economic considerations affecting trade and export markets and longer term economic, social and cultural considerations pertaining to sustainable agriculture, human health and environmental protection. AQIS's priorities and practices reflect the constraining influence of the mission statement of its host Department, Primary Industries and Energy. Australia's national quarantine authority should either be a statutory authority or measures should be taken to ensure that its broader responsibilities in sustainable agriculture, health and environmental protection are fully catered for. Any ministerial advisory council dealing with quarantine must be empowered to provide advice cognisant of these broader aspects of quarantine.

8. The Academy therefore welcomes this timely review of the functions and operation of AQIS and makes the following submission in a spirit of cooperation. It recognises that the task of AQIS will always be difficult and insufficiently rewarded because, when its efforts are successful they are largely unnoticed but when they fail everyone knows about it. The submission addresses the Terms of Reference of the Review but, for reasons that will become clear, not in the order that they were set out in the preliminary material. The submission begins with a general introduction that traces the changing perception of the role of quarantine in Australia and the policy shifts that have arisen from the several recent reviews and reports. It then examines the potential and actual routes of entry that exotic organisms might use to breach quarantine and the means that should be considered to meet these threats. This is followed by an examination of some recent incursions and the lessons that can be learnt from them, and an assessment of other potential invaders. These examples cover a wide taxonomic range from viruses through insects and plants to fish. The submission concludes with a series of key considerations and recommendations.

Recommendations
(in order of appearance in the text)

2.4.1 The Academy of Science strongly endorses Recommendation 22 of the NAQS Review, that the organisation of NAQS should be critically reviewed, to ensure that appropriate and experienced scientific leadership is available to NAQS field scientists, and that the present cumbersome and frustrating administrative channels are simplified.

3.1.1.1 The Review Committee is encouraged to consult stored grain experts to assist in assessing the risks of pests and diseases entering Australia with bulk grain imports and to determine procedures that will facilitate these importations, while reducing the risk of unwanted incursions to an acceptable level.

3.1.2.1 AQIS should reform the quarantine requirements for the import of legume seed and establish fumigation procedures that are effective and do not affect the viability of the seed.

3.2.1 Before permission is granted for import of any potential pasture plant it should be investigated for its potential weediness (which often makes it an attractive pasture plant) by a broadly based committee that will consider environmental impacts, as well as potential benefits for agriculture.

3.2.2 The Review Committee should explore the linkages between AQIS, ANCA and DEST, to ensure that environmental impact of exotic weeds and pests are addressed in Australia's best interests.

3.3.1 The Academy recommends that cut flowers be subject to mandatory rigorous treatment schedules based on a systems approach of decremental pest control measures from field to preshipment disinfestation, in order to reduce the infestation load on transported material. AQIS inspectors should be posted to countries from which cut flowers are imported to ensure that any such treatments are adhered to.

3.3.2 The Academy recommends that AQIS should identify gaps in knowledge and commissions research to underpin the development of effective protocols so that trade opportunities are fully exploited for cut flowers and ornamentals, but not at an unacceptable level of risk of quarantine failures. These protocols should be enforced without exception.

3.7.1 The Academy recommends that NAQS be given adequate resources so that field officers are well placed to ensure sound quarantine is maintained in the Torres Strait.

3.9.1 Given the increasing volume of biological research material entering Australia, AQIS should consider the appointment of a specialist Quarantine Officer, along the lines of the CSIRO Canberra model, in each of the capital cities in Australia. This officer would be associated with a research institution and act as a focal point for the clearing of imported biological research material for all research institutions in that city. Such an arrangement would have significant benefits both in enforcing quarantine regulations and facilitating the timely delivery of material for research.

3.10.1 The Academy acknowledges the leadership role of AQIS in the safe and efficient importation of natural enemies for biological control of weeds and pests and recommends that measures be taken to ensure AQIS is able to maintain this role.

4.1.6.1 The Academy urges the Review Committee to investigate why Australia appears better prepared to cope with certain livestock diseases than with adverse plant health and environmental impacts of incursions of unwanted pests and diseases into Australia. This imbalance appears to have a historical basis and should be redressed as a matter of urgency.

4.4.1 The Academy is concerned that Australia, more or less by default, is lowering its capacity to exclude the entry of exotic diseases of humans. It recommends that the Government's advisory council contain at least one medically qualified member.

5.1.1. The responsibilities of AQIS should be adequately directed to the protection and conservation of Australia's fauna and flora, as well as to the safe and efficient protection of Australia's plant and animal industries.

5.1.2. Lists of all known or suspected organisms that could pose a threat to Australia should be maintained on computer network and up-dated regularly. Information should include diagnostic kits, countries of origin, potential or actual routes of entry and an assessment of the risk of entry, and probable impact on industry and the environment. The data should be easily accessible by a wide audience. In addition, any successful biological control used elsewhere and measures for long term management should be included.

NAQS scientific and other relevant staff should be provided at each location with specimens of each target organism and colour photographs of damage, together with means of identification and where to send suspected new pests for positive identification.

5.1.3 For species identified as of high risk, research should be conducted in the country of origin, or neighbouring countries where it has recently arrived, by active collaboration with Australian scientists, supported by Australian funds.

5.1.4 For the most important species, contingency plans to meet a possible incursion should be developed, along the lines of the Screw-worm Fly Plan and AusVetPlan.

5.1.5 A much greater involvement of the Australian scientific community - State departments, CSIRO and Universities - in research of relevance to quarantine, in the areas of taxonomy and risk assessment should be encouraged. This could take the form of competitive grants for relevant research projects and the encouragement of undergraduate courses in these disciplines, as an essential component of environmental studies.

5.1.6 The education of incoming passengers about the importance of quarantine for the Australian environment and primary industry should be expanded. This could include inflight videos and articles in the inflight magazines.

5.2.1. Surveillance at harbours and airports should be strengthened and the Northern Australian Quarantine Survey (NAQS ) should be continued. This could be achieved by increasing Commonwealth funded AQIS staff. Because the risk can potentially affect the whole community for the indefinite future, Commonwealth funding is appropriate.

5.2.2 Procedures for the importation of living organisms, other than mammals and birds, needs to be tightened; restrictions on the import of fish and many types of plant are inadequate to meet environmental risks.

5.2.3. A highly conservative approach to import licences should be implemented. Instead of approving those species that are not on the prohibited list, the onus should be placed on the applicant to establish the risk-benefit balance for any species that has not been previously cleared for entry. In the assessment, the risk factors should include the possibility of vicarious species and pathogens inadvertently being carried on the species being applied for.

5.2.4 Consideration should be given to adopting, as a model, relevant aspects of the New Zealand legislation on import of exotic organisms, which treats all species in the same way.

5.3.1.1 National contingency plans, such as AusVetPlan, which are developed for the identified high risk species, must be based on a thorough use of all relevant data and methodology. This should include population ecology of potential hosts and epidemiology of the target species, ecological modelling and game theory, leading to explicit risk assessment and realistic contingency plans. Current approved plans fall short of this.

5.3.1.2 The Review Committee should explore the feasibility of establishing the equivalent of AusVetPlan to cope with the wide range of risks to commercially important plant species through the incursion of insect pests, diseases and weeds into the country.

5.3.2.1 The Academy strongly recommends that the Review confirm the essential role of research groups outside AQIS in maintaining Australia's quarantine capabilities. The Review should explore ways for these services to be properly costed and the respective organisations should be paid for their services. Funding for this work by University and Museum taxonomists would be best managed through a peer review system, such as used by the ARC or NHMRC.

5.3.3.1 In the event of an incursion of a new pest species a high priority needs to be given to determining precisely how it entered Australia and from whence it came; surmise and conjecture are not sufficient.

5.3.3.2 The procedures required for the introduction of organisms for the biological control of existing pests should be reviewed, with the aim of facilitating their importation and release.

5.3.5.1 The Academy recommends that the Review Committee support the initiative to develop a modern quarantine and containment facility in Northern Australia. The emphasis should be on plant health relevant to sustainable agriculture and protection of Australia's biodiversity.

5.4.1 The Academy fully agrees with the application of cost recovery from the user for those activities of AQIS where a user, who captures the benefits of the service, can be identified, e.g. the issue of export licenses, provision of inspection services and quality assurance certification. A clear distinction, however, needs to be made between export costs, for which user pays, and the costs to Australia of importing unwanted foreign organisms. In the latter case, the risk of failure is borne, not by the importer alone but by the whole country and for a very long time. For this reason the surveillance must be impeccable and the cost should therefore be borne by the Commonwealth.

5.5.1.1 The Academy recommends that careful consideration should be given to establishing AQIS as a Statutory Authority.

5.5.1.2 The Academy requests the Review Committee investigate the linkages between AQIS and all relevant agencies, and ABARE should be asked to examine the relevant policies underpinning quarantine aspects of exports and imports to determine if any anomalies exist.

5.5.1.3 Strong links should be established between AQIS, DEST, EPA, ANCA, CSIRO and the Department of Health to ensure policy, practice and resources reflect the comprehensive aspects of quarantine.

5.5.2.1 QIAC should have a broader mandate and its functions should clearly indicate that it is expected to advise the Minister on all quarantine matters, which include the wellbeing of the environment and human health, and that its membership should be broadened to include members with backgrounds in health, science and environment.