AAS AQIS Review

The Australian Academy of Science welcomes the decision to establish 'a wide ranging and independent scientific enquiry into Australia's quarantine policies and programs' and the wish of the Chairman of the Review Committee for a 'full and fruitful exchange of views on the future direction of Australian quarantine policies and programs'. To that end the Academy's submission draws on a wide body of expert opinion. It includes the views of several Fellows of the Academy in the biological sciences, members of the Academy's National Committee for Animal and Veterinary Sciences and other scientists with specialist knowledge of one or another aspect of the terms of reference of the Review.

The Academy recognises the past success of Australia's quarantine service in preventing the introduction of unwanted exotic pests and diseases that could have adversely affected Australia's economy and environment, and the health of its people. The Academy is very sympathetic to the staff and management of AQIS, who work under the unenviable condition that when their efforts are successful they go largely unnoticed. However, the Academy also recognises that the conditions that prevail today differ in many critical respects from those of past decades, when Australia's outstanding record of exclusion of unwanted exotic species was established. Australia's quarantine defence must now be appropriate to these new conditions, some of which are indicated below.

The movement of people, goods and commodities into Australia has greatly increased and will continue to do so. In particular, there has been a massive increase in living plant material entering Australia (see Sections 3.2, 3.3).
The routes of entry for exotic pests have multiplied and become more unpredictable and the conditions for survival of 'travelling' pests are more favourable, through containerisation and refrigerated air transport (see Section 3).
The prospect of global warming, with attendant changes in altered precipitation patterns and long distance wind movements, will gradually make Australia a favourable environment for new exotic pests, including vectors of human and animal diseases, over a wider range of entry points (see Section 4.4).
Ramifications of the World Trade Organisation's General Agreement on Tariffs and Trade (GATT) have profound implications for quarantine. Even to restrict the movement of commodities on legitimate quarantine grounds will often not be without cost to a country's reputation in terms of trade. Trade considerations are placing pressure on quarantine authorities to take greater risks, both technically and philosophically, in relation to diseases and pests entering the country (see Section 3.1).
Disposal of ballast water from bulk ore carriers on arrival at Australian ports is a means by which marine pests can and do invade Australia's coastal habitats (see Section 3.4).
There will also be a growing demand for the import and export of Genetically Modified Organisms (GMO's) and the quarantine service must be prepared to cope with these technical advances (see Section 3.11).

In parallel with 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 (see Section 5.1).

While its quarantine controls have been widely recognised as a model of best practice, Australia is in danger of forfeiting this position to countries like New Zealand, which are tightening rather than releasing control over quarantine (see Section 5.2.3). To maintain Australia's excellent reputation, vital scientific/technical issues must be addressed about how to facilitate the increased movement of plant, animal and other biological material for efficient trade and commerce without lowering our quarantine standards. This will require additional research on protocols to ensure that they are efficient, and yet remain appropriate and effective for rapidly evolving targets. It also requires a rigorous examination of the policy of user pays, industry self regulation and quality assurance to ensure that these concepts do not ignore the externalities and reach false conclusions.

The place of AQIS in the bureaucracy and its links to policy, technical and service agencies such as the Bureau of Resource Sciences (BRS), Australian Bureau of Agriculture and Resource Economics (ABARE), Commonwealth Scientific and Industrial Research Organisation (CSIRO) and Australian Nature Conservation Agency (ANCA) need to be reevaluated to ensure that adequate balance is given to plant, animal and human health and to environmental issues. Trade and primary industry resource issues need to be balanced by these broader quarantine considerations.

This submission begins with an historical 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. The recommendations in the 1987 Lindsay Review and the 1995 NAQS Review are examined to see whether the failure to implement some of these contributed to the recent incursions of the papaya fruit fly, whitefly and western flower thrips (see Section 4). In Section 3 it 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 in Section 4 by an assessment of other potential invaders. These examples cover a wide taxonomic range from viruses through insects and plants to fish. The Submission concludes, in Section 5, with an assessment of the key issues to meet Australia's quarantine defence and offers a series of recommendations.

2.1 Historical perspective

The concept of quarantine has a long history. In Australia we can trace a change in perception of its primary purpose from a need to protect the human population from foreign pathogens, to the need to protect animals and plants used in primary production from disease. Now there is a new perception, to protect the indigenous flora and fauna from foreign pathogens and competitors, for which the quarantine service is being expected to take responsibility as well.

2.1.1 Quarantine and human health

The idea of quarantine dates from the days of the Black Death in Europe, when the authorities in Ragusa (1465) and then Venice (1485) required that any ship arriving from a port suspected of plague had to anchor in a secluded place and remain for forty days without communication with land. In Australia, quarantine was introduced when the convict ship Bussorah Merchant arrived on 28 July 1828 with cases of smallpox on board. The beginning of animal quarantine for cattle dates from 1871 and for other livestock from 1884. Port inspection of cargoes which covered plants and arthropod vectors was introduced in Sydney in 1889, but the first set of regulations governing plant quarantine did not come into operation until 1909.

After Federation, a Quarantine Bill was introduced to Parliament in 1907, and the Minister commented that 'the six states have laws dealing with the quarantine of humans, livestock and plants and we now propose to embody in one comprehensive measure a system of quarantine to be administered by the Commonwealth Government'. The three divisions of quarantine were initially operated by the states on behalf of the Commonwealth Government, under the direction of the Director of Quarantine, who was a Commonwealth Medical Officer in the Department of Trades and Customs. By 1916 all States had difficulties with the service as it related to human quarantine, and after the influenza epidemic in 1919 a new Commonwealth Department of Health was created. The Commonwealth Government became fully responsible for human quarantine, while day-to-day administration of animal and plant quarantine services continued to be operated by the States. In 1921 a Division of Veterinary Hygiene was created within the Department of Health, and in 1927 a Director of Plant Quarantine was appointed to assist the Director-General of Health, who remained the Director of Quarantine.

2.1.2 The establishment of the Australian Quarantine and Inspection Service (AQIS)

The emphasis in quarantine shifted to animal health with the general improvement in hygiene and human health after the Second World War, and the eradication of smallpox in 1977. This was recognised in the 1977 Review of Australian Quarantine Arrangements (AGPS, Canberra) and further enhanced by the 1981 Royal Commission into the Australian Meat Industry and the subsequent passage of the Export Control Act of 1982 and formation of the Export Inspection Service. Formal transfer of responsibility from the Department of Health to the Department of Primary Industry occurred in 1986 by amalgamating the General Quarantine function of the former, with the Animal Health and Quarantine Branch, the Plant Health and Quarantine Branch, and the Export Inspection Service from the latter Department. In their stead was formed the Australian Quarantine and Inspection Service (AQIS) (see AQIS Senate Inquiry Submission, February 1995).

2.1.3 The role of quarantine services

The role of the quarantine service is to prevent entry into Australia and spread of exotic diseases of humans, plants and animals. In fulfilling this role AQIS is bound by Australia's obligations under the International Plant Protection Convention, the International Animal Health Code under the OIE (International Office of Epizootics) and the Agreement On the Application of Sanitary and Phytosanitary Measures under the World Trade Organisation Agreement. These obligations relate to ensuring that quarantine measures are scientifically based and do not unnecessarily restrict trade. AQIS must also be responsive to the needs of the Australian community by developing protocols and conditions for the safe importation of a wide range of goods, including plant and animal genetic material, microorganisms, biological control agents and biological products.

AQIS's quarantine strategy in managing quarantine risks in the national interest is based on risk analyses taking into account the assessed biological risk from unwanted pests and diseases and options for responding to the assessed risks. This strategy has been Australia's long standing approach to quarantine and has served well in the past. However, the current pressures on AQIS to be open and transparent and to consult widely with industry has strained its scientific resources, and highlighted the need for additional resources. It has also shown the urgent need for a structured approach to risk analyses and to managing the consultative processes so as to minimise the kinds of controversies that have surrounded AQIS risk analyses in recent years, e.g. proposals to import bananas from Ecuador, apples from New Zealand, pig meat and uncooked salmon from Canada, cooked and uncooked poultry meat from USA, Thailand and Denmark, and cereal grains from USA.

Under the former arrangements with State agriculture/primary industries departments contracted as agents for AQIS, considerable scientific resources were available to support quarantine operations through the State networks of entomologists, plant pathologists, weed scientists, veterinary scientists and other experts. However, it is unlikely that AQIS will have the same free access to this experienced support under the new arrangements unless special provision is made on a retainer or some other basis.

2.2 The Lindsay Review

In 1987 the Government commissioned the Quarantine Review Committee with Professor David Lindsay as convener; it produced an interim report in November 1987 and a main report in May 1988.

The Interim report dealt with aerial surveillance and quarantine strategy in northern Australia and led to the establishment of the Northern Australia Quarantine Strategy in 1989 (see below, 2.4).

In the main report there were fifty nine recommendations. In December 1988 a Policy Statement was issued by the Government that addressed these recommendations. Two recommendations, dealing with charges and cost apportionment, were not accepted but the remainder were; the majority without comment. The Policy Statement contained a statement of fundamentals of quarantine in the form of objectives, strategy and principles. The move towards the new approach of full cost recovery was signalled by the rejection of the two recommendations on finance (see Section 5.4).

Eight years later it can be said that the majority of the recommendations have been implemented and/or developed further. But three recommendations, with direct bearing on incursions by agricultural insect pests have, in the light of recent invasions, not been implemented adequately.

Recommendation 6:

Recommendation 24: With the exception of a program for monitoring mosquitoes at international airports, no national program for monitoring and control of insect vectors and pests of significanceto agricultural quarantine and human health has been established at international airports and seaports.

The policy statement indicated support for this recommendation but stated that the placement of any program would be on the basis of assessed risk (p.23). Two reports in 1991 strongly recommended that traps for fruit flies be installed at major and minor airports and seaports in eastern Australia. The Horticultural Policy Council's report specifically listed Cairns. No action was taken even though in 1993 and in 1995 the papaya fruit fly was detected on islands in Torres Strait just an easy plane or boat ride from Cairns. As a consequence, when the papaya fruit fly was discovered around Cairns, it had been present for well over a year. The delay in its discovery means the difference between a low cost eradication program with a high probability of success and a multimillion dollar program with a less than certain outcome if, indeed, it is not already too late to attempt eradication. From this example, doubts must be placed on the mechanism employed by AQIS to assess risk.

Recommendation 34: The Lindsay Committee recognised the difficulties posed in dealing with the enormous range of pests of plants but nonetheless recommended that there was an urgent need to develop a strengthened, planned and coordinated approach to responding to outbreaks of exotic pest and disease in plants.

The Policy Statement states that 'arrangements ... are in place that would allow Australia to analyse and immediately respond to [the entry of an exotic pest or disease of plants'.

Currently the system operates through the Standing Committee on Agriculture and Resource Management and its Plant Health Committee. There is no commitment to funding, which must be discussed for each episode. The speed of response is handicapped by the process. Even with insects, where there has been ample opportunity to have had contingency plans prepared (such as with the silverleaf whitefly, the western flower thrips, and the papaya fruit fly, see Section 4.1), response has been slow or muted.

The Lindsay Review Committee noted that quarantine in Australia was conducted under the Quarantine Act 1908 with major amendments affecting agricultural quarantine being made between 1981 and 1985. The Report stated that the Act had become virtually unintelligible to all but those who worked with it closely, there being more amendments than original text. This statement would still be true today since the new Agricultural Quarantine Act, anticipated in 1988, has not eventuated.

Since the Government's policy statement on quarantine made in 1988, following the Lindsay Report, AQIS has made a number of significant changes to its arrangements for quarantine operations which can be expected to affect its performance. These have been achieved by fully integrating animal, plant and human quarantine functions into one operational service with multi-skilled personnel at all quarantine barriers. Service delivery costs have been reduced, particularly those attributed to overheads, by transferring operations staff in 1995 from State departments of agriculture/primary industries in NSW, Victoria, Queensland and South Australia to the Commonwealth Public service directly under AQIS control. AQIS has argued that this initiative can also be expected to improve the consistency of service delivery throughout Australia. AQIS has also further developed its inter-agency cooperation with the Australian Customs Service particularly with electronic lodgement of documents and automated cargo clearance.

2.3 The Quarantine and Inspection Advisory Council (QIAC)

QIAC was established in 1992 with strong representation of grower and export interests. While its Terms of Reference are reasonably broad, QIAC appears to have focused its attention on trade and export considerations which are prominently articulated in its Terms of Reference. 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 dairy products for the growing export markets (see Section 5.5.2). QIAC, during its period of existence, appears to have been silent on the sustainable aspects of agriculture, human health and environmental protection. QIAC lacks representation in these areas.

2.4 Review of the Northern Australia Quarantine Strategy (NAQS)

This review, chaired by Professor Mal Nairn, was published in August 1995. Its main purpose was to evaluate whether or not NAQS, as recommended by the Lindsay Committee, had been a worthwhile program and to consider whether it should be modified.

The Academy agrees with the main thrust of most of the recommendations, in particular Number 1,

'that the strategic importance of NAQS be recognised by AQIS through the continuation of a NAQS program'.

Detailed comments that could strengthen, extend or modify several of the other recommendations are given at Section 5.3.

It is clear that NAQS has suffered (and perhaps still suffers) from inadequate senior and experienced scientific leadership, both in the field of plant pests and diseases and of weeds. Its activities are largely unknown to the majority of Australian plant scientists and entomologists (including relevant university, museum, CSIRO and other personnel) working part- or full-time in Northern Australia. Most are unaware of the target lists, and conversely, some know of potentially damaging species that have not been considered by NAQS for inclusion in their lists. As a result, NAQS is not taking advantage of relevant information held by Australian biologists. So far, no response from the Minister or the Department of Primary Industry and Energy has been forthcoming to the NAQS Review.

Recommendation 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.

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