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Home > Reports and submissions > 1996


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


3. Routes of Entry of Non-Indigenous Pests


3.1 Grain and seed imports

3.1.1. Bulk grain imports

From 1980-1994 total imports of grains, pulses, oilseeds and oilseed meal have been approximately 1.3 million tonnes (Grain Statistics 1994). However, due to the recent drought there has been a significant increase in the volume of bulk grain imported, maize and sorghum specifically, for the feedlot industry. This pattern of higher bulk grain imports appears likely to become the norm as the feedlot industry seeks the cheapest sources of grain. With these imports comes the risk of weed seeds, plant pathogens and insect pests entering Australia.

One important risk from these imports is the possible introduction of two serious insect pests of stored products, as well as strains of other stored product insects already in Australia that are resistant to the fumigant phosphine.

The Khapra beetle, Trogoderma granarium (Coleoptera:Dermestidae) has a well established reputation as a quarantine risk and is the subject of vigilant inspection.

The larger grain borer, Prostephanus truncatus (Coleoptera: Bostrychidae) is less well known. Once apparently restricted to Mexico, parts of Central America and the extreme south of the USA, it has now become established in Africa, as a result of at least two separate accidental introductions; one into Tanzania and the other into Togo. In both regions it quickly became a major pest of farm-stored maize (especially cob maize). Now it is becoming widely distributed in sub-Saharan Africa. One of the most important aspects of the biology of P. truncatus in the Americas is that it is found living away from maize production areas in natural habitats in Mexico, and in a wide range of bush and forest habitats in Honduras. In Kenya it has been shown to be capable of breeding in several species of savanna trees, and there are indications that it could survive and disperse in the Australian acacias (D. Rees, pers. comm.). In addition P. truncatus has been shown to be a very mobile insect, capable of flying many kilometres, and more cold tolerant than the lesser grain borer, Rhyzopertha dominica.

Actions that can be taken to prevent introductions of insect pests of stored grains include

  • effective pre-shipment fumigation of all imported grain and grain products, substantiated by records of gas concentration data monitored over the exposure period,

  • rigorous sampling and inspection of imports, at least to the sampling level required for grains exported from Australia, and preferably more stringent,

  • where AQIS-authorised controlled atmosphere protocols are applied, these should be subject to rigorous supervision by reliable and impartial agents,

  • where a failure to comply is detected, rigorous sanctions should be imposed on the importer (and the exporter). It is suggested that the process used by United States Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) be adopted; a product may be detained by reputation, and errant fumigation contractors are blacklisted so that their fumigation certificates are not accepted without diligent inspection of the treated commodity,

  • again referring to USDA practice, AQIS should prepare a monthly list of Import Detentions and make it available to importers and exporters. Such a list could be made easily accessible by publishing it on the Internet. It would also have the effect of identifying the causes for detention. Citations in the USDA listing have been used by quarantine authorities in PNG as an indication of quality in a situation where local monitoring would have been very difficult.

The latest version of the AQIS standard for fumigation with methyl bromide has been severely criticised by an executive of a multinational pest control business (see Section 5.4). It has been suggested that the standard makes no provisions for fumigators who undertake cut price jobs at prices below that necessary for the correct dose of fumigant required for the job. Such practices occur in South East Asia, where Quarantine Officers have, off the record, openly admitted that this practice occurs and their inability to control it. Very little reliability can be placed on fumigation certificates accompanying some imports, and there is a need for more rigorous inspection of commodities on arrival in Australia.

Sampling and pre-shipment fumigation should be directly supervised by AQIS inspectors, by temporarily positioning inspectors in exporting countries for the duration of a 'season'. Such supervision should not preclude further inspection on arrival in Australia. This practice is commonly applied by Japanese inspectors positioned in Australia for the duration of the mango and orange seasons.

The recent identification of methyl bromide as a serious depletor of the ozone layer and its toxic effects on mammals has jeopardised the future of a very useful fumigant. Presently, the phase out proposals specifically exclude pre-shipment and quarantine applications of methyl bromide. However, it is likely that these applications will also be phased out. Thus it is important to ensure the availability of phosphine as a fumigant because it is the only suitable 'plug-in' replacement for methyl bromide.

Recommendation 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 Germplasm imports

Imports of germplasm, in the form of seed material, are significantly less in volume than those of bulk grain but the frequency of seed imports is likely to increase with the effort to diversify and improve Australian seed crops, especially grain legumes; this will increase the risk of introducing new pests.

Notionally, all such seed introductions are rigorously inspected for the presence of both pathogens and insect pests. However, where such introductions are made from the Consultative Group for International Agricultural Research (CGIAR) and other international organisations, no assumptions based on experience of earlier introductions, should be made concerning their pest freedom. There is also a concern about the use of methyl bromide (see above) and alternative methods may affect the viability of the seed. A particular concern is the risk of entry of bruchids, which are, weevil pests of legumes. At present the only bruchid of importance in Australia is Bruchus pisorum, the pea weevil. Effective control of this pest requires a specific fumigation regime, with a high phosphine dose. Similar requirements may be necessary for any new bruchid pests introduced to this country. Incursions of species presently unknown in Australia could adversely affect current storage practices for these commodities and jeopardise strategies for agricultural expansion into legume crops new to Australia.

While there is a requirement for mandatory disinfestation of species of annual Trifolium brought into Australia and farmers are permitted to import up to 50 kg of seed without quarantine inspection, the decision is based on a visual inspection. This is of dubious value if the seed has been recently infested. Similarly, lentils are not subject to inspection.

Two recent examples illustrate the potential risk in these policies. In one, a scientist working in Western Australia insisted that samples sent to him be disinfested with phosphine and subsequent examination of the material revealed evidence of bruchid infestation. In the second, concern was expressed (pers. comm., Darryl Hardie) about a consignment of legume seeds that was carried into Australia, declared and passed by the AQIS inspectors on duty at the airport concerned. Subsequently, a number of insects, tentatively identified as Bruchus affinis, lesser pea weevil, emerged from the material. This insect is a potentially serious pest of legumes.

At present, however, there is no specific AQIS requirement to inspect or disinfest any legume seed for bruchids, except for the mandatory fumigation requirement for medic seed from the Mediterranean region. Currently, only fumigation with methyl bromide is permitted. However, this treatment is known to adversely affect germination.

An alternative treatment that will also kill pathogens is required. It has been suggested that heat treatment provides a possibility. Much of the work on thermal disinfestation has been undertaken by the CSIRO Stored Grain Research Laboratory and it is possible that the laboratory-scale rigs developed for this work could be developed to handle small volumes of seeds.

Recommendation 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 Deliberate introductions of plant material for pasture improvement and horticulture

A number of the plant species, which are now recognised as pests, entered Australia as ornamental plants and were first cultivated in Botanical Gardens. Examples are Mimosa pigra that lived in the Darwin Gardens for many years before escaping to become a major pest in Northern Australia; likewise, Lantanaand Patterson's curse, came as ornamental plants. The North American prickly pear (Opuntia spp.) was introduced both as an ornamental and as a paddock hedge. These cases could be considered to be unforseen disasters, but more serious in its implications was the program, from 1947 to 1985 to introduce grasses and legumes to tropical Australia to improve the nutritional quality of pastures for beef production. The purpose in the view of those funding this work was no doubt laudable but, the outcome, as Lonsdale shows (Australian Journal of Ecology 19, 345-54, 1994), was a serious disregard for the long term effects of introducing alien plant species. Again, there was no legal impediment to their importation, nor their incidental release into the environment, once they were discarded as useless for pasture improvement. During that period 463 species in 2033 accessions were introduced, the grasses mainly from Africa, the legumes mainly from Central and South America. There was no screening for potential adverse effects of the plants before trial, nor was there any attempt at containment of these species during or after evaluation. Of all these species only 21 have proved to be useful to the cattle industry, while 60 other species have become recognised as weeds, 13 of them being listed as major weeds. Of these species 21 are weeds of cropping, 20 are weeds of conservation and the remainder weeds of both cropping and conservation. The annual rate of production of the cattle industry in the Northern Territory is $1.48/ha, while the cost of weed control is $30/ha for annuals and $129/ha for perennials. In this important instance, the environmental externalities had not been considered, and it required the individual effort of a plant ecologist to draw attention to an unsatisfactory situation. Because the benefit to the cattle industry was perceived as a national good, Australia must now continue to pay a huge and continuing cost for these introductions.

Recommendation 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.

Kochia scoparia, a roly-poly type plant was introduced into WA in 1990 to stabilise salinised land. At that timeKochia was not listed in the schedules of Proclamation 86P and there was no legal impediment to its importation. It is now listed as a noxious weed.

Siam weed, or Chromolaena odorata, a major tropical weed species,Chromoleana odorata was first discovered in Queensland in 1995 by a NAQS officer while on holidays. The weed had been in the country for some years and was well established. The area of infestation was just south of NAQS's region of responsibility and, on this technicality, it was difficult for the officer, who detected the infestation, to elicit effective action by or through NAQS. In this case, pre-emptive declaration of Chromolaena as a noxious weed by the Queensland Department of Lands, facilitated an immediate response to the weed.

Seeds of weed species, likeKochia andChromolaena, can be transported unwittingly by travellers and establish in remote areas before detection, making eradication difficult or impractical. N.M. Wace (in Pests and Parasites as Migrants, pp 3-32, 1985) gives figures for 305 seeds of 37 species germinated from the clothing of 12 tourists, who had recently arrived in Australia from 10 different parts of the world. This shows how great is the magnitude of this, inadvertent, route of entry for unwanted plant species.

Another newly detected plant, which appears set to become a major weed, is the South American Praxelis clematidea (Asteraceae), previously unknown, but found to be common during the survey for Chromolaena. It has since been recorded over a very wide area and is thriving as a weed of roadsides, river banks etc. It is also known in Hong Kong and other parts of southern China where it is spreading rapidly. This is an example of a plant species which is unlikely ever to be placed on an AQIS target list, (even though it belongs to the very weedy supertribeEupatoriae) becoming a serious threat when transferred to Australia.

Australia is so large and bioclimatically diverse that it would be difficult to arrive at a list of plant species that might become invasive in unmanaged Australian environments if imported. Nevertheless, a list could be compiled of those species that are known to be invasive elsewhere, along the lines of the US Department of Agriculture Handbook No. 498, entitled Economically Important Foreign Weeds - Potential Problems in the United States(1977), and Alien Plant Invasion in Native Ecosystems of Hawaii, published by the University of Hawaii in 1992.

Recommendation 3.2.2

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

3.3 Cut flowers and ornamentals

The Australian cut flower and the ornamental industries are involved in both export and import of flowers and plant cuttings. Imports into Australia consist mainly of ornamentals and propagative or seed stock.

There has been a dramatic increase in the amount of living plant material entering Australia on a daily basis over the past decade, especially cut flowers. Figures indicate that the number of consignments of cut flowers entering Australia during the period 1993-1995 through Mascot airport has remained steady at approximately 800 per year. There has however, been a significant increase in the size of these consignments. The international airport at Perth receives around 10,000 separate cartons of plant material each year. The actual figures between 1988 and 1994 range from 9,400 to 14,165 cartons.

This route of entry for exotic plant pests and diseases undoubtedly represents the greatest opportunity for quarantine failures for Australia. This can be discerned by examination of the AQIS listing of pest interceptions, in which nearly half the interceptions are made from imported cut flowers.

The threat posed by cut flowers stems from a number of reasons:

  • inspection at port of entry into Australia is, in many cases, the only point at which flowers are inspected - potentially too late as they have already landed.
  • cut flowers do not appear to be subject to the same standard of rigour applied to imports of other plant materials.
  • the sampling level is low, possibly due to the perishable nature of the product. There is similarly a sense for a requirement for non-destructive inspection, which can lead to pests being 'overlooked'.
  • flowers are 'designed' to attract insects and are subject to infestation by all life stages, some of which are very small, cryptic and can be easily overlooked during an inspection.
  • where consignments of cut flowers are accompanied by a Phytosanitary Certificate, these are sometimes of dubious value, especially from certain parts of Africa.
  • where consigners gain a reputation for continually exporting infested shipments, they are able to evade 'black banning' simply by changing their business names.

There is good evidence that the whitefly,Bemisca tabaci, (biotype B) entered Australia on cuttings of Poinsettia from California, and the Western flower thrips, Frankliniella occidentalis, may have entered Australia from Zimbabwe on imported cut flowers (pers. comm. J. van Someren Graver, CSIRO, 1995). Both insects have wide host ranges and, more seriously, are vectors for plant viruses capable of infecting both native and cultivated plants. Thus because of inadequate control of entry, one relatively small industry has been responsible for a problem of national importance and great potential cost. Recent studies indicate that the whitefly is regarded as the most important insect pest of agriculture in the USA since 1991. It is estimated that in the Imperial Valley of California from 1991 to the end of 1994, 9,000 local jobs had disappeared and crop losses dues to this pest exceeded $300 million.

It is alleged, in the case of one introduction, that inspections undertaken on entry to Australia did not include searches for this pest 'because it was not known to be in the country of origin'. In another case it is alleged that the consignee, when told that a consignment had to be disinfested with methyl bromide, persuaded the inspector to use another treatment less injurious to the plant 'because methyl bromide damages the plants'. It appears that there has been a failure to communicate to the inspectorate the precise location details of some rapidly dispersing insect pests that are known to pose a quarantine risk to Australia; and a lack of rigour in the application of prescribed quarantine disinfestation treatments.

There is also a likelihood that some of the established disinfestation procedures may fail to completely control infestations. This view was expressed by R. Roush (Waite Institute) some years before the whitefly entered Australia. Treatments may be applied after detection of infestation by insect pests and the material released, without further inspection.

For example, two principal markets for Australian cut flowers are Japan and the USA, both of which apply stringent quarantine controls to prevent importation of living insects. There are reports from exporters, who have had consignments of cut flowers fumigated in accordance with established AQIS protocols before shipment, that such consignments have had to be retreated after living insects were detected in them by Quarantine Inspectors on arrival at the port of destination (J. van Someren Graver, pers. comm.).

The Academy does not suggest that the amount of living plant material entering Australia should be reduced. However, it does argue that adequate and effective protocols should exist and be implemented rigorously.

Recommendation 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.

Recommendation 3.3.2

The Academy recommends that AQIS identifies 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.

3.4 Ballast water from, and hull biofouling of bulk ore and woodchip carriers

Several marine organisms from the northern hemisphere have established themselves in Australian coastal waters in recent years and are said to be displacing indigenous species. The Centre for Research on Introduced Marine Pests (CRIMP) was set up in 1995 to develop methods for the early detection of marine pests, and to develop new methods to control the spread and minimise the impact of introduced marine pests. One likely route by which the organisms enter Australian waters is in the huge volumes of ballast water that are discharged by bulk ore and woodchip carriers on arrival in Australian ports, preparatory to loading cargo. AQIS is responsible for controlling the discharge of ballast water and approving the entry of ships into Australian ports and it will be taking advice from CRIMP on means to prevent the survival of foreign marine organisms in ballast water.

The second possible route is on the hulls of ships, even those that are well maintained with anti-fouling protection. There are sites on the hulls of most ships, such as rudder and propellor housings, bilge tanks and inlet ports, where colonial or aggregating marine organisms can become established (S.F. Rainer, CRIMP Technical Report 1, 1995) and then provide harbour for other species, even including small fish. Thus the ecological risk posed by biofouling on ships' hulls is not a function of area and, indeed may not affect the efficiency of the vessel. The species that have been observed on the hulls of bulk ore carriers appeared to vary with the port of origin and to include coastal species rather than open ocean species. Clearly, it is important to determine whether ballast water or the hull are the main route of carriage of potential pest species.

3.5 Aquaria supplies

In Australia 6-10 million ornamental fish are imported each year for the aquarium market (J.D. Humphrey, Australian Quarantine Policies and Practices for Aquatic Animals and their Products; a review for the scientific working party on aquatic animal quarantine, Bureau of Rural Sciences, 1995). Freshwater species must be held in quarantine for two weeks but marine species do not require even this minimum surveillance, and none of these imports require prior veterinary inspection before release. There are two hazards; escape of the species itself and the potential pathogens that it may harbour.

Most of these species would not survive outside the controlled environment of the aquarium, but some may be able to do so; no assessment of their long term effects in Australian waterways is made before each introduction. In the case of tropical species many are imported direct from the wild in South America or South-east Asia (W. Laurance, Search, 26, 300-303, 1995). A few years ago a large National Aquarium was set up in Canberra without consideration to the possible effects on the Murrumbidgee-Murray river system. At present in Australia the common carp is spreading at an increasing rate through the inland waterways, fouling the water and displacing native species. In 1995 it was discovered in some of the river systems of Tasmania and the likelihood is that it is being deliberately put into those rivers. Now the CRC for Freshwater Ecology has begun a program for the biological control of the carp; the task is immense.

The second risk of introducing foreign species of fish are pathogens that they carry, which may affect native species of fish and amphibia. Humphrey (1995) lists 42 exotic pathogens that have been identified in ornamental fish imported into Australia, some of which have become established in native species. Drawing on this evidence Laurance (1995) suggests that the spreading decline of many species of tropical amphibia in Queensland since the late 1970s may be due to one or more such pathogens, which are exotic to Queensland rainforests.

3.6 Natural phenomena

While human activity is implicated in the entry of most exotic pests and diseases into Australia, natural phenomena have been responsible for some significant incursions. For example, the leucaena psyllid incursion (c. 1980) most likely reached northern Australia during cyclonic weather. There is also a heavy traffic of small invertebrates and fungal spores in upper atmospheric jet streams. A further example is provided by the recent discovery in Darwin, NT, during a one week investigation by visiting scientist, Dr Laurence Mound, of several species of thrips known previously only from Indonesia. Numerous questions remain unresolved; do they represent recent arrivals, how did they get here, what is their ability to survive in their new environment. Even their presence in Australian would have remained unknown, had it not been for the fortuitous presence of an overseas taxonomist, with a special interest in this group.

While little can be done directly to reduce this 'natural biotic traffic', certain indirect measures can be taken to lower the risk; and more effort could be directed to risk assessment and contingency planning to cope with anticipated arrivals of undesirable species (see Section 5). Strong flyers such as the banana skipper and disease-bearing Asian honeybee species could island hop and enter Australia by their own efforts. In the latter case, better appreciation of the risks can sometimes suggest pre-emptive actions in the common interests of Australia and neighbouring countries. For example, collaborative research between Australia and its neighbours, funded by ACIAR and AusAID on biological control has reduced the abundance of pests like banana skipper and various bee diseases in PNG. Similar examples of biocontrol of other pests in the Pacific Islands have worked towards the common interests of these nations and reduced the risk of incursions into Australia.

3.7 Movement of indigenous peoples in Northern Australia.

The northern borders of Australia include islands only a few kilometres from the mainland of PNG. These islands are part of a chain of islands that spans the Torres Strait from PNG to Cape York. The movement of people, goods and livestock amongst these islands provide opportunity for the transport of exotic pests into Australia from PNG and vice versa.

These activities are permitted under the Torres Strait Treaty (ratified in 1985) which acknowledges traditional customary rights of the inhabitants. Many in the Torres Strait communities are aware of the quarantine risks through the education and extension activities of NAQS.

Recommendation 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.

3.8 Tourism

Many unwanted pests and diseases enter Australia with returning travellers, either on their persons, in the luggage as incidental hitchhikers or during attempts to import prohibited materials . Australian quarantine has always maintained a high profile with the travelling public and is well respected for its efforts. Its reputation for protecting Australia against the entry of exotic pests is well deserved. This aspect of AQIS' operation and the need for increased awareness by returning Australians and tourists is dealt with under Section 5.1.

3.9 Deliberate introductions for research

Research material in the form of live specimens including insect, plant material and seeds, fungal and viral material enters Australia after a permit has been raised through AQIS. Universities, other research institutions and some CSIRO Divisions generally use State Quarantine Services for these introductions. A number of CSIRO Divisions use the Plant Introduction and Quarantine Service within the Division of Plant Industry in Canberra. This Unit operates under a Quality Assurance agreement with AQIS and provides an efficient service for a number of clients importing biologicals for research purposes. The CSIRO officer in charge of this Unit is an accredited Quarantine Officer and this factor is important in facilitating the importation of research materials while at the same time ensuring that strict quarantine protocols are followed. There are numerous advantages in having a Quarantine Officer familiar with research requirements associated with a research institution. Apart from being able to facilitate the release of material for research purposes, the presence of such an officer raises the level of consciousness of quarantine requirements within a research institution. With the increasing traffic of material (plasmids etc.) used in genetic engineering research there is a need to exercise greater vigilance in this area. The potential for breach of quarantine regulations is increased by the small amounts of material involved. The CSIRO Quarantine Officer is confident of interception of all quarantinable material coming into CSIRO in Canberra. This is particularly important because of the significant amount of material that is missed at the international mail exchange in Sydney.

Recommendation 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 Deliberate introductions for biological control

Australia as an island nation has enjoyed freedom from many pests and diseases endemic to other countries. However, the flipside of this fortunate situation is Australia's high vulnerability to ecological, economic and environmental impacts when pests enter the country without the restraining influence of the biotic factors which might restrain the pest in its natural domain. The identification and introduction of specific and effective natural enemies to exert a measure of biological control has been a hallmark of research in CSIRO and all relevant State Departments in Australia. Australia is recognised around the world as a leader in this field because of its impressive record in safe and successful introductions. Australia has been a pioneer in many areas of biological control, e.g. being the first country to use fungal species to control weeds such as skeleton weed. AQIS, together with the EPA, provides approval for the importation and release of biological control agents, once specificity and safety has been demonstrated. In reaching its decision, AQIS and the EPA rely on the technical advice of CSIRO and the relevant State Departments, following an evaluation of the evidence supplied by the importing research organisation. In the past, these arrangements have been entirely satisfactory and have been conducted in a spirit of cooperation and collaboration. However, with the recent downsizing of AQIS, a considerable loss of technical expertise occurred and, in the view of some collaborating institutions, there exists a real danger that AQIS is compromising its capacity to maintain its leadership role in supervising the importation of biological control agents. A separation of operational and policy responsibilities and the early retirement of senior technical staff in AQIS has been a cause of real concern to biological control practitioners.

Recommendation 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.

3.11 Genetically modified organisms (GMO's) and quarantine

Under the Convention on Biological Diversity, Australia is engaged in consultations on a possible protocol on biosafety of GMOs. This is led by the Department of Foreign Affairs and Trade in consultation with other government departments and NGOs. At the most recent meeting held in Madrid during 24-28 July 1995, delegates from the majority of the countries favoured a legally binding instrument (a Protocol) on biosafety. However, Australia and some other countries had not developed a firm position at that time. Whether or not a Protocol is agreed upon, the movement of GMOs between countries is certain to become an important issue and one requiring regulation. Whether this should entail legislation separate from that already in place for the movement of organisms other than GMOs is debatable. For instance, New Zealand has adopted the stance that the same legislation should apply to the movement of all living organisms, be they naturally occurring species, those developed by conventional breeding or those resulting from recombinant gene technology. There is much to commend this approach.


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