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The Academy considers that there is a need to view Australia's quarantine requirements in a broad context. Responsibilities for the several components of the problem are divided among a number of Federal and State government instrumentalities, and much policy seems to have been developed in response to particular crises. As in law, bad cases do not make good quarantine procedures. The Academy considers that the matter of protecting the Australi an environment, primary industry and public health needs to be considered under five main headings. These, and the relevant Terms of Reference (TOR), are:
5.1 Awareness of, and preparedness for, potential threats. 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 a unique flora and fauna to evolve, protected from pathogens and competitors from other countries. Everyone knows that Australia's birds and mammals are unusual, but not everyone appreciates that almost the entire biota shares those characteristics of uniqueness. Many native species have inadequate resistance to introduced diseases, and most natural ecosystems cannot cope with introduced organisms without catastrophic change; they are more disturbed by introduced species than their counterparts in other countries. It is thus of great importance to understand that the World stands to lose a significant part of its biodiversity if Australian ecosystems are put further at risk by the accidental entry of pest species. This is perhaps the most important reason why quarantine defences must be strengthened, not downgraded. In addition the perception of the public has changed, with the environment now a prime concern of many Australians and likely to increase. In the past AQIS gave primary attention to trade-related issues, and the ecological consequences of pest introductions were of secondary importance. Priority setting in the immediate future will have to pay equal attention to the protection of the native biota and ecosystems, as to the protection of primary industry. This will affect funding policies for AQIS. Recommendation 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. An important component of being prepared is to know what the potentially dangerous exotic species are, where they come from, and what the probabilities of them becoming established in Australia are. If the biology of the species is well known, it is now a relatively simple matter to predict what its distribution in Australia would be, using systems like CLIMEX, developed by CSIRO and the CRC for Tropical Pest Management. This is even exemplified by the Russian wheat aphid (see Section 4.1.6). AQIS should arrange for a dossier to be prepared for each potential insect pest and weed, as is already done for human pathogens and animal and plant disease organisms. Such a dossier would summarise taxonomic status and means of identification (illustrated with keys and photographs); the area of origin, present distribution, physiological and ecological characteristics, life history, host plants (for insects) habitats (for weeds) and current pest status. With this information the probable distribution in Australia could be predicted and likely routes of entry identified. Current methods of control being employed elsewhere would be included, as well as prospective methods for eradication and/or long term control, including possibilities for biological control. Each dossier should be reviewed regularly and up-dated. Examples of dossiers that are relevant to the biological control of target insect pests and weeds can be supplied if the Committee so wishes. An important feature of such dossiers would be their public availability, through the print media but more importantly by being accessible on the Internet. A major omission in the NAQS review (1995) was any mention of the urgent need to provide NAQS personnel with an effective and ready means for recognising target plant pests and diseases and weeds. Specimens, keys, colour photographs of the pests/diseases and weeds and the damage they cause should be provided. Also, at least the scientific (and other key) personnel should be sent overseas to become familiar with the target pests/diseases/weeds and the damage they cause. This would greatly improve the chances of early recognition of target pests, should they appear on Australian soil. Recommendation 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. In relation to the knowledge that an unwanted organism is newly-present in a nearby country, there is great merit in consulting as soon as possible with that country to learn whether, with the assistance of Australian expertise and funding, it would welcome a collaborative control project. This was done successfully, for example, when the banana skipper (Erionota thrax) moved from Irian Jaya into Papua New Guinea (PNG). This serious defoliator of bananas posed a major threat to the Australian banana industry when it spread throughout PNG. With encouragement and funding from ACIAR, a collaborative project between CSIRO and PNG was established which, after three years, resulted in biological control of banana skipper in PNG. The carefully-tested parasites involved could now be available at short notice, should it ever be necessary to establish biological control for the banana skipper in Australia. Developing biological control of potential pests in countries where they now occur is particularly attractive; it simultaneously provides valuable aid to neighbouring countries and nurtures Australian expertise, which would be available in the event of an incursion in Australia. Also, by lessening pest populations in the neighbouring country, it not only provides an additional degree of protection against invasion of Australia, but would also greatly shorten the lead time for establishment of biological control here. This sort of collaborative research and development falls well within the remit of ACIAR (e.g. funding in Phillipines, Indonesia and Malaysia), AusAID, and possibly also ABARE (e.g. in Papua New Guinea). Recommendation 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. Recommendation 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. In the longer term there is a real danger that the corps of experts in taxonomy, who are the people competent to recognise potential and actual pest species, will be too small to provide the essential expertise on which quarantine services depend. In Australia there is a steady and serious decline in the number of professional taxonomists (see Report of the ABRS Workshop Taxonomy in Crisis, held in Canberra on 19 December 1995). Recruitment from the Universities is also in severe decline, because taxonomy is not regarded as a fruitful career path. In the short term there needs to be an injection of resources into the Australian Biological Resources Study (ABRS) in order to recruit appropriate specialists and to provide research funds for taxonomists in Museums and Universities. Also, in the longer term more attention needs to be paid to using the school system to better advantage. Almost every child now is exposed to some form of environmental education. A high proportion of children now place 'the environment' ahead of almost every other of their concerns, including unemployment and economic recovery. Furthermore, children are more responsive to environmental concerns than most adults. They are really coming to care about the maintenance of the ecosystem, even before they understand the meaning of the concept! The quarantine message has not been adequately directed at this group, and it should be. Children influence their parents even better than any direct approach to the parents themselves. In 1994 the Australian Academy of Science published the first comprehensive textbook for senior students, devoted to the topic of the Australian environment, entitled Environmental Science. Weeds and introduced animals are referred to in a number of places in the text, but the importance of quarantine, in a direct form, is missing. We give this example as one instance of the kinds of change that must be made, if the message is to be appropriately focussed on a receptive audience. One possible avenue for maintaining interest in quarantine, particularly in secondary schools, would be to emulate the combined exercise by the University of Melbourne and the Walter and Eliza Hall Institute in offering science teachers the opportunity to bring themselves up to date in their disciplines by allowing them to work in research organisations directly involved with quarantine-related research. By working alongside scientists, using laboratory and field techniques and being involved in the scientific methodology, such persons would be able to pass on the real problem at first hand to their pupils. Recommendation 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. Travel patterns have undergone remarkable changes in recent decades and the vast increase in tourists and others arriving by air presents a serious difficulty to ensure that the importance of quarantine to Australia, and our unique needs for protection, are appreciated. Lapses in quarantine may have serious consequences, so it is important that considerable effort be given to publicising our quarantine security, and awareness of the importance of quarantine issues for the national well being should be maintained. However, the low penalties imposed by the courts for infringements of quarantine does not reinforce the seriousness of quarantine protection and it is not surprising that the greater part of the population is unresponsive to the quarantine message. The seriousness with which we took this was formerly reinforced by the fumigation procedures carried out on landing. These procedures continue to apply to many but not all airlines (eg Qantas is excepted); the reason for this is not obvious. It is quite understandable that these procedures caused considerable annoyance but they did ensure that the need for quarantine was taken extremely seriously. Ways must now be found to get that message across without raising the ire of new arrivals. Would it be feasible to make it a requirement for landing an aircraft from overseas that a short but hard-hitting video message in appropriate languages be played shortly before landing? We do not underestimate the difficulty of such a proposal. However, the importance of getting the message across is so great that all possible ways of doing so must be explored. Static displays, the distribution of 'fliers' and leaflets, posters, and pleas by prominent Australians all play their part, but they are clearly insufficient. Reinforcing the message by all available means is truly vital. Recommendation 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 magazine. 5.2 Maintenance of appropriate and effective controls barriers Recommendation 5.2.1 Surveillance at harbours and airports should be strengthened and the Northern Australia 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. In regard to applications for the importation of exotic species, the need to apply the 'precautionary principle' is essential for the protection of native ecosystems. This principle was formerly a driving force in Australian quarantine policy, but it appears to have became subject to strong objections, being perceived to be too obstructive to trade. Its re-introduction as a guiding principle now requires serious reconsideration, with the increased importance of protection for the native biota and ecosystems. Recommendation 5.2.2 Procedures for the importation of living organisms, other than mammals and birds, needs to be greatly tightened up; restrictions on the import of fish and many types of plant are quite inadequate to meet environmental risks. Recommendation 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. The vexatious question of the Commonwealth/States relationships also affects the exercise of quarantine in Australia. In this important regard, New Zealand has a decided advantage over Australia. In New Zealand quarantine breaches and the consequent economic and environmental impact are handled holistically as 'two sides of the same coin' and are not considered as separate entities under different jurisdictions, an unnecessary and unfortunate outcome of the existence of the Commonwealth and States within Australia. Recommendation 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 Contingency procedures to deal with incursions 5.3.1 Exotic pests and biological control New insect pests and weeds will continue to arrive in neighbouring countries and, despite the best efforts of AQIS, many of these will sooner or later appear in Australia. Some will also come from further afield. The rate of intrusion of new insect pests has been (at least in recent years) greater than for all other unwanted organisms combined (see Section 4). Therefore, it is important to have contingency plans well developed in advance to eliminate new incursions at the first opportunity and, if this is not achieved to keep the new pest under control. Contingency planning for the incursion of target pests and diseases of plants was recommended by the NAQS review, but for a limited number only and over a period of five years. Preparation of plans should commence as soon as possible and, if necessary with the help of consultants, be completed within two years. Reference is made elsewhere (Section 5.2) to the importance of these dossiers of information on each pest. The higher priority recommended for surveying Torres Strait, Cape York and northeast Queensland is long overdue as a result of the history of actual invasions and the very high risk of further invasions. Not included, however, is the risk caused by the 40,000 or more visitors now travelling by road each year up into Cape York, many also visiting nearby Torres Strait Islands. In order for adequate surveys to be carried out in the regions in Australia and overseas that are the responsibility of Queensland NAQS personnel, their numbers need to be strengthened significantly. The Australian Veterinary Emergency Plan (AusVetPlan) is a set of strategies and contingency plans to cope with the entry into Australia of any one of a set of major livestock diseases, including foot and mouth disease, screw-worm fly, and Asian honey bees. The arrangements deal with many complex administrative arrangements such as cost-sharing provisions between the Commonwealth and the States and cover specific technical actions such as use of sterile males for old world screw-worm, quarantine areas and livestock destruction etc. The plans are predicated on identification of the disease in domestic stock and the ability rapidly to control movements of stock in the affected area. Feral populations of domestic species, such as goats and pigs, pose a serious hazard to the control of exotic disease of stock. For instance, Hone and Pech (Journal of Environmental Management, 31, 173-84, 1990) estimate that, with current surveillance techniques, the time to detection of an outbreak of Foot and Mouth Disease virus (FMD) in feral pigs could range from 23 to 358 days, depending on the density of the pig population, and Pech and McIlroy (Journal of Applied Ecology, 27, 635-50, 1990) estimate that the velocity of spread in a moderate density of 1.4 pigs per square kilometer would be 2.8km per day. Using these minimum estimates for time of detection, the disease could cover an area of 50,000 square km when first detected and would already be out of control. These conclusions emphasise the importance of considering disease preparedness in relation to the whole environment, rather than from the perspective of the specific industry and user group only. Recommendation 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. Apart from screw-worm fly and honey bees, no comparable arrangements to AusVetPlan have been put in place for exotic invertebrate pests, plant diseases or weeds entering Australia. Clearly, this cannot be due to a lower perceived risk or lesser magnitude of economic or environmental impact; whitefly, Russian wheat aphid or western flower thrips are each capable of inflicting enormous losses on agriculture (see Section 4.1). In the case of Russian wheat aphid, contingency plans were developed and pre-emptive research was conducted during the 1980s, so that some state of preparedness has been developed to cope with its entry. No arrangements were in place before whitefly and western flower thrips entered Australia, and surprisingly little has been done since these latter pests, or weeds such as Chromolaena, entered Australia. Indeed, there is even debate about when and how frequently these pests have breached quarantine and what was the mode of entry, whether as illegal or legal imports. It is only when identified exports are directly threatened, such as the incursion of papaya fruitfly in Cairns, that decisive action and the political will is evident (AQIS Bulletin, January-February 1996). Whitefly and western flower thrips are each likely to cause greater economic damage and production costs than the papaya fruitfly, but each of these is an incremental problem and therefore its impact is more insidious. Because of this, there was no obvious trigger for effective action to cope with these more significant incursions. What is required is a national contingency plan for each major potential pest and some suitable title, such as AusPLANT, could be coined to indicate the existence of a plan, designed to handle quarantine risks associated with plant health that affect agriculture or the environment. Recommendation 5.3.1.2 The Review Committee 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 Essential role of taxonomists in developing preparedness. There are many examples where taxonomic knowledge, or its absence, has had a major impact on quarantine issues both with export markets and with efficiency of our primary production systems. For example, citrus markets in Florida were at risk because of the detection of mite specimens in certain shipments. The Animal and Plant Health Inspection Service (APHIS) relied on the expertise and independence of CSIRO's Australian National Insect Collection (ANIC) to investigate the problem. It was established that not one, but four mite species were present in the shipments but, for a variety of reasons, none posed a problem to the USA. In another example shipments of table grapes to New Zealand were under threat because of records showing that a particular moth species occurred in Australia. Experts at ANIC demonstrated that these records were incorrect and the difficulty evaporated. Some might argue that recent taxonomic studies on the 'dorsalis' complex of fruit flies, revealing over 50 species in the complex was information we ' could have done without'! In the case of the papaya fruit fly incursion (Section 4.1.1) the taxonomic knowledge proved critical to resolving the problem. In that instance, ecological studies were also critical, and the situation would have been different if the technology on lures had been adopted, as recommended. Failure to identify, for over a decade, the changa mole cricket as a 'new' and damaging pest (it entered Australia before 1983 but was not recognised until 1995) of pastures, bowling greens and golf courses, and delays in recognising the multiple entry of whitefly, western flower thrips, and the incursion of the spotted clover aphid, all illustrate the need for sound taxonomic capability in the country and a capacity within AQIS to use these skills effectively. A major concentration of these skills lies within the ANIC, but critical skills also reside in Museums, some State Departments and several Universities. Whereas the number and importance of incursions of exotic pests into the USA and Australia is probably of similar magnitude, particularly insect pests (see Section 4), APHIS, the Agency responsible for plant quarantine in the US, pays an annual retainer of $US400,000 to the US Department of Agriculture Insect Collection in Beltsville to provide an identification service and other expert advice on risk assessment. Despite many discussions on this topic in recent years between AQIS officers and other relevant organisations, research providers in Australia are not adequately compensated for their services. These are presumed to be provided gratis to AQIS, which is inconsistent with the 'user pays' policy being applied to services provided by AQIS. It might be desirable to contract the larger providers such as the ANIC and pay such groups a retainer to provide an agreed set of services, with the costs ultimately being recouped from those who capture the benefits. Possibly such groups could subcontract out particular tasks to other organisations, if that is where the appropriate skills reside. At the very least, AQIS should acknowledge the role played by research agencies in assisting it in the discharge of its duties and support these agencies in their bid for appropriation resources. Recommendation 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 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 the ARC or NHMRC. 5.3.3 Plans for eradication of a new unwanted organism in Australia A number of factors influence the ease and cost of eradication, amongst which are:
Recommendation 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. Although eradication is possible for some pests, its cost (and sometimes public opposition to the methods involved) often preclude this option. An additional problem is the risk of re-infestation. Eradication almost always involves the extensive use of pesticides. In the case of a few well-researched insect pests (e.g. fruit flies, screw-worm), it may involve the mass liberation of sterile males and, in some cases, it may be possible to arrange for long host-free periods. In the case of weeds, mechanical control may be a valuable aid to eradication. Critical, often, is the speed of taking appropriate action before the insect pest or weed has spread so widely that eradication is prohibitively expensive. For speed of action, it is necessary to have, in advance, a dossier of information for each pest (or group of pests if the measures for each would be identical) detailing the most up-to-date technology for eradication and the organisational framework necessary to implement it. In relation to biological control, a special plea is made for the Review Committee to recommend a simplification of the very lengthy, cumbersome and complex procedures (involving some 20 separate Commonwealth and State authorities) before approval can be given by AQIS for the introduction of organisms for the biological control of insect pests and weeds. Recommendation 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. The aim here is to maintain the pest population indefinitely below the threshold at which it causes economic damage: sometimes also to restrict or delay its spread to other areas. This option is attractive because of the far lower initial cost than eradication. However, the cumulative long-term costs are often likely to be far greater, so the feasibility and cost of eradication should always be considered for a new intrusion. Long term pest management may involve many methods other than those available for eradication. The introduction of adequately-specific natural enemies (classical biological control) is the most highly desirable single option. Biological control aims to introduce and establish in Australia the natural enemies that maintain the exotic species at a low level in its region of origin - enemies that have not accompanied the pest to Australia. Australia has an unblemished record in the field of insect pests and weeds and, with impressive ratios of benefits to costs (probably on average in excess of 30:1). When classical biological control is carried out with long-established safeguards no unacceptable problems arise, the method is highly selective, non-contaminating and, once established, is self-sustaining. Of course, there are other components of pest management systems (cultural methods, use of resistant varieties, etc.) that can be valuable when biological control alone is inadequate. 5.3.5 Future of the National Facilities Initiative for quarantine capability in Northern Australia The recent outbreak of whitefly and papaya fruit fly has highlighted the need to have adequate preparedness to deal with quarantine issues in the tropics and in particular to have the necessary research capacity in situ to support industries in the tropics. A consortium has been established to plan and implement a replacement for outdated, outgrown and ineffectual containment facilities in the Brisbane area. A new, integrated complex, serving the northern Australian region is an integral component behind a broader concept for structural changes emerging for research providers supporting primary industry in northern Australia. The complex is also intended to underpin the development of a broader biological technology park involving CSIRO, University of Queensland, the Queensland Departments of Lands and Primary Industries and the CRCs for Tropical Plant Pathology and Pest Management by providing an advanced capacity for the biological quarantine and biotechnological containment needs of northern Australia through the development of a high security containment complex. The complex would have the potential to form a strong innovation cluster in northern Australia with emphasis on regional development, natural resource protection and sustainable primary industries. The cluster will become a collaborative framework for the integration of national and regional research, education and diffusion of biological sciences in northern Australia. The complex would provide secure quarantine and containment conditions with the highest appropriate quarantine standards for the following:
The biological resource complex would enable or enhance:
Recommendation 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. Compared to the sums spent on military defence, the budget for defence against exotic pests, which pose a more insidious threat, is very small indeed. There is a view that, because in the long term all organisms capable of invading various environments will come to do so, there is no point in attempting to slow the process. The Academy challenges the premise and rejects the conclusion, believing that it is irresponsible not to take every possible action to slow the spread to Australia of potential pests and diseases. On economic grounds alone, it is far cheaper to prevent the entry of a pest than to control it once it is in Australia. That being said, the costs of the recommendations set out above represent a substantial cost to the country and it is appropriate to consider how or from whom the costs should be recovered. The purposes and benefits of quarantine protection may be considered under three headings:
It is fairly clear that the costs under the first head must be borne by the whole country because all benefit. Conversely, the costs involved in the third head can be largely, if not entirely, recovered from the exporter, who benefits from Australia's reputation as a clean country, and who benefits from the assurance provided by AQIS that the products being exported have met international criteria. The area of contention and risk relates to the second head, where the individual importer may benefit in the short term but the long term costs of negligence are borne by the whole country. An example is the livestock industry, which has an understandable desire to import bulk grain when overseas sources are cheaper. While the shift was initially triggered as a 'one-off' by drought-induced collapse in local supplies, the demand for overseas feed-lot grain is unlikely to be completely reversed with favourable seasons. The intensive livestock industries also consider that the local grain industry may not be able to supply its long term needs if the livestock industry continues to expand on current projections. The up-country transport of grain containing insect pests, diseases and weed seeds for local disinfestation treatment by the relevant industries will place great demand on existing technologies and the robustness of procedures which rely on 'quality assurance' concepts. The Lindsay Report did not anticipate the major policy changes, structural reorganisations and down-sizing program that have been implemented within AQIS over the past five years. For example, Recommendation 41 stated that user charges should only be levied at the border 'for commercial importations where a treatment which is not a precondition for quarantine clearance is undertaken by the quarantine service at the importers' request'. This recommendation was not accepted in the Government's Response of Dec 1988 (1), but the Government's policy did not foreshadow implementation of full cost recovery for all operations, including all import activities. This policy is clearly articulated in AQIS's brochure titled 'Quarantine Inspection: the QA Alternatives' which states 'But, now that AQIS recovers 100 per cent of the cost of its services, the cost of inspection is a major consideration for importers. It is now possible for importers to introduce their own controls to address quarantine requirements'. Importers are attracted to this alternative because there is a real potential to reduce import costs and increase the flexibility of their operations.' This matter is further elaborated in the AQIS submission to the Senate Committee of Enquiry into Rural and Regional Transport, 1995. Thus industry participation and quality assurance are corollaries of a government decision to recover the operational costs of AQIS. In the 1993-4 financial year AQIS recovered $120 million of its $180 million operating costs from its clients. Do these figures imply that AQIS is two thirds the way towards achieving the Government's policy objectives of full cost recovery? Presumably some portion of AQIS's budget should derive from appropriation in recognition of its role as policy advisor to Government or for services such as airport terminal inspection where cost recovery for services to the travelling public would not be practical. In seeking greater industry participation, AQIS has encountered another significant challenge relating to container fumigation of commodities such as timber. This is illustrated by a specific example. In correspondence with Rentokil, UK AQIS states 'at some future date AQIS will no longer recognise fumigation certificates from all overseas fumigation companies. To gain listing as an approved fumigator, companies will need to submit to AQIS records and documented procedures to show that they have a Quality Assurance system in place to fumigate according to Australian requirements.' We quote from Rentokil some of its concerns about the direction taken by AQIS.
' when our people quote to undertake work it will be the right price for the job, taking into consideration the amount of work to be done, particularly if the containers are damaged or leaking. More often than not, our quotations are not accepted and the work is carried out by unqualified, inexperienced companies who consistently flout your regulations and undertake the work at the lowest price. There seems to be no enforcement and therefore over the years the standard has been undermined.' 'and our company (a company which has got the worldwide abilities and resources to conform to the standard) may, in many countries, decide that it is not economically viable for us to compete which I believe would be a pity.' This correspondence indicates that Australia's interests are not necessarily being well addressed by the course of action being imposed on AQIS by government policy. The experience in the USA, as interpreted by the US Congress's Office of Technology Assessment, on 'Fee for Service' where there are significant externalities which are ignored by economic rationalists is one of concern. They conclude 'Typically, fees are structured to raise revenue, not to recoup damages or to change people's behaviour.' Recommendation 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 therefore borne by the Commonwealth. 5.5 Quarantine policy framework 5.5.1 The place of AQIS in the bureaucracy The Academy draws attention to some of the limitations of AQIS' current relationship with DPIE. AQIS is one of the seven operating groups in DPIE. Its mission is subsumed in DPIE's mission which is ' to contribute to the sustainable, competitive growth of Australia's resource based industries'. Throughout the Academy's submission we emphasise that quarantine embraces environmental and health issues, which fall outside the scope of DPIE's mission. The Academy also notes that AQIS' primary interests are export and market focused. Incursions and threats are evaluated, and action taken with this emphasis in mind. For example, pests that threaten an overseas market attract a greater response than pests that largely impinge on sustainable and competitive production; incursions whose main initial impact is perceived to be environmental (eg Siam weed) receive less attention still. Despite the current perceived imbalance, the Academy does not believe the position would necessarily be improved by shifting AQIS to another Department. Recommendation 5.5.1.1 The Academy recommends that careful consideration be given to establishing AQIS as a Statutory Authority Whether AQIS becomes a Statutory Authority or remains in the Department of Primary Industries and Energy (DPIE), it is important that mechanisms are in place for AQIS to seek and receive relevant and appropriate advice from other Departments, such as Health and Environment, and with Agencies such as BRS, ABARE and ANCA, and with CSIRO. The Academy believes that Australia is not in a strong position to deal with some threats to its economy and environment and accordingly the Review should explore more appropriate mechanisms than Interdepartmental Committees to redress the situation. Most importantly, there should be strong and sustained links with the relevant experts in the Universities and Museums. The Government's belated but dramatic response to the papaya fruitfly incursion, and its failure to respond adequately to other major breaches to Australia's quarantine barriers suggests that there needs to be much better linkages between AQIS and other agencies. Recommendation 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. Recommendation 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 Quarantine and Inspection Advisory Council (QIAC) This Advisory Council (QIAC) was set up by the Minister of Primary Industries and Energy, Alan Griffith in 1992. QIAC's role is described in its Terms of Reference as facilitating 'the development by the Commonwealth Government of sound, consistent and comprehensive policies in relation to quarantine and inspection services through the active, coordinated participation of those industries involved in quarantine and inspection services and in reviewing developments in the policy formulation process'. While the remit of QIAC is broad, there is a clear emphasis on trade, especially Australia's export industries and the commercial and economic aspects of AQIS's operations such as 'charging regimes' and 'performance indicators'. The membership of QIAC also reflects this perspective, with members being drawn principally from primary industries and downstream food processing and export related industries. The Academy recognises the importance of protecting Australia's export trade interests but stresses that quarantine embraces a wider range of responsibilities, including human health and especially environmental issues. As noted elsewhere in this submission, the entry of exotic pests, weeds and diseases can materially affect the efficiency of production of our major export commodities, including meat products, grains and horticulture. The presence of these organisms can reduce the competitiveness of these industries, even render them inviable in extreme cases, and are likely to have enormous adverse impacts on the environment. The current position makes bad economic sense in the short term, as well as being indefensible economically and environmentally in the long term. Recommendation 5.5.2.1 The Academy proposes that 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.
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