- 4.2.1 Pre-harvest orchard survey
- 4.2.2 Enhanced inspection
- 4.2.3 Dasineura mali
- 4.2.4 Pseudococcidae spp.
- 4.2.5 Tortricinae spp.
- 4.2.6 Thrips obscuratus
- 4.2.7 Eriophyes mali
- 4.3 Nectria galligena
4.2 Arthropods
As New Zealand has indicated in previous sections, there are no arthropod pests of apple fruit that require risk management, as the assessment of risk associated with the unrestricted importation of apples is below Australia's stated ALOP. However, even if the level of risk assessed by AFFA is deemed to be an accurate interpretation of the scientific evidence, New Zealand believes that the phytosanitary measures proposed by AFFA are not the least trade restrictive measures available for these pests. In some cases the measures provide a level of phytosanitary security that is considerably higher than is required to meet Australia's ALOP.
New Zealand also requests a revision of the pest categorisation of Tortricinae and Pseudococcidae, and requests a review of the taxonomy of Eriophyes mali. As a result the proposed phytosanitary measures for these groups of pests should not be specifically required.
4.2.1 Pre-harvest orchard survey
AFFA has proposed that two management strategies be combined as risk management options. One such measure is an orchard survey designed to "ensure that pests do not occur at levels that would pose more than a very low risk of them being present on the fruit". No pest tolerance (other than that implicit in any sampling programme) is permitted on any part of the apple trees within the survey area. It appears, therefore, that AFFA is applying a phytosanitary measure to ensure that the ALOP is met at the point of harvest, i.e., to ensure that there is a very low risk of the pests being present on harvested fruit. This approach does not take into account any of the subsequent stages in the importation pathway that serve to reduce the probability of entry, establishment and spread.
New Zealand asks that AFFA review the basis of the orchard survey strategy to ensure that this risk management option meets, but does not greatly exceed, Australia's ALOP. New Zealand suggests that this may be done by looking at pest tolerances in the survey, or by reducing the intensity of inspection from entire trees to a certain number of leaves (or other parts appropriate to the pest being surveyed for).
| New Zealand requests that AFFA review the basis of the orchard survey strategy. |
4.2.2 Enhanced inspection
For a number of pests, AFFA is requiring a detailed examination of the calyx using a knife where appropriate. It is not clear whether the instruction to use a knife involves cutting or simply probing the calyx.
| New Zealand asks that AFFA clarifies that the intention is consistent with the statement that this "does not involve dissecting fruit" (p.105, l.40). |
4.2.3 Dasineura mali
New Zealand does not believe that the use of a hand lens is necessary when inspecting apples for D. mali. In section 3.2.1 we referred to literature which states that it is the mature larvae that are most likely to leave the leaf curls and move onto the fruit. These larvae are 4mm long and are orange in colour.
| New Zealand asks that AFFA reconsider the necessity for inspection using a hand lens. |
4.2.4 Pseudococcidae spp.
All of the species of Pseudococcidae recorded on apples in New Zealand have been categorised as non-quarantine by AFFA. New Zealand has, in section 3.3, presented arguments that the record of "Pseudococcidae spp." on the apple pest list is almost certainly one of the other mealybug species already recorded. New Zealand has asked that AFFA revises the pest categorisation, and removes "Pseudoccidae" from the group of quarantine pests. When this is done it is clear that no risk management measures are necessary for this group, as all species are non-quarantine.
| New Zealand considers that all Pseudococcidae spp. on apple fruit from New Zealand are non-quarantine. |
4.2.5 Tortricinae spp.
As for Pseudococcidae spp., New Zealand has asked AFFA to remove this reference from the draft IRA. Again, all of the species of this sub-family that have been found on apple are listed in the draft IRA.
| New Zealand considers that no measures are required for this sub-family over and above those for the species listed. |
4.2.6 Thrips obscuratus
In section 3.6 New Zealand presented arguments that supported a reassessment of risk to very low. On that basis New Zealand does not believe that further risk management measures are necessary or justified.
AFFA states that T. obscuratus has been intercepted on apricots, cherries, nectarines and peaches from New Zealand. The phytosanitary measures required for T. obscuratus on these crops are a visual inspection of the inspection sample with up to 10% inspected with 10x magnification. It is logical that the measures required for apples be equivalent to those required for this pest on stonefruit.
| New Zealand requests that AFFA applies equivalent measures for this pest on apples as it does on other crops from New Zealand. |
4.2.7 Eriophyes mali
The discussion in section 3.7 raised two main concerns in relation to the pest categorisation and risk assessment for E. mali. New Zealand has asked that the taxonomy of E. pyri in Australia be clarified, as this is recorded on apple. The two species are host specific, suggesting the presence of E. mali in Australia. New Zealand also believes that, even if E. mali is absent from Australia, the risk has been over-estimated. New Zealand believes that the risk should more appropriately be assessed as very low. In either case, no risk management measures should be required for this species.
| New Zealand believes that this pest falls below the ALOP and no measures are required. |
4.3 Nectria galligena
In section 3.8 New Zealand provided information that supports our position that the risk of entry, establishment and spread of N. galligena is very low. On that basis New Zealand does not believe that the orchard survey required by AFFA is justified. However, even if AFFA's risk assessment was substantiated New Zealand believes that AFFA should have considered other, less trade restrictive, risk management options. These may include options such as sourcing fruit from low risk areas, or phytosanitary inspection (alone) for latent rots.
AFFA has not provided any data to support the need for phytosanitary inspection in addition to orchard survey. The literature states that if an orchard is free from European canker, then latent infections never occur. It is therefore difficult to see how a phytosanitary inspection (and associated testing) for the disease can be justified.
| New Zealand asks AFFA to provide the justification for phytosanitary inspection and testing if orchard freedom (as determined by inspection) is also required. |
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