Comments of the New Zealand Government On The Draft Import Risk Analysis On The Importation of Apples From New Zealand
December 2000
1. Summary
This submission contains New Zealand's comments on the Draft Import Risk Analysis on the Importation of Apples from New Zealand (October 2000), which was prepared by the Department of Agriculture, Fisheries and Forestry - Australia (AFFA).
New Zealand considers that, in particular in respect of its evaluation of the risks associated with the disease fire blight, the draft IRA falls well short of meeting the established criteria for what constitutes a proper risk assessment1. In particular:
- the methodology adopted by AFFA has not been consistently applied at each of the steps identified in the biological pathway for fire blight;
- there has not been an assessment of the probabilities at every step identified along the importation pathway;
- there has been no separate assessment of the risks associated with fruit infection, infestation of the calyx-end of the fruit, epiphytic contamination of fruit surfaces, or the presence of trash, despite risk management measures being imposed by AFFA;
- AFFA has failed to assess one important step in the biological pathway for entry, establishment, and spread of fire blight;
- in some instances, AFFA has taken possibilities, as opposed to probabilities, into account in the risk assessment;
- in its assessment of some of the steps along the importation pathway, AFFA has inappropriately "inflated" the assessed probability by the premature application of Australia's "very conservative" appropriate level of protection;
- AFFA has made errors of significance to the outcome of the risk assessment when interpreting the conclusions of various authors;
- in establishing criteria for economic impact, AFFA has failed to follow international guidelines; and, as a result
- the assessment of the economic consequences for fire blight disease in Australia have been seriously overestimated.
These deficiencies are detailed in the sections that follow. If the deficiencies identified in this submission were corrected, then New Zealand believes that the overall likelihood of entry, establishment and spread of fire blight would be assessed by AFFA as negligible. Indeed, such an assessment would support New Zealand's long-held view, based on scientific evidence, that trade in mature apples free of trash poses negligible risk for the transmission of fire blight disease.
Furthermore, as a result of these deficiencies, the overall assessment of risk (the product of likelihood of entry, establishment and spread combined with assessed economic consequences), has been overstated.
Had both the likelihood of entry, establishment and spread, as well as the assessment of economic consequences, been properly estimated, the overall assessment of risk of entry of fire blight on exports of mature New Zealand apples free of trash to Australia, in the absence of any specific measures to mitigate risk, would have been "negligible", and therefore below Australia's Appropriate Level of Protection (ALOP).
New Zealand submits that AFFA should review the draft IRA accordingly.
In any event (i.e., regardless of whether or not the overall assessment of risk has been overstated) New Zealand further considers that a number of the measures identified by AFFA in the risk assessment as necessary in order to meet Australia's ALOP, in respect of fire blight in particular, do not bear any rational or objective relationship to the identified risks along the biological pathway. In other words, several of the measures identified are not based on the risk assessment.
A particularly prominent instance of such a measure is the requirement that registered orchard blocks be subject to three inspections in the season of export and in the previous season in order to establish freedom from fire blight disease, as a prerequisite for clearance to export.
Other instances of measures which New Zealand considers are not based on any risk assessment done by AFFA are:
- a 50 m detection zone;
- segregation and disinfestation of harvesting bins;
- disinfestation of fruit by chlorine dipping;
- disinfestation of pack houses; and
- 1m separation of product within cold stores
New Zealand further considers that the above measures are not the least trade restrictive available to Australia in order to meet its ALOP.
New Zealand submits that AFFA should review the above measures accordingly.
With regard to other pests, New Zealand considers that AFFA has over-estimated the risk posed by these pests and that the prescribed phytosanitary measures are not necessary. In particular:
- the categorisation of whole families or sub-families as quarantine pests is not justified (in this case Pseudococcidae and Tortricinae);
- it is questionable whether Eriophyes mali can be considered a quarantine pest due to its likely presence in Australia;
- the risk associated with Dasineura mali, Eriophyes mali, Ctenopseustis herana, C. obliquana, Planotortrix excessana, P. octo, Thrips obscuratus and Nectria galligena have been over-estimated;
- the requirement for enhanced hand-lens inspection for Dasineura mali is not justified because the life stage that may occur on fruit is easily recognisable without magnification;
- orchard surveys for arthropod pests appear to be designed to meet Australia's ALOP at the time of harvest, without regard to the other elements of the importation pathway that subsequently reduce risk, and hence provide a higher level of protection than is necessary.
- New Zealand also considers that, due to the overestimation of risk and the measures which AFFA proposes to implement, Australia would achieve a higher ALOP against risks associated with apple imports from New Zealand than that achieved in other comparable situations (for a number of arthropod pests Australia requires only a phytosanitary inspection of hosts such as stone fruit and kiwifruit, but is proposing more rigorous inspection or orchard survey for the same pests when they occur on apple). In New Zealand's view, this would be an unjustified and arbitrary distinction in Australia's ALOP, which would result in discrimination against New Zealand apple imports and which would constitute a disguised restriction on international trade.
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