Selection criteria for sea container hygiene system third party service providers

[expand all]

Context

The Sea Container Hygiene System (SCHS) is a long-term strategy by industry in collaboration with the Australian Department of Agriculture and Water Resources (the department) and the New Zealand Ministry for Primary Industries (MPI) to manage biosecurity risks associated with sea containers at the port of loading.

The system provides a high level of confidence that container processing at the port of loading will result in only clean containers being shipped to Australia and New Zealand reducing the requirement of additional cleaning or fumigation on arrival.

The development of a SCHS is authorised through a contract between the department , MPI and a Shipping Line or service provider. The practical operation of the system is run and overseen by third p arty s ervice p roviders (or ‘Consultant’), that are e xperienced in setting up complex processes in remote locations using local staff.

The following attributes should be considered when engaging a third party service provider;

  • Nationally recognised and approved qualifications in biosecurity risk and pest management
  • Auditing and WH&S
Knowledge of the relevant International Standards for Phytosanitary Measures (ISPM).

Roles and responsibilities

  • Understand the particular framework in which the SCHS is being implemented by:
    • Scoping the port and analysing the biosecurity risk in the logistics chain,
    • Scoping the capability of port and port staff, and
    • Identifying particular risks associated with the logistics chain.
    • Developing, implementing and maintaining quality management systems including detailing operational requirements in a Code of Practice (COP) and Quality Manual (QM).
  • Implement the SCHS by:
    • Treating critical biosecurity risk areas,
    • Establishing a pest free storage area and supply necessary pest control equipment and chemicals,
    • Implementation of effective container cleaning methods,
    • Providing biosecurity awareness and logistical training, process procedures with regards to sea container movements and requirements, treatment schedules and associated maps, and
    • Providing ongoing technical support to operations of the SCHS (offshore stakeholder engagement).
  • Provide assurance to MPI/the Department of Agriculture and Water Resources that system requirements and compliance levels, are being met by:
    • Conducting internal audits (on a regular and timely basis),
    • Enforcing the agreed schedule of inspections and policy requirements,
    • Promptly recommending appropriate corrective action for non-compliant containers/consignments, and
    • Follow up of audit reports non compliances and recommendations.
  • Work collaboratively with the Department of Agriculture and Water Resources and MPI, shippers, ports and port services to establish and operate the SCHS.

Code of practice (COP) and Quality Manual (QM)

    The third party service provider is required to develop both a COP and QM for consideration by the department, providing system assurance. The COP and QM should be comprised of or consider the following;

COP: Demonstrate all operational and WH&S procedures required by staff to effectively complete the required SCHS cleaning and treatment processes. Including a detailed site map of proposed treatment and storage areas.

QM: Demonstrate quality management system operational functions and processes including overall business objectives and include contingencies, assurance and sustainability plans.

Example QM document structure and content (below):

  • Purpose/Scope
    • Outlines relevant operations/procedures and identifies those outside of the system scope.
    • Summarises the objective of SCHS. i.e. Effective management of biosecurity risks associated with imported sea containers through implementation of off shore sea container hygiene systems.
  • Roles and Responsibilities
    • Detailed duties of all parties i.e. Management, training, implementation, auditing.
  • Documentation and Record keeping
    • Procedures for sufficient document maintenance, approval, filing, revision of crucial documents
    • Adequate records of all relevant qualifications/approvals/updates i.e. staff training certification, WH&S approvals etc
  • Training and Assessment
    • Detail of processes implemented to maintain training records, up to date WH&S of operational processes, auditing schedules (Internal and External).
  • Quality Improvement/Control Systems
    • Ability to continually improve on policy and operations as a result of on-going audit findings
  • Description of Proposed System
    • To increase management of biosecurity risks associated with sea containers through implementation of port hygiene SCHS measures.
    • This will detail all operational steps required to meet SCHS requirements.
  • Contingency Plan
    • Detailed description of how non- compliances will be managed and resolved.
  • Data Requirements
    • Documented data such as SCHS reports that will be required for the purpose of analysis and assurance of system compliance.

The Roles and Responsibilities of a 3rd Party Service Provider

A Service Provider will:

  • Understand the particular framework in which the SCHS is being implemented by:
    • Scoping the port and analysing the biosecurity risk in the logistics chain,
    • Scoping the capability of port and port staff, and
    • Identifying particular risks associated with the logistics chain.
  • Implement the SCHS including:
    • Treating critical biosecurity risk areas,
    • Establishing a pest free storage area and supply necessary pest control equipment and chemicals,
    • Providing biosecurity awareness and logistical training, process procedures with regards to sea container movements and requirements, treatment schedules and associated maps, and
    • Providing ongoing technical support to operation of the SCHS.
  • Provide assurance to MPI/the Department of Agriculture that system requirements and compliance levels, are being met by:
    • Conducting internal audits (on a regular and timely basis),
    • Enforcing the agreed schedule of inspections and policy requirements,
    • Promptly recommending appropriate corrective action for non compliant containers/consignments, and
    • Follow up of audit reports non compliances and recommendations.
  • Work collaboratively with the Department of Agriculture and MPI, shippers, ports and port services to establish and operate the SCHS.

Quality Manual (QM)

A QM is the document detailing all quality management system operational functions and processes. The QM outlines the overall business objectives and includes contingencies, assurance and sustainability plans. The QM should detail all key stakeholders involved and their roles and responsibilities (including reporting).

Key components of a QM are list below:

  • Purpose/Scope
    • Outlines relevant operations/procedures and identifies those outside of the system scope.
    • Summarises the objective of SCHS. i.e. Effective management of biosecurity risks associated with imported sea containers through implementation of off shore sea container hygiene systems.
  • Roles and Responsibilities
    • Detailed duties of all parties i.e. Management, training, implementation, auditing.
  • Documentation and Record keeping
    • Procedures for sufficient document maintenance, approval, filing, revision of crucial documents
    • Adequate records of all relevant qualifications/approvals/updates i.e. staff training certification, WH&S approvals etc
  • Training and Assessment
    • Detail of processes implemented to maintain training records, up to date WH&S of operational processes, auditing schedules (Internal and External).
  • Quality Improvement/Control Systems
    • Ability to continually improve on policy and operations as a result of on-going audit findings
  • Description of Proposed System
    • To increase management of biosecurity risks associated with sea containers through implementation of port hygiene SCHS measures.
    • This will detail all operational steps required to meet SCHS requirements.
  • Contingency Plan
    • Detailed description of how non- compliances will be managed and resolved.
  • Data Requirements
    • Documented data such as SCHS reports that will be required for the purpose of analysis and assurance of system compliance.

Third party service provider check list

Step

Description

Check List

1. Contact Department of Agriculture and Water Resources/MPI

Initial expression of interest to provide third party service provider functions on behalf of a port or shipping line in the department’s and MPI SCHS

2. Provide Proof of Qualification or Relevant Experience

Third party service provider documentation proving qualifications (or relevant experience) in areas such as, but not limited to the following;

  • Nationally recognised qualifications relevant to auditing, pest and biosecurity risk management and government regulators.
  • Fumigation, chemical application, WH&S

3. Initial Internal Site Inspection

Third party service provider to conduct Initial scoping visit of proposed SCHS port to determine viability.

4. Department of Agriculture and Water Resources/MPI scoping visit

Inform the Department of Agriculture and Water Resources/MPI of the proposed SCHS port. The department/MPI to conduct initial scoping visit of port to identify system viability

5. Develop Codes of Practice (COP)

Third party service provider will develop (in conjunction with shipping line) detailed COP’s to be used to ensure system safety and success. COP will detail correct use of personal protective equipment (PPE), application and storage of chemicals etc. COP will remain a working document with governing bodies auditing against document to inform level of SCHS compliance.

6. Develop Quality Manual (QM)

A QM is a working document which details operational procedures in place to ensure compliance and success of SCHS. The document includes details of record keeping, roles and responsibilities, operational requirements, quality control systems. The QM will be used during audits by regulatory authorities to inform level of SCHS compliance.

7. Provide Staff Training

Inform and outline procedures required by staff to undertake successfully (and safely) clean containers to SCHS standards. Staff will be required to know all processes for areas such as chemical application, cleaning, sticker system etc and location of all COP and.

8. Department of Agriculture and Water Resources/MPI Port Approval Audit

Inform the Department of Agriculture and Water Resources/MPI of complete system set up. The Department of Agriculture and Water Resources/MPI will inspect final port set up and approve the set up. Note: Dependant on port set up stage at the Department of Agriculture and Water Resources/MPI scoping visit, approval may be granted without a second inspection.

9. Business Rules

Document agreed to by both industry and regulatory authorities (the Department of Agriculture and Water Resources/MPI) detailing the following;

  • Reporting guidelines
  • Inspection rates
  • Contamination thresholds
  • Biosecurity risk matrix
  • Biosecurity definitions
  • Stakeholder roles and responsibilities.

10. Documentation

  1. signing Information Pack
  2. Operating Agreement
  3. Business Rules

Formalisation of all documents and agreed terms of business between Industry and the Department of Agriculture and Water Resources/MPI allowing for implementation of the SCHS.

11. Implementation of SCHS

Commencement of SCHS at port of loading, ensuring all container cleaning and treatment requirements as outlined in approved QM are implemented.

12. Internal audit

  1. Provide confirmation of resolutions to any non-compliances

Upon implementation of the SCHS an internal audit will be conducted as appropriate based on level of compliance to ensure correct procedures are followed and container cleanliness compliance is met. This will be done independently by the third party service provide to inform shipping line of compliance issues.

13. Department of Agriculture and Water Resources/MPI audit

  1. Provide confirmation of resolutions to any non-compliances

Upon implementation of the SCHS an external audit will be conducted at the 6 month mark by the Department of Agriculture and Water Resources and NZ MPI to ensure correct procedures and container cleanliness compliance is met. This will be done independently to the third party service provider. The audit will inform future intervention rates.