14 October 2015
Purpose
To advise industry of acceptable fumigation practices and responsibilities in ensuring requirements set by importing country authorities are met prior to export.
Background
The Department of Agriculture and Water Resources (department) maintains a nil tolerance for live insects in exports of prescribed goods. Authorised Officers inspect goods to ensure they do not contain live insects prior to export. Regardless of whether prescribed goods have been approved as free from insects, some countries require compulsory fumigation. Fumigation must meet importing country requirements and must be conducted by licensed fumigators. Where an importing country does not specify the name and dosage of the fumigant they must be applied according to label requirements. Where an importing country requires the goods to be fumigated contrary to label requirements, the fumigator must obtain an off-label permit prior to fumigation.
Summary of changes and key points
There are no changes to fumigation requirements, but the department has recently received a number of notices of non-compliance due to incorrect or inaccurately recorded fumigations. The requirements detailed in this Industry Advice Notice only apply to fumigations specified by importing country authorities. The department notes that to satisfy importing country requirements exports must meet the following conditions:
- Fumigation occurs within the timeframe set by the importing country; or if the importing country authority has not specified a timeframe, fumigation occurs within 120 days of the issuance of phytosanitary certification for the consignment.
- Traceability of each parcel of goods making up the consignment is maintained and evidence attesting to the fumigation is provided in the form of a treatment certificate. The treatment certificate must include details of the treatment location, fumigator name and contact details, fumigant, concentration, exposure, dates, product temperature, destination, vessel and other information as required by the importing country.
- Fumigators must hold a fumigation license issued by the relevant State or territory authority.
- Fumigators must use the fumigants and dosages specified by the importing country authority. When the fumigants and/or dosages specified by the importing country are not registered by the Australian Pesticides and Veterinary Medicines Authority (APVMA) for that product, the fumigator must seek an off-label permit from the APVMA before conducting the fumigation.
- When importing country authorities require fumigation to be conducted after inspection but prior to export, a post-fumigation inspection is not required if:
- The full details of the fumigator and proposed dates of treatment are provided to the Department of Agriculture and Water Resources at the time of booking the inspection.
- There is no reason for the authorised officer to reject the consignment during the inspection prior to fumigation
- Treatment certificate is presented prior to export.
- Fumigation must not be conducted when product temperature falls below 10˚C.
- India has been accepting dosage compensation for temperature below 21˚C. For each 5°C (or part of 5°C) the temperature is expected to fall below 21 °C, 8g/m³ must be added to the dosage, unless otherwise specified by the department. For example, using the standard dosage of 48g/m³ for a 24 hour exposure period, the dosage at:
- 21 °C and above is 32 g/m3
- 16 – 20 °C is 40 g/m3
- 11 – 15 °C is 48 g/m3
- 10 °C is 56 g/m3
- A shortened exposure period cannot be compensated for by increased dosage or vice versa.
- Overdosing (the application of fumigant at rates above those specified) to compensate for poor fumigation practice or inadequate equipment or sheeting should not be undertaken. Similarly, topping-up is not an acceptable action solely to compensate for inadequate operational practices.
Fumigators responsibilities
- To obtain a special use permit from the APVMA when seeking to fumigate under conditions not covered by registered fumigant label requirements.
- To assess and issue appropriate gas free certificate if the phytosanitary inspection is to take place after fumigation.
- The fumigation certificate must contain all the required information on the fumigation certificate to determine the efficacy of the treatment and assuring that it fully meets importing country’s quarantine treatment requirements.
Exporter responsibilities:
- Exporters must ensure prescribed goods requiring fumigation by the importing country authority are fumigated within the specified timeframe set by the importing country. If the importing country authority has not specified a timeframe, fumigation occurs within 120 days of the issuance of phytosanitary certification.
- Exporters must maintain traceability of goods to the treatment site and relevant dates, and provide evidence of traceability to authorised officers on request.
- For fumigations required by importing country authorities conducted after inspection, exporters must ensure required fumigation details are provided to enable the department to issue a phytosanitary certificate.
Authorised Officers responsibilities
- Must ensure that the fumigation treatment applied meets the importing country’s requirements if presented at the time of inspection.
Documentation Hub Officers responsibilities
- When fumigation is conducted after phytosanitary inspection or fumigation certificate is presented to the documentation hub for authorisation, the officer must ensure that the fumigation treatment applied meets the importing country’s quarantine requirements prior endorsing the details of the treatment on a phytosanitary certificate.
Contact Information
If you have any questions regarding this IAN please email: Grain Export or phone 02 6272 3229.
Dr Chris Parker
Assistant Secretary
Plant Export Operations Branch