Dr John C Radcliffe AM
Emeritus Professor Malcolm Nairn AM
Dr Mark Lonsdale
Dr TJ Higgins
Dr Mark Crane
APRIL 2009
Introduction
In 2004 the Eminent Scientists Group (ESG) was established to increase confidence in the administration of the import risk analysis (IRA) process conducted by Biosecurity Australia.
This report by the ESG is made in accordance with its original terms of reference, which are to:
- review the draft final IRA report prepared by the IRA team to ensure that the IRA team has properly considered all technical submissions received from stakeholders during the formal consultation period on the draft IRA, and
- within 60 days of being presented with the draft final IRA report, prepare a report to the Director of Animal and Plant Quarantine on their findings and recommend any action considered necessary to overcome any identified deficiencies. The ESG will provide a copy of the report to the Chief Executive of Biosecurity Australia.
The Secretary of the Department of Agriculture, Fisheries and Forestry has additionally sought any advice the ESG considers may be of assistance beyond these formal terms of reference on matters relating to the science within this IRA.
On 22 April 2009, Biosecurity Australia formally referred the draft final Import Risk Analysis (IRA) Report for Prawn and Prawn Products (draft final Prawn IRA Report) to the ESG.
To facilitate deliberations, the ESG was provided with:
- the draft final IRA Report for Prawn and Prawn Products;
- the 2006 revised draft generic IRA Report for Prawns and Prawn Products (Part A and B);
- 51 submissions from stakeholders received during the formal period of consultation on the draft generic IRA report; and
- a summary table setting out stakeholder comments and BA’s responses to those comments.
Following out of session consideration of these documents, the ESG met in Canberra on 28-29 April 2009 to prepare its findings. Throughout the course of these proceedings, the ESG met with members of the prawn IRA team on a number of occasions to obtain answers to questions relating to the Prawn IRA process.
This assessment report by the ESG provides observations on BA’s treatment of stakeholder comments in the development of the draft final Prawn IRA Report. ESG members agreed to the report out of session.
Assessment
The ESG notes that there were 51 submissions made by stakeholders, and that these encompassed a considerable range of issues. Biosecurity Australia has responded to these issues where appropriate by including additional information in the April 2009 draft final prawn IRA report and by making revisions to the draft text. The ESG considers that the responses made by Biosecurity Australia to the majority of the issues raised comprehensively address the concerns of stakeholders. Other issues raised by stakeholders were considered to be outside the scope of the IRA.
The ESG notes that while crabs and ballast water are outside the scope of the IRA, it deems there would be value in highlighting these as possible vectors that could be further considered in future revisions.
In addition, there would be benefit in the provision of additional information in the appendix, further elaborating on both the Darwin White Spot Syndrome Virus incident and the abalone incident in southern Australia (Victoria/Tasmania) relating to Abalone Viral Ganglioneuritis.
It is suggested that a table “Graphical representation of prawn imports based on preparation category (raw vs. processed) 2001-2005” be included to better demonstrate the ratio of cooked to uncooked prawns being imported into Australia. This table was provided to the ESG in response to questions raised.
The ESG also recommends that Biosecurity Australia incorporate some minor amendments to the Prawn IRA Report such as ensuring references used are correct and up-to-date and the correction of typographical errors.
Conclusion
Beyond these matters, the ESG concludes unanimously that Biosecurity Australia has properly considered the 51 submissions received from stakeholders on the draft final generic Import Risk Analysis Report for Prawns and Prawn Products.