Dr John C Radcliffe AM
Emeritus Professor Malcolm Nairn AM
Dr Mark Lonsdale
Dr TJ Higgins
August 2008
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 (BA).
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 adequately 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 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 BA.
On 14 August 2008, BA formally referred the draft final Import Risk Analysis (IRA) Report for the Importation of Cavendish Bananas from the Philippines (draft final banana IRA report) to the ESG.
To facilitate deliberations, the ESG was provided with:
- the draft final IRA Report for the Importation of Cavendish Bananas from the Philippines;
- the 2007 revised draft IRA Report for the Importation of Cavendish Bananas from the Philippines;
- 21 submissions from stakeholders received during the formal, extended period of consultation on the draft 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 19-20 August 2008 to prepare its findings. During the meeting, BA presented to the ESG an overview of the bananas IRA process, including BA’s progression of the matter from the original request for market access from the Philippines in May 2000 to the third draft report released in 2007. In addition, BA outlined the risk assessment model used for the evaluation, further expanding on the risk management options put forward in the IRA.
This assessment by the ESG provides observations on BA’s treatment of stakeholder comments in the development of the draft final IRA report. ESG members agreed to the report out of session.
Assessment
The ESG notes that there were 21 submissions made by stakeholders on the draft final IRA Report for the Importation of Cavendish Bananas from the Philippines (February 2007). These comments encompassed a range of issues relating to methodology, pathogens, arthropods and risk management. BA has responded to these issues where appropriate by including additional information in the August 2008 draft final banana IRA report and by making revisions to the draft text.
The ESG considers that the responses made by BA to the issues raised, especially in relation to Moko disease, are of a high quality and carefully address the concerns of stakeholders. The ESG considers, however, that the technical responses regarding potential impacts on the environment, while sufficient, could have been more comprehensive. While we understand that there have been discussions between BA and the Department of the Environment, Water, Heritage and the Arts (DEWHA), the ESG believes that there is still scope for DEWHA to have greater technical input to the IRA process.
The ESG noted that initially, a member of the IRA team had a differing view in relation to the risk management measures proposed for Moko disease. This difference in opinion has since been resolved and the minority report has been withdrawn in the latest draft of the IRA report. While there was some initial discussion of the minority report in the summary of the latest draft (Part A), no reference was made in the detailed report (Part B). Accordingly, further clarification as to how the matter was addressed should be included.
The necessity of effective auditing and monitoring to ensure compliance with the standards set by the IRA was raised in a significant number of submissions. Specifically, the ESG advises that BA should consider providing greater detail in how it would anticipate the protocols being developed for the implementation of the IRA recommendations in response to stakeholder comments concerned with the issue of confidence in the process to be used by AQIS to ensure compliance by the Philippine Government and their banana growers with import requirements.
Conclusion
Beyond these matters, the ESG concludes unanimously that the Banana IRA team has properly considered the 21 submissions received from stakeholders on the draft final IRA Report for the Importation of Cavendish Bananas from the Philippines (February 2007).