Australian Access Action Group (AAAG) Submission
03 July 2011
Office of the Chief Executive
Biosecurity Australia
GPO Box 858
CANBERRA ACT 2601
SUBMISSION
This submission is on behalf of the Australia Access Action Group (AAAG) and has been prepared in response to the Biosecurity Australia (2011) Draft report for the non-regulated analysis of existing policy for apples from New Zealand.
The Australian Access Action Group (AAAG) is an industry body established as a stand-alone organization with the sole objective of bringing a rational end to the Australian ban on NZ apples and pears. AAAG has been committed to this process for a considerable period of time, and activities have included negotiation with senior NZ government officials and meetings with staff from the Australian High Commission. AAAG has hosted visits from officials, including managing numerous events culminating in an industry day in Wellington. These activities were unprecedented in NZ.
The AAAG wish to provide comment against the following two key points with respect to
discussions relating to the above draft report:
- An Audited IFP System Does Not Improve Phytosanitary Outcomes
- Process Versus Outcome Based Protocols
Background - What Did the IRA Data Represent?
The protocol under discussion is based on the Australian Import Risk Assessment (IRA). It is our understanding that the pest data provided represented the outcomes of the NZ industry’s integrated fruit production (IFP) system that was taken from sources including:
- Globalgap certified growers
- Those certified by retail systems (e.g. Tesco’s Natures Choice)
- The Vegfed Approved Suppliers system, in the process of alignment with Eurepgap
- PipfruitNZ’s non-audited IFP system
The IRA pest data therefore came from a wide range of growers with a wide range of
management practices, audited and non-audited, exporting to a range of different markets. Approximately 97% of the NZ growers fall under the broad IFP categorization.
We therefore find endorsing any subset of growers under any system, e.g. Globalgap will undermine the IRA data as it was not based purely on growers audited via this system. This data verifies that New Zealand growers, despite using different systems are currently managing an IFP system very well, and are doing so within the standard required by the IRA.
1. Audited IFP System Does Not Improve Phytosanitary Outcomes
We understand the position of the UN FAO in that Good Agricultural Practice, including IFP “may help reduce the risk of non-compliance” with a range of international standards. Critical to this quote is the word ‘may’ with which is in no way provides any certainty.
There has been discussion about using an audited IFP system, e.g. Globalgap that has an auditable measure for ensuring phytosanitary compliance. AAAG does not believe this to an appropriate measure
The Globalgap system has no requirement to meet the International Plant Protection Convention (IPPC) objectives or to achieve any phytosanitary outcomes. Globalgap is an example of a privately owned system based on food safety considerations and pesticide minimisation and under the control of retail supermarkets. These companies have no expertise or responsibility for border security, where the main driver is to alleviate their customer’s pesticide concerns.
Globalgap requires growers to justify chemical intervention and so could be seen to stand in opposition to chemical interventions by encouraging growers to ask “is this really necessary?” Globalgap may therefore not provide confidence that pests in export fruit are well managed – as indeed, if you make no chemical interventions, you will pass Globalgap with less effort. The system appears to be indifferent to phytosanitary outcomes.
We are in agreement that the introduction of IFP should give confidence that pests in export fruit are well managed. We have this confidence as the implementation of an IFP in New Zealand has made growers more aware of pest and disease monitoring, allowing better decisions as an orchard level, resulting in better pest outcomes. This is undermined when any audited system is imposed, which has conflicting objectives.
The opportunity exists for growers to use a practical checklist approach, which may include a statutory declaration by individual growers, with signed declaration by a spray company representative as confirmation that IFP principles, including insect and disease monitoring, continue to be followed.
AAAG are not aware of any scientific evidence that supports where an IFP audited system can improve phytosanitary outcomes
In terms of the process:
- IFP provides better quality data with which growers can manage pests
- The drivers for pest intervention are commercial
- Audited IFP systems, e.g. Globalgap seek to provide an opposing force in the interests of food safety and consumer trends (often not based on scientific evidence).
Growers are therefore in the best position to take action and delivery phytosanitary utcomes when points 1 and 2 above are valid. This position is undermined with 3 is aso required.
AAAG believe that because an audited IFP system, e.g. Globalgap puts in place impediments to chemical intervention and that by using it as an auditable measure is likely to deliver pest outcomes that are inferior to those presented in the IRA risk data.
2. Process Versus Outcome Based Protocols
We are writing this submission to ensure that a grower perspective is provided in relation to the protocols that are in place, or those being mooted. There is a disturbing trend toward accepting process based measures as a requirement for access to various markets.
One example is the Taiwan protocol, where these processes may be of benefit in reducing the likelihood of pest problems, but should never be more than ‘best practice’ measures. There are many risk factors that are not considered such as tree age and proximity to pest host plants. There are many orchard blocks where no Taiwan measures are in place, but where the fruit is entirely suitable for that market. There are also many Taiwan blocks where no amount of careful management can hope to consistently avoid pest problems.
On average process protocols help, but when it comes to phytosanitary status, we should not concern ourselves with averages.
AAAG endorse that the principles of HACCP are much more robust than process based protocols.
The establishment of a Critical Control Point (CCP) is the only basis on which a sensible accept/reject decision should be made. The US protocol is an excellent system in that it is based on these principles. The individual orchard block risk only serves to modify the sampling levels. This is as it should be for all markets.
A practical application could be that if process based requirements have not been met, then all that should be required is that fruit be sampled at a higher rate, in order to achieve the appropriate statistical confidence levels. If this requires an increase from the standard 600 fruit sample, to say 2000 fruit sample, then growers would have to comply.
The point of phytosanitary inspection is so that outcomes can be independently determined to a defined degree of confidence. If sufficient confidence can be gained that a lot meets the market requirements, it should be certified as acceptable for that market.
Process based systems fail to adequately consider individual production blocks and instead focus on the collective. That is, process based systems fail blocks based on the premise that ‘on average’ they present too higher risk to export to a given market – not the actual.
AAAG highlights that process based protocols add significant cost, additional trade barriers and complexity to access protocols
Ultimately the suitability for export must be based on the outcome, or an assessment of the individual lot of fruit presented for export. Too often regulators accept that a range of process based requirements are essential for market acceptability.
This suitability for export via end point inspection should also extend to providing samples of new apple varieties. NZ and Australia are partners in Prevar Limited, an organization responsible for commercialising the ouputs from NZ’s Plant & Food breeding programme.
Typically research outcomes are assessed in NZ prior to being taken to Australia. Allowing access to sample lots (end point inspected) would assist the Australian industry to become more engaged in this process, to examine and consider new apple varieties in their early stages of development. Ready access for new variety samples to Australia would be mutually beneficial to both research communities.
AAAG requests that suitability for export via an end point inspection should be considered for sample lots of new apple varieties to provide benefit to the Australasian research communities.
In summary AAAG would suggest that a set of complex protocols around process rather than outcomes impart additional trade barriers, whilst adding no additional assurances or phytosanitary outcomes.
Any comments, queries or communications regarding this submission are to be referred to Paul Paynter of the Australian Access Action Group.
The contact details are:
Paul Paynter
548 St Georges Rd South, Havelock North
Email: paul@yummyfruit.co.nz
Phone: +64 6 8778127
Mobile: +64 21 2428264
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