Queensland Government submission

Quensland Government, Department of Agriculture, Fisheries and Forestry
Floor 8
Primary Industries Building
80 Ann Street Brisbane
GPO Box 46 Brisbane
Queensland 4001 Australia

Business Centre 13 25 23
Website www.daf.qld.gov.au
ABN 24 830 236 406

Reference: 02740/12

14 MAY 2012
Dr Colin Grant
Chief Executive
Biosecurity Australia
GPO Box 858
Canberra Act 2601

Dear Dr Grant

I refer to the 'Draft report for the non-regulated analysis of existing policy for fresh mangosteen fruit from Indonesia ' and your request for comments.

This draft import risk analysis (IRA) report proposes that the importation of fresh mangosteen fruit from Indonesia be permitted, subject to specific quarantine measures.
The Department of Agriculture Fisheries and Forestry, Queensland (DAFF Queensland) notes that Biosecurity Australia (BA) has identified different species of spider mites, mealybugs and ants as quarantine pests associated with the proposed importation which require risk mitigation measures to reduce the risks to an acceptable level. However, BA discounted the risk of fruit flies by considering mangosteen as a non-host and reducing the risk by importing only undamaged mature fruit.

The draft report proposes a number of biosecurity measures involving a combination of risk management and operational practice to reduce the risk associated with the importation of fresh fruit. The measures include systems approach (cleaning, fumigation , visual inspection etc), packing undamaged fruit of selected grade, pre-export or on-arrival inspections, verifying quarantine status of consignment, registration of export plantations, packing houses and auditing of procedures.
DAFF Queensland has reviewed the draft IRA report and does not agree with BA's 'Very Low' unrestricted risk assessment for important fruit flies and that no specific biosecurity measures are required for this pest during the importation. Biosecurity Queensland assessed these as a 'Low' unrestricted risk and therefore, specific biosecurity measures are required for this pest during the importation. Comprehensive comments on this issue and others are attached along with a number of recommendations.

Thank you for the opportunity to comment on the draft IRA report. DAFF Queensland will appreciate receiving a response on how the issues raised are to be addressed in any further review leading to the finalisation of this IRA.

Yours sincerely

Jack Noye

Director-General
Department of Agriculture, Fisheries and Forestry

Department of Agriculture Fisheries and Forestry, Queensland's response to the Draft report for the non-regulated analysis of existing policy for fresh mangosteen fruit from Indonesia

Biosecurity Advice 2012/05

March 2012

The Department of Agriculture Fisheries and Forestry, Queensland (DAFF Queensland) reviewed the mangosteen Import Risk Analysis (IRA) document and agrees with the pest list considered for phytosanitary measures. DAFF Queensland notes that the pests with more than one species (fruit flies and mealybugs) have a very wide host range and have the potential if established in Queensland to impact domestically on local agriculture and the environment. Therefore, DAFF Queensland has concerns and it differs with DAFF Australia on a number of issues raised in the proposed IRA. The specific comments on those issues are as follows.

4.3.1 Overall probability of entry - page 44

The likelihood that Bactrocera papayae and Bactrocera carambolae will enter Australia as a result of trade in mangosteen fruit from Indonesia has been graded as Extremely Low based on a number of factors associated with the pathway, pest biology, fruit processing, transportation and storage. DAFF Queensland strongly disagrees with this assessment for the following reasons:

The document states in several places that mangosteen is a non-host or conditional non-host for all fruit flies including B. papayae and B. carambolae. This assumption is made despite published evidence to the contrary (Allwood et al. 1999 for B. papayae and B. carambolae; Hancock et al. 2000 and Leblanc 2004 for other less virulent fruit fly species B. jarvisi, B. frauenfeldi, B. neohumeralis, B. expandens). Additionally there is supporting comment from Professor Dick Drew (20 1 0) that was provided to BA indicating that in southeast Asia intact mangosteen is a host for B. papayae (Professor Drew comments in page 3) *. Professor Drew is the leading world expert on tropical fruit flies with 40 years of research on fruit fly hosts, ecology, taxonomy, and pest management.
Page 41, para 7.The extensive research on the host status of mangosteen for fruit flies consists of two unpublished reports that have not been peer reviewed and are not generally available for stakeholder assessment (Leach 1997; Iswari et al. 2011); and published work that was conducted on another species, Bactrocera dorsalis (Unahawutti and Oonthonglang 2002). Different species of fruit flies have very different host ranges (Allwood et al. 1999, Hancock et al. 2000) and consequently research on non-host status for one species cannot be used to make assumptions about another. Further in the report page 42 it states "Bactrocera carambolae and B. papayae have been shown to be unable to infest sound mangosteen fruit (Leach 1997; Iswari et al. 2011)", again the evidence is two unpublished reports with the published report ignored (Allwood et al. 1999). Additionally Leach's trial ( 1997) used small insect and fruit sample sizes that provided statistically very low confidence levels (<10%).
Page 42, dot point 5. The published report of mangosteen as a host for B. papayae and B. carambolae (Allwood et al. 1999) is disregarded by conjecturing that it's possible that the fruit may have been damaged. Professor Drew also remarked (2004, 2010- previously provided to BA) that the fruit was not damaged when collected.*
Page 43, dot point 2. "The secretion of the yellow latex seals off any damage to the mangosteen skin such as oviposition entry wounds". This indicates that the DAFF Australia believes that intact mangosteen can be oviposited into, which is contrary to the conditional non-host claim made repeatedly in the document.
4.3.1, dot point 11. "The secretion of the yellow latex seals off any damage to the mangosteen skin such as oviposition entry wounds, feeding punctures physical cracks or mechanical injuries. The sealing of the mangosteen skin prevents larvae from emerging from the fruit to complete their life cycle". No evidence is provided to support this assumption. The references provided (Unahawutti and Oonthonglang 2002; Dorly et al. 2009) refer to the fact that mangosteen fruit produces latex and do not support the assumption that latex-sealed wounds would impenetrable by fruit fly larvae. Even if it were the case that fruit flies can't emerge from mangosteen fruit, larvae in fruit would still be able to complete their lifecycle. As fruit is being air freighted it would be on the supermarket shelf within 7-14 days of export, sufficient time for larvae to survive in the fruit without needing to pupate, be purchased, broken open and if infested then discarded (this is acknowledged under Reassessment of Probability of Distribution), and continue to pupation and adult stage.
Page 43, dot point 3. "Fruit flies have not been intercepted in Australia on mangosteen fruit imported from Thailand since trade commenced in 2004". This cannot be categorically stated. Dipteran larvae were intercepted by AQIS on commercial Thai mangosteens in Perth in 2006. These were either fruit fly larvae or other Diptera. Regardless of if they were other Diptera, it indicates that a pathway is present, as imported fruit would have to be arriving damaged or very unclean (in which case fruit fly damage would not be visible) to have a substrate for larval survival. Larvae would have to be feeding on something associated with the mangosteens, either fruit or rotting material indicating that imported fruit is not meeting entry conditions. As Thailand has more developed biosecurity systems than Indonesia it is reasonable to expect a similar occurrence with Indonesia.
Page 43, para 5 ' .... damaged (and mature) fruit which are susceptible to fruit flies are easily detected' (in summary justifying likelihood estimate for importation). This is an unsupported assumption. Mangosteen fruit that appear intact and undamaged have been purchased from Cairns' farmers markets and on several occasions found to contain fruit fly larvae. The IRA states that Indonesian fruit showing 30 percent scratch damage (Super II) (page 25 dot point 4) would be exported to Australia making it more unlikely that small fruit fly oviposition holes would be detected.
Page 1, 22 & 43. The assumption that stage 2-3 maturity mangosteen is a conditional non-host is not supported at all by any scientific evidence in the report. Communications from Prof. Drew (2010) and Dr Vijay Shanmugam (2009) previously provided to BA have stated that no research has been conducted on fruit flies' ability to infest mangosteen at different maturity levels, and that research into this is needed. Several species of fruit fly (including B. papayae) oviposit in hard green fruit (Leblanc et al. 2001, Sati 2003) including fruits with a thick pericarp comparable to mangosteen (jackfruit, Sati 2003). This indicates that it is physically feasible for fruit flies to oviposit in fruit such as semi-ripe mangosteen.
Page 43, dot point 1. 'Exporting undamaged fruit at maturity levels that cannot be infested by fruit flies' is considered an insufficient risk mitigation measure given that no evidence has been provided to demonstrate that the proposed maturity levels are resistant to fruit fly infestation.
Page 45, Unrestricted risk estimates. Based on the change in 4.3.1 page 44 'Extremely Low' should be changed to 'Low', placing the unrestricted risk estimate is above Australia's appropriate level of protection. Therefore, specific management measures are required for fruit flies (B. papayae and B. carambolae).

* Professor Drew comment (previously provided to BA)

In a fruit fly host study in South-East Asia, B. papayae was reared from three mangosteen samples (Allwood et al. 1999) of undamaged fruit (Drew 2010 pers. comm.).
Drew (pers. comm. in AQIS 2004) stated that results of his recent field trials in South-East Asia, particularly Malaysia, were contrary to that of Leach's ( 1997) unpublished laboratory observations which indicated that undamaged mangosteen is not a host for B. papayae. According to Drew, B. papayae were regularly collected from the field and reared from mature, unblemished (skin unbroken) mangosteens (Drew pers. comm. in AQIS 2004).
In relation to B. papayae, Drew (2010, pers. comm.) commented that mangosteen collected in Sabah were intact and had to be cut open with a knife to examine for larvae. They did not appear to have cracks or blemishes to assist flies to oviposit.
During field work in Sabah in 1988, Drew reported dissecting mangosteen fruit in the field and seeing fruit fly larvae (Drew pers. comm. in Shanmugam 2009, pers. comm.).

In summary, the two fruit flies (B. papayae and B. carambolae) are by far the most detrimental pests of those assessed in the risk analysis. B. papayae infests well over 200 fruit and vegetables and incursion would have a dire impact on the majority of Australia's horticulture and as such should not be taken lightly. Moreover, other countries (Japan, Korea, USA) importing mangosteens from Indonesia and Thailand require irradiation, vapour heat treatment or freezing of fruit to mitigate the risk of these species of fruit flies (USDA-APHIS 2007, Baker 2008, Wismitanant 2009).

Mealybugs

In the interests of brevity, DAFF Queensland has elected to refer to the entire mealybug species considered in the Draft Report as a group.

4.6.4 Consequences for Mealybug- page 61:

Given the following observations, DAFF Queensland contends that the consequences for the entry establishment and spread of mealybugs to Australia need to change from 'Low' to 'High':

Mealybugs have very wide host range (more than 200 plant species including many native plants in Australia).
There are multiple species of mealybug associated with the proposed imported mangosteen.
Mealybugs are known vectors of many serious plant diseases.
Mealybugs are very difficult to control because of their high reproductive rate, cryptic nature and lack of effective chemical controls.
Eradication would be impossible due to its wide host range.
Both domestic and international trade will be significantly affected due to movement restrictions on a wide range of commodities and nursery stock.
Mealybugs pose significant risks to the environment due to their unknown effects on Australian native plants.

4.6.5 Unrestricted risk estimate for Mealybugs, page 61:

Given the increase of the consequence rating to 'High', the unrestricted risk estimate for mealybugs would also change to 'High' (based on the risk estimation matrix table 2.5 in page 14).

5.1.1 Pest risk management for quarantine pests - page 72:

Unlike other fruits, complex calyx structure of mangosteen fruit provides good hiding place for pests. Considering the trade volume and nature of the fruit calyx it appears implausible for the treatment regime proposed in this section to be effective. The high failure rate for Thai mangosteen imports into Australia (80 percent infested) prior to the introduction of methyl bromide fumigation reveals this fact. Can individual pest inspection and treatment realistically be conducted on substantial volume of imported fruit? For example:

Air Blowing: In terms of time and labour, it appears very impractical to carry this out for such a large volume of trade
Brushing: Reliable and thorough brushing of individual fruit in huge batches appears implausible
Quality Control (maturity index 2-3): similar concerns and
Advanced quality visual inspection: This appears to be an unrealistic expectation
DAFF Queensland is very doubtful that these steps can be carried out as outlined. DAFF Queensland is also concerned about how the success/failure of these measures will be evaluated.

Errors in section 4. 7.1 page 66

Based on the assessments 'High' for both importation and distribution in the document, the overall probability of entry (importation x distribution) should be 'High' not 'Moderate', unless one of the assessments is 'High'. Similarly in second last lines of section 4.7.5 (page 67) it should be 'moderate' not 'low'.

Conclusion

It is the considered opinion of DAFF Queensland scientists that the IRA process for fruit fly has been conducted using unpublished non-peer review reports while ignoring published information and expert comment. If there is a lack of science for pests from the exporting countries then careful consideration needs to be given to them, particularly if they have the potential to have a very high impact on Australian horticulture. Most decisions from past IRAs are based on a published article of some kind which is a good practice, although problems arise if there are gaps in the science or something is "unknown" and therefore not published. In the past a lack of research has been overlooked as unimportant in the decision making process even if it has the potential to be very important (for example lack of information on the biology and ecology of important pests, detailed insect fauna surveys, economic damage etc).
DAFF Queensland strongly encourages Biosecurity Australia to consider published reports and expert comments and incorporate their data, experiences and suggestions into the IRA.
DAFF Queensland strongly recommends the re-examination of the risk assessment for fruit flies and mealybugs to identify the appropriate level of protection before importing fresh mangosteen fruit from Indonesia.

References

(See attached document for complete list of references)