Part 3: Summary and Recommendations

Ministry of Agriculture and Forestry: Management of Biosecurity Risks.


New Zealand’s biosecurity arrangements are among the best in the world.

Experts here and in other countries consistently expressed to us the view that New Zealand’s biosecurity arrangements are among the best in the world. Overseas organisations, even those disadvantaged by some of our officials’ decisions, commented on:

  • the professionalism;
  • the more than satisfactory working relationships; and
  • the fairness, consistency and transparency of New Zealand’s approach.

We too were impressed with the arrangements. For example, the traceback system to identify the source of pests entering the country with commodities is effective. Other countries are copying measures that were first introduced here – such as comprehensive border inspection arrangements for mail items and passengers’ baggage.

The sea containers pathway – 410,000 sea containers arrived at ports in 2001-02 – is the most difficult to manage and the least well controlled. A review of the management of this pathway is under way.

We concluded that the large majority of the people running the biosecurity arrangements apply high levels of professionalism, expertise, and commitment in the conduct of their duties. New Zealand has a particularly high level of expertise in some areas of biosecurity risk management – such as pest and disease risk analysis.

A number of this country’s experts also play important roles in a range of influential international organisations and committees. These links are valuable because, to be effective, biosecurity risk management has to span international boundaries. Also (as illustrated by the UK outbreak of foot and mouth disease), some serious incursions are ideally met by responses that involve close international collaboration and sharing of expertise.

Paragraphs 6.14 (page 86), 6.39-6.40 (page 92), and 6.51-6.55 (page 94).
Management of biosecurity risks is a classic example of a highly complex activity that crosses traditional organisational boundaries.

Biosecurity is multifaceted:

  • The risks are wide-ranging – involving threats to the wider economy and personal wealth, to the primary production sector and animal health, to human health and well being, and to New Zealand’s biodiversity.
  • The range of possible preventative measures is extensive – involving pre-border and border security, surveillance, responding to incursions, control and containment of specific pests and diseases, education, enforcement, and research.
Paragraphs 4.22-4.28 (page 53) and paragraphs 4.49-4.50 (page 58).
Managing risks and setting priorities across the various threats and between the different possible responses is a massive challenge that the Government faces in dealing with a range of cross-sectoral issues, not just biosecurity. It requires officials across Government to work closely and effectively together.

Relationships between the three departments that we examined (MAF, MoH and DOC) are generally sound, but the difficulty of their working together effectively across the wide range of complex issues that biosecurity presents cannot be overstated. To have some chance of success there need to be:

  • clear roles and responsibilities;
  • clear accountability for the Biosecurity Programme;
  • agreement on a common outcome; and
  • an agreed, common framework for assessing risks and priorities.
Paragraphs 4.12-4.18 (page 50) and 4.54-4.59 (page 58).
Roles and responsibilities have been unclear, but the departments have been developing a framework to allocate responsibility and improve co-ordination.

For some pests and diseases it is clear to officials which department should have responsibility for managing the threat they pose. For example, foot and mouth disease is primarily a threat to the agricultural sector and is therefore MAF’s responsibility. But for some pests and diseases responsibility for managing the threat can be less clear – the two main pests of table grapes from California are separate concerns of MAF (the glassywinged sharpshooter) and MoH and DOC (the black widow spider). As the department with the most funding for biosecurity, MAF tends to take responsibility, even though the main threat may not be to the sectors of greatest concern to MAF.

Arrangements have been improved through measures such as Memoranda of Understanding between the departments, but the amount of interdepartmental contact is still too low and irregular to support important activities such as strategic planning for biosecurity. Ensuring that the decisions taken and recommendations made at all key meetings are recorded will also improve co-ordination, both between and within the main departments.

Paragraphs 4.54-4.71 (page 58).
There is currently no clear accountability for the Biosecurity Programme as a whole.

The Biosecurity Council’s broad membership and lack of mandate has limited its potential effectiveness. Quite appropriately, it does not have an operational focus, but its role and responsibilities need to be clarified, to highlight its primary role of providing advice to the Minister on biosecurity matters.

Most importantly, the accountability arrangements for the whole Biosecurity Programme need to be clarified and adjusted to more transparently reflect the specific accountabilities of the chief executives of the main departments.

Paragraphs 4.87-4.98 (page 65).
A lack of clear and agreed goals and outcomes for biosecurity activities has contributed to the lack of clear accountability, and has sometimes made it difficult for the departments to find common ground from their different perspectives.

Effective co-ordination requires clarity about goals and outcomes. But there are currently no clear goals or outcomes for biosecurity. Work under way on the Biosecurity Strategy is intended to develop a statement on the appropriate level of protection against biosecurity risks. It is important that the main departments work together to ensure that they can all accept and be committed to this statement, and that they then use it to help make their approaches to biosecurity more transparent and consistent.

Paragraphs 4.72-4.75 (page 63) and 5.18-5.20 (page 78).
There is little systematic analysis of the relative benefits and costs of the different components of the Biosecurity Programme.

Each of the four main departments separately receives funds through Votes Biosecurity, with around 93% going to MAF – which runs most of the core components of the Biosecurity Programme (pre-border and border security, surveillance, etc.). Changes to the core components have been made on an unplanned basis – for example, the increases in border controls that were put in place in response to the risk of foot and mouth disease – without systematic assessment of the costs and benefits of competing priorities in the Programme.

Figure 4 (page 49) and paragraph 4.12 (page 50).
Deciding the allocation of resources to deal with specific threats is highly complex, and there is currently no agreed, common framework for assessment that is well communicated and understood.

Where additional funds are required – such as to fund a response to a pest or disease incursion – timeliness can be critical to mounting an effective response. There is no specific incursion response fund. However, lack of such a fund did not directly compromise any of the incursion responses we examined.

Nevertheless, our review of the response to the southern saltmarsh mosquito incursion illustrated that departments need to undertake a complex process in order to prepare a response recommendation and seek funding. The analysis required is inevitably resource-intensive and time-consuming. And to get the best trade-off between quality and comprehensiveness of information and speed of response, there needs to be close and effective communication between the departments and with others (such as the Treasury).

We consider that the current arrangements require improvement to ensure that they consistently incorporate an agreed, common framework for assessment that is well communicated and understood. The framework should enable:

  • the risks of different biosecurity threats (e.g. to primary production and public health) to be assessed on a consistent basis;
  • decision-makers (Ministers) to be presented with the priority for the assessed threat against all other relevant priorities; and
  • a timely reassessment should any of the key assumptions or risks change after the decision has been taken.
Paragraphs 4.19-4.39 (page 51).
Some progress is being made on, for example, assessment of specific threats and on more complex risk analyses. Further work is required to improve qualitative assessment and to increase consistency and transparency of assessment methods.

Assessment of biosecurity threats is at a different stage of development depending on the sector under threat. In the primary production sector, the costs and benefits of responses are relatively straightforward to identify. For human health it is also possible to undertake some quantitative assessment. In the environmental area, valuing benefits such as protection of native biodiversity is difficult and relatively underdeveloped.

Some progress is being made on more complex risk analyses. For example, in respect of the importation of table grapes, MoH is currently preparing a health impact assessment for black widow spiders, while MAF is working with DOC on the spiders’ risk to biodiversity of native flora and fauna.

Large additional funding pressures come from demands to respond to new incursions – and yet the related funding bids lack a common analytical framework. Such a framework would need to recognise that some areas of analysis are likely to provide more reliable data than others. The framework would bring together the cost-benefit analysis and other qualitative assessment, and provide a means by which decision-makers could take a view on relevant priorities.

Paragraphs 4.19-4.21 (page 51) and 6.11-6.18 (page 86).
We believe that there is a strong case for assessing all biosecurity risks on the same basis, regardless of the sector under threat.

The requirement for a consistent framework was illustrated by the way that obtaining resources for the response to the southern saltmarsh mosquito was handled. In that case, there was uncertainty and some disagreement over whether the response to the incursion should be treated as a biosecurity or health issue. In the event, the bid for funding the response was assessed against traditional health priorities (such as smoking cessation) rather than against other incursion responses, such as the painted apple moth or red imported fire ant.

Assessing all biosecurity risks on the same basis would remove the possibility that the results of different bids will differ, purely because of the different methods of assessment being used. It is an important principle that decisions about relative priorities should be transparent – and to be transparent, the decision-makers (Ministers) need access to full and consistent information and analysis.

Paragraphs 4.22-4.28 (page 53).
Public and industry involvement in biosecurity measures is important – because they play a key part in strengthening the arrangements by securing compliance with quarantine requirements and increasing the chances of identifying early those pests and diseases that do enter the country.

Members of the public initially alerted biosecurity agencies to the presence of the southern saltmarsh mosquito, the painted apple moth, and the red imported fire ant. MAF has a range of programmes and activities to help increase and maintain awareness of biosecurity threats and what can be done to minimise them. It has started to use surveys to evaluate the effectiveness of their awareness measures.

The surveys are also providing useful information on high-risk groups and public attitudes to biosecurity measures such as aerial spraying. MAF’s experience with the response to the painted apple moth incursion illustrated the need for early consultation with communities that are affected by its activities, particularly in relation to incursion responses.

Paragraphs 6.66 (page 97) and 6.128-6.143 (page 110).
While it is not possible for MAF Biosecurity to have total confidence in the work undertaken by overseas agencies, its pre-border and border measures and good international relationships substantially increase the likelihood that its requirements will be met.

MAF Biosecurity6 necessarily relies partly on overseas agencies to ensure that countries exporting goods to New Zealand meet the biosecurity measures set out in its import health standards. Pre-border inspections and audits of these measures are appropriate and provide an effective way of raising the level of understanding with overseas agencies of New Zealand’s unique biosecurity situation, and its approach to managing the risks.

Taken together, the audits and pre-border inspections foster productive relationships between MAF officials and their counterparts in the exporting countries. Good relationships tend to encourage cooperation and compliance with MAF’s requirements.

In 2001-02 MAF X-rayed just over 50 million incoming international mail items, but this screening excluded approximately 22 million bulk and direct entry mail items. Most of these items present a relatively low biosecurity risk and MAF treats them as cargo. In addition, there is a large and growing number of courier packages and mail items that enter New Zealand other than through the New Zealand Post international mail pathway. These items could potentially pose a seriously high biosecurity risk, and require suitable systems to be in place to deal with the risk.

Paragraphs 6.8-6.10 (page 84) and 6.40-6.50 (page 92).
MAF Biosecurity has groups that work relatively independently of one another, and are therefore unlikely to be making the best use of their collective capability.

MAF Biosecurity officials have a high degree of expertise, particularly in relation to the risks posed to the primary production sector.

However, the three main operational groups – animal, plants, and forest – work in a relatively isolated way. And we found inconsistencies in the way that different incursion responses have been managed. The response to the red imported fire ant has been very well managed, but (in contrast) the response to the painted apple moth has been poorly managed.

From those two and the other case studies, we identified a number of important issues that need to be addressed. The most pressing issues relate to the need for:

  • closer and more effective management oversight, so that any problems with incursion responses are picked up early;
  • all Chief Technical Officers to have a high level of both technical and management (including project management and communications) skills; and
  • clear terms of reference for Technical Advisory Groups (which are set up to advise on each response) from the point they are established, and standard operating procedures – including arrangements for clearly documenting the Groups’ decisions.

MAF Biosecurity has accepted and is addressing these issues. It has also made some progress in improving the consistency of methods and practices. But, until the three operational groups are working in a more co-ordinated way, we cannot be certain that high standards are consistently maintained throughout MAF Biosecurity. Further effort is required to make best use of the information, knowledge, expertise and good practice available.

Paragraphs 4.76-4.78 (page 64), 6.14-6.18 (page 86), and 6.88-6.100 (page 103).
We found a number of examples of workload pressures in both MAF Biosecurity and other key agencies that sometimes result in important work being deferred or slowed.

With increasing knowledge, expertise, and a new process that includes more peer review and consultation, the risk analyses to support adoption of new or revised import health standards are required to be more comprehensive. As a consequence, the time needed to complete risk analyses has increased.

MAF Biosecurity has substantial backlogs of pest risk analyses to be undertaken, which have made the prioritisation of import health standards and their related risk analyses a matter of particular concern to the department.

Surveillance to detect pest or disease incursions was considered by many of the people we interviewed (both within the main departments and elsewhere) to be the weakest component of the Biosecurity Programme. We understand that resources applied to surveillance have decreased over recent years. Historically, there has been no clear strategy for levels of and objectives for surveillance, and it is therefore not possible to judge whether surveillance is adequate or likely to lead to cost-effective outcomes.

We also found that the time-scales for planned work and reviews across the Biosecurity Programme are often changed as a result of the need for MAF Biosecurity to reprioritise its workload, particularly in relation to responses to new pest and disease incursions.

Paragraphs 5.13-5.16 (page 78), 6.19-6.32 (page 87), and 6.67-6.75 (page 97).
Some resource planning for contingencies (such as a large emergency incursion response that would need significant additional resources quickly) is undertaken, but there is not a high level of assurance that sufficient expert resources could be made available quickly and comprehensively.

We consider that the extent of reprioritising that goes on between different activities indicates that the provision of resources for carrying out the ordinary day-to-day business of biosecurity leaves little flexibility for undertaking unplanned activities.

We noted other capability shortfalls. For example:

  • The National Plant Pest Reference Laboratory (NPPRL) does not have dedicated incident control staff with the skills to manage incursion responses. Staff of NPPRL did their best to overcome this shortcoming, but it still adversely affected the NPPRL’s management of its component of the response to the painted apple moth incursion.
  • The inability to transfer large volumes of complex data between response headquarters, the incident control facility, and field operations could compromise the management of a major incursion response.

On the basis of this evidence, and taking the advice of experts in biosecurity, we conclude that there is not a high level of assurance that resources could be found quickly and comprehensively for a very large urgent incursion response. Also, for most potential incursions, the capability gap is not precisely known. For example, MAF Biosecurity currently has resources to deal with an outbreak of foot and mouth disease involving 25 contaminated sites in the first week and 10 sites a week thereafter.

It is difficult for MAF Biosecurity to accurately predict what size of outbreak it should prepare for. The current level of resources is influenced by historical factors and what contractors can be held to.

Without a reliable assessment of the extent of the capability gap, it is difficult to determine what would be required to eliminate the gap. However, our recommendations in the following paragraphs are directed to the more obvious pressure points, and include some suggestions on how current processes and use of resources could be improved.

Paragraphs 6.101-6.110 (page 105 ).


Whole of Government – Improving Co-ordination

The Memoranda of Understanding between the four main departments should be amended to accord greater priority to regular inter-departmental contact, and to contact with regional councils, to reflect operational requirements. The Memoranda should be reviewed and updated to reflect any changes in roles and responsibilities.

All meetings between the departments should be documented to record what decisions have been taken and how the decisions were reached.

Whole of Government – Agreeing Common Outcomes

The main departments should work together to ensure that they have a consistent approach to, and application of, the statement on appropriate level of protection that is to be defined in the Biosecurity Strategy.

The Biosecurity Strategy should include a specification of goals and outcomes for biosecurity activities against which the activities are then measured.

Whole of Government – Strengthening Accountability

The role, membership, and mandate of the Biosecurity Council and its two forums should be reviewed taking into account the Biosecurity Strategy. The review should include consideration of the Council’s role in co-ordinating and prioritising biosecurity-related research – a task that might best be undertaken by the Council’s Technical Forum.

The Directors-General/Chief Executives of the main departments should meet on a regular and formal basis and report to the Minister for Biosecurity. This should be the core executive, multi-agency group responsible for strategic planning, which is able to take and be accountable for decisions in relation to biosecurity. The group should consider how regional councils could best be involved in biosecurity policy decisions.

A Framework for Analysis and Priority Setting

The main departments and the Treasury should develop an agreed, common framework for analysing the benefits and costs of:

  • different categories of preventative measures (for example, pre-border, border, and post-border security) to address biosecurity risk; and
  • targeting resources at different biosecurity risks.

All incursions that are biosecurity risks should be prioritised on a consistent basis, irrespective of which department is managing the response to the incursion and the main sector under threat. Comparisons of relative priorities should be presented in a transparent way, including both:

  • intra-sectoral comparisons (e.g. the potential threat to human health from mosquitoes compared with other health priorities); and
  • inter-sectoral comparisons (e.g. comparing the response to the incursion of the southern saltmarsh mosquito against that for the painted apple moth).

The Treasury and the main departments that may need to apply for additional funding for new incursion responses should agree on a process for doing so. This process should include clear time-lines, be documented, pre-agreed, and well communicated. Once the process is agreed, the Treasury and the departments should ensure that they have a clear, shared understanding about what procedure will be followed should any of the key assumptions or risks subsequently change.

MAF Biosecurity, together with the Treasury and the other main departments, should take the opportunity provided by the development of the Biosecurity Strategy to review the Biosecurity Programme to ensure that the balance in emphasis and funding between the different components is appropriate. Improving the Way that MAF Biosecurity Operates

MAF Biosecurity should:

  • review the goals of the Biosecurity Programme in line with the Biosecurity Strategy, and develop performance measures against which the success of biosecurity activities can be measured;
  • improve its strategic oversight of other ongoing reviews (such as the sea containers review) to ensure that the effects of any unforeseen delays in completing the reviews are identified and managed;
  • review its assessment of the risks posed by bulk and direct-entry mail and by other mail items, including couriered items not covered by the compliance agreement with New Zealand Post;
  • implement a system to reduce the risks posed by those items that takes account of the assessed relative risks;
  • use information from the sea containers review as the basis for examining the level of risk posed by this pathway relative to others, so that an appropriate level of inspections of the containers can be established;
  • use information from the recently published surveillance review to develop a surveillance programme that has clear goals and objectives for surveillance activities, and in which priorities are determined in a transparent way;
  • ensure that its awareness campaigns include sufficient measures targeted at high-risk groups and locations;
  • continue to develop and implement measures to improve inter-group co-ordination and consistency (such as cross-group discussion of approaches to risk analysis); and
  • examine options for reducing the backlogs of risk analyses and import health standards, such as by contracting out some of the work or increasing the direct input from would-be importers (measures like this would need to be carefully assessed and tested to ensure that the integrity of MAF Biosecurity’s processes is not compromised).

Improving the Management of Incursion Responses

MAF and the other departments responsible for managing pest or disease incursions should consider whether a wide-ranging review of biosecurity capability (including preparedness for one or more major incursions) is required. Such a review should be carried out after the goals and outcomes for biosecurity activities have been identified.

The Director-General, MAF should consider whether a specific capability review of MAF Biosecurity is required and, if so, how this would feed into a wider review.

MAF and the other main departments should:

  • ensure that their Chief Technical Officers have an appropriate mix of management skills and sound technical knowledge;
  • ensure that incident controllers with appropriate experience and resources are used for all important incursion responses;
  • agree on a common purpose and core terms of reference for Technical Advisory Groups (TAGs) – from which each TAG should agree on specific terms of reference at an early meeting, and all TAG meetings should be comprehensively documented to record discussions and recommendations and how they were reached;
  • develop standard reporting arrangements to enable management oversight of major incursion responses while they are under way; and
  • convene a community advisory group early in the planning of a response whenever the response has the potential to affect a community.

In respect of MAF, the Director-General should consider delegating to the Group Director, MAF Biosecurity, the power to direct a Chief Technical Officer in the exercise of statutory functions.

MAF Biosecurity should:

  • develop a comprehensive operational checklist to be added to its Incursion Response Policy to help achieve greater consistency in the way incursion responses are managed;
  • ensure that the information technology review for major incursion responses is completed as soon as possible and that, while the review is under way, contingency plans are in place to deal with an emergency situation;
  • review the resourcing model used by the National Centre for Disease Investigation (NCDI) to see whether it would be appropriate for adoption by the National Plant Pest Reference Laboratory (NPPRL) (the review should include consideration of costs and benefits of expanding the resources of the existing NCDI group to allow them to provide services to the Chief Technical Officers of Plants and Forest Biosecurity, and also those in MoH and DOC); and
  • in conjunction with MAF Operations, work with MAF Corporate Human Resources to identify ways to address staff retention and recruitment at the laboratories.

6: MAF Biosecurity has the primary responsibility for biosecurity matters within MAF. It was formed as MAF Biosecurity Authority in 1999, but is commonly referred to as MAF Biosecurity. We have used this term throughout our report.

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