Part 6: MAF's Implementation of the Biosecurity Programme

The Biosecurity Programme

6.1
The Biosecurity Programme has seven components, each of which we examine:

• pre-border activities;
• border inspections;
• surveillance;
• incursion response capability;
• control and containment;
• education and enforcement; and
• research.

Pre-border Activities

Key Findings

6.2
MAF Biosecurity 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 requirements, and its approach to managing the risks. The audits foster productive relationships between MAF officials and their counterparts overseas. Taken together, the audits and pre-border inspections and constructive relationships encourage cooperation and compliance with MAF’s requirements.

6.3
MAF Biosecurity officials have a high level of experience in biosecurity risk analysis – in particular, in relation to those risks associated with possible impacts on the primary production sector.

6.4
However, given the relatively isolated way in which the different groups within MAF Biosecurity work, we cannot be certain that high standards are consistently maintained throughout all the groups.

6.5
The substantial backlogs in MAF Biosecurity of pest risk analyses and import health standards are unacceptable. The backlogs have made the prioritisation of import health standards and their related risk analyses an issue of particular concern to the department.

Relevant Case Studies – 1. Importation of table grapes from California. 6. Management of risks associated with sea containers. 7. Preparedness for an outbreak of foot and mouth disease.

6.6
Where possible, MAF takes steps to address biosecurity risks before commodities leave their country of origin. Risks are addressed through import health standards, which specify those requirements that must be met before MAF will issue biosecurity clearance for the commodities to enter New Zealand. Import health standards specify those conditions that must be in place:

• in the country of origin or export; and
• in transit, on importation, and in quarantine.

6.7
How an import health standard is issued and compliance with it enforced is described in Figure 11 on the opposite page.

Undertaking Audits and Pre-border Inspections

6.8
It would be logistically difficult and inefficient for MAF to carry out every aspect of pre-border inspection itself. Instead, MAF relies partly on overseas agencies to ensure that commodities destined for export to New Zealand meet the biosecurity measures set out in its import health standards.

6.9
We examined how pre-border inspection works in relation to the importation of Californian table grapes:

• MAF Biosecurity officials conduct audits to determine whether the biosecurity measures required in its import health standard for the importation of table grapes are being properly applied overseas.
• MAF Quarantine Officers also undertake inspections and issue biosecurity clearance before the grapes leave the country of export. The grape importers who benefit from the trade meet the costs of the inspections.

Figure 11
An Import Health Standard – Issuing it and Ensuring Compliance

6.10
The audits and pre-border inspections are an effective way of making overseas agencies aware of the biosecurity risks facing New Zealand, and our approach to addressing those risks. They also help MAF officials to build productive relationships with counterparts overseas. The good relationships in turn promote cooperation and compliance by overseas authorities.

Preparing Risk Analyses To Support Import Health Standards

6.11
As a member of the World Trade Organisation (WTO), New Zealand has agreed that its biosecurity measures (including import health standards) should be technically justifiable and transparent. As part of its obligation under the WTO Agreement on the Application of Sanitary and Phytosanitary Measures¹¹, all New Zealand’s import health standards are based on a documented risk analysis process¹².

6.12
This risk analysis process involves:

• identifying all pests and diseases associated with a particular commodity;
• determining whether these pests or diseases are established in New Zealand; and
• for any pests or diseases not established here, assessing the likelihood of the commodity bringing the particular pest or disease into the country, and the consequences should this happen.

6.13
Once the risks have been established, measures to mitigate them are developed which form the basis of the import health standard.

6.14
We examined the risk analysis for the importation of table grapes from California. We noted the application of domestic and international peer review, and MAF Biosecurity officials’ considerable expertise in the conduct of risk analyses. Their expertise is especially well developed in relation to addressing the risks posed to the primary production sector, but MAF Biosecurity is expanding its risk analysis approach to improve its assessment of the risks to indigenous flora and fauna. Risk analysts in Biosecurity Australia (MAF Biosecurity’s Australian equivalent) are adopting aspects of MAF’s risk analysis for their own processes.

6.15
MAF Biosecurity is better placed to assess the impact of identified risks if it is able to quantify them in financial terms. For example, the impact of a pest that threatens an agricultural crop can be quantified in terms of the financial loss that farmers would incur if the pest were to destroy their crop.

6.16
However, impacts cannot always be readily quantified in financial terms – such as threats to the natural environment from a disease that might kill native trees. It is harder to analyse these risks because the potential impacts of the pest or disease are less certain and less easy to measure.

6.17
Assessing impacts that cannot be quantified in monetary terms is a major focus of the recently established Indigenous Flora and Fauna (IFF) Group (see paragraph 4.58 on page 60). In our view, progress will be made more quickly if the main departments work together more closely and increase their sharing of information and expertise.

6.18
The same applies to sharing information and expertise within MAF Biosecurity itself, and with other parts of MAF. We identified risk analysis as an area where gains could be made by increasing the sharing of best practice, experience, and expertise between the animal, plants, and forest groups. We also see this as a particularly important means of developing the expertise of the relatively new IFF Group.

Meeting the Demand for Import Health Standards

6.19
MAF Biosecurity comes under considerable pressure (such as from importers, exporters, and overseas governments) to issue new import health standards. Delays in issuing standards can prevent commodities being imported. Import delays can affect not only importers but also local manufacturers and exporters who use imported commodities to make finished products here.

6.20
Risk analyses involve collation, examination, and assessment of large volumes of complex information. And as knowledge and skills in risk analysis have increased, and peer review and consultation have become more thorough, risk analyses have become more comprehensive and time-consuming.

6.21
The import health standards developed out of these risk analyses can also take a long time to finalise – because, for example, both the risk analyses and the import health standards require consultation with a range of different people and organisations.

6.22
Two of the case studies illustrated issues relating to risk analyses and import health standards:

• Importation of Californian table grapes – where MAF’s consultation with relevant industry groups and technical experts had to be undertaken in the context of time pressures for completion of the revised import health standard by the start of the new grape-importing season.
• Response to the red imported fire ant incursion – which highlights the issue of whether temporary risk mitigation measures should (or could) be put in place while a detailed risk assessment is under way.

6.23
Import health standards also have to be kept under constant review and, if necessary, the biosecurity risks must be re-analysed when it appears that the risks have changed. This is what happened in 2001, when MAF had to revoke the import health standard for table grapes imported from California as a result of the spread of the glassy-winged sharpshooter and Pierce’s disease throughout southern California.

6.24
Also, following the foot and mouth disease outbreak in the UK in 2001, MAF gave priority to amending 95 existing import health standards – standards in the animal group in particular frequently require updating. In these circumstances, planned work (on, for example, new import health standards) may have to be delayed while an urgent review of a previous standard and its supporting risk assessments is undertaken.

6.25
These and other factors have made it difficult for MAF Biosecurity to keep pace with the demand for import health standards. Large backlogs have built up in each of the three groups, as shown in Figure 12 below. Backlogs have also built up in preparing risk assessments, as shown in Figure 13 on the next page.

Figure 12
Backlogs in Issuing Import Health Standards

Group	Currently under development or requested	Completed in 2001-02	Estimated Backlog (years)1
Animal	350	111	4.4
Forest	13	4	3.2
Plants	1550	24	64.6

1 This estimate assumes that outstanding standards are a similar size to those being completed, and that the resources required to complete them will remain the same.

Figure 13
Backlogs in Preparing Risk Analyses

Group	Requests Outstanding	Completed in 2001-02	Estimated Backlog (years)1
Animal	28	92	2.8
Forest	2	2	1.0
Plants	85	23	42.5

1 This estimate assumes that outstanding risk analyses are a similar size to those being completed, and that the resources to complete them will remain the same.

2 In addition, a number of much simpler risk analyses have been completed for MAF’s Agricultural Compounds and Veterinary Medicines Group.

3 In addition, a large number of pest risk categorisations and pest risk assessments have been completed by this group to determine which pests should be subject to full pest risk analyses.

6.26
Figures 12 and 13 show that the backlogs in import health standards and risk analyses are particularly large in the Plants Biosecurity Group. For the purpose of issuing import health standards for plants, MAF sets priorities for dealing with requests according to:

• the length of time since MAF received the request;
• the value of the crop concerned; and
• the potential consequences of any associated pests or diseases.

6.27
Given the number of risk analyses awaiting preparation, it is important that MAF has a sound, transparent method for setting priorities that is consistently applied. We noted one instance where MAF Biosecurity had given precedence to a request over others without following its normal process. MAF officials suggested that this was an exceptional occurrence and we saw no evidence to contradict this view. However, the occurrence reinforces the importance of having a transparent method for setting priorities that applies in every case.

6.28
For 2002-03 MAF received additional funding specifically for risk analyses and import health standards. Despite this increase, MAF Biosecurity is unlikely to be able to clear its backlog of import health standards while at the same time keeping existing standards under review.

6.29
One means of reducing the backlog would be to shorten the risk analysis process. However, MAF officials would need to test any revised process to ensure that the changes:

• have not compromised the quality and integrity of the process; and
• are consistent with New Zealand’s obligations under WTO agreements.

6.30
Other options to reduce the backlogs include the re-allocation of resources from within MAF Biosecurity and contracting out some work to other agencies or individuals.

6.31
The current backlogs of risk analyses and import health standards are, in our view, unacceptable because they could compromise biosecurity. For example, the backlog for plant import health standards, and consequential delay in development of risk mitigation measures, increases the likelihood of illegal importation of risk material. In some cases, a delay to an import health standard could be viewed as a restraint on trade.

6.32
Nevertheless, measures to reduce the backlogs need to be carefully considered. MAF needs to strike a difficult balance, especially if it chooses to make resource transfers. More resources to enable new commodities to be imported could be at the expense of other biosecurity activities (such as border control) that are mainly designed to protect New Zealand from the assessed risks associated with commodities that are already coming in.

Recommendations

6.33
MAF Biosecurity should:

• Continue to develop and implement measures to improve intergroup co-ordination and consistency (such as inter-group discussion of approaches to risk analysis).
• Examine options for reducing the backlogs of risk analyses and import health standards, such as contracting out work or greater direct input from would-be importers. Any such measures would need to be carefully assessed and tested to ensure that the integrity of MAF Biosecurity’s processes is not compromised.

Inspections at the Border

Key Findings

6.34
Inspections for biosecurity risk material at New Zealand’s borders are comprehensive for all pathways except the sea containers pathway, which is both the most difficult to manage and the least well controlled.

6.35
New Zealand conducts biosecurity examinations on a large proportion of mail items and all passengers’ baggage that enter the country through recognised entry points.

6.36
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 be in place to deal with the risk.

Relevant Case Studies –   6. Management of risks associated with sea containers. 7. Preparedness for an outbreak of foot and mouth disease.

6.37
MAF Quarantine Service (MAF QS) inspects goods crossing the border. The inspectors check that commodities comply with MAF’s import health standards for all possible pest and disease entry pathways – i.e. passengers, vessels, mail, and commercial consignments.

6.38
MAF QS inspections are most visible at international airports, where quarantine officers check passengers and their luggage for products that have been banned or that may contain pests or disease. Less visible to the general public is the work undertaken by quarantine officers at:

• ports visited by international vessels;
• the Auckland International Mail Centre; and
• various overseas locations where people and commodities are inspected before they reach the border – for example, biosecurity clearance of cruise ships and inspections of New Zealand troops and their equipment returning from East Timor.

People Entering the Country

6.39
Nine airports receive international passengers. This is a tightly controlled pathway. In recent years, MAF has introduced major measures, such as X-ray machines and detector dogs, that it assesses have improved the detection of suspect goods:

• Up to 1996, MAF assessed that it was detecting approximately 55% of risk goods brought into the country by passengers arriving at international airports. At that time MAF did not use X-ray machines or detector dogs.
• With the introduction of X-ray machines and detector dogs at Auckland International Airport in 1996 (examining approximately 50% of all baggage) the assessed detection level of suspect goods climbed to between 85% and 95%.
• In March 2001, Cabinet approved funding for a further 11 teams of detector dogs and further installations of soft-tissue X-ray machines. (The funding also paid for a public awareness campaign for foot and mouth disease and to provide veterinary support for the UK foot and mouth disease outbreak.) MAF has assessed that these measures have enabled it to detect almost all suspect goods coming into the country with international passengers.

International Mail

6.40
Since August 1999 MAF has reported that virtually all incoming international mail has been screened by X-ray at the Auckland International Mail Centre, and in many cases also by quarantine detector dog teams. We understand that some other countries are planning to follow our example.

6.41
In the course of our audit we found that approximately 22 million mail items per year arriving at the International Mail Centre are not, in fact, being screened. In 2001-02 MAF reported screening just over 50 million mail items, and that these items encompassed virtually all arriving international mail.¹³ However, New Zealand Post’s figure for the incoming international mail it handles was 71.8 million items for 2001-02.

6.42
The approximately 22 million mail items not screened appear to be mostly in the form of:

• m-bags – approximately 120,000 bags of mail a year containing multiple printed matter (magazines, etc.), addressed to a single addressee – MAF considered this mail to be a low biosecurity risk, but the New Zealand Customs Service recently intercepted magazines containing seeds during a random check (since this incident, all bags have been screened, and countries using the service have been reminded that it is intended for printed matter only);
• bulk mail – mostly comprising business mail or direct marketing material from known customers who have a direct customer relationship and an operational agreement with New Zealand Post – this mail is not X-rayed, but may be inspected by the New Zealand Customs Service and MAF officials; and
• direct-entry mail – which is the same as bulk mail, but the direct customer relationship is held by another postal administration (e.g. Australia Post).

6.43
MAF does not treat either bulk mail or direct-entry mail as international mail. Instead MAF treats it as cargo. Once delivered to the International Mail Centre, the mail is handled according to a compliance agreement between New Zealand Post, MAF and the New Zealand Customs Service. If bulk and direct-entry mail is identified as low risk (as specified in the agreement), it is released for delivery without screening. Mail identified as medium to high risk is screened or inspected by MAF before release. The New Zealand Customs Service may also screen bulk and direct-entry mail, and mail that arrives in m-bags.

6.44
In addition, a large unknown quantity of mail items is brought into the country by freight forwarders and lodged at domestic mail centres or delivered by carriers other than New Zealand Post. This mail is also treated by MAF as cargo. MAF does not have a compliance agreement with these other carriers to ensure that biosecurity risk items are detected.

6.45
Mail that enters through courier companies is a further exception to the screening of “virtually all” international mail. In recent years, the use of courier companies as an alternative to postage through ordinary mail has been increasing. We understand that up to 12 international courier companies are currently operating in New Zealand, and that the number of courier packages brought in by three of the main companies is estimated at over 1.1 million a year. Unlike bulk mail and direct-entry mail, this method may be used for sending a wide range of items, not just printed material. Couriered packages therefore can carry items posing a high biosecurity risk.

6.46
Currently, both MAF and the New Zealand Customs Service rely on manual screening of a manifest (that describes the contents of a consignment of couriered items) to detect risk goods. Unlike international mail received through New Zealand Post, the items are not X-rayed or screened by detector dog teams on a consistent basis.

6.47
Between October and December 2001, MAF Quarantine Service undertook a survey of couriered items in order to analyse and quantify the risk posed by courier cargo for both MAF and the New Zealand Customs Service, and to evaluate the effectiveness and efficiency of the current screening process.

6.48
The survey showed that the manifest screening as currently operated does not give high detection rates for risk items in courier cargo, and that a significant proportion of packages entering New Zealand were not on the flight manifests provided (so would not be detected without further screening). In addition, 10% of packages had manifest descriptions that did not accurately reflect the contents of the package.

6.49
The survey concluded that courier cargo may be more similar to international postal mail [than cargo]. Rather than including courier cargo in [the] cargo clearance programme, the possibility of screening it in the same way as international postal mail should be considered.

6.50
MAF has considered a number of options for addressing the risks posed by this pathway, including the suggestion that courier items be treated as mail. It has agreed that manifest screening must be improved, and will now require courier companies to hold back items not included in the manifest until documents are provided and screened. At present, some biosecurity risk items are still being intercepted by the New Zealand Customs Service either by manifest screening or by a mobile X-ray machine that is used to screen couriered items at the courier companies’ warehouses on a random basis.

Sea Containers

6.51
It is not practical or possible for MAF to fully inspect all containers – the volume of material imported in sea containers is huge – 410,000 arrived at ports in 2001-02. Sea containers are therefore the least controlled pathway by which unwanted organisms can enter because of the difficulty in identifying and achieving the correct balance between:

• the cost and time it takes to inspect sea containers; and
• the level of biosecurity risk they might pose.

6.52
We therefore decided to include MAF’s management of the biosecurity risks associated with sea containers as one of our seven case studies.

6.53
MAF surveys have shown that targeting containers for inspection is more effective than random selection in detecting risk goods and unwanted organisms. It therefore inspects selected containers – currently approximately one-quarter of all arriving sea containers.

6.54
MAF uses a number of risk factors to select containers for inspection. Those that can prompt an inspection include:

• absence of documentation certifying that the container has been cleaned;
• the container’s country of origin; and
• the type of goods declared to be inside the container.

6.55
A cleaning certificate attests that a container is free of contamination. However, a significant proportion of certificates (44%) has been found to be inaccurate for wood packaging. MAF is currently reviewing its import health standard for sea containers. The first draft of this review is due in December 2002, and is likely to give a range of options for better targeting of containers for inspection.

Recommendation

6.56
MAF Biosecurity should:

• review its assessment of the risks posed by bulk and direct-entry mail and by other mail items (including couriered items), that are not covered by the compliance agreement with New Zealand Post;
• implement a system to reduce the risks posed by these items that takes account of the assessed relative risks; and
• use information from its current review of sea containers as the basis for examining the level of risk posed by this pathway relative to others, so that an appropriate level of inspections of containers can be established.

Surveillance

Key Findings

6.57
Many of the people we interviewed during this audit considered that judging the appropriate levels of surveillance funding and activity is one of the most difficult and important issues related to the Biosecurity Programme. Many also viewed surveillance as the weakest component of the Programme.

6.58
The sooner pests or diseases are detected after entering the country, the greater the likelihood that they can be eradicated – there is a point in the spread of each pest and disease at which eradication, or even a measure of control, will either not be possible or not be cost-effective.

6.59
Where a decision has been made to avoid a particular pest or disease becoming established, it is vital that the type and level of surveillance undertaken is sufficient to detect the pest or disease early enough to enable cost-effective countermeasures/eradication to be undertaken.

6.60
Historically, there has been a lack of effort to formulate a strategy and set levels and objectives for surveillance to achieve this aim. Clearer goals and outcomes for biosecurity surveillance measures are required.

Relevant Case Studies –   2. Response to the incursion of the southern saltmarsh mosquito. 3. Response to the incursion of the painted apple moth. 4. Response to the incursion of the varroa bee mite. 5. Response to the incursion of the red imported fire ant. 7. Preparedness for an outbreak of foot and mouth disease.

6.61
While New Zealand is viewed as having among the best border control measures in the world, it is impossible to eliminate all biosecurity risks. One of MAF’s key biosecurity roles is to detect those pests and diseases that do manage to enter the country.

6.62
When a pest or disease has entered the country it is vital to detect it early because:

• generally, detection before the pest or disease has spread greatly increases the chances of being able to eradicate it; and
• once it has spread, eradication or even control may no longer be possible or cost-effective.

6.63
Therefore, the success of the Biosecurity Programme depends on surveillance activities that are adequately funded and effective. Successful surveillance also demonstrates to other countries to which New Zealand exports that the country is free from pests and diseases.

6.64
Surveillance involves a wide range of activities and is undertaken by many different people and organisations. Each of the three sector (animal, plants, forest) groups within MAF Biosecurity has its own surveillance programme which provides for:

• standards for surveillance activities;
• purchase of the activities – such as survey design, sample collection, diagnostic services, and reporting – from contractors; and
• audit of the delivery of activities against the standards.

6.65
In addition to the surveillance activities purchased by MAF Biosecurity:

• MoH’s Public Health Service operates a surveillance programme for exotic mosquitoes of public health significance;
• DOC operates surveillance programmes for specified established animal and fresh water fish pests, and conducts limited surveillance for new pests and diseases at some high-risk sites (e.g. campsites); and
• Some regional councils and industry groups fund surveillance programmes for pests and diseases relevant to their regions and sectors.

6.66
An important element of surveillance is the role played by the general public in informing MAF and other agencies (such as regional councils) of any unusual insects that they might see. A number of exotic pest incursions – including the southern saltmarsh mosquito, painted apple moth, and Argentine ant – have come to the attention of biosecurity agencies through the vigilance of members of the public.

6.67
Unlike border control capability that has been strengthened over recent years (see paragraphs 4.12 on page 50 and 6.39 on page 92), some of the people we spoke to believe that surveillance capability has become weaker over the same period for a range of reasons – including:

• a reduction in the level of resources applied to surveillance (work done in support of the recent surveillance review indicated that funding for animal disease surveillance has reduced from approximately $8 million to about $5 million a year over the last ten years);
• fragmentation of services, which may have resulted in part from the introduction of contestability (see paragraphs 5.7-5.11 on page 77);
• issues concerning the Votes Biosecurity structure and associated difficulties in co-ordinating and prioritising activities between departments (discussed in paragraphs 4.8-4.39 on pages 48-56); and
• difficulties with co-ordination between central, regional, and industry surveillance.

6.68
Delays in detecting pests or diseases make it more difficult to respond to an incursion, limit the response options available, and make it less likely that a control strategy will be effective. This was clearly illustrated in the case of the varroa bee mite, which is thought to have been present in New Zealand for up to five years before it was detected. Over this period, the resources available for surveillance of the mite were lower than in previous years.

6.69
The Technical Advisory Group established to advise the Minister on the response to the bee mite recommended measures to control and contain its spread in recognition of the fact that, by the time it was detected, eradication was unlikely to succeed. Had the bee mite been detected earlier, eradication may have been a feasible option.

6.70
Overseas experience points to similar consequences of a failure to detect pests or diseases at an early stage. Delays in detecting the presence of the red imported fire ant in Queensland, and foot and mouth disease in the UK, have been responsible for these incursions spreading far more widely than would have been the case had they been detected earlier.

6.71
Surveillance measures designed to detect specific pests and diseases known to pose high risks if they were to enter the country would make the public and industry stakeholders more aware of the pests and diseases, what they or their symptoms look like, and their potential impact on the community.

6.72
However, with the exception of some pests and diseases that are known to pose specific risks to certain parts of the primary production sector (for example, Asian gypsy moth, fruit fly, and foot and mouth disease), there is currently no list of the highest-risk pests and diseases that should be targeted for surveillance.

6.73
In the past, little priority had been given to developing a surveillance strategy, and programme objectives and priorities. A project is currently under way to identify the most serious environmental pests for which surveillance programmes may need to be put in place. And in November 2001, MAF Biosecurity commissioned a review of biosecurity surveillance programmes operated by government departments.

6.74
The aims of the review were to make recommendations on the efficacy, efficiency, and appropriateness of surveillance programmes designed to:

• detect organisms new to New Zealand;
• monitor established pests and diseases of plants and animals; and
• verify existing plant and animal health situations.

6.75
The review was to develop a framework for prioritising surveillance programmes, and an economic model to help determine appropriate funding levels for surveillance. The review was completed and the report published in September 2002. A copy of the review is available on MAF’s web site (www.maf.govt.nz). The results have been used to inform the development of the Biosecurity Strategy.

Recommendation

6.76
MAF Biosecurity should use the information from its recent review to develop a surveillance programme that has clear goals and objectives for its surveillance activities, and in which priorities are determined in a transparent way.

Responding to Incursions

Key Findings

6.77
In paragraphs 4.19-4.39 on pages 51-56 we examined the process for seeking funds for an incursion response and the need to improve it. The response to the incursion of southern saltmarsh mosquito illustrated the problems that can sometimes occur when funding for an incursion response is sought.

6.78
We found inconsistencies in the way that different incursion responses were managed, and we identified a number of important issues that need to be addressed – including:

• management oversight, so that any problems with incursion responses are picked up early;
• the demanding role of the Chief Technical Officers, who require not only sound technical expertise but also high levels of project management and communications skills; and
• inconsistencies in the purpose of Technical Advisory Groups and the ways they operate that reduce the clarity and transparency of the decisions taken and recommendations made at TAG meetings.

6.79
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.

6.80
The inability to transfer large volumes of complex data between response headquarters, incident control facility, and field operations could compromise the management of a major incursion response.

Relevant Case Studies –   2. Response to the incursion of the southern saltmarsh mosquito. 3. Response to the incursion of the painted apple moth. 4. Response to the incursion of the varroa bee mite. 5. Response to the incursion of the red imported fire ant. 7. Preparedness for an outbreak of foot and mouth disease.

6.81
Figure 14 on the opposite page illustrates the roles and responsibilities of the main people and organisations involved in a pest incursion response. The responsibilities of the lead agency are particularly complex and multi-dimensional.

Figure 14
Roles and Responsibilities in an Incursion Response

6.82
A response to a pest or disease incursion will often pass through different phases – such as from control and containment through to eradication. In some instances, departments have sought funding for a single phase of a response – with the intention of collecting information and preparing advice for the Government on the further action that may be required.

6.83
Funding one phase at a time represents good practice, but only insofar as it does not unduly constrain the response and/or unnecessarily increase the number of separate approaches to obtain funding. The response to the incursion of the southern saltmarsh mosquito illustrated the problems that can sometimes occur when funding for an incursion response is sought.

6.84
The case studies – in particular, the painted apple moth and red imported fire ant – illustrated other differences in the way in which incursion responses are managed. We identified a number of factors that accounted for these differences.

• Until February 2001, MAF did not have an incursion response policy.
• Different Chief Technical Officers (CTOs) took different approaches to their responsibility for the responses we examined.
• There were differences in the operation of the Technical Advisory Groups advising on the responses.
• There is a need to improve management oversight.
• There are shortfalls in the laboratory resources available to deal with the work arising from some responses.
• Some responses are especially dependent on advanced information technology, which is not yet sufficiently developed to support a major incursion response.

Need for an Incursion Response Policy

6.85
Comprehensive emergency response procedures to deal with outbreaks of diseases such as foot and mouth have been in place for some years. However, it was not until February 2001 that MAF issued a Draft Policy on Responding to an Exotic Organism Incursion applicable to all sectors for which its CTOs are responsible.

6.86
The purpose of this policy is to ensure that decisions and actions taken in responding to incursions are transparent and consistent. The policy sets out a generic approach to guide decision-making and the development of response programmes for specific organisms.

6.87
MAF successfully tested the policy in responding to the incursion of the red imported fire ant. However, the independent review of MAF’s response to the incursion of the painted apple moth recommended that the policy be complemented by a Standard Operating Procedure (SOP), which would list actions to be taken as a guide to formulating an incursion response. In order to ensure that the SOP was applied consistently, CTOs would be required to record any decision to depart from it.

Role of Chief Technical Officers

6.88
The Animal, Plants, and Forest Biosecurity Groups are each headed by a director. The three directors are also MAF’s CTOs and, as such, have statutory duties under the Biosecurity Act 1993.

6.89
CTOs must be:

• technically proficient, with appropriate qualifications and experience in their respective sectors;
• scientifically credible to industry and other stakeholders; and
• able to take decisions based on highly technical scientific data.

6.90
These attributes are essential to the role, and should be given considerable weight when new appointments are made. CTOs also require good management skills because overseeing major incursion responses demands:

• expertise in project management;
• a strong ability to communicate effectively, both orally and in writing, to a range of audiences; and
• the skill to manage many different sets of relationships, especially to secure the co-operation of relevant industry groups.

6.91
It is crucial that CTOs have all of these skills – both technical and managerial. MAF’s response to the painted apple moth incursion well illustrated the difficulty that will sometimes occur in expecting these complex roles to be fulfilled by one individual.

Operation of Technical Advisory Groups

6.92
When a pest or disease is detected and a response initiated, a Technical Advisory Group (TAG) is established to provide technical advice to the responsible CTO. The ways in which these groups operate are very different – both within MAF and between MAF and MoH.

6.93
While a TAG needs to operate flexibly as appropriate to the requirements of a particular response, a common purpose and core terms of reference for TAGs would help to:

• more clearly define the role of group members; and
• improve communication and understanding between the group, stakeholders, and members of the public, by providing some consistency and link through to overall biosecurity policy.

6.94
The core terms of reference could form the basis of more detailed terms of reference for each TAG, to be agreed at an early meeting.

6.95
The TAGs play a key role in providing expertise and advice to help the Government in taking what can often be controversial decisions – such as to approve aerial spraying with an insecticide or to decline the option to attempt eradication of a pest or disease. Therefore, it is vital that TAG meetings are documented, and particularly that they clearly record what recommendations were made and how they were reached.

Oversight by Senior Management

6.96
At the completion of an incursion response MAF carries out a debriefing review to identify lessons for the future. Furthermore, the Biosecurity Council has agreed that MAF should commission independent reviews for every major incursion response, similar to that undertaken of MAF’s response to the painted apple moth.

6.97
While debriefs at the conclusion of each response enable lessons to be learned, we found evidence of the need for the same kind of review during the course of major incursion responses. Such reviews would help senior management to monitor progress with response activities by providing status reports showing achievements against plans.

6.98
MAF’s response to the incursion of the painted apple moth illustrates clearly the need for information to support more effective management oversight. MAF took too long to identify problems with its response, thus limiting the options available.

6.99
CTOs have statutory authority to take certain actions to manage incursion responses. This can create uncertainty regarding the oversight role of their manager, the Group Director, MAF Biosecurity.

6.100
In our view, the oversight role of the Group Director would be strengthened if the Director-General, MAF were to delegate to the Group Director the power to direct a statutory officer (in this case, the CTOs) in the exercise of their statutory functions (a more detailed discussion is provided in the Case Studies, pages 70-71). The Group Director would then be clearly mandated to manage the CTOs in their oversight of incursion responses and to ensure that potential problems are identified early and any necessary action taken.

Shortfalls In Laboratory Resources

6.101
MAF uses two reference laboratories to identify exotic organisms and enable it to plan a suitable response:

• the National Centre for Disease Investigation (NCDI); and
• the National Plant Pest Reference Laboratory (NPPRL).

6.102
The NCDI incorporates the New Zealand Animal Health Reference Laboratory and the Exotic Disease Response Centre. Its functions are to:

• diagnose and manage incursions of exotic or emerging pests and diseases, including those affecting the environment; and
• facilitate trade in animals and animal products by delivering accurate and timely information on the health status of New Zealand’s animals.

6.103
Within NCDI, staff roles are separated between those assigned to laboratory functions and those involved in the planning and implementation of response management.

6.104
The NPPRL was established in November 1998 to monitor the health status of New Zealand’s plants by identifying plant pests and diseases. Two sets of factors are impeding the operations of the laboratory:

• overcrowded conditions – we were informed by MAF that the laboratory does not meet occupational safety and health, molecular biology, or MAF/ERMA quarantine requirements; and
• shortages of staff to deal with growing numbers of incursions, investigate environmental and forest pests, and assume project management responsibilities.

6.105
The workloads of both NCDI and NPPRL have grown substantially in recent years. In addition, there is a limited pool of suitably qualified people in New Zealand to fill positions at both NPPRL and NCDI. We were informed that staff recruitment and retention was an issue for the two laboratories. Staffing requirements at NCDI in the event of a substantial response are considered in the foot and mouth disease case study.

6.106
The additional funding in 2002-03 (see footnote 7 on page 48) includes amounts for sustaining and developing reference laboratory capability. This funding is intended to help relieve the workload pressures faced by NCDI and NPPRL. MAF Biosecurity will be monitoring the impact of the workload of the laboratories, and the extent to which the new funding is enabling the problem to be addressed.

6.107
The separation of staff roles at NCDI between the technical, scientific work and project management roles does not apply at NPPRL. There, the same member of staff can be responsible for both technical work (such as diagnostic work) and project management (such as managing incursion responses and dealing with external enquiries).

6.108
As with the more senior CTO role described in paragraphs 6.88-6.91 on page 103, it can be difficult to find a person suitably qualified to fulfil both of these complex roles.

Information Technology Support

6.109
Effective response programmes require the management and co-ordination of large volumes of data between the response headquarters, the incident control facility, and staff in the field. Because of MAF’s need to protect the integrity of its databases, current Information Technology (IT) arrangements do not enable these locations to share data, thereby creating the potential for compromising the successful management of incursion responses.

6.110
MAF Biosecurity has reviewed its IT systems and has additional funding in 2002-03 to develop a new incursions database. It is also examining the use of IT in the management of the UK foot and mouth disease outbreak to identify how future IT needs might best be met. This part of the review has involved looking at ways to optimise the use of the EpiMan software developed by the EpiCentre at Massey University. Elements of the EpiMan software were used in the UK outbreak.

Recommendations

6.111
The main departments should consider whether a wide-ranging review of biosecurity capability (including preparedness for one or more major incursions) is required.

6.112
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.

6.113
MAF and the other departments responsible for managing pest or disease incursions should:

• ensure that their CTOs have an appropriate mix of management skills and sound technical knowledge;
• ensure that appropriately experienced incident controllers with sufficient resources are used for all important incursion responses;
• agree a common purpose and core terms of reference for TAGs (from which each TAG should agree specific terms of reference at an early meeting);
• ensure that all TAG meetings are comprehensively documented to record discussions and recommendations and how recommendations were reached; and
• develop standard reporting arrangements to enable management oversight of major incursion responses while they are under way.

6.114
The Director-General, MAF should consider delegating to the Group Director, MAF Biosecurity the power to direct a CTO in the exercise of statutory functions.

6.115
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 IT 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 NCDI to see whether it would be appropriate for adoption by NPPRL. This review should also consider expanding the resources of the existing NCDI group to allow them to provide services to the CTOs Plants and Forest Biosecurity, and also the CTOs in MoH and DOC.
• In conjunction with MAF Operations, work with MAF Corporate Human Resources to identify ways to address staff retention and recruitment at the laboratories.

Control and Containment Measures

Key Finding

6.116
Pest management strategies are complex and costly to produce, and only two have been produced.

Relevant Case Studies –   2. Response to the incursion of the southern saltmarsh mosquito. 3. Response to the incursion of the painted apple moth.

6.117
We looked at the risks posed by imported pests and diseases, not the risks posed by those that are endemic. However, MAF and other organisations (such as regional councils) play an important role in managing endemic pests such as possums. Some of the people we interviewed expressed views about one aspect of the measures to control and contain endemic pests and diseases – pest management strategies. We therefore considered it valuable to reflect these views in our report.

6.118
When a pest or disease has become established, the Biosecurity Act 1993 provides for the drawing up of either a national pest management strategy (by government departments) or a regional pest management strategy (by regional councils) designed to manage or eradicate pests and diseases. Strategies can also be drawn up in collaboration with or separately by industry groups that have an interest in controlling or eradicating the endemic pest or disease.

6.119
National pest management strategies require approval by the Minister for Biosecurity, who seeks advice from MAF as to the soundness, feasibility and cost of a proposed strategy. Other ministers (such as the Minister of Agriculture) can also propose or notify national pest management strategies that relate to their responsibilities.

6.120
Drawing up a national pest management strategy can be a timeconsuming, complex, and costly process. At the time of writing this report, only two such strategies have been prepared – one for bovine tuberculosis control and the other for American foulbrood (a disease of bees).

6.121
A national pest management strategy is being developed for the varroa bee mite. Another, started by MoH for exotic mosquitoes of public health significance, was abandoned when the Associate Minister for Biosecurity agreed that the resources being used to draw up the strategy could be better used on other aspects of exotic mosquito management.

6.122
Of the 33 recommendations made in the independent review of the response to the painted apple moth, the only recommendation not to have been accepted and acted upon by MAF was to develop a pest management strategy for the moth. As with exotic mosquitoes, MAF felt that the resources required to do so would be better used on other response measures.

6.123
Because of the difficulties associated with preparing and obtaining approval for National Pest Management Strategies, departments have chosen to use administrative powers in the Biosecurity Act in order to respond to particular incursions without recourse to a strategy. This approach was criticised in the painted apple moth review, and by an earlier review of the response to an incursion of the white spotted tussock moth.

6.124
On the basis of views expressed to us, and in the light of the clear difficulties with preparation, MAF Biosecurity might consider conducting a review of the procedures required for the preparation and approval of National Pest Management Strategies. Such a review could usefully focus on how to create the strategies as a more practical tool for responding to pest incursions.

Education and Enforcement

Key Findings

6.125
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 these programmes and activities. The surveys are also providing useful information on high-risk groups and public attitudes to biosecurity measures such as aerial spraying.

6.126
In the 12 months to 30 June 2002, 9630 infringement notices were issued, of which 91% were paid within the specified period.

6.127
Calls have been made for importers to pay instant fines for failure to comply with biosecurity import requirements for containers. The Ministry of Justice has told MAF that such fines would be inappropriate. The lack of instant fines is partly balanced by a requirement for importers to pay for inspection, and for any subsequent cleaning of containers found to be contaminated.

Relevant Case Studies –   6. Management of risks associated with sea containers. 7. Preparedness for an outbreak of foot and mouth disease.

Educating People and Industries About Biosecurity Risks

6.128
When people and industries are aware of the potential dangers from risk goods entering the country, they are more likely to comply with biosecurity requirements. Public and industry awareness is crucial to minimising the risks to New Zealand’s biodiversity and the primary production sector.

6.129
Members of the public initially alerted the two departments concerned (MAF and MoH) to the presence of the southern saltmarsh mosquito, the painted apple moth, and the red imported fire ant. All three pests were detected at a stage when eradication was feasible. These cases highlight the benefits of public education on biosecurity issues, and demonstrate the importance of having an ongoing biosecurity awareness campaign.

6.130
The response to the painted apple moth incursion illustrated the need for early consultation with communities – community concerns, particularly in respect of aerial spraying, needed to be addressed. In such situations, early and well-managed engagement with the public is important in establishing constructive relationships with communities to explain and overcome difficult and complex issues.

6.131
MAF undertakes a variety of activities to raise general awareness of biosecurity. For example, it has:

• entered into arrangements with overseas authorities whereby people wishing to export goods to New Zealand are informed of requirements of the relevant import health standard that must be met before the goods can enter the country; and
• arranged for multilingual brochures and in-flight videos to be shown to arriving passengers informing them of their biosecurity obligations.

6.132
Following the outbreak of foot and mouth disease in the UK, MAF launched a Biosecurity Awareness programme called Stop Foot and Mouth by Word of Mouth. The programme involved the distribution of pamphlets and posters that explained what would happen in the event of an outbreak of the disease in New Zealand, and how the risk of an outbreak could be reduced. MAF also ran a television advertising campaign to warn against the dangers of the disease.

6.133
In addition, in September 2001 MAF launched a national publicly funded programme – Protect New Zealand – to raise awareness of biosecurity issues in general. This programme has involved television advertisements to raise general awareness and the launch of a web site informing people of biosecurity risks and measures to reduce these risks.

6.134
The Protect New Zealand programme also includes measures targeted at particular groups in the community – such as garden centres, people living near ports of entry, importers, and people working with cargo. For example, MAF distributed a fact sheet on the red imported fire ant to people thought most likely to detect the ant, such as people working in garden centres.

6.135
All port, airport, and devanning site14 staff play an important role in the detection of biosecurity risks by being alert to the presence of exotic pests and diseases as they perform their daily activities. The current targeted awareness campaign should include all such staff.

6.136
There is a danger that some high-risk groups may be missed by the current campaign. One example is people who keep, or people who visit relatives who keep, small numbers of their own pigs mainly fed on scraps. For instance, if meat infected with foot and mouth disease were illegally brought into New Zealand and fed to pigs as food waste (as is thought to have happened in the UK foot and mouth disease outbreak), an outbreak of foot and mouth disease could result.

6.137
Even so, feeding of food waste in this way to pigs is not regulated in New Zealand. Previous regulations were repealed in 1998, because they were found to be costly and difficult to administer, and were a low priority in the Biosecurity Programme. However, MAF has identified the feeding of illegally imported animal products to pigs as one of the most likely pathways by which foot and mouth disease could enter the country, and MAF is now reviewing the feeding of food waste to pigs.

Measuring the Effectiveness of Awareness Campaigns

6.138
In late-2001, MAF commissioned a survey to assess the public’s awareness of biosecurity issues with a view to:

• identifying risk areas that required more focused effort; and
• providing a benchmark for future campaigns.

6.139
The survey identified low levels of awareness. For example:

• about half the people surveyed did not know what “biosecurity” meant;
• only 60% of people recognised fruit and vegetables as risk goods, and only 6% identified camping and tramping gear as a risk to biosecurity; and
• one in four people were aware of the exotic pest and disease hotline (though this was better than before the UK foot and mouth outbreak, when the hotline was virtually unknown).

6.140
Furthermore, 90% of people said they would contact an official agency to isolate or destroy articles they suspected were risk goods.

6.141
The survey results indicated the need to intensify education and awareness of biosecurity issues, the risks, and their importance for the country. MAF has been given additional funding in 2002-03 to continue and strengthen the biosecurity awareness programme.

6.142
MAF has identified some groups of people – such as those from countries where foot and mouth disease is widespread and where English is not the first language – as being high-risk because of their relative lack of knowledge about biosecurity issues. A specific media campaign will target these groups.

6.143
In addition to the 2001 survey, MAF recently surveyed 800 residents in the West Auckland area – where it was carrying out spraying to eradicate the painted apple moth – to identify levels of awareness about the spray programme, views on aerial spraying, and any concerns the residents had. The survey indicated that the majority of residents supported the eradication programme, and that 64% had no concerns about it.

Enforcing Biosecurity Regulations

6.144
Two branches of MAF deal with enforcement of biosecurity regulations:

• The Quarantine Service Enforcement Group issues infringement notices (instant fines). In the 12 months since the infringement notice regime was introduced in June 2001, the group issued 9406 notices to people who failed to declare risk goods at airports across the country.
• The MAF Special Investigation Group has 22 staff who deal with MAF’s enforcement work relating to biosecurity, animal welfare and, prior to the establishment of the Food Safety Authority, food assurance. In the year to 30 June 2000, the group responded to 3000 incidents, of which 293 related to complaints under and breaches of the Biosecurity Act 1993.

6.145
In our 1994 report on Controls to Prevent the Entry of Fruit Fly into New Zealand we recommended that MAF seek authority to impose instant fines.15 We made this recommendation on the basis that the fines would act as a deterrent to people who might otherwise bring biosecurity risk goods into the country. A number of other countries such as Australia, Canada and the United States have similar arrangements.

6.146
MAF acted on our recommendation, but it took until June 2001 for instant fines to be introduced. MAF told us there were two reasons for the delay:

• Lack of resources to introduce the instant fines system.
• A legal issue, in that, until the Biosecurity Act was amended in May 1999, anyone who would have been issued with an instant fine would also have received a criminal conviction. This was felt to be unacceptable in situations where negligence (rather than a deliberate act) was the cause of an incoming passenger being found to possess undeclared risk goods.

6.147
As the legal issue was addressed in 1999, it appears that lack of resources was the primary reason for delaying the introduction of instant fines until June 2001.

6.148
From June 2001, passengers arriving who fail to declare quarantine items on their declaration forms are issued with an infringement notice and are liable to pay a fine of $200. The offence is one of strict liability, which means that anyone failing to declare items (whether they act deliberately or accidentally) is liable to the instant fine. The fine must be paid at the time the notice is issued or within 14 days of the date of issue.

6.149
If the failure to declare is deliberate, more serious penalties are also available under the Biosecurity Act. Where people are found deliberately attempting to smuggle prohibited goods, and where it can be proven that a false declaration has been made, a maximum penalty of up to five years in prison and $100,000 in fines can be imposed by the court.

6.150
MAF Biosecurity received an appropriation of $1.2 million and the Department for Courts received $0.7 million to introduce and operate the infringement notice regime. In mid-December 2001, the number of notices issued each week was 220 – although this rate was expected to drop as awareness of, and compliance with, biosecurity requirements increased.

6.151
It is difficult to measure the success of the infringement notice regime. MAF QS staff attempt to do so by monitoring the number of non-declared risk items seized. The number of items seized dropped by 3.5% in the first six months after instant fines were introduced.

6.152
MAF Biosecurity is currently undertaking a review of the infringement notice regime. The report is currently in draft form. The review is assessing whether the regime:

• improves compliance with biosecurity requirements;
• treats all incoming passengers fairly; and
• is given adequate resources.

6.153
Sea containers present a high-risk pathway through which several pests may have entered the country in recent years. There have been calls to introduce instant fines for failure to comply with biosecurity import requirements for containers. However, the Ministry of Justice has told MAF that to introduce such fines would be inappropriate, because importers have no control over the state of the containers they import, nor over the process by which they are packed.

6.154
There is a different financial incentive for importers to do whatever they can – such as by liaison with their agents overseas – to ensure that the containers they import are free from biosecurity risk material. The incentive is the requirement for importers to pay for inspection, and for any subsequent cleaning of containers found to be unacceptable.

Recommendation

6.155
MAF should ensure that its awareness campaigns include sufficient measures targeted at high-risk groups and locations.

Research

Key Finding

6.156
Priorities for and co-ordination of biosecurity-related research need to be better managed. We understand that this is to be addressed in the Biosecurity Strategy.

6.157
None of the seven case studies directly raised the subject of biosecurity research and we have not, therefore, examined it in depth. We discuss research only on the basis of the comments received by the Biosecurity Strategy Development Team.

6.158
Scientific research plays an essential role in managing biosecurity risks. Research is required to:

• continuously improve and update knowledge of biosecurity risks;
• develop more effective preventative measures and surveillance; and
• respond appropriately to incursions.

6.159
Information received by the Biosecurity Strategy Development Team has indicated that biosecurity-related research is dispersed across a number of Crown Research Institutes and needs to be better prioritised and coordinated.

6.160
In August 2000, MAF Biosecurity released a document outlining areas for biosecurity research, and the principles and objectives for biosecurityrelated research in New Zealand. It did not, however, prioritise the areas for research.

6.161
We understand that these issues will be addressed in the Biosecurity Strategy, due to be launched in 2003. In our view, the co-ordination and prioritisation of research might be an appropriate role for the Biosecurity Council.

Recommendation

6.162
Consideration should be given to the Biosecurity Council taking on the role of co-ordinating and prioritising biosecurity-related research. This task might best be undertaken by the Council’s Technical Forum.

11: A summary of the agreement is given in Appendix 2 on pages 120-121.

12: MAF’s process for conducting and applying risk anaylsis is set out in its Biosecurity Risk Analysis Policy Statement.

13: MAF Biosecurity Authority Border Management Group Annual Statistical Report 1993/94-2001/02.

14: A “devanning site” is where containers are taken to be unpacked.

15: Third Report for 1994, parliamentary paper B.29[94c], pages 87-108.

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