Part 4: Risk profiling of sea containers

4.1
In this Part, we discuss the Ministry’s identification of high-risk sea containers through risk profiling. We discuss:

• our expectations;
• risk profiling;
• the processes and procedures for setting risk profiles;
• collecting information and intelligence for risk profiling; and
• the Ministry’s responsiveness to new and emerging risks.

Our expectations

4.2
We expected that the Ministry would have robust systems and processes for effectively risk profiling imported sea containers. More specifically, we expected that:

• there would be a clear and consistent process for establishing risk profiles;
• all information required by the Sea Container Import Health Standard would be collected, analysed, and evaluated by the Ministry;
• the Ministry would collect, analyse, and evaluate intelligence relevant to sea container risk profiling; and
• risk profiling would be responsive to new and emerging risks.

What is risk profiling?

4.3
Container data analysts in the Border Monitoring Group in Biosecurity NZ undertake risk-profiling activities. These staff are responsible for identifying which sea containers are most likely to be contaminated with pests and diseases.

4.4
Sources of information used to set risk profiles include:

• the results of sea container inspections and checks;
• the results of sea container audits, and a survey of 11,000 sea containers undertaken in 2003;
• information from external intelligence;
• advice from specialist staff in Biosecurity NZ and Quarantine Service inspectors; and
• risk factors associated with specific sea containers (for example, port or country of origin, importer, exporter, customs broker, shipping company, type of goods carried, and quarantine declaration answers).

4.5
The Ministry uses this information to prepare risk profiles for identifying which sea containers are considered high risk. High-risk sea containers need to be inspected, fumigated, or cleaned once they arrive in the country.

4.6
When a sea container is imported into New Zealand, customs brokers or importers enter information (such as the origin of the container, the types of goods in the container, and the answers to the quarantine declaration questions) into CusMod through a “customs import entry”. If the information entered into CusMod matches a sea container risk profile, an alert is automatically raised about the sea container.

4.7
The alert results in a message being sent to the customs broker or importer and port company telling them, for example, that the container must be taken to the Quarantine Service inspection area. If no alerts are triggered, a message is sent to the customs broker or importer and port company saying that the sea container can be released from the port to a transitional facility, to be checked for contamination by an accredited person.

Processes and procedures for setting risk profiles

4.8
The processes for preparing, modifying, and implementing sea container risk profiles are set out in a draft procedure document. It gives guidance on:

• events that would trigger the creation or modification of sea container profiles (for example, a change in the overseas distribution of a significant pest or disease);
• the information to analyse on a regular basis (for example, weekly analysis of the sea containers where inspection or check results show that undeclared wood packaging was present);
• the identification of risk factors (for example, the sea container’s country of origin); and
• deciding whether to create a new profile or modify an existing risk profile.

4.9
The Ministry’s Risk Profile Review Group decides whether to introduce a new risk profile, or to change an existing one.

4.10
Establishing a new or modified risk profile involves analysing quantitative data on the risk of sea containers introducing a specific pest or disease, while taking into account factors such as the compliance costs involved in introducing the risk profile and the resource implications for the Ministry. This is part of the process because port facilities and inspectors could be overwhelmed by alerts on a large number of sea containers as the result of a new risk profile.

4.11
Once a risk profile is approved and in use, it is applied consistently and nationally to all sea containers. A sea container that meets high-risk criteria will be inspected regardless of the New Zealand port it is shipped to.

4.12
In addition to criteria for specific pests and diseases, risk profiles may also have a compliance intent. For example, the Ministry may set up a risk profile for a company or individual found to have supplied inaccurate information, and their containers may be inspected to check that their compliance has improved.

Collecting information and intelligence for risk profiling

4.13
The Sea Container Import Health Standard states that all imported sea containers must be covered by documentation that includes:

• the origin of the sea container (where it was packed), and the port at which the sea container was first loaded aboard a ship for transportation to New Zealand;
• the destination of the sea container once it arrives in the country (this must be a transitional facility); and
• a quarantine declaration.

4.14
However, the existing design of CusMod does not allow the electronic entry of all the biosecurity information required under the Sea Container Import Health Standard, and which could be used to identify which sea containers pose a high risk.

4.15
For example, information about the port at which a container was first loaded aboard a ship is not recorded electronically if the container has been moved from one ship to another during its journey to New Zealand. The customs broker or importer is only required to enter into CusMod the port where the goods were loaded onto the ship for the final leg of the journey – not the country the container originally came from. For biosecurity purposes, the country of origin is of greater importance. The country of origin is used, for example, to identify high-risk sea containers from far east Russia, which could be contaminated with Asian Gypsy Moth.

4.16
In addition, CusMod can only record “Y” for yes and “N” for no answers. The quarantine declaration asks how wood packaging has been treated, but this information cannot be recorded electronically in CusMod because it is not a yes or no answer.

4.17
Furthermore, despite it being a requirement of the Sea Container Import Health Standard, customs brokers or importers are not required to enter into CusMod the destination of a container once it arrives. They must indicate that a sea container is going to a transitional facility, but do not have to specify which transitional facility or where it is located. This has implications for ensuring compliance with the Sea Container Import Health Standard.

4.18
Also, Ministry staff have only a limited ability to electronically search biosecurity alerts within CusMod, because the computer system does not have the technical capability to support such searches. This means that the Ministry is unable to check that it is targeting all the sea containers it wants to.

4.19
The Ministry and the New Zealand Customs Service have discussed improving the electronic risk profiling system, but have not yet agreed the scope of such a project. We were told that the New Zealand Customs Service is reviewing its information technology work programme and will consult with the Ministry about priorities.

Manual risk profiling of empty sea containers

4.20
Empty sea containers may be contaminated, but there is no requirement for a customs broker or importer to enter any information about empty sea containers into CusMod.

4.21
Empty sea containers require a quarantine declaration, and there is a facility for customs brokers or importers to electronically enter the answers to the quarantine declaration questions, and the origin of the container, into CusMod if they choose to. However, for many empty sea containers this information is not provided electronically. If an electronic entry is made, the country of origin is often not given.

4.22
Because of this, the Quarantine Service must manually check the information provided by the shipping company to identify which empty sea containers it needs to inspect. This is time consuming. It would be more efficient if high-risk empty sea containers could be identified using the electronic risk-profiling system.

Accuracy of the quarantine declarations

4.23
For quarantine declarations to be useful in assessing risk, they need to accurately reflect the cleanliness of, and the type of packaging material used in, the sea containers they relate to.

4.24
The Ministry’s 2003 survey of more than 11,000 sea containers found that containers with cleaning certificates (a predecessor to quarantine declarations, intended to provide assurance that sea containers are free from internal contamination) did not have a lower contamination rate than sea containers without cleaning certificates. However, the survey found that the requirement for cleaning certificates may have been responsible for 80% of sea containers arriving in New Zealand free from internal contamination.

4.25
In 2005, about 4000 sea containers with quarantine declarations stating that the sea container was clean were found to be contaminated. In about 10,000 sea containers, wood packaging was found when the quarantine declaration stated that no wood packaging was used.

4.26
Between October 2005 and February 2006, the Ministry checked the paper and electronic copies of quarantine declarations for almost 1500 sea containers. The Ministry found that 1.4% were non-compliant. In three-quarters of these cases, the customs broker or importer made an incorrect electronic declaration (that the sea container had been inspected before it was packed and was found to be free of contamination, or that no high-risk packaging material was present), when the hard copy of the quarantine declaration stated otherwise.

4.27
The Ministry is yet to assess whether the information provided in quarantine declarations accurately reflects the cleanliness of, or presence (or not) of high-risk packaging material in, the sea containers they relate to. This aspect of the Audit Requirements document is intended to be implemented after July 2006 (see paragraphs 3.7-3.8).

4.28
Many of the industry stakeholders and Ministry staff we spoke to during our audit questioned the accuracy of quarantine declarations. They doubted whether the person signing the quarantine declaration overseas had seen the container, and if they could attest to its cleanliness, or whether wood packaging or other restricted packaging materials were present, with any certainty.

4.29
Staff in some parts of the Ministry consider that quarantine declarations are beneficial (for example, quarantine declarations raise awareness of the requirement to transport clean sea containers), and that these benefits will be greater when the fully implemented Audit Requirements document enables the Ministry to identify and penalise those importers making incorrect declarations. However, because of delays in implementing the Audit Requirements document, the Ministry currently has little assurance over the integrity of the answers to quarantine declaration questions – which are used for risk profiling.

4.30
In our view, it would help if the Ministry further analysed the usefulness of quarantine declarations as a risk-profiling tool. If quarantine declarations are found to be a valid tool for risk profiling, this should be communicated to internal and industry stakeholders.

Timeliness of results entered into QuanCargo

4.31
Contamination found during Quarantine Service inspections, or during checks of sea containers by accredited persons, is required to be entered into the Ministry’s computer system (QuanCargo). This information is critical for risk-profiling purposes, because it shows where contamination is found and enables the container data analysts to examine contamination trends over time – and then design risk profiles to target the containers most likely to be contaminated.

4.32
Quarantine Service staff are responsible for entering the results of their inspections into QuanCargo. Accredited persons are required to provide the Quarantine Service with the results of their sea container checks. Some accredited persons opt to enter the check results into QuanCargo through a website, and others send check results to the Quarantine Service in hard copy.

4.33
There is a backlog of hard copy check results to be entered into QuanCargo. To mitigate the risk that this information is not available for identifying high-risk sea containers, Biosecurity NZ has informed the Quarantine Service that inspection results showing contamination or wood packaging should receive priority for recording in QuanCargo. These type of results are vital for identifying high-risk sea containers.

4.34
We agree that entry of these type of results should be a priority. In our view, delays in entering this information into the computer system could result in delays in identifying and responding to new biosecurity risks.

Contamination found during fumigation or cleaning of sea containers

4.35
Some high-risk sea containers require decontamination (cleaning or fumigation). The Ministry uses contractors to clean and fumigate sea containers, but does not collect (or require the contractors to collect) any information about the nature or extent of contamination.

4.36
Recording the details of the nature of any contamination found during cleaning or fumigation would further inform the identification of high-risk sea containers. In our view, information on contamination needs to be recorded for risk profiling purposes.

Gathering biosecurity information and intelligence

4.37
Under the draft procedure document for sea container risk profiling (see paragraph 4.8), Biosecurity NZ is responsible for staying informed of changing pest distributions overseas, and outbreaks of serious pests and diseases in new areas, that may change the risk of pests or diseases entering the country in or on sea containers from those areas.

4.38
Biosecurity NZ regularly gathers information and intelligence on international biosecurity issues. It does this, for example, through internet alerts and information from overseas quarantine organisations and international agencies about emerging plant pests.

4.39
The Border Monitoring Group also receives information from specialist staff within Biosecurity NZ – for example, updates on the presence of invasive ant species in various countries. In addition, Biosecurity NZ is in contact with the Quarantine Service about contamination observed by its inspectors.

Monitoring and evaluating the information that informs risk profiles

4.40
Under the draft procedure document for sea container profiling, Biosecurity NZ is responsible for regularly monitoring the results of sea container inspections and checks. It does this to identify sea containers where contamination or disease agents have been found, and where the results of sea container inspections conflict with the statements made on the quarantine declaration.

4.41
The draft procedure document identifies the data queries to be regularly run in QuanCargo. Data queries are run to calculate the proportion of contaminated sea containers that fit various criteria. The Border Monitoring Group uses this information to assess changes over time, or overall contamination levels.

Responding to new and emerging risks

4.42
The Quarantine Service has observed significant contamination on sea containers that are not profiled as high risk, and has shared this information with Biosecurity NZ. This shows that the Quarantine Service and Biosecurity NZ are able to work together in managing the biosecurity risks associated with sea containers.

4.43
In one example, Quarantine Service staff noted unacceptable contamination on sea containers from Pacific Island countries. The Quarantine Service and Biosecurity NZ worked together to generate the statistics on contamination that were needed to determine the action required, and to structure increased inspections to get the best value for money. This exercise has had the added benefit of improving the cleanliness of sea containers from some Pacific Island ports. The increased costs to importers of having their sea containers inspected has encouraged them to try to clean the sea containers before they are shipped to New Zealand.

4.44
In another example, Quarantine Service staff noted that 2 sea containers that arrived at Tauranga were contaminated with Asian Gypsy Moth egg masses on the underside of the sea container. Information about the sea containers entered into CusMod showed they came from Hong Kong, which does not pose a risk for Asian Gypsy Moth. The sea containers were inspected only because they contained timber. If these sea containers had not contained timber, they would have had only a 4-sided inspection and the contamination could have gone unnoticed.

4.45
The sea containers had been transported from far east Russia to Hong Kong, and then moved to a second ship that transported them to New Zealand – this is referred to as “transhipping”. Because this information cannot be recorded electronically (see paragraph 4.15), the sea containers were not identified as high risk.

4.46
Once the origin of the transhipped sea containers was identified, Biosecurity NZ took steps to amend the risk profile. As well as a high-risk alert for sea containers from far east Russia, an alert is raised for any sea containers that contain goods from far east Russia irrespective of the port they come from. These containers receive a 6-sided inspection.