Part 5: Biosecurity clearance for high-risk sea containers

5.1
In this Part, we focus on the steps taken before the Ministry gives biosecurity clearance for high-risk sea containers. In particular, we discuss:

• our expectations;
• training and guidance for the biosecurity clearance (clearing) of sea containers;
• inspecting high-risk sea containers;
• decontamination of high-risk sea containers; and
• equivalent systems for clearing high-risk sea containers.

Our expectations

5.2
We expected that the Ministry would have targeted, comprehensive, and consistent procedures to ensure that high-risk sea containers are free from contamination. More specifically, we expected that:

• inspectors would be trained, supervised, and supported in their roles;
• clear and comprehensive guidance material would be available to inspectors;
• there would be a nationally consistent approach to dealing with high-risk sea containers;
• inspectors would report the results of their inspections accurately and consistently; and
• high-risk sea containers would be cleared in accordance with the Sea Container Import Health Standard.

Training and guidance for clearing sea containers

5.3
The Ministry recruits inspectors who hold a tertiary qualification (most often a degree in applied science, biology, or resource management). It takes up to one year to train new recruits, and training consists of both technical and on-the-job training.

5.4
The Ministry’s National Training Centre runs the technical training for new recruits. The technical training course teaches new recruits about insect and plant pests and diseases, and then assesses their knowledge. The course is based on unit standards of the New Zealand Qualifications Authority, and allows staff to work towards a Certificate in Biosecurity.

5.5
The National Training Centre also teaches communication skills, customer service, assertiveness training, health and safety considerations, and computer skills.

On-the-job training

5.6
On-the-job training is given by trainer-assessors (who are usually experienced Quarantine Officers with an interest in training), or senior staff and managers. Some trainer-assessors are employed in a full-time training role, while other worksites employ staff with trainer-assessor responsibilities as well as their regular role.

5.7
The staff member responsible for training at particular worksites must ensure that training for new recruits covers all aspects of clearing sea containers, including handling paperwork, risk assessment, and sea container inspections.

5.8
At all the Quarantine Service sites that clear sea containers, a buddy system is used to train new recruits how to inspect sea containers. The new recruit spends time with experienced inspectors to observe container inspections. For example, at the Auckland wharf worksite, new recruits learn from a range of experienced inspectors to ensure that they receive training to inspect sea containers from more than one person. In Wellington, 2 inspectors who are based permanently on the wharf observe new recruits.

5.9
Initially, new recruits are supervised, and their work is checked by experienced inspectors. While the timing varies from site to site, the new recruits are assigned to carry out inspections unassisted when they are considered competent by the worksite trainer, experienced inspector, or manager.

5.10
Some generic tools are used to assess the ability of staff to clear sea containers. The most common method of ensuring that new recruits understand a particular procedure is having them complete a written test (called a competency review).

Consistency of on-the-job training throughout the country

5.11
Not all worksites have specific staff appointed as trainer-assessors, or support from a trainer-assessor. For example, the Tauranga worksite (which handles the second biggest volume of sea containers after Auckland) does not have a trainer-assessor, and is not visited by a trainer-assessor from another region. In contrast, the Auckland wharf worksite employs 2 full-time trainer-assessors. Where worksites are not covered by a trainer-assessor, there may be no staff available to set training programmes, or with the ability to train new recruits and assess their competency.

5.12
There is also no consistency in on-the-job training between worksites. The content of the on-the-job training provided at each worksite is the responsibility of those in charge of training at each worksite. We consider that there would be benefit in a nationally consistent on-the-job training programme for use at all worksites.

5.13
In addition, staff at most Quarantine Service worksites are under significant pressure to handle their workload, and the need for training can be overtaken by the need to complete routine work. This is particularly so when the trainers are combining their training role with routine work.

Written guidance on what to do when contamination is found

5.14
The Ministry has operational guidelines for clearing sea containers – Process Procedure 32: Clearance of imported sea containers. This document gives effect to the Sea Container Import Health Standard.

5.15
We expected this document to provide written guidance for staff about what to do when contamination is found. It does not.

5.16
In our view, it would be beneficial, particularly for new recruits and those who work at airport and wharf worksites on a roster system, for there to be written guidance about the action to take when contamination is found on or in sea containers. We note that an updated draft of the operational guidelines contained some information about the action to be taken when contamination is found, but the draft was not in use at the time of our audit.

5.17
Several stakeholders we spoke to told us that it can be frustrating when decisions are not consistent from one inspector to another. For example, one inspector may require that a shipment of sea containers is fumigated, while another may not. We consider that, where possible, written guidance would improve the consistency of decision-making for inspectors (both regionally and nationally) on what action to take when contamination is found.

Changes to the Sea Container Import Health Standard and procedure documents

5.18
The main documents available to guide staff in clearing sea containers are the Sea Container Import Health Standard and Process Procedure 32: Clearance of imported sea containers. These documents are out of date.

5.19
The Quarantine Service advises staff, through a “standing order”, of any changes to procedures. Staff are informed at team meetings about any change in procedure given through a standing order, and each worksite employs a Quality Officer who is responsible for communicating changes to staff.

5.20
In June 2004, a standing order was issued that made a significant amendment to Process Procedure 32: Clearance of imported sea containers. It introduced a category of “medium risk” for sea containers that did not have a quarantine declaration, but were not from a country that is deemed to be a high risk for Asian Gypsy Moths or Giant African Snails. The required inspection changed from 6-sided to 4-sided. This change has not yet been reflected in Process Procedure 32: Clearance of imported sea containers or the Sea Container Import Health Standard.

5.21
In another example (see paragraphs 5.26-5.28), the period within which high-risk sea containers must be inspected has been amended from 8 to 14 hours. The Ministry has not updated the Sea Container Import Health Standard to reflect this change.

5.22
While staff have been informed of the changes to the process for clearing sea containers, it would be better practice if the amendments were reflected in one clear set of guidance material, rather than in memoranda, standing orders, e-mails, or oral instructions. When staff have many documents to refer to for guidance, it creates confusion and inconsistency, and there is a possibility that an incorrect process might be used.

Ongoing competency assessments for inspectors

5.23
Significant changes to procedures can and do occur. However, staff are not reassessed on their understanding of procedures once they have passed an initial competency assessment during their training.

5.24
In addition, inspectors are not regularly assessed to ensure that they are carrying out their inspections in keeping with the latest procedure. We note that this type of assessment is being introduced for staff at the Auckland passenger terminal. In our view, it may be useful for this to be introduced at all relevant worksites.

5.25
We note that Quarantine Service staff are subject to review or audit if they make a significant mistake.

Inspecting high-risk sea containers

5.26
The Sea Container Import Health Standard specifies that all high-risk sea containers should be brought to a Quarantine Service inspection area as soon as practicable, but in all cases within 8 hours of being unloaded from the ship. This deadline was put in place to minimise the risk of pests moving off a container before it underwent a 6-sided inspection.

5.27
This deadline was difficult to implement, because it meant that some sea containers would have to be inspected at night, when there was neither adequate light nor inspectors on duty. In December 2003, the Ministry approved a 6-hour extension for undertaking 6-sided inspections of high-risk sea containers, with the exception of containers that might carry highly mobile pests (for example, invasive ant species).

5.28
Process Procedure 32: Clearance of imported sea containers was amended in March 2004, and confirmed that high-risk sea containers should be inspected within 14 hours of being unloaded from the ship. However, no alternative arrangements were made for containers that might carry highly mobile pests. Some sea containers identified as high risk come from countries where invasive ant species are present.

5.29
We expected that sea containers considered high risk for external contaminants would be inspected within the specified deadlines. Most sea containers (69%) are imported into Auckland and Tauranga. In Auckland, high-risk sea containers are usually inspected within 14 hours, but there are times when this target cannot be met because of competing work (for example, giving biosecurity clearance for fresh produce, used cars, and machinery). In Tauranga, the 14-hour period is frequently exceeded, because several hundred high-risk sea containers can arrive on a single ship.

5.30
We were told that, in Tauranga, it takes an hour to inspect about 30 empty sea containers, or 10 full sea containers. At this rate, it can take 2-3 days to inspect shipments of several hundred sea containers. During this time, pests could move off the container. There are no specific mechanisms for preventing these pests from moving to an area where they could establish a nest.

5.31
If it is impossible for sea containers to be inspected within the specified deadlines, then arrangements need to be made to mitigate the risk of pests moving off the sea containers and becoming established.

5.32
There is some surveillance for ants at ports – baits are laid and the ants feeding on them are collected and identified. This surveillance detected a nest of Red Imported Fire Ants at the Port of Napier (the nest has since been eradicated). We were told that this ant nest was almost certainly introduced through sea containers.

Reporting inspection results

5.33
Inspectors record the results of their inspections on a paper check list, and enter the results of the inspection into QuanCargo when they return to their worksite. It would be more efficient for staff to have electronic equipment for recording the results of inspections while in the field. This would reduce the need for duplicate recording of results.

5.34
A draft Information Solutions Strategic Plan for the Quarantine Service has been written. The strategy recognises the need to significantly change the way the Quarantine Service works. This includes using mobile technologies and (close to) real time interaction with computer systems wherever the inspector is working, and for data to be recorded once, accurately, and in a timely manner.

Decontaminating high-risk sea containers

5.35
One of the options included in the Sea Container Import Health Standard for dealing with high-risk sea containers is that they are fumigated with methyl bromide at 48gms/m³ for 24 hours at a temperature of at least 10^oC. Very few sea containers are fumigated.

5.36
In addition, all quarantine risk goods (including sea containers) that have signs of live insect infestation must be treated on entry to New Zealand (some potentially high-risk goods are treated offshore). Treatment options include fumigation by one of several toxic chemicals.

5.37
We expected that the Ministry would have processes in place to provide assurance that fumigations are effective in killing pests on high-risk sea containers. Biosecurity NZ has produced standards that specify the requirements to be met by fumigation operators working on behalf of the Ministry, and standards specifying technical fumigation rates.

5.38
The Quarantine Service has produced Process Procedure 38: Quarantine Treatments, which covers:

• the approval of fumigation operators (who are contractors);
• methods for determining the effectiveness of fumigation;
• the monitoring, supervising, and auditing of fumigation operators; and
• the requirements for fumigation facilities.

Testing whether fumigation is effective

5.39
Process Procedure 38: Quarantine Treatments states that it is important that each quarantine treatment (fumigation) carried out is measured in some way to ascertain whether the treatment has successfully achieved the desired outcome (that is, the pests are killed). Methods to detect whether fumigation has been successful include the use of control insects, indicator chemicals, monitoring equipment, re-inspection, post-fumigation testing, and observation. The procedure document does not specify which methods should be used, or under what circumstances.

5.40
Fumigation operators are subject to regular monitoring and audit by either Ministry staff or an Independent Verification Agency. This monitoring or audit checks that the fumigation operator is carrying out fumigation in accordance with the Ministry’s standards.

5.41
During our audit, several people raised concerns about the level of assurance that the Ministry receives about the effectiveness of treatments, and the current monitoring of fumigation operators. In particular, there were concerns about the:

• Effectiveness of the audit process to identify non-compliant fumigation practices – the audit practices check only if the fumigation has been set up appropriately and that gas was present, not whether it was effective in killing pests. Even when fumigation has been set up appropriately and gas was present, it may not be effective in killing pests if, for example, the gas leaks from the container.
• Limited Ministry resources available for fumigation audits – the Quarantine Service currently undertakes most of the fumigation audits, but has not been able to meet the required audit interval for fumigation operators in many instances. There has been a lack of trained staff, and site managers have been reluctant to provide resources for fumigation audits when their ability to undertake core activities is already strained.

5.42
In our view, improvements to fumigation processes could provide greater assurance that fumigation is effective in killing pests. For example, the United Nations advocates that gas concentration readings are taken from 3 points of the container. The Australian Quarantine Inspection Service requires the air-tightness of sea containers to be verified, or gas concentration readings to be taken.

5.43
The costs associated with Ministry staff carrying out audits of fumigation operators are recovered from fumigation operators. We see value in the Ministry continuing to be involved in audits of fumigation operators to ensure high auditing standards, and to reduce the possibility that private sector auditors might form too close a relationship with the fumigation operators to audit them thoroughly. Therefore, the Ministry needs to give priority to maintaining effective levels of auditing of fumigation operators.

Monitoring decontamination facilities

5.44
The Sea Container Import Health Standard also makes provision for high-risk sea containers to be subject to a “decontamination process” (usually cleaning).

5.45
About 180,000 empty sea containers were imported into the country in 2005. About 15,000 of these were from countries considered high risk for Giant African Snails. As mentioned in paragraphs 4.20-4.22, empty sea containers are not subject to electronic risk profiling, but many are subject to cleaning at a decontamination facility.

5.46
In 2005, the Ministry commissioned a review of the cleaning practices used by decontamination facilities for imported empty sea containers. The review was commissioned because the Ministry was concerned about the management of empty sea containers. In our view, the concerns were well founded.

5.47
The review found that:

• The Ministry could not readily identify the number of empty sea containers being taken off ships or where those sea containers would be cleaned. There is no single electronic point of collection or co-ordination of information relating to the movements and decontamination of empty sea containers.
• A complete and up-to-date list of decontamination facilities did not appear to exist within the Ministry.
• The cleaning process was designed to manage animal disease risks, not live insect contamination.
• The systems for establishing “off wharf” decontamination facilities lacked a robust assessment of the risks, establishment of controls, and measurement of their effectiveness.
• There was no stipulation of the period within which empty sea containers should be decontaminated.
• Monitoring frequency and practice varied widely between Quarantine Service sites. Responsibilities for monitoring were not clear, and in the 3 regions considered in the review staff were not routinely monitoring the standard of decontamination facilities.

5.48
Some of the practices used by decontamination facilities that were identified in the review posed potential risks to New Zealand’s biosecurity. For example, sea containers were stored near seed and fertiliser storage areas (which could result in the transfer of pests to rural areas) or near vegetation (which provides a potential habitat for pests to become established).

5.49
In our view, the issues raised in the review required urgent action. The Ministry has suspended one decontamination facility, and changes have been made at another. The Ministry also intends to clarify roles and responsibilities for carrying out decontamination facility audits, and to address national consistency issues.

Equivalent systems for clearing high-risk sea containers

5.50
The Sea Container Import Health Standard allows for equivalent systems to manage biosecurity risks. Equivalent systems provide a means for the Ministry and industry to work together to achieve business efficiency under the Sea Container Import Health Standard. Other benefits can be the management of biosecurity risks offshore (therefore preventing potential pests from entering the country), and reducing the need for the Ministry to be involved in inspecting sea containers.

5.51
We looked at 2 examples of equivalent systems:

• Empty sea containers from countries considered a high risk for Giant African Snails were being cleaned and inspected offshore before being shipped to New Zealand. Both the Ministry and the importer supported this equivalent system, because the biosecurity risks were managed offshore, and it was more cost-effective for the importer.
• Sea containers are transported from the port of entry to inland container yards (known as inland ports). The example we looked at facilitated the transport, by rail to South Auckland, of about 80% of the sea containers arriving at the Port of Tauranga.

5.52
Where equivalent systems are set up, we consider it is vital that the Ministry regularly monitors whether the system is adequately managing the biosecurity risks. Equivalent systems can potentially allow pests and diseases into the country in a way that would not usually be a risk – for example, where sea containers are transported through rural areas, there is a risk that pests could escape into farmland.

5.53
In the first example in paragraph 5.51, the Ministry was monitoring the cleanliness of the empty sea containers on arrival into New Zealand. This equivalent system has been withdrawn because the sea containers were not cleaned to an acceptable standard.

5.54
In the second example in paragraph 5.51, the Ministry requires that all sea containers undergo 4-sided checks before they are transported to Auckland. The Ministry carries out regular audits of these checks. We were told by both the logistics company operating this equivalent system and the Ministry that contamination is regularly found during the checks on the sea containers.

Procedures for setting up equivalent systems

5.55
There is no set process for preparing equivalent systems, and no baseline against which to assess whether a proposed equivalent system will manage biosecurity risks to an appropriate or equivalent level.

5.56
One operator of an equivalent system considered that it would have been useful if guidance on setting up an equivalent system had been available. It might also be helpful if the Ministry provided a point of contact for any stakeholders looking to set up an equivalent system.

5.57
Despite the lack of formal guidance available, the Ministry has worked collaboratively with industry to accommodate equivalent systems – even in circumstances where the main benefit of the equivalent system is to industry stakeholders. Setting up an equivalent system can take considerable time and effort for Ministry staff and the importers, port company, or logistics company.