Chapter 5
The proposed importation of fresh ginger from Fiji
5.1
As mentioned in Chapter 1, the terms of reference for this inquiry
required the committee to examine, amongst other things, the scientific basis
on which the Import Risk Analysis (IRA) for the importation of fresh ginger has
been developed. While the committee focussed on the Provisional Final Import
Risk Assessment (PFIRA) during much of its inquiry, the final IRA was published
in late January 2013, and is therefore used as the main reference in this
chapter.
5.2
The ginger industry is a very important industry to Australia, even
though it is small when compared to a range of other agricultural crops.
Therefore, the proposed importation to Australia of fresh ginger from Fiji
could have a major impact.
5.3
The central issue for this inquiry has been to examine whether the IRA
for fresh ginger from Fiji is adequate. This chapter covers the committee's
examination and findings regarding the IRA process undertaken, and examines
whether the consequences, likelihoods and risks have been appropriately
estimated for the importation of fresh ginger from Fiji.
Australia's ginger industry
5.4
Ginger is thought to have originated in the southern Asian and Indian
regions and was first grown commercially in Australia in South East Queensland
in the early 1900s, mainly for the domestic fresh market. At that time, all
processed ginger was imported from China. Imports of processed product were
disrupted during World War II and, consequently, the first processing
facility was built in Buderim in 1941. Ginger is now grown in areas in and
around Caboolture, Nambour and Gympie.[1]
5.5
The Queensland Department of Agriculture, Fisheries and Forestry (DAFF
Queensland) advises on its website that growing ginger requires relatively
flat, well drained soils that are free of rocks, sunny aspects with wind
protection, high-quality water and particular chemical conditions in the soil.
The website also advises that it is important that growers spell the land for
two years between crops to control nematodes.[2]
5.6
Australia is a relative small producer of ginger, contributing less than
one per cent of global production. The global market is dominated by China and
India, with Indonesia, Nepal and Nigeria also producing significant crops.
Production of ginger is both labour and capital intensive. Of the 8000 tonnes
produced annually in Australia, 45 per cent is supplied to the domestic
fresh market, with much of the remainder destined for processing:
Queensland Primary Industries and Fisheries (QPIF) estimates
the current farm-gate value of the Australian ginger industry at approximately
A$15.6 million. Ginger is also used as a vital ingredient in a wide range
of semi-processed products for the food manufacturing sector and processed
products for the retail sector. The value of these products, in which
Australian ginger is a key ingredient, is estimated at over A$80 million.
The Sunshine Coast region produces approximately 6075 tonnes
of ginger annually. The Wide Bay-Burnett [the coastal and hinterland areas
between Caloundra and Gladstone] is the second largest growing region, with
production estimated at 1837 tonnes per year.
Buderim Ginger is the largest ginger processor in Australia,
taking over 95% (4200 tonnes) of the ginger produced for processing.[3]
5.7
Ginger is also exported from Australia in both raw and semi-processed
forms to destinations including Japan, the United States, New Zealand and the
United Kingdom. As with many other crops, the prices for fresh ginger vary with
supply, demand, seasonal factors, product quality and levels of promotional
activity.
Growers indicated that during the 2006-2007 season the
average price received from wholesalers purchasing fresh ginger was between
$2.50 and $4.00 per kilogram, but prices have spiked as high as $12.00 and
dropped as low as $1.50 due to fluctuations in supply capacity.[4]
5.8
At the inquiry hearing in October 2012, Mr Ashley Gill informed the
committee that retail prices range between $2.50 for early-harvest ginger and
$20 for old ginger.[5]
Pests and diseases
Previous outbreaks
5.9
The committee received evidence about previous outbreaks of pests and
diseases in Australia's ginger industry during the inquiry. Buderim Ginger
informed the committee, for example, that the pythium outbreak had
significantly affected its processing operations:
...since the outbreak of pythium in Australia in 2010, the
ginger processed by Buderim has been sourced from within Australia, from its
own operations in Fiji and from third party suppliers in China and other parts
of Southeast Asia. [6]
5.10
Buderim Ginger added that:
Any inadvertent introduction of other pest varieties into the
Australian growing region that severely impacted the supply of ginger available
would have the capacity to significantly disrupt these arrangements and adversely
impact on Buderim's profitability and threaten the viability of the Australian
ginger industry.[7]
5.11
The committee was also informed of a previous outbreak of bacterial wilt
that was devastating for the industry. Templeton Ginger's submission noted that
the company had seen:
...the introduction of Bacterial Wilt Biotype IV which almost
wiped out the industry in the 1960's. Bacterial Wilt Biotype IV can start in a
small corner of a 2Ha field and spread across it in 3-5 days causing 100% loss.
The only way to combat this was to quarantine any infected fields and either
leave the infected equipment there or steam sterilize it thoroughly so as not
to shift any infected soil particles elsewhere.[8]
Current
pests and diseases
5.12
The ginger IRA identified over 60 pests for fresh ginger in Fiji,
including beetles, hemiptera, butterflies, moths, nematodes, bacteria and
viruses.[9]
Of the 60 pests, nine were identified as requiring a pest risk assessment on
the basis of:
-
their potential to be imported;
-
whether they were already present within Australia;
-
the potential for them to establish and spread; and
-
the potential for economic consequences.
5.13
These nine pests are shown in Table 5.1. Two of these nine pests – yam
scale and burrowing nematode – required risk mitigation measures in order to
fall below Australia's ALOP.
Table 5.1—Restricted and unrestricted[10]
risk assessments for quarantine pests for fresh ginger from Fiji
Pest
|
Common
name
|
Unrestricted
risk assessment
|
Restricted
risk
|
Arthropods
|
|
|
Elytroteinus
subtruncatus
|
Fiji
ginger weevil
|
Negligible
risk
|
|
Aspidiella
hartii
|
Yam
scale[11]
|
Low
risk#
|
Very
low risk
|
Nematodes
|
|
|
Radopholus
similis – putative intraspecific ginger variant
|
Burrowing
nematode[12]
|
Low
risk#
|
Very
low risk
|
Discocriconemella
discolabia
|
Ring
nematodes
|
Negligible
risk
|
|
Mesocriconema
denoudeni
|
Helicotylenchus
egyptiensis
|
Spiral
nematodes
|
Very
low risk
|
|
Helicotylenchus
indicus
|
Helicotylenchus
mucronatus
|
Sphaeronema
sp.
|
Cystoid
nematode
|
Very
low risk
|
|
Source: Department of
Agriculture, Fisheries and Forestry, Provisional final import risk analysis
report for fresh ginger from Fiji, August 2012, pp 21 and 54–56.
5.14
The draft IRA for fresh ginger from Fiji identified burrowing nematode as
a pest that is present in Fiji. However, at that time it was concluded that a
pest risk assessment was not required as burrowing nematodes had been recorded
as being present in Australia – in Queensland, the Northern Territory and
Western Australia.[13]
5.15
The committee notes that the presence of a Fijian variant of the burrowing
nematode was brought to DA's attention by the ginger industry. The ginger IRA
states that:
Information was provided by the Australian Ginger Industry
Association (AGIA) and Department of Agriculture Fisheries and Forestry
Queensland (DAFF Queensland) researchers through stakeholder submissions on the
draft IRA report and subsequent consultation that a new, yet to be described,
intraspecific variant of burrowing nematode, (Radopholus similis), is
likely present in Fiji.
The characteristics of this putative intraspecific ginger
variant, as described by the DAFF Queensland researchers, are: 1) The Fijian
variant is highly pathogenic on ginger, while banana is a poor host. 2). In
contrast, the Australian variant is highly pathogenic on banana, while ginger
is a poor host (Mike Smith, Jenny Cobon, DAFF Queensland, personal
communication).[14]
The import risk analysis for fresh ginger from Fiji
5.16
The proposed importation of fresh ginger from Fiji has been a long-standing
issue, with a formal request from Fiji received in 2003. Fiji currently exports
fresh mature ginger to a number of countries including New Zealand, Canada and
Hawaii for direct retail in supermarkets. The DA Biosecurity report on its field
visit to Fiji in 2007 noted that:
Fiji previously exported fresh mature ginger to the United
States but the export program has since ceased due to a reduction in prices
following China's access for ginger to the United States. This has further
elevated the importance of the access for baby ginger to Australia for the Fiji
Government.
Fresh mature ginger for further processing is currently
permitted from Fiji to Australia subject to specific import requirements. The
import requirements stipulate that the imported fresh mature ginger is to be
processed commercially in an AQIS Approved Premises.
Fiji also exports processed ginger (preserved in sugar,
preserved in brine, and ginger powder etc) to Australia. [15]
5.17
Table 5.2 below provides a timeline of events in relation to the Fijian
ginger IRA.
Table 5.2—Timeline of Fijian ginger IRA
November 2003
|
Biosecurity Australia[16]
received a formal request from Fiji, seeking market access for fresh ginger
to Australia.[17]
|
2004 and 2007
|
Further information was provided on the Fiji ginger
production system, land preparation, pest management, pre- and post-harvest
handling.[18]
|
23 – 29 September 2007
|
DA Biosecurity officers observed ginger production,
cultivation and harvesting practices in Fiji.[19]
|
2008
|
The Import Market Access Advisory Group (IMAAG)
allocated priority A to the IRA for fresh ginger from Fiji.[20]
|
2008
|
DA Biosecurity work program adjusted to include Fiji
ginger.[21]
|
13 August 2010
|
Commencement of the IRA for the import of ginger
from Fiji.
|
September 2011
|
DA Biosecurity met with the Australian Ginger
Industry Association to discuss the IRA process and the pests of quarantine
concern.[22]
|
March 2012
|
The IMAAG advised DA that ginger from Fiji was
Priority A.[23]
|
16 April 2012
|
Release of the draft IRA for the importation of
fresh ginger from Fiji.
|
25 May 2012
|
Field trip report on ginger production and
processing in Fiji, made available to industry.[24]
|
10 August 2012
|
PFIRA report released by DA.
|
10 September 2012
|
No appeals were received by the IRA Appeals Panel during
the regulated timeframe. The Chair has confirmed that no IRAAP will be
convened.[25]
|
22 January 2013
|
Final IRA for fresh ginger from Fiji released.[26]
|
Source: Department
of Agriculture, Fisheries and Forestry, www.daff.gov.au/ba/ira/current-plant/ginger_from_fiji,
(accessed 10 December 2012).
Reasons for
the IRA
5.18
In advancing the IRA process, the Department of Agriculture (DA) has
undertaken some background work including a field trip to Fiji. In 2008, the
request was allocated 'priority A' by IMAAG and work on the request commenced
under the department's work program. DA advised the committee that the
importation of fresh ginger from Fiji was discussed a number of times during
bilateral discussions and official government-to-government representations.[27]
5.19
DA further advised that it provided the following written advice to
IMAAG for its consideration of the priority for fresh ginger imports from Fiji.
DA Biosecurity recommended that Fiji be allocated priority A:
Top priority for Fiji. Preliminary pest list sent to Fiji for
comment in 2004. Main activity for AusAID-funded IRA officer for the South
Pacific.[28]
Committee comment
5.20
It is unclear to the committee why importing fresh ginger from Fiji was
the main activity for Commonwealth-funded AusAID officer. It is also unclear to
the committee why the importation of fresh ginger from Fiji was given priority
A status, particularly when, in response to questions from this committee, DA
Biosecurity confirmed that there is no avenue for a formal appeal of an IMAAG
decision to assign a specific priority.[29]
5.21
The confirmation by DA Biosecurity that Australian taxpayers have been
funding an AusAID IRA officer to assist with the Fijian ginger import proposal
(amongst others) is troubling, given that DA Biosecurity has steadfastly
refused to commission research that would clarify the level of risk posed by
the Fijian burrowing nematode variant to the Australian ginger industry. It
would appear that the Government has been providing funding to assist
importers, while denying the Australian ginger industry appropriate access to
the resources needed to properly determine the risks arising from importing
fresh ginger from Fiji.
5.22
The committee is concerned by the lack of transparency and opportunity
for review of the decisions made by IMAAG. The committee therefore recommends
that the full reasons and relevant supporting documentation for IMAAG's decisions
should be made publicly available.
Recommendation 12
5.23
The committee recommends that the full reasons and relevant supporting
documentation of the Import Market Access Advisory Group should be made
publicly available within 30 days of a decision being taken.
Risk and consequences of importation
5.24
Industry witnesses provided the committee with evidence about the risks
and consequences of the importation of fresh ginger for Australian industry. As
noted above, ginger crops have already been adversely affected by pythium and
bacterial wilt. The industry's concerns centred on any inadvertent importation
of a pest which could threaten the viability of the Australian ginger industry.
5.25
The committee was particularly interested in the issues surrounding
pests such as nematodes and their propensity to spread and the substantial crop
loss of up to 70 per cent reported in some instances in Fiji.[30]
Dr Graham Stirling, informed the committee how easily other nematodes had
spread and impacted farming across wide areas:
We have a major nematode problem in our cereal industry. In
1965 there was a paper published that showed this nematode occurred on five
farms within 20 kilometres of Toowoomba—that is 1965. Now, 45 or 50 years
later, it is in every field just about in Queensland, New South Wales and
everywhere. Once you introduce it, it gets taken around in soil to other
places, and so what might start off as a minor problem because of soil
transmission can finish up everywhere.[31]
Unrestricted
risk assessment for quarantine pests for fresh ginger from Fiji
5.26
DA Biosecurity explained how the risk analysis process works:
The risk analysis looks at the unconstrained risk: what would
happen if you just allowed this into the country? Then we look at what we can
do to prevent this happening, to reduce the risk of this happening to a very
low level but not zero. Those are the measures we put in place. This is the
process. It is a very repetitive and simple process.[32]
5.27
As discussed previously in this report, DA Biosecurity uses a risk
management process to derive the unconstrained risk of an event, such as an
outbreak of a particular disease or pest. A key feature of the process is the
use of a risk estimation matrix (REM) to combine the likelihood and consequences
of an event to obtain a risk assessment.
5.28
The pests considered in the ginger IRA and the unrestricted and
restricted risk assessments for fresh ginger from Fiji are listed in Table 5.1.
The 'low' unrestricted risk assessed for yam scale and burrowing nematode
exceeded Australia's ALOP of 'very low'. The ginger IRA includes additional
phytosanitary measures (discussed later in this chapter), which DA argued are
effective in reducing these 'low' risks to 'very low'.[33]
5.29
The AGIA was not convinced that the overall risk estimate was correct
for several pests, based on specific research it had conducted in relation to
one of the pests – the burrowing nematode:
Given that several pests could be potentially imported and
could wipe out the industry, the risks presented by those pests should not be
assessed as any lower than moderate. Independent advice in relation to the risk
matrix should be conducted. Industry has shown this test case with the evidence
provided through Radopholus similis. This potentially could be the case
for other pests and diseases. We believe it is up to the Fijian ginger industry
to conduct further research to really examine their own industry and their own
pests.[34]
Assessment
of likelihood of entry, establishment and spread
5.30
The ginger IRA sets out how the overall likelihood of pest entry,
establishment and spread is estimated using the likelihood of importation,
distribution, establishment and spread individually and then combining those
likelihoods using a set of matrix rules.[35]
This section examines those assessments in some detail for the two pests that
did not initially achieve Australia's ALOP: yam scale; and Fijian burrowing nematode
variant.
Yam scale
5.31
In relation to yam scale, the likelihoods of entry establishment and
spread are as follows:
Table 5.3—Likelihoods of entry, establishment and spread
by yam scale
Entry – Importation
|
High
|
Entry – Distribution
|
High
|
Entry – Overall
|
High
|
Establishment
|
High
|
Spread
|
High
|
Overall entry, establishment and spread
|
High
|
Source: Department of
Agriculture, Fisheries and Forestry, Final import risk analysis report for
fresh ginger from Fiji, 22 January 2013, pp 54–55.
5.32
The ginger IRA states that, in relation to yam scale:
The major risk from Aspidiella hartii is the
importation of live scales on ginger rhizomes that are subsequently diverted
from their intended use for human consumption and used as planting material.
Infested rhizomes could also be discarded in the vicinity of suitable host
plants, although most life stages are immobile and unlikely to establish.[36]
5.33
The risk management measure proposed is pre-export phytosanitary
inspections by the Biosecurity Authority of Fiji (BAF) to ensure that infested
ginger is identified and subjected to appropriate remedial action.[37]
This action is aimed at achieving Australia's ALOP of very low risk.
5.34
The committee heard evidence, however, about the ineffectiveness of
visual inspections for the presence of yam scale:
Yam scale is another thing that can decrease yields on ginger
and leave unmarketable parcels of ginger. The yam scale can get that small that
it is undetectable by the eye. So I do not know how having Biosecurity Fiji
just physically inspect for yam scale is going to stop the yam scale coming
into the country.[38]
5.35
Concerns were also raised about the proposed arrangements in relation to
fumigation treatments – specifically, whether they were compulsory:
Page 55 of the Provisional Final IRA also notes fumigation
for Burrowing Nematode (ginger variant) will also be effective for Yam Scale.
This is correct if it was compulsory, but it is not so how can this statement
[be] made?[39]
Recommendation 13
5.36
The committee recommends that the Department of Agriculture review its
assessment of the likelihood of entry, establishment and spread of yam scale.
If a risk above Australia's ALOP were to emerge from the review, then the
committee expects stronger risk management measures would be required. If such
risk management measures were not sufficient to reduce the risk to Australia's
ALOP, then imports of Fijian ginger to Australia should not be permitted.
Burrowing nematode
5.37
Burrowing nematode is the second pest with an unrestricted risk above
the ALOP. The likelihood, entry, establishment and spread set out in the ginger
IRA in relation to this pest are as follows:
Table 5.4—Likelihoods of
entry, establishment and spread by burrowing nematode
Entry – Importation
|
Medium
|
Entry – Distribution
|
High
|
Entry – Overall
|
Medium
|
Establishment
|
High
|
Spread
|
High
|
Overall entry, establishment and spread
|
Medium
|
Source: Department of
Agriculture, Fisheries and Forestry, Final import risk analysis report for
fresh ginger from Fiji, 22 January 2013, pp 54–55.
5.38
The ginger IRA states that in relation to the burrowing nematode:
The major risk from Radopholus similis – putative
intraspecific ginger variant is the importation of live nematodes on ginger
rhizomes that are subsequently diverted from their intended use for human
consumption and used as planting material. Infested rhizomes could also be
discarded in the vicinity of suitable host plants. The use of clean seed,
application of manure and rotation of crops have been shown to reduce burrowing
nematode populations to undetectable levels (Turaganivalu et al. 2012).[40]
5.39
Combining the 'medium' probability of entry, establishment and spread,
with the 'low' consequence for burrowing nematode results in the IRA with the unrestricted
risk of 'low'. DA Biosecurity informed the committee that:
We have said that there is a risk. The unrestricted risk
would be too high. We are, therefore, going to place measures upon the
introduction of ginger from Fiji into Australia and those measures, as has been
indicated in reports and today in evidence, will work if applied appropriately.
We will require it to be applied appropriately. This is standard process. We do
it over and over again.[41]
5.40
Industry stakeholders disputed DA Biosecurity's view and provided the
committee with evidence to suggest that:
-
there is potential for nematodes to reside in remnant soil;
-
nematodes have the capacity to reside within ginger and remain
undetectable and possibly untreatable;
-
there is the potential for burrowing nematode to spread from residential
use ginger to farms;[42]
and
-
the Fijian burrowing nematode variant has greater pathogenicity.
Soil
contamination
5.41
One mitigation measure proposed by DA Biosecurity involved inspections
to confirm that ginger is 'visually free of soil'.[43]
Industry stakeholders noted, however, that it was very difficult to clean all
the soil off ginger because of its complex shape. Mr Shane Templeton of
Templeton Ginger stated that:
When we wash ginger to send to the fresh markets, we have
always got those little crevices that it is very hard to get the soil out of. [44]
5.42
Concerns about the ineffectiveness of visual inspections were also
raised by Peasley Horticultural Service:
The PFIRA also minimises the potential risk of soil as a
vector of a range of pests. It is well understood that soil is a hitchhiker on
a wide range of commodities entering Australia however the PFIRA fails to
concede that the ginger rhizome is not a smooth conventional shape and contains
crevices which commonly trap soil clods which cannot be effectively removed by
conventional high pressure water treatment.[45]
5.43
The Botanical Food Company outlined its experience in trying to ensure
ginger is free from soil and argued that:
Given BFC's considerable experience in this field, BFC
totally supports the findings of the AGIA submission Appendix 1 June 2012: Due
to the morphology of the ginger rhizome it is not possible to remove all traces
of soil from ginger destined for the fresh market in a commercial operation.
In fact BFC experience has proven 100% removal of soil and
other potential contaminants can only be removed from fresh ginger by slicing,
sorting and sanitising.[46]
5.44
The committee was also told that tiny amounts of remnant soil could
contain large numbers of nematodes:
Ginger has a complex morphology with lots of crevices
allowing soil to hide in corners and between rhizomes. A study conducted by
Deedi showed soil less than 1 gram in weight still contained up to 17
nematodes. Free from soil must be just that, free from soil. A few grains of
soil is all it would take to introduce Burrowing Nematode. Otherwise other risk
mitigation measures are required.[47]
5.45
Given that nematodes can remain in small amounts of soil, industry stakeholders
have ongoing concerns about how the issue of soil contamination will be managed
and exactly how much soil would be allowed. The AGIA told the committee that:
Throughout the IRA process, the issue of soil has been
debated and to this point the goal posts consistently vary when the topic is
discussed. Australia has a zero tolerance of soil. From documented minutes
between industry and DAFF Biosecurity, we are constantly told that perhaps a
cup of soil will be allowed. It is then up to AQIS to deal with it and make a
line call decision if the product does not meet its import guidelines.[48]
5.46
The AGIA further questioned information provided by DA Biosecurity
regarding the amount of soil that leads to the introduction of burrowing
nematodes:
Dr Colin Grant stated in 'Official Committee Hansard, Senate,
Rural and Regional Affairs and Transport Legislation Committee Estimates
Monday, 21 May 2012' that 'A few grains of soil will not be a medium sufficient
to maintain nematodes. You would have to have clumps of soil—fairly small
clumps, admittedly'. However, data supplied in the AGIA's response to the Draft
IRA (pp. 12–13 and Table A.1 on p. 66) show that even extremely small amounts
of soil can harbour nematodes. Up to 17 nematodes were extracted from each of
10 samples of less than 1 gram of soil hidden in crevices on ginger rhizomes.[49]
Burrowing
nematode present inside ginger
5.47
Industry stakeholders told the committee that, even if it were possible
to remove all the soil from imported ginger, it was still likely that the
Fijian burrowing nematode variant could exist inside the ginger and thereby be
imported into Australia.[50]
AGIA noted, for example, that the burrowing nematode reproduces internally in
the ginger rhizome.[51]
5.48
The evidence offered in the ginger IRA that 'the experience of Fiji's
ginger exports to other markets over a number of years does not suggest a high
likelihood that Radopholus similis would be present in export-quality
ginger'[52]
is not particularly convincing. This position is reinforced by an answer to a
question on notice which indicated that there have been three consignments (to
New Zealand) over a period of 10 years where nematodes have been intercepted.[53]
Burrowing
nematode entry with other host and non-host crops
5.49
Burrowing nematodes are able to live and multiply on a number of other
host crops, such as bananas, carrots, citrus, lettuce, mango, rice, tomatoes,
black peppercorn, coconuts, coffee, pineapples, sugarcane and tea.[54]
5.50
However, in response to questions from the committee, DA Biosecurity indicated
that:
Rice, black pepper, coconuts, coffee and tea can be imported
from Fiji. None of these imported products are considered a viable pathway for
the burrowing nematode to enter and establish in Australia.[55]
5.51
DA Biosecurity also acknowledged that in conducting the IRA on fresh
ginger from Fiji it did not assess the likelihood of the Fijian burrowing
nematode variant being imported
into Australia via other crops from Fiji. Crops including – but not
limited to – carrots, citrus, lettuces, mangoes, rice, tomatoes, bananas, black
peppers, coconuts, coffee, pineapples, sugarcane and tea.[56]
5.52
The committee is aware that taro (as a non-host crop for burrowing
nematodes) is often grown in rotation with ginger in Fiji and sought to explore
whether there were any risks associated with the import arrangements for taro
from Fiji.
5.53
When questioned by the committee, DA Biosecurity confirmed that
nematodes had been found on taro imported from Fiji [57]
however, to date, the Fijian burrowing nematode variant had not been found on
taro.[58]
In addition, DA Biosecurity confirmed that fresh taro from Fiji is moved into
ginger growing regions:
Fresh taro from Fiji is imported into Brisbane on a regular
basis. DAFF does not monitor the movement of goods once they are released from
quarantine control.[59]
5.54
As discussed in Chapter 4, DA Biosecurity has indicated that it is
unable to control what happens to imported produce once quarantine clearance is
given at the border. The committee is aware, therefore, that in the same way as
fresh pineapple from Malaysia could pass Australian border controls and not be
restricted in its distribution, there would be no restrictions placed on the
distribution of fresh ginger from Fiji. The committee notes that once border
clearance is provided, the distribution of that product ceases to be relevant
from the biosecurity perspective:[60]
If they have cleared
the border, and we are satisfied that they have met our conditions, they can go
wherever.[61]
Committee comment
5.55
The committee considers that the ginger IRA does not adequately address
the difficulties associated with ensuring that soil containing burrowing
nematodes is removed from ginger being imported from Fiji. The level of
difficulty in ensuring that very small amounts of soil are not present is not
adequately reflected in the 'medium' likelihood of entry prior to mitigation
measures, or the lower likelihood of entry after the mitigation measures.
5.56
The committee therefore considers that for the purposes of the
unrestricted risk assessment, the likelihood that the Fijian burrowing nematode
variant would be imported into Australia with fresh ginger from Fiji is 'almost
certain'. This likelihood was estimated in the ginger IRA as 'moderate' with a
probability of 0.3 to 0.7, but the committee considers this is not a credible
assessment for an event that is 'almost certain' to occur. The three cases of
nematodes detected in ginger consignments to other countries over the past
decade highlight for the committee the very high likelihood of nematodes being
imported. The committee notes that these are the detected cases and that there
may have been cases where nematodes went undetected by quarantine inspection.
5.57
The committee notes that if the likelihood of importation had been rated
as 'high' which would be more appropriate for an event that is 'almost certain'
to occur, the overall probability of entry, establishment and spread would also
be 'high'.
5.58
The committee is concerned that it has identified a significant
shortcoming in the ginger IRA as it did not consider that the more pathogenic
Fijian burrowing nematode variant could be imported from Fiji on other host
crops, such as rice, black pepper, coconuts, coffee and tea.
5.59
In addition, the committee remains concerned about the potential for the
Fijian burrowing nematode variant to be imported on taro which is grown in
rotation with ginger in Fiji. While the committee acknowledges that Fijian
burrowing nematode variant have not been found on taro imported from Fiji to
date, DA Biosecurity has admitted that other nematodes have been found on taro
from Fiji. The committee considers that this demonstrates that the burrowing
nematode could also be imported and thus pose a threat to Australian ginger
crops.
5.60
The committee therefore considers the likelihood of entry, establishment
and spread of the Fijian burrowing nematode should be reassessed.
Recommendation 14
5.61
The committee recommends that the Department of Agriculture review its
assessment of the likelihood of entry, establishment and spread of the Fijian
burrowing nematode variant. If a risk above Australia's ALOP were to emerge
from the review, then the committee expects stronger risk management measures
would be required. If such risk management measures were not sufficient to
reduce the risk to Australia's ALOP, then imports of Fijian ginger to Australia
should not be permitted.
Assessment of consequences
5.62
As discussed in previous chapters, the assessment of the consequences
that may arise from a pest incursion is a key part in determining the risks
associated with importation of ginger from Fiji.
5.63
The IRA sets out how the consequences are assessed over four geographic levels:
local, district, regional and national, against the following six criteria:
-
plant life or health;
-
other aspects of the environment;
-
eradication, control;
-
domestic trade;
-
international trade; and
-
environment.[62]
5.64
The magnitude of the potential consequence at each geographic level is
put into one of four categories: indiscernible, minor, significant, and major
significant. The magnitudes for the six criteria are then combined into overall
consequence ratings for each pest through two sets of decision rules.[63]
Burrowing
nematodes and yam scale
5.65
The consequences for both yam scale and burrowing nematode are both
assessed by DA Biosecurity as 'low'. Both pests were given an impact score of 'D'
meaning 'significant at the district' level for plant life or health.[64]
In relation to the burrowing nematode, the ginger IRA states that:
Radopholus similis – putative intraspecific ginger
variant may have an impact on ginger production where poor crop management and
production practices are in place. Radopholus similis – putative
intraspecific ginger variant was not detectable in crops that employed crop
rotation with non‑host crops and which used hot water treated seed
planting material (Turaganivalu et al. 2009). Infestation results in
stunted, chlorotic low yielding crops (Vilsoni et al. 1976). Rhizomes
can be completely destroyed (Turaganivalu et al. 2009).[65]
5.66
However, key industry stakeholders were not convinced that the consequence
of an infestation of burrowing nematode should be assessed as 'low'. Rather, it
was argued that the ginger IRA has underestimated the risks. The
AGIA stated for example:
...that DAFF Biosecurity has significantly underestimated the
risks posed by the introduction of various pest and disease organisms and has
not provided for adequate risk mitigation measures...[66]
5.67
Similarly, Buderim Ginger submitted its concerns about the level of risk
assigned to yam scale and burrowing nematode:
Buderim supports the industry position that DAFF Biosecurity
has significantly underestimated the risk posed by the potential introduction
of these two pests.
...the assumption that it is possible to rely on farm
management practices alone without the mandatory fumigation of the imported
ginger to control the pests identified is impractical and ill-conceived.[67]
5.68
Templeton Ginger told the committee that if burrowing nematode were to
enter Australia, it would be as devastating to the ginger industry as Foot and
Mouth disease would be to the cattle industry.[68]
It was also submitted that:
Burrowing Nematode has been found to be pathogenic on ginger
in Fiji, with losses of up 70% of their crop. It could not only affect our
yields but would affect our access to overseas markets like Japan.[69]
This import request is to deliver ginger into Australia,
anywhere! It is not limited to 1or 2 places with strict quarantine
restrictions. It can be bought by anyone, anywhere for almost any use. Any
piece of ginger can be used as planting material intentionally or
unintentionally.[70]
Impact of
geographic scale in the assessment of consequences for ginger
5.69
The committee is concerned that because the highly specialised growing
conditions for ginger limit its production to a relatively small geographic
area, the DA Biosecurity decision rules in Tables 2.3 and 2.4 of the ginger IRA
mean that regardless of how serious the impact of a specific pest would be on
the ginger industry, the consequences could never be rated above 'moderate'.[71]
5.70
As noted previously, ginger requires light shade, a well-drained soil, frost-free
climate and 1500 mm of rain annually or supplementary irrigation. Ginger
grows well in loamy or alluvial fertile soils and likes the addition of
well-rotted manure or compost. It cannot stand waterlogging.[72]
The Queensland Government's 2009 overview of the Australian ginger industry
states:
Ginger is a tropical crop and therefore grows particularly
well in the wet tropics and subtropics. It also grows well in areas that
experience a dry season, provided there is irrigation. Areas that are too windy
or too exposed may cause issues for growers as crops perform best in more
sheltered areas. For this reason, the majority of Queensland’s ginger farms are
located along coastal areas such as the Sunshine Coast that experience high
temperatures and humidity, and high rainfall during summer.[73]
Committee comment
5.71
The committee is concerned that the IRA does not allow 'high' or even 'extreme'
consequences to be determined when, for example, the entire or large proportion
of the area capable of growing a crop such as ginger is under a threat of
'major significance'.
5.72
The committee notes that Mr Peace identified this limitation in his
report to the committee on the DA Biosecurity REM. Mr Peace suggested several
alternatives to crude geographic levels, including percentage of national crop
at risk, or viable planting area at risk.[74]
The committee has made a recommendation on the broader issue of geographic
level in Chapter 3.
Assessment
of consequences for other crops
5.73
The committee was informed that in addition to ginger crops, yam scale
can also affect other crops:
Yam Scale has been determined as a quarantine pest. Yam Scale
Pest Risk Management measures are Phytosanitary inspection by BAF.
Yam Scale could affect Australian grower’s yields and leave
pieces unmarketable if introduced into Australia. It should also be noted that
Yam Scale has many other host crops...[75]
5.74
The committee notes that the ginger IRA drew on references regarding a
range of tropical root crops as potential hosts of yam scale.[76]
5.75
For the burrowing nematode, the IRA acknowledges a wide range of other
potential host crops, including bananas, black peppers, coconuts, coffee,
ginger, pineapples, sugarcane and tea. However, bananas are the only other host
crop explicitly considered in terms of the Fijian burrowing nematode variant
that is highly pathogenic for ginger. While bananas in Fiji are shown to be a
poor host,[77]
it is less clear whether the Fijian burrowing nematode variant is pathogenic to
Australian bananas.
5.76
DA Biosecurity indicated in an answer to a written question on notice
that, in its view, it was not applicable for the Chief Executive to use the
powers available under regulation 69G(1) of the Quarantine Regulations 2000 to
obtain further information regarding the impact of the Fijian burrowing
nematode variant on other host crops grown in Australia.[78]
5.77
The committee observes that DA Biosecurity appears to consider it
unnecessary to seek further information on the consequences of the Fijian
burrowing nematode variant. The committee assumes that this is because it has
put in place mitigation measures to reduce the risk below Australia's ALOP.
However, as discussed elsewhere in this chapter, the committee is not convinced
that the mitigation measures are effective, or that the risk is below
Australia's ALOP.
5.78
The committee sought information on whether in conducting the IRA, DA Biosecurity
explicitly considered the extent and consequences of the Fijian burrowing
nematode variant to the particular species of other known host crops grown in
Australia, including, but not limited to carrots, citrus, lettuces, mangoes,
rice, tomatoes, bananas, black peppers, coconuts, coffee, pineapples, sugarcane
and tea. DA Biosecurity responded:
The key attribute of Radopholus similis intraspecific
variant is its postulated pathogenicity on ginger. As there is no published
information available on the pathogenicity of the Radopholus similis intraspecific
variant on crops other than ginger, the pest risk assessment took a
conservative approach in rating the consequences of this pest on plant life or
health, including other crops. The report specifically recognised the putative
intraspecific strain on ginger and addressed those risks.[79]
Baby ginger
versus mature harvest ginger
5.79
Dr Graham Stirling, a consultant to the AGIA, clarified that if the
Fijian burrowing nematode variant escaped into Australian ginger growing areas,
it may not prevent all ginger growing, but would affect the higher quality
ginger that is obtained by leaving the crop in the ground for longer:
If we got this pest in Australia, we would be able to grow
early-harvest ginger, which only grows in the ground for four or five months.
The problem will come after that. We would lose these two-year plantings...
They would be destroyed. We would lose, probably, a large percentage of our
market, but we would still be able to grow ginger provided we harvested it
early, before the nematodes did the damage.[80]
5.80
DA Biosecurity informed the committee that the IRA covered both immature
and mature ginger, but that different harvest times were not assessed.[81]
Committee comment
5.81
The committee acknowledges that the IRA's assessment of consequences is
inherently prone to a degree of subjectivity. Nevertheless, the committee
considers that the language used by industry stakeholders indicates that the magnitude
of the consequence of the entry of Fijian burrowing nematode variant is likely
to be of 'major significance'. The IRA defines major significance as:
...expected to threaten the economic viability through a large
increase in mortality/morbidity of hosts, or a large decrease in production.
Expected to severely or irreversibly damage the intrinsic ‘value’ of
non-commercial criteria.[82]
5.82
However, in the ginger IRA, DA Biosecurity appear to consider that if
Australian farmers use crop rotation and hot water treatment of seed ginger,
the magnitude of the consequences of burrowing nematode will only be
'significant'.[83]
As discussed later in this chapter, the committee has concerns about both the
effectiveness of the proposed mitigation measures and whether the consequences
have been correctly assessed.
5.83
The committee observes that if the percentage of the national crop at
risk or the proportion of the possible growing area were used instead of
geographic size, the consequences would possibly be assessed as 'moderate' or
higher for both yam scale and burrowing nematode. As a result, the unrestricted
risk may be 'moderate' or higher.
5.84
Even if the proposed mitigation measures reduced the likelihood of
entry, establishment and spread of yam scale and burrowing nematode to 'low',
the restricted risk assessment for both pests would be 'low risk' and therefore
above the ALOP and fresh Fiji ginger would not be able to be imported without
the application of further mitigation measures.
5.85
The committee also observes that if the same adjustments to assessment
consequences were made for some of the other seven quarantine pests associated
with fresh ginger from Fiji, the unrestricted risk may also be higher than what
was previously assessed and additional mitigation measures may be required.
5.86
The committee therefore reiterates the importance of the recommendation
made in Chapter 3 in relation to the way in which geographic impacts are taken
into consideration in the IRA process.
5.87
The committee is concerned at the assessment of potential consequences of
the Fijian burrowing nematode variant spreading in Australia as 'low', in spite
of the fact that there does not appear to be any information on the
consequences for crops other than ginger.
5.88
The statement by DA that a conservative approach had been taken
regarding the consequence for other crops does not appear to be consistent with
plant life or health impact score given in the ginger IRA of 'D—significant at
the district level'.[84]
The other host crops are grown in areas extending far beyond the district level
in which ginger is grown.
5.89
In addition, as noted above, the ginger IRA appears to assess
consequences as 'significant' on the basis that crop rotation and hot water
treatment can be used to manage the Fijian burrowing nematode variant in
Australian ginger crops. However, it is not at all clear to the committee that
crop rotation and hot water treatment are effective against the Fijian
burrowing nematode variant for other host crops in Australia. Again, this draws
into question the assertion by DA Biosecurity that a conservative approach was
taken in rating the consequence for other host crops.
5.90
The committee considers that based on the above, and using Table 2.3 of
the IRA, the plant life or health impact score for the Fijian burrowing
nematode variant should be at least 'E' and quite possibly 'F'. Hence, the
overall consequence rating based on Table 2.4 of the ginger IRA would then be
'moderate' or 'high'. The corresponding unrestricted risk based on Table 2.5 of
the IRA would then be 'moderate' or 'high'. Even if the entry mitigation measures
were as effective as DA Biosecurity propose, the restricted risk would be 'low'
or 'moderate' and therefore above the ALOP.
5.91
The committee considers this to be a significant flaw in the IRA,
particularly given that the Fijian burrowing nematode variant has been shown to
be so much more pathogenic for ginger.
5.92
The committee therefore considers that the consequences of the Fijian
burrowing nematode variant entering Australia should be reassessed.
Recommendation 15
5.93
The committee recommends that the Department of Agriculture review its
assessment of the consequences of the establishment of the Fijian burrowing
nematode variant in Australia. If a risk above Australia's ALOP were to emerge
from the review, then the committee expects stronger risk management measures
would be required. If such risk management measures were not sufficient to
reduce the risk to Australia's ALOP, then imports of Fijian ginger to Australia
should not be permitted.
Adequacy and effectives of quarantine conditions
and arrangements
Requirements for mitigation measures
5.94
The identification and assessment of risk management measures is a key
part of any IRA process. If the risks associated with an import proposal are
determined through an IRA process to exceed Australia's ALOP, there are two
possible paths. First, risk management measures are proposed to reduce the
risks to a level that achieves Australia's ALOP; or secondly where it is not
possible to reduce the risks to below the ALOP, trade will not be allowed.[85]
5.95
In the case of fresh ginger from Fiji, the ginger IRA identified two
pests (yam scale and the Fijian burrowing nematode variant) for which the
unrestricted risk is 'low' and above Australia's ALOP of 'very low'.[86]
Yam scale
5.96
The IRA proposed the following mitigation measures in relation to yam
scale:
...pre-export phytosanitary inspection by BAF for Aspidiella
hartii [yam scale] to ensure that infested ginger rhizomes are identified
and subjected to appropriate remedial action.[87]
5.97
Stakeholders raised concerns about the proposed mitigation measures and
raised questions about whether inspections for yam scale would be effective
given the size of yam scale.[88]
5.98
The ginger IRA also suggests that the proposed methyl bromide fumigation
for burrowing nematode would also be effective for yam scale.[89]
However, it was pointed out that the fumigation would only work if it is
compulsory and the ginger IRA currently lists it as an optional treatment.[90]
Fijian
burrowing nematode variant
5.99
The IRA proposed the mitigation measures set out below for the Fijian
burrowing nematode variant:
It is proposed that the risk of Radopholus similis – putative
intraspecific ginger variant in ginger exported to Australia be managed by
either:
- a systems approach, such as, but not limited to: the use
of clean seed certified as nematode-free, or seed dipped in hot water at 51°C
for ten minutes, and either:
- a crop rotation program using non-crop hosts and fallow period,
or
- production in a recognised area of low pest prevalence.
or
- methyl bromide fumigation or other suitable treatment of
rhizomes, either in Fiji or on arrival in Australia.[91]
5.100
DA Biosecurity informed the committee that in general, systems
approaches are quite commonly used[92]
and summarised the systems approach as follows:
We have talked about the use of clean seed certified as
nematode free or seed dipped in hot water at 51 degrees for 10 minutes and
either a crop rotation program using non-crop hosts and fallow period or
production in a recognised area of low pest prevalence.
That is a combination that would give us our systems
approach. We would also consider other systems approaches that might be
proposed to us by the Fijian government, and we would make some assessment of
those. The alternative to that systems approach for Radopholus similis is
a methyl bromide fumigation or other suitable treatment, either in Fiji or on
arrival in Australia.[93]
5.101
The ginger IRA asserts that the objective of the mitigation measures is
to reduce the likelihood of importation for the Fijian burrowing nematode
variant to at least 'low'.[94]
The committee sought further information on two key points in relation to the
proposed mitigation measures – including the systems approach. Firstly, whether
there is scientific evidence that properly implemented mitigation measures would
guarantee elimination of the nematodes, and secondly, whether the mitigation
measures would be implemented correctly.
Evidence
for the effectiveness of mitigation measures
5.102
Stakeholders informed the committee of their concerns that the proposed
management approaches were not sufficient[95]
and the scientific basis of the systems approach was queried by some submitters.
For example, Peasley Horticultural Services stated that:
The risk management measures proposed in the PFIRA are
scientifically and commercially unproven and have not been technically or
practically demonstrated.[96]
5.103
The Chairman of the AGIA also argued that:
The Provisional Final IRA (PFIRA) had implemented mitigation
measures for Radopholus similis [burrowing nematodes]. These measures
are simply inadequate. Based on my industry experience as a seed grower, my
conclusion is that heat treating, certified seed and crop rotation are not
adequate measures.[97]
5.104
Templeton Ginger raised concerns about the hot water treatment part of
the risk management approach, and suggested that it may not eliminate burrowing
nematodes:
From what I can see it has been taken from the ACIAR [Australian
Centre for International Agricultural Research] report and it has taken
sections out of it so that it says using a clean seed scheme with hot water
treatment will do. It also says in that report that hot water treatment is not
being done well in Fiji, and there is no science around that says that that
will eliminate burrowing nematode. It also says in that report, where it is
taken out, that there is crop rotation and retillering of ginger. So you have
affected plants once again as well as other weed hosts that actually come in.[98]
5.105
In its submission on the draft IRA, the AGIA asserted that the
guidelines for hot water treatment are aimed at controlling rather than
eliminating nematodes:
...most guidelines for hot-water
treatment are aimed at reducing pest populations rather than eliminating them.
For most pests, protocols have not been developed to eliminate organisms; this
would likely require higher temperatures or longer treatment times, and these
may affect the resultant quality of ginger rhizomes. Where required for
particular organisms, methods must be developed to achieve elimination without
affecting the quality of ginger rhizomes intended for human consumption.[99]
5.106
The committee notes that in relation to the effectiveness of dipping in
hot water, the ginger IRA itself states that 'steps such as hot water dipping do
not guarantee the rhizomes will be pest free'.[100]
5.107
Mr John Allen from Oakland Farms also expressed concerns about the
proposed protocols:
The protocols that DAFF Biosecurity required for their
containment of burrowing nematodes will not work here, and I am sure that Fiji
will not be much different. In my view, unless very definite and stringent
protocols are put in place, this pathogen will enter Australia.[101]
5.108
One of the risk mitigation measures proposed by DA Biosecurity for use against
burrowing nematode was
methyl bromide – a measure widely considered by stakeholders as being largely
ineffective The committee notes, however, that the AGIA did consider methyl
bromide fumigation 'potentially effective' against the Fijian burrowing
nematode variant.[102]
5.109
Dr Stirling stated that:
It is a question about what rate of methyl bromide. We do not
even have the research to actually know that it will actually do the job. So it
may very well be okay but, as far as I am aware, I have not seen any literature
which actually indicates that it is effective.[103]
5.110
Mr Shane Templeton informed the committee that when a burrowing nematode
burrows into ginger, the wounds will heal over and the methyl bromide might not
effectively get to those burrowing nematodes.[104]
Similarly the Australian Ginger Growers Association (AGGA) argued that:
Methyl bromide was put forward by DAFF B as the alternative
control measure. Due to the reproductive system of Radopholus similis [burrowing nematode],
will this fumigant be 100% affective when the burrowing nematode reproduces
internally in the ginger rhizome? Methyl bromide is not systemic. One must
question whether this mitigation measure requires further research before
ginger is imported. How long and at what rate and at what temperature will
methyl bromide be used? Who will be required to conduct this operation?[105]
5.111
While willing to admit the potential effectiveness of methyl bromide
fumigation, the AGIA expressed similar concerns in relation to fumigation in
respect of internal organisms:
However, there is little information available on the
effectiveness of fumigation on organisms living inside plant tissue. As R.
similis is an endoparasitic nematode, reproducing inside the rhizome, we
believe that further work is needed to determine the effect of methyl bromide
fumigation on nematodes contained within rhizomes.[106]
5.112
The AGIA also informed the committee of the area freedom requirements
for export of Australian ginger to Japan and suggested that this would be a
suitable measure for fresh ginger coming into Australia:
R. similis
is not found in Australian ginger, yet area freedom is the
requirement for export of Australian ginger to Japan. Therefore, importation of
ginger from Fiji, where R.
similis is
found extensively, should require measures no less stringent than area freedom
and/or methyl bromide fumigation.
The AGIA proposes that the minimum suitable risk mitigation
strategy for R. similis
on ginger imported from Fiji includes area freedom and fumigation with
methyl bromide.[107]
5.113
The Biosecurity Authority of Fiji also questioned the scientific
validity of the proposed mitigation measures:
...the Provisional Final IRA has recommended measures for the
burrowing nematode without validated scientific evidence to support these
measures. The evidence that has been provided is insufficient and flawed. Fiji
looks forward to the removal of these unjustified measures in the near future.[108]
5.114
The committee notes
that in response to questions from the committee, DA Biosecurity admitted that
'no quarantine treatment can guarantee total elimination of any pest in
practice.'[109]
In addition DA stated that:
Methyl bromide is an effective quarantine treatment used by
many countries. In practical application it is possible that low numbers may
survive a quarantine treatment.[110]
5.115
The committee sought further information from DA Biosecurity on what
mitigation measures are applied in other countries including Japan, Britain,
the United States, New Zealand, Canada, China and the European Union. In
response, DA Biosecurity noted that some countries use only inspections,
however, information was not available on countries including Japan, the United
Kingdom, China and the European Union.[111]
Implementation
of the mitigation measures
5.116
A closely associated further issue explored by the committee was the extent
to which the mitigation measures, even if capable of being effective, would be
likely to be effective if not properly implemented. The committee took specific
evidence on the likelihood of full and correct implementation of measures in
Fiji, and took evidence which suggested that, in the past, mitigation measures
have been poorly implemented. Dr Stirling explained the systems approach to the
committee and in doing so, informed them of a range of problems with the
implementation of the systems approach in Fiji:
Dr Smith and I did some research in Fiji... Basically we
showed...that they have got serious Radopholus problems. They grow taro
and cassava as rotation crops. If you grow taro and cassava that are non-hosts
for the nematode, the population will drop. What we found was that the nematode
was being carried over on volunteer ginger. There are still a few ginger plants
that come up in the field, or weeds. Providing you grow cassava and taro
properly and keep all your weed and your volunteer ginger down, you can get
quite a low population of nematodes in three years time when you come back to
plant ginger. That is the first part of the systems approach, to get that
right. Then they plant dirty seed that has already got the nematode in it and
they have completely wasted their time. So the second part of the system is to
hot water treat the seeds and eliminate the nematodes. If that was done
properly, it would not completely eliminate the nematode but it has a good
chance of reducing the populations to more manageable levels. That is what we
call the systems approach. We saw no evidence in Fiji that they are capable of
doing it properly.[112]
5.117
Dr Stirling also pointed out that there had been issues with
implementing the hot water dipping approach correctly:
If you have to hot-water treat to 51 degrees for 10 minutes,
that does not mean 50 degrees for nine minutes. It has to be done properly. We
actually measured temperatures in tanks over there, and they were 42 degrees.
That is not going to do anything.[113]
5.118
The committee queried DA Biosecurity in relation to how the hot water
treatment would work in practice, including how the temperature would be
maintained above 51 degrees. At the time of the hearing, DA Biosecurity
were not clear on how it would work, or how appropriate temperatures would be
maintained.[114]
5.119
The field trip to Fiji undertaken by DA Biosecurity in 2007 also
uncovered evidence of poor implementation of mitigation measures and varying
practices:
The results from farmers who follow the ginger production procedures
(such as dipping in hot water) are mixed, and do not conclusively indicate that
a single factor (pests and diseases or environmental conditions, or both) is
responsible for the loss of the ginger for some farmers. This raises the
question of whether factors other than nematodes are affecting the ginger
during its growth.
For example, the ginger planted on the slopes where the soils
are well drained has high yields (approx less than 3 per cent loss of total
crop) despite avoiding the dipping of the planting material in hot water. On
the other hand, the farmers on relatively flat land who did not follow the hot
water treatment suffered losses of around 70 per cent due to rotting of the
rhizomes.[115]
5.120
DA Biosecurity acknowledged that the details of how the mitigation
measures would be put in place through an appropriate work plan were still to
be worked out. DA Biosecurity also told the committee that making the work
plans available to the committee and the Australian ginger industry was subject
to the willingness of Fijian authorities.[116]
Committee comment
5.121
The ginger IRA notes that for yam scale, the 'risk management measure is
consistent with Australia’s quarantine policy for scale species on other
imported commodities.'[117]
While consistency with other policy is potentially useful, the committee
considers that it is necessary for DA Biosecurity to reference appropriate
scientific evidence that the proposed inspections regime is effective.
5.122
The committee also considers that, to allow appropriate scrutiny,
scientific evidence in relation to the effectiveness of fumigation for yam
scale should be set out in the ginger IRA.
Recommendation 16
5.123
The committee recommends that before an import license is granted, the
Department of Agriculture make available to stakeholders the scientific
evidence used as the basis for the effectiveness of the proposed mitigation
measures for yam scale.
Recommendation 17
5.124
The committee recommends that if the Department of Agriculture cannot
produce such scientific evidence, the mitigation measures for yam scale must be
reassessed.
Committee comment
5.125
The committee notes that while some other countries appear to use only
inspections, DA Biosecurity was not able to inform the committee of what
mitigation measures are used in key markets, including Japan, China, the United
Kingdom and the European Union. In the committee's view this indicates that DA
Biosecurity has not adequately benchmarked their proposed mitigation measures
against international best practice. The committee observes that this is a
further example of IRAs being completed without taking sufficient information
into account.
5.126
The committee acknowledges that the mitigation measures for the Fijian
burrowing nematode variant do have some utility in controlling and reducing the
populations of the nematode and that there is scientific evidence to support
that.
5.127
However, the committee is not convinced by the information in the ginger
IRA, or evidence provided by DA Biosecurity that there is scientific evidence
that the mitigation measures will be effective in the elimination of the Fijian
burrowing nematode variant. As a result, Fijian burrowing nematodes are almost
certain to be present in fresh ginger from Fiji. The committee therefore
considers that the 'low' likelihood of entry stated in the IRA[118]
cannot possibly be credible or correct.
5.128
The committee remains concerned that significant systems upgrades and
compliance monitoring would have to occur in Fiji for there to be confidence
that the mitigation measures would be implemented correctly. In this regard,
the committee considers that it is essential that the work plan be made
publicly available in Australia, so that the Parliament, the public and the
ginger industry can apply appropriate scrutiny to it.
5.129
However, the committee notes that, as discussed in the previous section,
even if the mitigation measures are implemented fully, an appropriate standard
of evidence has not been provided to ensure confidence as to their
effectiveness. This is especially concerning in relation to the Fijian burrowing
nematode variant, as DA Biosecurity has not examined the effectiveness of the
measures relative to the previously unknown burrowing nematode variant.
Recommendation 18
5.130
The committee recommends that the draft work plan for importing ginger
from Fiji be made available to the Parliament and industry for appropriate
scrutiny over a suitable period of time, prior to it being finalised.
5.131
The above examination of the ginger IRA's likelihoods, consequences,
unrestricted and restricted risks has identified a number of serious flaws.
5.132
The committee has persistent concerns regarding the IRA framework as
discussed in Chapter 3. When combined with the additional flaws and
concerns discussed above that have arisen in relation to the ginger IRA, the
committee does not have confidence that the IRA for fresh ginger from Fiji is
credible or viable in its current form. The committee therefore recommends DA
Biosecurity repeat the IRA, taking account of the issues set out in the
recommendation below.
Recommendation 19
5.133
The committee recommends that the Import Risk Analysis for fresh ginger
from Fiji be recommenced. In recommencing the IRA, DA Biosecurity should ensure
that particular attention is paid to:
- the likelihood of the Fijian burrowing nematode variant being
imported given:
-
the potential for the Fijian burrowing nematode variant to be
imported via other host crops; and
-
the potential for the Fijian burrowing nematode variant to be
imported via other non-host crops grown in the same fields as ginger.
-
the consequences of importing the Fijian burrowing nematode
variant when the following are taken into account:
-
the suggestions made in the Peace Report regarding geographic
scale for crops that are limited to particular districts or regions due to
climatic conditions;
-
the greater geographic scale for other host crops grown in
Australia that could be susceptible to the Fijian burrowing nematode variant;
-
proper consultation with stakeholders for other host crops, who
should be fully informed of the Fijian burrowing nematode variant and its
unknown pathogenicity to those other host crops; and
-
whether there are any effective management measures for the
Fijian burrowing nematode variant in other host crops that are grown in
Australia.
-
the effectiveness of the proposed mitigation measures, taking
into account:
-
the scientific evidence for the limited effectiveness of methyl
bromide treatment when the Fijian burrowing nematode variant is resident inside
ginger rhizomes;
-
the assessment of the import likelihood, given that the
mitigation measures do not guarantee elimination of the Fijian burrowing
nematode variant and that inspections will not detect nematodes resident inside
the ginger;
-
the relative effectiveness of the mitigation measure for the
Fijian burrowing nematode variant compared to the more common variant; and
-
a comprehensive examination of overseas practices.
Other Pests and Diseases
5.134
While the report in relation to the ginger IRA has largely focussed on
yam scale and the burrowing nematode, the committee also received evidence in
relation to other pests of concern.
5.135
DA Biosecurity indicated that it had investigated bacterial wilt in Fiji
and that:
In conducting the IRA we looked for any signs of bacterial
wilt or other pests of concern. There was no evidence that bacterial wilt was
in Fiji. To our knowledge there is still no knowledge that bacterial wilt is in
Fiji.[119]
5.136
However, the AGIA noted that DA Biosecurity's field report 'claimed that
further work was required to ensure bacterial wilt in Fiji is researched
appropriately'.[120]
Mr David Peasley also argued that there were still some questions to be
answered in relation to this particular disease:
For instance, bacterial wilt—is it there or is it not? That
is the basic question and it was highlighted in the trip report. They said
there was up to 70 per cent death of rhizomes in Fijian ginger.
They did not know whether it was waterlogging, Pythium,
bacterial wilt or nematodes. You cannot start a risk analysis until you know
what you are looking at.[121]
5.137
The AGIA raised concerns that other pests and diseases – in addition to
burrowing nematode – may have different variants in Fiji. The AGIA also raised
the possibility that these pests may have different pathogenicity to ginger and
other crops:
The AGIA is also concerned about the
risk of importing Fijian strains of the fungal pathogens Pythium graminicola, P. vexans and Fusarium
oxysporum f.sp. zingiberi
on ginger rhizomes and that these may differ from Australian strains
in their pathogenicity and host range. We believe that evidence outlined in our
response to the Draft IRA and some preliminary experimental data (pp. 30–3, 76)
cast sufficient doubt and support our view that further research is required to
compare Australian and Fijian isolates of these pathogens.[122]
5.138
As with the burrowing nematode, submitters raised concerns about risks
being assessed at low levels, nut that the assessment was made without
reference to relevant information:
The DAFF Biosecurity position (PFIRA pp. 88–90) is that these
species are present in Australia and, therefore, without ‘published peer
reviewed literature’, it will not accept that there is evidence of differences
between Australian and Fijian isolates of these fungi. The AGIA finds it
difficult to accept that an argument of lack of information implies no risk. We
believe therefore that, before the IRA is finalised, there should be research
to compare the pathogenicity and host ranges of Australian and Fijian strains
of these fungi.
Of particular concern is the fact that, if not for research
done by the Australian ginger industry, DAFF Biosecurity would not have known
of the threat caused by R.
similis (it
was not discussed as a quarantine pest in the Draft IRA). The AGIA is concerned
that other Fijian pests may pose significant threats to the Australian ginger
industry and considers that all major pests should be fully investigated before
the IRA is finalised.[123]
Committee comment
5.139
The committee has largely focussed its attention on the Fijian burrowing
nematode variant in order to demonstrate the inadequacy of the Fiji ginger IRA.
Given the various flaws identified in the ginger IRA process, the committee
considers that the threat posed by other pests should be also be reassessed.
Recommendation 20
5.140
The committee recommends that when the IRA is recommenced for fresh
ginger from Fiji, all relevant pests and diseases should be reassessed.
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