2009 Import Risk Analysis for Prawns and Prawn Products
This chapter examines the development of the 2009 Generic Import Risk
Analysis Report for Prawns and Prawn Products (IRA). During the development
of the IRA, a number of scientific concerns were raised regarding the content
of the IRA, along with concerns over the timeframe in which the IRA was
This chapter presents evidence submitted to the inquiry about the need
for an urgent review of the IRA. The chapter considers the efficacy of several
prawn treatments in addressing disease risks.
The IRA considers a number of pathogenic agents that can infect prawns,
such as YHV, Taura syndrome virus (TSV) and necrotising hepatopancreatitis
bacterium. However, for the purposes of this inquiry, the committee has focused
primarily on the inclusion of WSSV in the IRA.
Development of the IRA for prawns
Prior to 1992, there was no animal health related policy in Australia
for the importation of prawns or prawn products. Following a 1992 major review
of aquatic animal health and quarantine, the National Taskforce on Imported
Fish and Fish Products (NTF) was established in 1995. It recommended that:
AQIS [Australian Quarantine and Inspection Service] review
aquatic animal quarantine policies and practices, including that quarantine
requirements for imported bait prawns, prawn feeds and prawns for human
consumption, be revised as a high priority.
The government agreed to most of the NTF recommendations. In 1996, AQIS
imposed restrictions on the entry of 'uncooked prawns and prawn-based products containing
uncooked prawns for bait use, to address concerns relating to use of imported
prawns as recreational fishing bait'.
In 1997, the development of an IRA for prawns commenced, resulting in
the release of a draft IRA in 2000. In December 2000 and based on this draft
IRA, post‑arrival AQIS inspections for prawns were introduced to manage
the risk of WSSV entering Australia. In addition to post‑arrival
inspections, further measures were added in June 2001 and included:
a ban on whole uncooked prawns weighing less than 15 grams to
minimise their use as bait;
health certification from the relevant government authority in
the exporting country, attesting that the products had been appropriately
processed, were free from visible lesions associated with infectious disease
and were fit for human consumption; and
WSSV testing of all imported batches of uncooked whole prawns or
unpeeled headless prawns.
International reaction to the draft
On 23 November 2000, Australia presented the draft 2000 IRA to the World
Trade Organisation (WTO) Committee on Sanitary and Phytosanitary Measures
(CSPM). The CSPM was established to allow WTO member governments to exchange
information in relation to the SPS Agreement, and discuss issues including
compliance with the SPS Agreement, and trade disputes.
The draft IRA provided by Australia to the CSPM identified 15 disease
agents as potential hazards, and concluded that risk management was needed for
two agents in particular, WSSV and YHV. Australia sought comment from the CPSM
on the draft by 15 January 2001.
Prior to this deadline, in February 2001 Australia implemented interim
measures on the importation of prawn and prawn products from countries within
the Association of Southeast Asian Nations (ASEAN). The measures were based on
the fact that imported diseased prawn product might be used illegally as
The WTO published a summary of concerns raised regarding the draft IRA
by CSPM members, between 2001 and 2007. In 2001, Thailand urged Australia to
lift its interim measures, objecting to the inclusion of 'illegal domestic
practices as a major element in risk analysis'. Thailand further argued that the
interim measures were more restrictive than necessary.
In response, Australia noted that the interim measures were a response
to a WSD outbreak. Further, 'investigations had revealed far more imported
prawns were being used for bait than had been previously thought', leading
Australia to ban the import of whole uncooked prawns weighing less than 15
Over the following years, a number of concerns were raised with
Australia at the CSPM by WTO member countries. Some of the concerns raised are
October 2001: Thailand expressed 'serious concern about the
inclusion of Australia's domestic enforcement practices as a major element in
Australia's risk analysis'. ASEAN argued Australia's measures were not based on
scientific evidence and were overly restrictive;
June 2002: Thailand, Malaysia and the Philippines requested
information on how long the interim measures would apply, and their scientific
basis. Australia advised that a draft risk analysis report would be released
after July 2002, but the scientific concerns about WSSV remained;
April 2003: Thailand observed that 'interim measures against the
import of uncooked prawns and prawn products from ASEAN countries had been in
place for over two years and there was no legitimate reason for the
continuation of these emergency measures'. Australia replied that the measures
were only on high‑risk products, and that tests had shown the presence of
WSSV in uncooked prawns from Thailand. Further, 'Biosecurity Australia had
commissioned a study on bait use which provided clear support for the measures
June 2003: Thailand noted that the interim measures were still in
place and that the IRA was unlikely to be concluded within a short period of
In February 2007, Thailand 'again expressed serious concerns about the
revised draft generic import analysis report on prawns and prawn product as
notified by Australia'. Thailand was:
in particular concerned that there
was no scientific justification for the proposed quarantine measures. The
analytical methods employed suffered from a lack of empirical data, and the
conclusions were not based on scientific data but tailored to fit the views of
policymakers. Thailand considered that these measures were unnecessary and
would create trade obstacles for its exports.
Thailand further noted that the 'more than 6-year delay in completing
the IRA was an undue delay', and if the measures imposed were in fact interim,
they 'should have been reviewed within a reasonable time'. China expressed
similar concerns, arguing that the measures were overly restrictive and that
'Australia had imported prawns from Asia for ten years with no evidence that
the disease had been spread through trade'. China also argued against the heat
treatment of imported prawns, as it would reduce marketability. These arguments
were supported by Indonesia, Malaysia, the Philippines and Sri Lanka.
Australia released a further revised draft IRA in 2007, arguing that it
presented a comprehensive review of the science. The draft IRA concluded that
stricter import control measures were needed, but these measures were yet to be
determined. In June 2007, Thailand 'expressed serious concerns about
Australia's revised IRA process, which was long and unpredictable'.
Vietnam also raised concerns, stating that:
To date, there were no reports
of any disease outbreaks related to Vietnamese prawn exports. [Vietnamese]
authorities had carefully studied Australia's draft risk analysis. Of the five
diseases identified to be of concern in the IRA, three were not known to occur
in Viet Nam. The other two diseases were widespread in South East Asia, yet had
never been introduced into Australia despite years of prawn imports without the
current quarantine restrictions. The risk management measures proposed in the
draft IRA lacked scientific justification and would present a serious barrier
The draft IRA was further revised in September 2008, before the IRA was
finalised by Biosecurity Australia in 2009.
2009 Import Risk Analysis
In 2009, Biosecurity Australia released the final IRA. This IRA covered
the import of prawns and prawn products into the country, excluding live
The IRA examined what pathogenic agents could be introduced into
Australia through the importation of uncooked prawns and prawn products,
intended for human consumption. The IRA recommended the importation of prawns,
subject to 'compliance with risk management measures to manage the quarantine
risks of a range of significant pathogenic agents to a very low level'. WSSV
was considered a pathogenic agent.
The IRA determined a number of acceptable risk management measures,
sourcing all uncooked prawn product from a country or zone that
Australian government authorities considered free of WSSV;
removal of the prawn head and shell, and holding each imported
batch on arrival in Australia under quarantine control, for testing and
confirmation that the product was free of WSSV;
importing highly processed product, with the prawn head and shell
removed, and coated for human consumption in crumb, batter, wet or dry
marinade, or marinated and placed on skewers (with the marinade in all cases
clearly seen on the prawns); or
cooking the product in a premises approved by, and under the
control of, an appropriate authority in the exporting country, to a minimum
time and temperature standard, resulting in no remaining uncooked meat.
The IRA stipulated that, unless an importing country is free from prawn
pathogens, all imported prawns must have heads and shells removed, be frozen
and each batch tested on arrival in Australia, and found to be free of WSSV and
YHV. Alternatively, the IRA required prawns to be 'highly processed', with the
head and shell removed, and:
coated for human consumption by crumb or batter;
coated for human consumption in a wet marinade, where the
marinade is not less than 12 per cent of the total product weight;
coated for human consumption in a dry marinade, which must be
clearly seen to cover the product;
coated for human consumption by being marinated and placed on
skewers, with the marinade clearly seen to cover the product; and
the raw prawn meat processed into dumpling, spring roll, samosa,
roll, ball or dim‑sum type product.
The IRA further stated that imported uncooked and highly processed
prawns would be randomly inspected by quarantine officers to ensure the import
complied with the import permit and health certificate.
In determining that all imported uncooked prawn product should come from
a country or zone considered free of WSSV, the IRA argued that Australian Government
authorities must have knowledge of the activities of the relevant authority in
the other country. The Government should be satisfied the authority can control
disease, and undertake proper monitoring and surveillance for disease. A
satisfactory assessment of the procedures from these countries would reduce the
overall risk of WSSV from imported prawns.
Overall, the IRA found the likelihood of release of WSSV 'via the
unrestricted importation of non‑viable, farm‑sourced, frozen,
uncooked whole prawns intended for human consumption is estimated to be high'.
Reaction to draft and final IRAs
The committee was concerned to learn that prior to the finalisation of
the IRA in 2009, testing had determined that WSSV was present in Australia.
Some of these results are presented in the IRA.
For example, the IRA notes that WSSV was detected in 2004 in Australia,
in imported frozen uncooked prawns intended for human consumption. In 2006, the
Western Australian and Queensland governments tested raw, peeled imported
supermarket prawns. These tests found a 20 to 100 per cent prevalence
of WSSV, in the 14 batches tested, with five prawns tested per batch.
In 2006, QDAF received from the Commonwealth a request for feedback on
the revised draft IRA for prawns and prawn product. In response, QDAF undertook
a limited testing program. QDAF advised the committee that where it held particular
concerns with Commonwealth proposals regarding imported products, it would
'test and form a view' on that proposal.
QDAF advised the committee that a small amount of its testing:
indicated a high level of infection in imported product at
that time and therefore [the Queensland Government] did not support the
proposed approach to the import of green prawns.
In correspondence seen by the committee, dated 16 February 2007, the Queensland Government's Department of Primary Industries and
Fisheries (DPIF) provided its advice to Biosecurity Australia on the revised draft
IRA. This advice contained the testing results undertaken by DPIF:
To date the testing of sixteen batches of imported uncooked
prawns has detected WSSV in 87.5 per cent of samples tested (some with severe
viral infection loads) and TSV in 62.5 per cent of samples, (some severe) and
not only in prawns from China but also Thailand and Indonesia. Although the two
samples from Vietnam were negative to TSV they were both tested positive for
WSSV. Prawns were sourced from supermarkets in Brisbane, Rockhampton, Mackay,
Townsville and Cairns and were all different batches according to the packet
DPIF argued that the testing results showed that WSSV was entering
Queensland through imports from various countries, 'despite existing quarantine
conditions intended to exclude WSSV'. DPIF supported a review of a number of
quarantine policies, to ensure the effectiveness of Australia's biosecurity
policy. DPIF argued that the reviews should consider:
the validity of foreign‑issued animal health certification;
the efficacy of post arrival inspections;
the efficacy of WSSV testing on quarantined prawn products,
including sampling rate, sample management and test methodology; and
the efficacy of processes for the exclusion of prawn products (that
fail quarantine conditions) from entering the Australian market.
DPIF noted that:
with the price of imported uncooked prawns dropping
substantially and the tonnage of imports increasing there has been a heightened
risk of cheap readily available product being purchased for other uses such as
bait and berley. Despite a communication campaign by the [DPIF] to alert
fishermen to the risk of such practices it is clear that use of imported prawns
as bait and berley remains a risk.
DPIF argued for the screening of all batches of imported prawns for
exotic viruses, noting that this 'would go a long way towards ensuring that
prawn product containing exotic viruses will no longer be readily available for
During the inquiry, QDAF confirmed its position that it did not support
the IRA at the time of its development, and noted that it has 'consistently
pointed out risks that are not apparent to the Commonwealth or have in our view
been assessed differently by the Commonwealth'.
Revision of the 2009 IRA
Over the course of the inquiry, various stakeholders argued for urgency
in revising the 2009 IRA, especially given the WSD outbreak. Stakeholders
argued for an appropriate assessment of biosecurity risks moving forward, in
light of the lessons learned from the recent WSD outbreak and the possibility
of varied incursion pathways.
The NSIA stated that while it was not against the importation of
seafood, it was 'extremely concerned about the failures of border control and
the incursion of the white spot disease into south-east Queensland'. The NSIA argued
that the IRA had failed, and called for its comprehensive and urgent review
with the full involvement of industry throughout the review process.
The APFA stated that the high prevalence of WSSV detected in Australia
showed that the current arrangements under the IRA had failed comprehensively,
repeatedly and on a large scale. The APFA argued there would 'always be
breakdowns in the system due to human error, test failure, sampling errors and
deliberate fraud', and called for the simplification and strengthening of
The APFC called for the urgent review of the biosecurity regime for
prawns and crustaceans, noting that the controls in place under the current IRA
were insufficient to control risk, and were open to human failure and improper
implementation. The APFC called for improved post-entry product surveillance,
noting that prawn products did not have post-border controls similar to other
The APFC further encouraged any biosecurity review to look at, among
other things, emerging diseases in prawns and crustaceans; changing consumer
behaviours with regard to prawn products; the proficiency of testing
laboratories, and post‑border disincentives to stop product substitution
With regard to revision of the IRA, Dr Ben Diggles argued that:
The strong possibility that this disease incursion was caused
by the use of imported prawns as bait signals an urgent need to revise the
prawn IRA and reassess this and other potential pathways of aquatic animal
disease introduction into Australia. The IRA has now not only failed, it is
simply out of date. The risk profiles of diversion of prawns and other imported
seafood products to bait and burley have either changed or were not properly
identified in the first place.
The SIAA noted that there were at least 35 viral, bacterial or other
diseases affecting prawn farms globally, and that more would evolve, including
in Australia. While supportive of appropriate import controls, the SIAA argued
that imported prawns were not the only risk to biosecurity, and that:
An over‑reliance on border controls would inevitably
lead to an endless procession of revised import risk analyses, revised import
conditions, and further trade restrictions – with no guarantee that these
diseases won't reach here by other pathways...these are aquatic diseases and
Australia is surrounded by water.
SIAA urged DAWR in its review of the IRA to undertake an assessment of
all disease pathway risks, and not just importation. SIAA encouraged DAWR to
'look at which are the relevant points in the supply chain to apply necessary
controls rather than focusing on just one potential pathway and placing almost
all the control effort on just one point in the supply chain'.
The ABFA agreed with this view, arguing that the reliance on border
testing to manage disease risk was 'illogical' and did not account for new and
emerging diseases that may not yet have tests in place.
In reviewing the IRA, Dr Patrick Hone of the FRDC urged that effective,
science‑based systems were used to inform biosecurity measures. Dr Hone
encouraged consideration of new and different processes being included in an
updated IRA, rather than simply fixing the existing provisions.
More broadly, there were calls to ensure that all IRAs were updated in a
timely manner, rather than as a retrospective result of a disease outbreak. A
number of submissions to the inquiry noted that the limited number of IRAs for
particular seafood products were outdated, and did not have appropriate review
mechanisms, thus increasing disease risk. For example:
the ABFA noted that the IRA for barramundi products was 20 years
old, generic and out of date;
the NAC advised that the IRA for finfish was completed in 1999
and no longer reflects the breadth of finfish imports, and that no IRA exists
for molluscs (including oysters); and
the APFC noted that the prawn IRA appeared to have no review
mechanism in place, outside of a high‑profile failure such as occurred in
late 2016 with WSD.
Support for the IRA
Other evidence to the inquiry suggested that the development of the 2009
prawn IRA was sound. Dr Monckton, of Monckton Consulting, argued that:
The scientific basis for the 2009 IRA was carefully and
extensively debated by an expert panel with significant contributions from
expert scientists overseas as well as local and public input. There was an
expert scientific review panel to review the submissions from all stakeholders
including the importers as well as the local prawn farmers and anyone or
anybody who had to do with the importation and testing. While not a perfect
document...it seemed to have most if not all the requirements to fulfill [sic] the
requirements under the OIE and the acceptance of ALOP especially to have a low
level of risk for any imported prawns.
SIAA submitted that there was no conclusive evidence that the IRA had
failed. SIAA argued that the provisions of the 2009 IRA 'would have been
sufficient to ensure imported uncooked prawns remained a low risk to
Australia's marine environment and fisheries – if they had been robustly
enforced', and supplemented with pre‑export testing.
DAWR review of the IRA
The committee notes that on 16 May 2017, DAWR announced a review of the
import conditions for prawns and prawn products, intended for human
consumption. The review will consider the biosecurity risks from the imports of
such products, and 'recommend appropriate import conditions to manage these'.
The review will examine the IRA and other existing import conditions and
DAWR advised the committee that in undertaking the review, it would
engage fully with the industry. To that end, DAWR would hold a consultation
roundtable with stakeholders before the end of 2017, to 'ensure that all
interested parties are informed, engaged and consulted'.
Diseases in the IRA
Given the IRA was finalised in 2009, a number of submitters argued that
the IRA should be updated to include new and emerging diseases not considered
by the current IRA.
Evidence to the committee suggested that other disease agents not
considered in the 2009 IRA included, among others, acute hepatopancreatic
necrosis disease (AHPND), monodon slow growth syndrome, and Covert Mortality
DAWR advised that it engages in ongoing monitoring of prawn diseases
that may present a biosecurity risk to Australia. For example, in relation to
AHPND, DAWR has reviewed scientific information and reached a preliminary
conclusion that 'the current risk management measures for uncooked prawns, such
as freezing, reduce the biosecurity risk of AHPND to an acceptable level'.
Importing cooked prawns
Over the course of the inquiry, the committee received evidence from a
number of witnesses that the best way to achieve Australia's ALOP from disease
was to only import cooked prawns.
In its submission, the APFA stated that 'there does not appear to be any
compelling reason why prawns must be imported to Australia in an uncooked
state'. It was argued that other products, such as salmon, chicken and pork
must be cooked prior to arrival in Australia, and there was no explanation as
to why the same ALOP did not apply to prawns.
The ABFA likewise asserted there were quarantine conditions for some
imported meat products where cooking was required, and that this was
permissible under the WTO and OIE rules. The ABFA argued, however, that prawns
'have a lower biosecurity threshold with raw product allowed', and that a
higher risk burden should be introduced.
Dr Diggles also argued that quarantine conditions requiring the cooking
of imported meat products were within the rules of the WTO and the OIE, however
the fishing and aquaculture industries were treated differently. Dr Diggles
supported the importation of cooked prawn products, stating:
By requiring cooking prior to entry, the processes of
inspection at the border would be simplified, additional costs of testing for
diseases would be eliminated, and other risk mitigations like processing (removal
of heads/peeling/deveining) may no longer be required, resulting in a more
streamlined inspection process at the border and potentially a cheaper product
to the end consumer. Furthermore, the technology required to cook seafood is
virtually no cost, imposing little burden on exporting countries, and we would
no longer have this ridiculous situation whereby uncooked commodities enter
Australia from WSSV positive overseas countries, while commercial fishers and
aquaculturists in SE QLD have to cook their commodities prior to sending them
interstate or up to North QLD.
The NSIA held a similar view, and stated that cooking prawns was a
'simple, cheap and effective sanitary process that inactivates most pathogens' that
present a threat to the environment and human and animal health. Further, the
NSIA was of the view that cooking prawns was a low cost, low risk process that
could be implemented quickly, and would reduce the costs associated with
compliance testing and inspection. Importing only cooked prawns would 'likely
be the only way to level the playing field and reduce risks to within the ALOP
enjoyed by other non‑seafood industries'.
However, some submitters raised concerns about importing only cooked
prawns. SIAA argued that while the import of cooked prawns would address some
biosecurity concerns, to do so was to 'misunderstand the Australian market
entirely'. SIAA continued that:
Limiting supply to pre‑cooked prawns would deprive
foodservice businesses of their capacity to apply their culinary skills to add
value through cooking – the very activity that underpins their competitive
advantage, their revenue, and, some would argue, their purpose.
There is a real danger that this would also inflict a major
degrading of the quality of prawn meals available to consumers and jeopardise
the premise that prawns are inherently high quality food...This in turn could
lead to a slump in sales that would affect both local supply and imports.
SIAA further argued that Australian-sourced uncooked prawns would not be
able to fill the gap in the uncooked prawn market, as the production volume is
less than the demand. This was confirmed by the FRDC, who noted that Australia
would have to double its production of raw prawns to meet current market
DAWR made the point that only allowing the import of cooked prawns would
not provide a '100 per cent guarantee' in preventing a white spot incursion, as
there would remain other pathways for the disease to enter Australia. Further,
importation of raw prawns and prawn product would be based on risk assessments,
and if Australia could trade safely, 'then we should be trading'.
This position on trade was also put forward by Minister Joyce. In
correspondence to Mr Michael Crandon MP, Queensland Member for Coomera,
Minister Joyce stated that:
our two-way trading relationships are vital for Australian
producers who rely on selling their products overseas and the government has an
obligation to allow agricultural imports, where the science says it is safe to
'Highly processed' prawns
Throughout the inquiry, there was discussion as to whether the
processing of prawns in certain ways reduces the viral load, or changes the
likelihood of raw, imported prawns being used as bait. In particular, it was
suggested that marinades on highly processed prawns were being washed off, and
the clean raw prawns subsequently used as bait.
Removal of head and shell
The IRA contends that removal of the prawn head and shell reduces the
viral load of infected prawns. DAWR has argued that shelled prawns being used
as bait 'may result in a lower rate of viral introduction into the
However, some evidence suggested that removing the prawn head does
little to reduce the viral load. Dr Diggles summarised scientific evidence that
removal of a prawn head does little to reduce the WSSV viral load, as 'viral
load in individual prawns is nearly identical in either heads (49% of total
virus) or tails (51% of total virus)'. The processing of green prawns (removing
the head or shell) therefore reduces the viral load only by half.
Mr Alistair Dick argued that while removing the head and shell of a
prawn does not reduce the viral load, such an action could in fact increase the
likelihood of a raw prawn being used as bait, and therefore increase the
probability and risk of viral transfer.
The NSIA argued that there was no scientific evidence that marinating or
breadcrumbing prawns inactivates disease, or stops consumers from using prawns
as bait or burley. The NSIA also questioned whether marinating and
breadcrumbing were 'processing steps' that removed the need for disease testing.
The NSIA contended that:
this was simply misleading and heightened risks of disease
introduction, instead of reducing them, by providing a loophole to avoid
testing and allow entry of infected prawns into the retail sector.
The APFA supported this view, stating that the term 'highly processed',
as applied to marinated and breadcrumbed prawns, was a 'misnomer because it implies
some form of heat or energy has been applied to the product, which would reduce
or eliminate pathogens'. The APFA argued that as there was no scientific
evidence that prawn pathogens are inactivated when highly processed, the
importation controls presented a loophole for infected product to enter
Australia. The APFA stated that this loophole should be closed.
The SIAA submitted that it was unclear to what extent people were
washing marinades off prawns. SIAA noted that despite this pathway being repeatedly
mentioned by stakeholders, 'it is hard to imagine that a marinated product
would be the first choice of anyone intending misuse when better suited
products (e.g. un-marinated meat and cutlets) were available'. Nevertheless, the
SIAA encouraged further research into the effectiveness of marinade in
preventing the prawns being used as bait.
The committee notes that as part of the enhanced import conditions in
place from 7 July 2017, uncooked and marinated prawns are considered
as one product class and subject to enhanced testing and import conditions such
as seals intact inspection and pre‑export disease testing.
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