Chapter 4
The proposed importation of pineapples from Malaysia
4.1
The terms of reference for this inquiry required the committee to
examine the scientific basis on which the Import Risk Analysis (IRA) report for
the importation of fresh, decrowned[1]
pineapple was developed. The committee was also required to determine the
adequacy of quarantine conditions and measures recommended by DA Biosecurity in
relation to the importation of pineapple from Malaysia.
Australia's pineapple industry
4.2
The Australian pineapple industry is a relatively small but important
agricultural industry. The following section provides a brief background on the
Australian pineapple industry and provides context for the later discussion of
the December 2012 Final import risk analysis report for the importation of
fresh decrowned pineapple (Ananas comosus (L.) Merr) fruit from Malaysia
(the pineapple IRA).[2]
4.3
The most suitable soils for pineapple production are non-compacted,
well-aerated loams, sandy loams and clay loams, which have no heavy clay or
rock within one metre of the surface. Good drainage is essential, particularly
because poor drainage can lead to a weak root system and make plants more
susceptible to root and heart rot diseases.
4.4
Temperature is the most important climatic factor affecting
productivity. The optimum air temperature is 32˚
Celsius during the day and 20˚
Celsius at night. For every 1˚
above or below these temperatures, the optimum growth rates decrease by about 6
per cent. During periods of intense sunlight and high temperature (above
approximately 35˚ Celsius)
fruit also becomes susceptible to sunburn damage. A frost-free site is
essential and for non-irrigated crops, rainfall should be well distributed
throughout the year and in excess of 750 mm per annum.
4.5
Australian pineapples are grown year round – primarily in Queensland –
with an average turn-around of 18 months from planting to crop harvest and
16 months from crop harvest to the ratoon crop[3] harvest.
4.6
In the 2009-10 season, the Australian pineapple processing sector
produced 41 000 tonnes of fruit for canning and juicing, which was worth $13.25
million. This sector of the industry, has however, been in decline over many
years, due in part to competition from cheaper imported product.
4.7
In contrast, the fresh pineapple sector has expanded considerably over
the last 12 years, due to both improved quality and the adoption of better
fresh market fruit varieties. In the 2009-10 season, 43 720 tonnes of fresh
pineapple was produced and sold on the domestic market. The gross value of
Australian pineapples at the farm gate is currently estimated at $79 million.
4.8
Production is predominantly concentrated in South East Queensland and
key production districts include: North Queensland, Yeppoon and Cawarral,
Bundaberg, Maryborough and Hervey Bay, Mary Valley and Nambour, Glasshouse
Mountains and Beerwah, Wamuran and Elimbah. It is estimated that approximately
60 per cent of pineapples produced for the fresh fruit market and for
processing are grown in the Cooloola-Sunshine Coast region.
4.9
More than 70 per cent of fresh pineapples are packed and marketed
through four primary packhouses. Golden Circle, which was recently acquired by
Heinz Australia, is the one primary pineapple processor. As noted above,
however, the industry is becoming increasingly fresh-market based, due to new
fresh-market varieties and competition from imported processed fruit.
4.10
The fresh fruit market is split between Smooth Cayenne, Queen (rough
leaf) and new hybrid varieties. The hybrid varieties are noted for their higher
sugar to acid ratios and greater consistency. Current hybrid varieties include
73-50, MD2 (73-114) which are marketed under various brand names, and
Aus-Jubilee and Aus-Carnival.
4.11
The majority of Australian produced fresh and processed pineapples are
consumed within Australia. Exports of fresh pineapples account for only 6 per
cent of total production and only a small quantity of Australian processed
pineapple is exported to retail markets in New Zealand. There is limited
potential for expansion of export markets, primarily due to the competition of
lower-cost production in Asian countries. There has, however, been some
interest in reviving the New Zealand market, and the pest free status of
Australian produce may play an important role in increasing Australia's market
share.
4.12
There are limited fresh pineapple imports into Australia, but extensive
processed imports. Countries currently able to import fresh pineapple include
the Philippines, Sri Lanka, the Solomon Islands and Thailand.
Pests and diseases
4.13
The National Pineapple Industry Biosecurity Plan for the pineapple
industry (the Pineapple Biosecurity Plan) was developed by Plant Health
Australia (PHA) in collaboration with industry and government stakeholders. It
was launched in July 2008. The Pineapple Biosecurity Plan argues that
Australia's geographic isolation has resulted in the region being relatively
free of many of the pests and diseases that have impacted overseas plant
industries. The Pineapple Biosecurity Plan also notes that:
Freedom from these
exotic pests is a real trade benefit for Australia in terms of securing market
access domestically and internationally. Maintenance of our plant health status
is vital for retaining trade opportunities, negotiating access to new overseas markets
and ensuring the future profitability and sustainability of our plant
industries.[4]
4.14
The development of each Biosecurity Plan commences with the production
of Threat Summary Tables (TST). These tables identify all the potential exotic
pest threats to an industry and with expert consultation, rank their potential
threat based on entry, establishment, spread potential, consequences of
establishment and eradication potential (where available). From this
information, the high priority Emergency Plant Pests can be established (for
which diagnostic protocols and contingency plans are created).[5]
4.15
The Pineapple Biosecurity Plan lists (in alphabetical order) the
top-ranked pest threats to the Australian pineapple industry as:[6]
-
False codling moth; bollworm – Cryptophlebia leacotreta
or
-
Argyroploce leucotreta; Cryptophlebia roerigi; Thaumatotibia
roerigii; Olethreutes leucotreta;
-
Grey pineapple mealybug; annona mealybug – Dysmicoccus
neobrevipes;
-
Bacterial fruit collapse – Erwinia chrysanthemi
(distinct pathovar);
-
Fusariosis – Fusarium guttiforme; and
-
Pineapple fruit borer – Strymon megarus or
Thecia basilides.
4.16
The pest threats on this 'Emergency plant pest priority list' are all
exotic pests not currently found in Australia. Importantly, for this inquiry,
the risks associated with Bacterial fruit collapse are rated as 'high' in
relation to entry potential, establishment potential, spread potential,
economic impact and risk (see Appendix 13 for further detail).
4.17
The Pineapple Biosecurity Plan stresses the importance of a consistent
approach to threat identification and risk assessment, and argues that
facilitating a more coordinated strategy will provide a stronger base for
future risk management activities.[7]
4.18
As part of a coordinated approach, the Pineapple Biosecurity Plan
defines 'Emergency plant pests' as those that meet one or more of the following
criteria:
-
It is a known exotic plant pest, the economic consequences of an
incident of which would be economically or otherwise harmful for Australia, and
for which it is considered to be in the regional or national interest to be
free of the plant pest.
-
It is a variant form of an established plant pest which can be
distinguished by appropriate investigative and diagnostic methods, and which if
established in Australia, would have a regional or national impact.
-
It is a serious plant pest of unknown or uncertain origin which may, on
the evidence available at the time, be an entirely new plant pest, and which if
established in Australia would have an adverse economic impact regionally and
or nationally.
-
It is a plant pest of potential economic importance to the area
endangered thereby and not yet present there or widely distributed and being
officially controlled, but is occurring in such a fulminant outbreak form, that
an emergency response is required to ensure that there is not either a large
scale epidemic of regional or national significance or serious loss of market
access.[8]
4.19
The Pineapple Biosecurity Plan also argues that the identification of
high risk pests facilitates:
-
a more pre-emptive approach to risk management;
-
the implementation of effective grower and community awareness
campaigns;
-
targeted biosecurity and education and training programs for
growers and diagnosticians; and
-
the development of pest-specific incursion response plans.[9]
-
Listed on PHA plant pest priority list
Committee comment
4.20
The committee notes that PHA's description of the impact of Emergency
Plant Pests (EPPs) echoes the sentiments expressed by industry stakeholders over
the years. PHA argues that EPPs:
...have the potential
to deeply impact on the livelihoods of producers and others along the value
chain, damage the economic health of industries and regional economies, deplete
amenity values and food security for the broader Australian community, and
tarnish Australia's reputation as a producer of clean, quality product
internationally.[10]
4.21
The committee also notes that PHA supports the adage that 'prevention is
better than cure'[11]
and agree with industry stakeholders who argue very strongly that preventing
incursion is ultimately preferable to managing incursion:
When EPPs are
detected early enough, eradication may be an option, but these are invariably
expensive and technically challenging exercises with no guarantee of success.[12]
The import risk analysis for pineapples from Malaysia
4.22
The Department of Agriculture[13]
received a formal request for market access for fresh pineapple fruit to
Australia (from the Malaysian Department of Agriculture) in May 2004. The
Malaysian submission included information on the pests associated with
pineapple crops in Malaysia and the standard commercial production practices
for fresh pineapple fruit in Malaysia.
Timeline of events
4.23
Table 4.1 below provides a timeline of events in relation to the
Malaysian pineapple IRA.[14]
Table 4.1—Timeline of Malaysian pineapple IRA
|
May 2004
|
DA Biosecurity[15]
received a formal request from the Malaysian Department of Agriculture,
seeking market access for fresh pineapple fruit to Australia.
|
|
September 2007
|
DA Biosecurity advised stakeholders that changes to the
IRA process had been implemented when regulations made under the Quarantine
Act 1908 formally took effect. That advice also notified the transitional
arrangements for DAFF Biosecurity's import work program, including pineapples
from Malaysia that would be conducted under the new regulated IRA process.[16]
|
|
2009
|
A supplementary submission was provided by the Malaysian
Department of Agriculture.
|
|
January 2010
|
The scope of the request from the Malaysian government was
changed to consider fresh, decrowned pineapple fruit.
|
|
9 June 2010
|
DA Biosecurity formally announced the commencement of the
IRA on pineapples from Malaysia and advised stakeholders that it would be
progressed as a standard IRA, using the process described in the IRA
Handbook.
|
|
July 2010
|
DA Biosecurity met with industry representatives to
discuss development of the draft IRA report.
|
|
11 April 2011
|
DA Biosecurity provided a draft pest categorisation table
for decrowned pineapple fruit from Malaysia to state and territory
departments of primary industry/agriculture for their informal consideration
of regional pests.
|
|
19 October 2011
|
DA Biosecurity released the draft IRA report for a 60 day
stakeholder comment period.
|
|
25 November 2011
|
DA Biosecurity met with industry stakeholders.
|
|
Date unknown
|
Two submissions on the draft IRA report were received from
the pineapple industry representative, Growcom and from the Queensland
Department of Agriculture Fisheries and Forestry.
|
|
7 June 2012
|
DA Biosecurity notified stakeholders of the release of the
Provisional final IRA for fresh pineapple fruit from Malaysia. Stakeholders
were informed that the report had identified four species of mealybugs which
required quarantine measures to manage risks to a very low level (in order to
achieve Australia's ALOP).
Stakeholders were also informed that appeals could be
lodged (in writing) to the Import Risk Analysis Appeals Panel (IRAAP) –
within 30 days. The deadline for appeals was set as 7 July 2012.[17]
|
|
13 July 2012
|
DA Biosecurity notified stakeholders that an IRAAP had
been convened to consider an appeal submitted on the Provisional final IRA
report for fresh decrowned pineapple fruit from Malaysia.
The IRAAP Secretariat advised that one stakeholder had
provided a submission during the appeal period and that IRAAP would consider
the appeal and deliver a finding (or series of findings) in relation to the
appeal by 21 August 2012.[18]
|
|
14 December 2012
|
DA Biosecurity notified stakeholders that Australia's
Director of Animal and Plant Quarantine had determined a policy for the
importation of fresh decrowned pineapple from Malaysia, based on
consideration of the IRA for fresh decrowned pineapple fruit from Malaysia.
(In doing so, the Director provided guidance to the Department's permit
issuing staff to take account of the measures set out in the final IRA report
in considering applications for permits).[19]
|
Scope of the IRA[20]
4.24
The scope of the Malaysian pineapple IRA involved the consideration of:
...the quarantine
risk that may be associated with the importation of commercially-produced fresh
decrowned pineapple fruit Ananas comosus (L.) Merr. (decrowned pineapple
fruit) free from trash from Malaysia, for human consumption in Australia.[21]
4.25
In the IRA, decrowned pineapple fruit are defined as fruit with crown
and basal leaves removed. The IRA assessed all commercially-produced pineapple
fruit Ananas comosus (L.) Merr. varieties of Malaysia and the regions in
which they are grown.[22]
4.26
As noted above, Australia currently permits the importation of fresh
pineapple fruit from the Philippines, Thailand, Sri Lanka and the Solomon
Islands, subject to a range of phytosanitary measures, including decrowning.
4.27
The committee was told that Australian imports of pineapple from these
countries have been very limited. It was noted, for example, that there had
been a small number of pineapples imported from the Philippines in 2006. These
importations had however proved commercially unsuccessful. The committee also
received anecdotal evidence regarding a small amount of imported fruit which
had, over recent years, been provided to the Western Australian market.[23]
4.28
In conducting the IRA, DA Biosecurity indicated that it had considered
all pests previously identified in the IRAs for the importation of fresh
pineapple fruit from the Philippines, Thailand, Sri Lanka and the Solomon
Islands and taken them into account in the current policy where relevant. It is
noted that these IRAs recommended decrowning as a risk management measure to
meet Australia's ALOP.[24]
4.29
The Malaysian pineapple IRA also noted that standard hygiene and
cleaning practices, the registration of export grade fresh pineapple fruit
plantations and phytosanitary inspections further reduce the risk of weed species
entering Australia on decrowned fresh pineapple fruit.[25]
Results of the IRA
4.30
The Final import risk analysis report for the importation of fresh
decrowned pineapple (Ananas comosus (L.) Merr.) fruit from Malaysia (the
final IRA) identified four species of mealybugs as quarantine pests that
require measures to manage risk to a very low level in order to achieve
Australia's ALOP.[26]
4.31
Regional differences were identified for one quarantine pest—a mealybug
species—for Western Australia. DA Biosecurity indicated that the proposed
quarantine measures would take account of these regional differences.[27]
4.32
The final IRA report recommended a combination of risk management
measures and operational systems aimed at reducing the risk associated with the
importation of fresh decrowned pineapple fruit from Malaysia into Australia to
achieve Australia's ALOP. These measures included:
-
pre-shipment or on-arrival methyl bromide fumigation or an
alternative post-harvest treatment as approved by DA Biosecurity for mealybugs,
and;
-
an operational system for the maintenance and verification of the
phytosanitary states of pineapple fruit, including:
-
registration of export plantations;
-
registration of packing houses and auditing of procedures;
-
registration of fumigators/treatment facilities and auditing of
procedures;
-
packing and labelling requirements;
-
specific conditions for storage and transport;
-
pre-export phytosanitary inspection and certification by the Malaysian
Department of Agriculture; and
-
on-arrival phytosanitary inspection, remedial action when required, and
clearance by DA Biosecurity.[28]
Changes to final IRA
4.33
DA Biosecurity noted that following consideration of stakeholder
comments (in relation to the draft IRA) and a subsequent review of the
literature, a number of changes were made to the risk analysis. These
amendments included:
-
additional points have been included under 'probability of
importation and distribution' in the risk assessment of bacterial fruit
collapse and heart rot disease caused by Erwinia chrysanthemi (pineapple
strain, Dickeya sp.), and minor changes to the rating for consequences
(but not resulting in any change to the unrestricted risk estimate);
-
identification of the armoured scale, Unapsis citri, as a
pest of regional concern to South Australia;
-
a summary of major stakeholder issues and how they were
considered; and
-
minor corrections and rewording for consistency and clarity.[29]
Issues raised by stakeholders
4.34
The committee received submissions from a number of individual growers,
industry organisations and peak bodies which expressed a lack of confidence in
the Malaysian pineapple IRA, and its recommendation that imports of fresh,
decrowned pineapple should be allowed for all commercial production areas of
Malaysia (subject to a range of quarantine conditions).
Erwinia chrysanthemi (pineapple
strain, Dickeya sp.)[30]
4.35
Stakeholders, including the Queensland government, raised serious
concerns about DA's assessment of the risks posed to Australia's pineapple
industry by the importation of pineapples from Malaysia. Specifically, the
Queensland government and industry representatives argued that there was a lack
of knowledge and a limited understanding of the science in relation to the
pathogen Erwinia chrysanthemi recently renamed Dickeya sp. and
referred to by DA Biosecurity as Erwinia chrysanthemi (pineapple strain Dickeya
sp.).
Scientific background
4.36
The Malaysian pineapple IRA noted that in 1953, the bacterial species Erwinia
chrysanthemi was first proposed for the agent causing blight in
chrysanthemums. Similar bacteria were later isolated from soft rots and wilts
of numerous diseased plant species. Following extensive biochemical studies,
all isolates were gathered into the single species Erwinia chrysanthemi (syn.
Pectobacterium chrysanthemi. Subsequently, the genus Pectobacteriuym
was included within the genus Erwinia and in 1980, phytobateriologists
divided E. chrysanthemi into six pathovars.[31]
4.37
The use of pathogenicity tests to define the affiliation of a strain to
a given pathovar ultimately proved difficult to implement. Therefore, in the
early 1980s it was proposed that the pineapple strain be known as E.
crysanthemi (pineapple strain).
4.38
In 2005, Samson et al proposed a new genus—Dickeya—to
accommodate bacterial species previously assigned to E. chrystanthemi and
P. chrysanthemi and proposed six species of Dickeya.
4.39
However, the study found that the status of pineapple infecting strains
was unclear. A strain isolated from pineapples in Martinique (France) was
placed under Dickeya zeae and the strain isolated from pineapples in
Malaysia was placed under Dickeya sp. without being able to allocate it
into any of the other six Dickeya species.
4.40
In 2009, Parkinson et al attributed the Malaysian pineapple
infecting strain to D. zeae. However, this study used the gene sequence at
one locus and in 2011, the limitations of this type of approach were
highlighted.
4.41
In 2010, Peckham et al argued that until the pineapple strains
are genetically characterised, the strains infecting pineapples should be
referred to as unclassified Dickeya sp. Marrero et al argued (in
2009 and 2010) that the pathogen infecting pineapple warranted classification
as a new species or subspecies of D. zeae. Most recently (2011)
Marrero and Alvarez used the name E. chrysanthemi (Dickeya sp).
Defining the pest
4.42
The Malaysian pineapple IRA noted that 'even after several decades of
work, the position of the Malaysian pineapple affecting strains has not been
resolved satisfactorily'.[32]
However, it was also noted that international guidelines for Pest Risk Analysis
require that the identity of pests be 'clearly defined to ensure that the
assessment is being performed on a distinct organism and that the biological
and other information used in the assessment is relevant to the organism in
question'.[33]
It was decided, therefore, that in order to avoid confusion, and for the
purposes of the IRA, the pineapple affecting strain would be referred to as Erwinia
chrysanthemi (pineapple strain, Dickeya sp.).
4.43
The Malaysian pineapple IRA notes that the strain of the bacterium E. chrysanthemi
infecting pineapple in Malaysia is specific to pineapple and that recent
molecular studies 'support that the Malaysian pineapple strain is distinct'.[34]
Fruit collapse and bacterial heart
rot
4.44
The strain of Erwinia chrysanthemi infecting pineapples in
Malaysia causes two diseases—fruit disease called 'fruit collapse' and a leaf
and stem disease called 'bacterial heart rot'. Both diseases have been known in
the Malaysian pineapple industry from around 1937. It has been reported that
both diseases are now present in Costa Rica, the Philippines and Brazil.
4.45
In 2003, Dickeya sp. was discovered in Hawaii and it has been
suggested that the first appearance of the pathogen in Hawaii 'coincided with
importation of planting material from Costa Rica, Honduras, and Philippines'.[35] Although
strains of E. chrysanthemi infecting other hosts including corn,
potato, banana and ginger are present in Australia, the specific strain
infecting pineapple in Malaysia is considered absent.
Threat to Australian pineapple industry
4.46
Stakeholders pointed to the inclusion of the pathogen Dickeya sp.
on the Pineapple Biosecurity Plan's 'Emergency plant pest priority list',[36] and noted
that the Pineapple Biosecurity Plan lists the level of threat (in relation to
this pathogen) as 'high' for entry potential, establishment potential, spread
potential, economic impact and overall risk.[37]
It was argued, therefore, that the estimation of risk from this pathogen in the
Pineapple Biosecurity Plan is in stark contrast to the IRA prepared by DA
Biosecurity.[38]
4.47
It was argued that both fruit collapse and bacterial heart rot pose
'serious biosecurity threats to the Queensland pineapple industry',[39] particularly
as both diseases are systemic (able to spread throughout the whole plant and
the fruit) and the pathogen can remain latent in fruit—even after harvest.[40]
4.48
The Queensland Department of Agriculture, Fisheries and Forestry (DAFF
Queensland) submission stated that:
DAFF Queensland
scientists are of the opinion that these two diseases would have a high risk of
spreading to Australia in imported fruit, even under strict inspection
procedures.
In Malaysia, both
diseases are endemic, with field crop losses of up to 40% recorded. These
diseases were detected in Hawaii in 2003, and have subsequently caused
significant crop losses.
Australia has very
similar climatic conditions and pineapple varieties to both Hawaii and
Malaysia. Therefore the impact of this disease in Australia could reasonably be
expected to approximate the field losses (up to 40 percent) reported from
Malaysia.[41]
4.49
The Malaysian pineapple IRA indicated that the prevalence of the pathogen
causing fruit collapse in Malaysian pineapple production systems has, over the
past 50 years, been reported at various levels—ranging from 0–40 per cent. The
IRA also noted that while there were no specific figures available regarding
the incidence of fruit collapse in the new 'Josapine' and 'N36' varieties, 'the
incidence of heart rot has been demonstrated to cause losses as high as 64 per
cent in the 'Josapine' variety'.[42]
Undetected (latent) infections
4.50
The Malaysian pineapple IRA noted that 'while the greatest incidence of
fruit collapse can be observed in the field and such fruit excluded from
harvest',[43]
there is also research which indicates that a small percentage (up to 2 per
cent) of fruit 'can remain as undetected latent infections beyond the initial
picking phase'.[44]
4.51
Stakeholders raised concerns about the possible latency of infection in
pineapple fruit. The IRA report indicated, for example, that in the case of
fruit collapse, the pathogen 'enters the plant through the flower and remains
latent in the developing fruit for over 2 months'.[45] Stakeholders argued that
this is problematic, particularly as it means that up to 2 per cent of fruit
with latent infections could go undetected at harvest.
4.52
The Malaysian pineapple IRA noted that the percentage of fruit collapse
is highest 2–3 weeks before harvest. It was also noted that:
DAFF agrees, like any
other biological process, latency break and symptom expression times are
variable and as seen from Liam and Lowings (1979), up to about 2% of fruit may
not have expressed symptoms at harvest and may still have latent infection.[46]
Uncertainty about latency
4.53
Stakeholders also challenged the credibility of the 2 per cent latency
figure cited in the IRA. It was noted, for example, that although the IRA
report referred to Lim (1986) and Lim and Lowings (1979) to support the 2
per cent figure, the reliability of this information was questionable, given
that it relies on data originally published in 1937 (Thompson).[47]
4.54
Officers from DA Biosecurity acknowledged that 'up to two per cent of a
consignment [of pineapples] will have a latent infection'[48] and argued that the two
per cent latency figure is based on scientific research conducted in Malaysia
and published in scientific journals.[49]
In addition, DA Biosecurity also told the committee that:
The disease usually
expresses two to three weeks before harvest. You will see it on the pineapples
in the field; it will be quite obvious and it might be explosive in some cases.
Obviously they are not going to pick those pineapples that are rotting and not
very good. These are commercial plantations sending to an export market. They
are looking to send the best fruit they can. The latency does not always break
two or three weeks before harvest but the majority of them well, so you will
see those symptoms on the fruit. Those will be excluded. So it will be there
some time before you take them off and put them through the processing plant
for export. There will be up to two per cent – and we have used a very
conservative figure. That does not mean to say that every pineapple plantation
in Malaysia will have two per cent latency in their fruit, but we were looking
on the conservative side that up to two per cent will – and in may be fewer
than that.[50]
4.55
The Malaysian pineapple IRA also indicated that the Malaysian Department
of Agriculture had provided some preliminary unpublished results from a field
and packing house survey conducted in April 2012. The survey was designed to
evaluate current rates of infection of pineapple fruit with the fruit collapse
bacterium E. chrysanthemi and latency in export production systems.[51]
4.56
The IRA noted that the results of the survey were based on pineapples
sampled from several fields and packing houses during the export packing
process, and generally supported the possibility of fruit carrying lower levels
of latent infection at harvest than indicated in the Lim and Lowings papers in
the 1970s. It was acknowledged, however that 'DAFF is unable to fully assess
this survey and trial with the limited methodological details and data
provided'.[52]
4.57
The issue of latent infection rates and the audit process was raised
with peak industry body Growcom at the committee's August hearing:
Senator BOSWELL: We are in Malaysia. Someone is going to bring in
some pineapples... Do you know what would be required in the audit?
Dr Gambley: I do not believe that they can audit for latently
infected fruit in Malaysia. They can audit for fruit that is obviously showing
symptoms and discard that fruit, but you cannot audit for something that is not
showing disease. It would be packed and sent without detection.
Senator BOSWELL: So there is no way of knowing that the particular
fruit could be diseased and there is no way of auditing it through the packing
house. All you can audit is something that has the symptoms of the disease?
Dr Gambley: That is correct.[53]
4.58
Mr Alex Livingstone, Chief Executive Officer of Growcom, agreed that the
disease, in its latent phase, is undetectable and therefore it is likely that
diseased fruit will be picked and shipped without being detected. Mr
Livingstone argued that, as a consequence:
When that fruit comes
into Australia it would bring the disease in with it. A serious point of
contention is whether or not the disease will spread from there. We contend
that the imported fruit could find its way anywhere around the retail
distribution chain. It could find its way into the processing chain. Nobody
knows what happens to the waste product. If a consumer buys a pineapple that is
imported and this disease starts to take hold, the fruit will look unappealing
and they will just toss the whole thing in the bin. So where does that end up?
We do not know.[54]
4.59
It was argued that the latency of the pathogen is just one of a number of
areas where scientific information is inadequate and inconclusive. It was further
argued the lack of conclusive information about the latency of the pathogen is
unsatisfactory it is an area that should be researched and tested properly.[55]
Committee comment
4.60
It is clear to the committee that there is considerable uncertainty
surrounding latent infection rates of Dickeya sp., particularly as DA
Biosecurity's best estimate of up to 2 per cent post-harvest latency is based
on a study from the 1970s, which itself is based on research from the 1930s.
The committee notes that DA was unable to fully assess a 2012 survey conducted
by the Malaysian Department of Agriculture due to the provision of limited
methodological details and data. The committee strongly supports the collection
of more robust data and further analysis of this critical issue, prior to the
commencement of any imports of fresh pineapple from Malaysia.
Recommendation 9
4.61
The committee recommends that before commencing the importation of fresh
pineapples from Malaysia, the Department of Agriculture should establish to a
much greater degree of certainty the degree of post-harvest latency of
pineapple fruit collapse and heart rot.
DA Biosecurity has underestimated
the risk
4.62
Stakeholders also argued that DA Biosecurity has underestimated the risks
associated with Dickeya sp. It was claimed that DA Biosecurity not only
underestimated the risk of the pathogen's arrival in Australia, but also
underestimated the pathogen's potential to be distributed within Australia, to
become established, and to spread.
4.63
The IRA contains a detailed assessment of the various preconditions
necessary for an incursion of the pineapple fruit collapse and heart rot
pathogen Dickeya sp. to occur.
Importation risk: low
4.64
The IRA concludes that there is a low likelihood that Dickeya sp.
will arrive in Australia as a result of the importation of decrowned pineapple
fruit from Malaysia. It is argued that:
As the exported fruit
will be without crowns and all basal leaves, the association of the pest with
the pathway would be only as the fruit collapse disease and not as the heart
rot disease.
Although the
incidence of fruit collapse in Malaysian pineapple plantations can sometimes be
as high as 40%, the biology of the disease is such that infected fruit can be
easily detected before or at harvest and inclusion of infected fruit in exports
will be reduced to a high degree. However, a small volume (estimated as up to
2%) of export fruit may contain latent or visibly undetectable infection.
Therefore the likelihood estimate for importation is ‘low’.[56]
4.65
Mr Glenn Taniguchi, Entomologist and Plant Pathologist from the
University of Hawaii provided his views on evidence provided by DA Biosecurity
and raised questions about how the figure of two per cent was arrived at:
Throughout this
testimony the figure of 2% risk of importing infected fruits into Australia is
mentioned. The question of how this figure was derived has not been answered.
Is this an arbitrary number to coincide with "low risk"? A 2% risk
cannot be a fixed figure when dealing with infections with Dickeya sp.
because field infections fluctuate with weather conditions. Normal field
infection ranges between 5% and 40%. Thus your risk goes up when field
infection is higher.[57]
4.66
Tropical Pines noted the concerns raised about Dickeya species (and
the dangers of importing pineapples from Malaysia) by scientists in both Hawaii
and Malaysia. Tropical Pines suggested that these concerns 'may have been
ignored because their concerns have not been published as peer reviewed
scientific papers'.[58]
4.67
Tropical Pines also argued that the Department of Agriculture's own
estimate is that infected pineapples will be imported into Australia at a rate
of 2 per cent, and that the 'infection will be in a latent form and completely
undetectable'. Tropical Pines therefore asked the question:
If, as DAFF biosecurity says, the disease would be very
difficult to eradicate, why take any form of risk to allow the entry of a
potentially damaging pathogen? While 2% may seem a low incidence, in real terms
it amounts to 2 cases in every 100 cases of fruit. i.e. 14 fruit per pallet.[59]
4.68
In its supplementary submission to the inquiry, Tropical Pines told the
committee that by working through the IRA, they had 'reached very different
conclusions about the overall risk of this bacterium'.[60] It was argued that:
The probability of importation has been assessed by DAFF
Biosecurity to be low. Our view is that the risk of importation is certain or
high as it has been acknowledged that the bacterium will enter Australia in 2%
of the fruit that is imported.[61]
4.69
Growcom's submission expressed a similar view to that of Tropical Pines
in relation to the risk of importing the pathogen, and noted that:
It is the industry's position that DAFF Biosecurity has
significantly underestimated the risk posed by the potential introduction of a
bacterial pathogen that causes serious fruit disorders and crop failure.[62]
Distribution
risk: low
4.70
The IRA concludes that there is a low likelihood that the pineapple
heart rot and fruit collapse pathogen Dickeya sp. 'will be distributed
within Australia in a viable state as a result of the processing, sale or
disposal of decrowned pineapple fruit from Malaysia and subsequently transfer
to a susceptible part of a host.'[63]
4.71
The IRA also states that the waste from any fruit carrying the latent
infection would be 'discarded mostly into municipal waste by retailers, consumers,
or processing plants.'[64]
It goes on to describe the possible transfer mechanisms of the pathogen from
infected fruit in waste to a susceptible host plant as a 'complex variable'
which is dependent on a number of critical factors including:
...the location of
the bacteria; survival in waste and viability; survival in water; survival in
soil; transfer mechanisms; availability of hosts; host susceptibility and entry
points; and inoculum source, dose and host proximity.[65]
4.72
In summary the IRA concludes that:
...with a host range
limited to pineapple, a number of factors would need to align in order to
facilitate a successful transfer of this pathogen to a susceptible host. A
freshly discarded infected fruit or infected waste would need to be in close
proximity to a susceptible pineapple plant, with suitable vectors in the direct
vicinity.
...
Potential vectors and
agents of transfer are available; however, the transfer opportunity for ants
and beetles and the viability of the bacterium in soil and water is short.
Considering the low volume of fruit expected to be imported into Australia and
distributed to and potentially disposed of in areas near pineapple production,
the number of infected fruit that are likely to come in close proximity to
susceptible pineapple plants would be limited. This will minimise the
likelihood of achieving all the necessary factors for a successful transfer.
Therefore the likelihood estimate for distribution is ‘low’.[66]
4.73
However, this is not the conclusion of other stakeholders. At the
Brisbane hearing, Mr Alex Livingstone, CEO, Growcom, noted that, according to
the pineapple industry's national biosecurity plan, the Dickeya sp. pathogen
is one of the pineapple industry's greatest biosecurity threats. Mr Livingstone
also noted that in the Pineapple Biosecurity Plan the 'level of threat was
estimated to be high for entry potential, establishment potential, spread
potential, economic impact and overall risk'.[67]
4.74
Mr Livingstone argued that the disease's spread potential is a serious
point of contention. He told the committee that it was Growcom's position that:
...the imported fruit could find its way anywhere around the
retail distribution chain. It could also find its way into the processing
chain. Nobody knows what happens to the waste product. If a consumer buys a
pineapple that is imported and this disease starts to take hold, the fruit will
look unappealing and they will just toss the whole thing in the bin. So where
does that end up? We do not know.
There has been no work done on what are called vectors or
methods of transmission of the disease around Australia. That work cannot be
done, because the disease is not here and some of the proposed vectors are
native Australia. Therefore, you cannot do the research without matching those
two up. We do not know how much transmission would happen through native
Australian species.[68]
4.75
NQ Paradise Pines raised similar concerns regarding the disposal of
waste:
The possibility of infected fruit from Malaysia being
purchased for example by a processor, who would be after a quantity of cheaper
fruit, opens the door for the potential waste of cores and peel being dumped in
a pineapple growing area with a very high chance of disease spreading to
growing plants.[69]
4.76
It is worth noting that Department of Agriculture officials acknowledged
at the hearings that once fresh pineapples from Malaysia passed Australia's
border controls, there would be no restriction on where they can be
distributed:
If they have cleared
the border, and we are satisfied that they have met our conditions, they can go
wherever.[70]
4.77
Furthermore, departmental officials explained that the shelf life of
pineapples, and their rate of deterioration once they have cleared the border,
'is not relevant from the biosecurity perspective.'[71]
Establishment
and spread risk: high
4.78
The IRA concludes that if Dickeya sp. were to achieve entry into
Australia, the probably of establishment would be high:
The presence of the
vectors of the disease and suitable environmental conditions in Australia, the
strong reproductive and survival characteristics of the pest within pineapple
plants, and a lack of fully effective cultural practices and control measures,
all support a likelihood estimate for establishment of ‘high’.[72]
4.79
The IRA further concludes that once established, the likelihood of Dickeya
sp. spreading within Australia is high:
Suitable
environmental conditions and the presence of vectors in Australia, the intended
use of the commodity, short distance movement with fruit and long distance
movement with infected planting material, all support a likelihood estimate for
spread of ‘high’.[73]
4.80
DA Biosecurity's assessment of the risk of the pathogen's spread as
high, was one conclusion stakeholders were able to agree on.[74]
Committee comment
4.81
The committee notes DA Biosecurity's assessment in relation to the
probability of entry, establishment and spread of Dickeya sp. – the
pathogen responsible for pineapple fruit collapse and heart rot.
4.82
It is clear to the committee that DA Biosecurity has undertaken an
extensive assessment, but harbours concerns about the assessment in two
important areas.
4.83
First, DA Biosecurity has assessed the probability of importation as 'low'.
In the committee's view this appears to defy common sense. Although there is
some uncertainty surrounding the precise figure, the Pineapple IRA has
estimated that there is a two per cent latency rate post-harvest. The committee
understands this to mean that for every 100 pineapples imported from Malaysia,
up to two would be infected with Dickeya sp. but show no visible signs
of fruit collapse and heart rot at the time of quarantine inspection.
4.84
The committee notes that, based on 2009-10 data, were Malaysian
pineapples were to capture just one per cent of the domestic fresh pineapple
market, up to approximately 8.5 tonnes of imported fresh pineapple would
contain the undetected Dickeya sp. pathogen, and would be free to enter
the Australian domestic fresh pineapple market.
4.85
Based on the above scenario, it is the committee's view that, should the
proposal to import proceed, it is almost certain that pineapples infected with
the Dickeya sp. pathogen will be imported into Australia. The committee
therefore does not support the IRA's conclusion that the risk of importation of
the Dickeya sp. pathogen is low and would expect a significantly higher
probability to be assigned.
4.86
Second, as noted earlier, DA has no role in the process of post-quarantine
control. Departmental officials told the committee that once cleared at the
border 'they can go wherever'.[75]
The committee acknowledges the complex path that would be required to
distribute the Dickeya sp. pathogen from a retail outlet to pineapple growing
areas. However, the committee has, over the years, observed many examples of
flagrant biosecurity risks which were entirely unpredicted and unanticipated.[76]
4.87
The committee is well aware that humans do not always act in entirely
rational and predictable ways. It is for this reason that the committee does
not support the IRA's conclusion that the risk of distribution of the Dickeya
sp. pathogen is 'low' and would expect a moderately higher probability to be
assigned.
4.88
The committee concludes, therefore, that DA Biosecurity should review
its assessment of the probability of importation and the probability of
distribution. If a risk above Australia's ALOP were to emerge, then the
committee expects stronger mitigation measures would be required.
Recommendation 10
4.89
The committee recommends that the Department of Agriculture review its
assessment of the probability of importation and the probability of
distribution of the Dickeya sp. pathogen. 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
Malaysian pineapples to Australia should not be permitted.
Assessment of consequences[77]
4.90
DA Biosecurity noted that, in terms of the IRA process, the objective of
the consequence assessment is to provide a structured and transparent analysis
of the 'likely consequences if the pests or disease agents were to enter,
establish and spread in Australia'.[78]
It is also stated that the assessment considers 'direct and indirect pest
effects and their economic and environmental consequences'.[79]
4.91
According to DA Biosecurity, the IRA considered the direct pest effects
in the context of the effects on plant life or health and other aspects of the
environment. However, indirect pest effects are considered in the context of
the effects on:
-
eradication, control etc;
-
domestic trade;
-
international trade; and
-
environment.
4.92
As previously indicated in Chapter 3, for each of the criteria listed
above, the consequences were estimated over four geographic levels, defined as:
-
Local: an aggregate of households or enterprises (a rural
community, a town or a local government area).
-
District: a geographically or geopolitically associated
collection of aggregates (generally a recognised section of a state or
territory, such as 'Far North Queensland').
-
Regional: a geographically or geopolitically associated
collection of districts in a geographic area (generally a state or territory, although
there may be exceptions with larger states such as Western Australia).
-
National: Australia wide (Australian mainland states and
territories and Tasmania).
4.93
The magnitude of the potential consequences at each of these levels is
then described, using the categories of indiscernible, minor significance,
significant and major significance.
4.94
Estimates of the magnitude of the potential consequences over the four
geographic levels were translated into a qualitative impact score from A to G
using the Pineapple IRA's Table 2.3.[80]
For example, a consequence with a magnitude of 'significant' at the 'district'
level will have a consequence impact score of 'D'.
Table 2.3 Decision
rules for determining the consequence impact score based on the magnitude of consequences
at four geographic scales
|
|
|
Geographic
scale
|
|
|
|
Local
|
District
|
Region
|
Nation
|
|
Magnitude
|
Indiscernible
|
A
|
A
|
A
|
A
|
|
Minor
significance
|
B
|
C
|
D
|
E
|
|
Significant
|
C
|
D
|
E
|
F
|
|
Major
significance
|
D
|
E
|
F
|
G
|
4.95
The overall consequence for each pest is achieved by combining the
qualitative impact scores (A–G) for each direct and indirect consequence using
a series of decision rules.[81]
These rules are mutually exclusive, and are assessed in numerical order until
one applies.
Committee comment
4.96
Any 'consequence assessment' in relation to a crop such as pineapple
must take into consideration its growing conditions. As indicated earlier in
this chapter, to ensure optimum growth rates, pineapple is a crop that requires
temperatures between 32˚
Celsius during the day and 20˚Celsius
at night, well-drained soil and rainfall in excess of 750 mm, evenly distributed
throughout the year.
4.97
These specific growing conditions mean that pineapple is not a crop that
will ever be grown in Australia's arid centre or its more temperate climates.
This, therefore, excludes vast areas of Australia. Even on a regional scale, pineapples
will never be suitable to be grown across all parts of Queensland – some parts
of the state will be too hot and others too cold or too dry.
4.98
The committee is concerned, therefore, that because the growing
conditions for pineapples are limited to a relatively small geographic area,
the DA Biosecurity rules applied in tables 2.3 and 2.4 of the Pineapple IRA
mean that regardless of how serious the impact of a pest may be on the
pineapple industry, the consequence could never be rated above 'moderate'.
4.99
The committee also notes that DA Biosecurity also rated the consequence
to 'plant life and health' as 'significant at a regional level'. 'Significant'
is said to be related to a moderate increase in mortality/morbidity, or a moderate
decrease in production. The committee is of the view that losses of 40 per cent
and up to 64 per cent would better be described as a 'large decrease in
production' which equates to a 'major consequence' rating. The committee notes
that a 'major consequence' rating would then shift the overall consequence to
'high' rather than 'moderate'. Based on this scenario, the overall rating would
be increased to 'low' which is above Australia's ALOP.
Recommendation 11
4.100
The committee recommends that the Department of Agriculture review its
assessment of the consequences of the establishment of the pineapple heart rot
and fruit collapse pathogen Erwinia chrysanthemi (pineapple strain, Dickeya
sp.) 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 Malaysian pineapples to Australia
should not be permitted.
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