Draft Pest Risk Analysis

for cut flower and foliage

imports – part 1

Victorian Farmers Federation and Flowers

Australia Submission

The Victorian Farmers Federation The Victorian Farmers Federation (VFF) is the only recognised consistent voice on

issues affecting rural Victoria and we welcome the opportunity to comment on the

draft Pest Risk Analysis for cut flowers and foliage:

Victoria is home to 25 per cent of the nation’s farms. They attract neither government

export subsidies nor tariff support. Despite farming on only three per cent of

Australia’s available agricultural land, Victorians produce 30 per cent of the nation’s

agricultural product. The VFF represents the interests of our state’s dairy, livestock,

grains, horticulture, flowers, chicken meat, pigs and egg producers.

The VFF consists of a nine person Board of Directors, with seven elected members

and two appointed directors, a member representative General Council to set policy

and eight commodity groups representing dairy, grains, livestock, horticulture,

chicken meat, pigs, flowers and egg industries.

Farmers are elected by their peers to direct each of the commodity groups and are

supported by Melbourne-based and regionally located staff.

Each VFF member is represented locally by one of the 200 VFF branches across the

state and through their commodity representatives at local, district, state and national

levels. The VFF also represents farmers’ views on hundreds of industry and

government forums.

David Jochinke

President

Victorian Farmers Federation

Farrer House

24 Collins Street

Melbourne 3000

p 1300 882 833 f 03 9207 5500

e vff@vff.org.au w www.vff.org.au

Contact: Alana Pittard

VFF Horticulture Manager

Foreword

The Victorian Farmers Federation and Flowers Australia welcome the opportunity to comment on

the Draft Pest Risk Analysis for Cut flower and foliage imports – Part 1 (PRA).

This submission is made on behalf of the Victorian farmers who are involved in plant industries

covering Flowers Victoria, VFF Horticulture Group and VFF Grains Group.

Flowers Australia is the national body representing flower growers, wholesalers and florists. Flowers

Australia represents over 400 members in these industries.

The horticulture industry in Victoria with a farm gate value of approximately $2.4 billion, is made up

of 3500 businesses and employs over 60,000 people during the peak harvest period. Victoria is the

nation’s leader in horticulture production and with many Victorian based horticulture businesses

also investing in other states but preferring to have their headquarters based in Victoria. Victoria

produces more than 30% of Australia’s cut flowers and foliage and most years represents more than

50% of Australia’s horticultural exports.

The Victorian vegetable industry has a value of more than $950 million and is Australia’s largest

exporter of vegetables with around 30% of the export value. It is the largest Australian producer of

broccoli, mushrooms and asparagus (95% of Australia’s national Asparagus crop).

The Victorian grains industry is worth more than $1.6 billion. While wheat remains Victoria’s largest

crop Victoria also produces high quality barley and is a significant producer of pulses such as lentils

and canola.

Introductory comments The timing of the Department of Agriculture and Water Resources consultation period coincides

with peak harvest period for most Horticultural and Grain producers. This is extremely disappointing

given the importance of the issue and the wide reaching ramifications of the information contained

in the draft pest risk analysis. The information contained points to an almost systemic failure of the

DAWR to acknowledge they are far from effectively managing the biosecurity threats posed by

imported cut flowers and foliage.

The VFF notes that during 2018 DAWR have been developing a National Biosecurity statement,

highlighting the need for the broader community to be aware of biosecurity and the impact

biosecurity threats can have on our agricultural sector, environment and way of life. While at the

same time allowing cut flower and foliage importers to directly put at risk Australia’s plant

industries.

The VFF believes for the report to be considered complete, additional information must be included

in a number of sections of a revised PRA. There is also a need for the report to be far more broadly

discussed with the wider plant industries given the threat the horticulture, grains and cotton

consideration in the development of the 2018 protocols. Data should then be provided to highlight

whether the 2018 protocols have so far been more effective in reducing the number of

interceptions.

Question: Given the high level of risk to plant industry biosecurity posed by imported flowers and

foliage what level of financial contribution are the flower importers paying towards Plant Health

Australia?

Concern regarding the efficacy of pre-shipment fumigation

The VFF wishes to express concern regarding the efficacy of the pre-shipment treatments being

undertaken in exporting countries. The VFF also have concerns about the accuracy of the records

being provided by the fumigation facilities with regards to the treatment of flowers and foliage. It

appears that either the pre-shipment fumigation is ineffective, the chemical rates being used are not

appropriate or the shipments are not being consistently treated regardless of what the

documentation implies. No other explanation accounts for the appallingly high level of interceptions

and non-compliance still being recorded.

Question: Given the high level of interceptions of live insects what number of facilities audits have

been undertaken by independent and appropriately qualified Australian quarantine staff?

Concerns regarding broader risks from pests as vectors for disease and resistance

There is the obvious risk of allowing insects, which are known or potential vectors for diseases and

viruses into Australia. USA researcher George Agrios of the University of Florida, discusses insect

transmission of xylem-inhabiting bacteria (including specific reference to some of those pests have

been detected in flower imports) and the possibility of virus transmission by mites. This includes

Tetranychid mites that can transmit viruses, such as two spotted mites (Tetranychus urticate)

currently classed as non-actionable by the department.

The other concerning factor is the likelihood pesticide resistant strains of insect are entering

Australia. The risk is they will enter the local pest population, increasing their levels of pesticide

resistance amongst the local population.

When a pesticide is first used, a small proportion of the pest population may survive exposure due to

their distinct genetic makeup. These individuals pass along the genes for resistance to the next

generation. Subsequent uses of the pesticide increase the proportion of less-susceptible individuals

in the population. Our concern is that through this process undesirable change in the gene pool of

overseas pests has resulted in a form of artificial selection favouring pesticide resistance.

These resistant individuals can reproduce and pass on their resistance to the offspring. Resistance

may develop to only a single insecticide. However, it is more common for insects that exhibit

resistance to one insecticide to be resistant, or develop resistance more rapidly, to other insecticides

with the same Mode of Action (MOA). This phenomenon is known as cross-resistance.

Internationally, pest species are becoming resistant to pesticides at an increasing rate so introducing

them into Australian pest populations is something our biosecurity system should be preventing at

all costs.

industries have now been exposed to from importation of two spotted mite, aphids and thrips,

added risk of chemical resistance not to mention the diseases the pests may be vectors for.

Key concerns:

There are gaps in the data provided within the report, which should be addressed, for

example why is even a three month outline of initial data about the effectiveness of the

import protocols implemented in March 2018 not included in the report?

The information about non-compliance and actions taken against importers guilty of non-

compliance needs to be provided.

The lack of transparency regarding the membership of the cut flower and foliage working

group need to be remedied. If, as is suspected, there is insufficient representation from

Australian flower and foliage producers or appropriate representative bodies this needs to

be immediately addressed,

Risk analysis areas appears to lack input from Australian producers, in particular the section

dealing with the distribution and use of imported cut flowers and foliage is particularly brief,

Fumigation efficacy and the process for auditing and verifying that fumigators are meeting

the required standard should be more clearly outlined. Audit results should be provided,

The biosecurity risk posed by the pests entering Australia on non-compliant shipments is of

concern, the potential for those pests to be vectors for far more dangerous plant biosecurity

threats such as xylla has not been adequately acknowledged nor addressed in the report,

and

An analysis of the control options available in Australia for two spotted mite, aphids and

thrips should be included in the assessment of level of risk. Two spotted mite, Aphids and

thrips should be considered high risk because of the lack of control options and the

scientifically recognised risk of imported bugs fostering accelerated resistance to the only

chemical control options we have available in Australia.

Victorian Farmers Federation recommendations In the interests of transparency, there is a need for data, which in some cases has been relegated to

the extensive appendices of the document to be brought forward into the main report.

The VFF also notes there are a number of areas where it appears data is available but for some

reason the data has been excluded from the report. Whilst the data regarding the efficacy of the

import protocols implemented in March 2018 may not make comfortable reading it is data that is

crucial to establishing the report as an accurate reflection of our current situation. It is also crucial to

providing a fair and frank assessment of the effectiveness of the “current” protocols and

enforcement regime.

It is important the report makes it clear whether the Government are capable of giving priority to

the biosecurity needs of Australian based plant industries. Currently Australian farmers are having

pest control options reduced, are paying for the management of a significant number of pest

incursions and are also being put under pressure by Government to implement traceability programs

to support biosecurity and market access. Yet at the same time Australian plant industries are being

put under threat by a lack of transparency regarding a well-recognised and significant threat to

biosecurity from imported cut flowers and foliage.

Plant pests, which are likely to have entered through cut flower and foliage imports that have

already had an impact on horticulture and other plant industries across Australia:

Russian Wheat Aphid

Chrysanthemum White Rust

Western Flower Thrip

Myrtle Rust

Alstomeria Gall Midge

Product Traceability

Dealt with briefly in section 2.4.1 and 3.1.2 is product traceability and Country of Origin labelling.

Recommendation: Country of Origin Labelling needs to be reconsidered, given the high level of non-

compliance, traceability and the ability to investigate and where necessary take actions against

exporting countries for non-compliance with certification requirement.

Pest risk analysis

Section 3.1.1 provides a brief outline regarding the perishability of cut flowers. It also provides a

clear illustration of where assumptions have been made which led to an under-estimation of the

pest risk posed by cut flowers and foliage.

Relying on The Draft ISPM International movement of cut flowers and foliage (FAO & IPPC 2017)

could prove highly dangerous for Australia. While the PRA acknowledges the limitations of the ISPM

we believe additional information should be included in this section to clearly outline the increased

level of risk posed by factors such as:

Speed with which cut flowers and foliage are distributed across Australia,

High potential for spent flowers and foliage to be inappropriately disposed of, including in

poorly managed home composting systems rendering ability for pests to thrive in urban

backyards on host plants, especially relevant in city areas where it has become popular to

have highly productive fruit and vege gardens,

Growing popularity of vineyard and outdoors weddings leading to flowers being used to

decorate highly susceptible venues,

Growing popularity of petals for use in Weddings and multi-cultural special events,

Due to lack of country of origin labelling on flowers and foliage it would be difficult for aware

and discerning purchasers to reduce their own biosecurity risk by only purchasing Australian

grown flowers and foliage.

Imported Cut Flowers and Foliage Regulation Working Group

Section 4.3 provides an overview of stakeholder consultation, further information is provided in

Appendix B. Membership of the Working Group should be provided within the report. It is important

there is transparency regarding the group that has been presented as having a key role in the

engagement across industry sectors regarding the biosecurity risk posed by cut flowers and foliage.

Despite 30% of Australia’s cut flowers and foliage being produced in Victoria we can find no

evidence to suggest a Victorian based representative organisation was invited to join the Working

Group. There is also a need for more inclusive consultation with the broader agricultural sectors that

could be impacted by pests brought in through the importation of cut flowers and foliage. The

Working Group lacks the appropriate level of representation from the grains and horticulture sectors

in addition to the lack of a representative number of true Australian grown flower industry

representatives. This is an urgent issue that needs to be addressed.

Recommendation: Given the high level of risk to the domestic Australian cut flower and foliage

industry and the potentially high impact of biosecurity impact on the broader plant industries

additional representation from State Farming Groups and national bodies should be sought.

Question: In July 2018 the department announced the PRA through a Biosecurity notice and

factsheet on the Department’s website. Why was the notice not sent to all plant industry signatories

to the Emergency Pest Plant Response Deed (EPPRD)?

Recommendation: The Department has access to information regarding all signatories to the EPPRD,

they should send all documentation relevant to plant industry bodies with a responsibility for

biosecurity to EPPRD signatories as a matter of requirement.

It is noted that Appendix B states correspondence was undertaken with importers due to on-going

non-compliance with the March 2018 import protocols from importers and their suppliers. The

report was not released until November 2018 but no further detail of compliance actions is

provided. It would be reasonable to expect an outline of compliance activities and penalties imposed

for continued non-compliance.

Interception data points to system wide problems and threatens Australian biosecurity

Section 5.2 of the PRA notes that from January 2000 to February 2018 more than 38,000

interceptions of live arthropods occurred. The report notes that only 37% were identified to species

level meaning the danger from some species could be far greater than identified.

It is also disappointing to the Australian industries that despite this section of the report noting the

inherent quarantine pest containment risk, the high number of interceptions and the ever increasing

number of interceptions the report somehow still concludes that Australia can reach an appropriate

level of protection (ALOP).

In 2017 alone, the information in table 5.1 shows that 82% of consignments from Kenya were found

to contain live arthropods, 81% from India and China, 78% from Colombia, 54% from Vietnam, 47%

from Ecuador (significant because of the large number of imports from this country). These figures

are simply unacceptable.

Recommendation: Section 5.2, should be followed by a section containing detailed information on

remedial actions taken and penalties or actions imposed on the higher risk importers. It is not

enough to simply note in the conclusion 5.4 that the interception rate data was taken into

Conclusion

The VFF is deeply concerned about the level of protection able to be achieved under the current

import conditions and given the current high level of non-compliance by cut flower and foliage

importers. The risk to the Australian plant industries is high and yet an appropriate level of

consultation and consideration has not been awarded. While flower importers have had the ear of

the Department the Australian industries being put at risk have been kept from the discussion table.

The entire situation outlined in the PRA is of considerable concern to the VFF and we expect a higher

level of consideration to be granted to the Australian based industries and peak industry bodies

during the next steps in this consultation process.

Victorian Farmers Federation

Farrer House

24 Collins Street

Melbourne 3000

p 1300 882 833 f 03 9207 5500

e vff@vff.org.au w www.vff.org.au

Flowers Australia

PO Box 41

Mount Gravatt

QLD, 4122

E admin@flowersaustralia.org

W www.flowersaustralia.org