Plant Export Operations Branch - Department of Agriculture ... · 29 September 2014 FINAL v3.2 Plant Export Operations Branch Page 7 of 12 Detection of pests/contaminants requiring

Title: Volume 8: Commodity Inspections - Grain, seeds, nuts and stockfeed

Date Published Current Version Number Program Page Number

29 September 2014 FINAL v3.2 Plant Export Operations Branch Page 1 of 12

Plant Export Operations Branch

Plant Export Operations Manual

Volume 8: Commodity Inspections – Grain, seeds, nuts and stockfeed

Contents Introduction ............................................................................................................................... 2

Legislation ................................................................................................................................. 2

Conduct Pre-Inspection Tasks ................................................................................................... 3

Empty Container, Bulk Vessel or Packaging approval ............................................................. 3

Conduct Flowpath Inspection Tasks ......................................................................................... 4

Conduct Goods Inspection Tasks .............................................................................................. 5

Pests and Contaminants ............................................................................................................. 5

Rejection Procedure .................................................................................................................. 6

Inspection of Resubmitted Goods after Treatment ................................................................... 8

Related eLearning Module ...................................................................................................... 10

Questions ................................................................................................................................. 10

Appendix 1 .............................................................................................................................. 11




Introduction

This volume outlines the principles relating to sampling, inspection and export certification of

prescribed plants and plant products including grain, seeds, nuts and stockfeed in packages and

bulk into containers or vessels, and bulk raw sugar.

Under the Export Control Act 1982, there are ‘prescribed’ and ‘non-prescribed’ goods.

Depending on what is to be exported, the requirements that must be complied with may vary.

Grains, as listed in Section 6 of the Export Control (Plants and Plant Products) Order 2011,

are always prescribed goods and will therefore be inspected and sampled irrespective of

whether the importing country requires a Phytosanitary certificate. If a Phytosanitary certificate

or any other certificate is required by the importing country the goods must be treated as

‘prescribed goods’.

The sampling and inspection of prescribed goods must be carried out at a registered export

establishment by an authorised officer (AO). Individuals undertaking these activities must be

suitably qualified and have relevant authorisation and delegations necessary to inspect

prescribed goods presented for export.

Reference and Instructional Material

Work Instructions: The AOs can use the work instructions as a quick guide to complete

a specific job function. These can be accessed via the downloadable resources link.

Plant Exports Operation Manual:

o Volume 2: Export legislation

o Volume 5: Product Identification

o Volume 6 Part A: Pests, Diseases and Contaminants of Grain and Plant Products

(excluding horticulture)

o Volume 10: Bulk Vessel Inspection

o Volume 11: Empty Container Inspections

o Volume 16: Work Health and Safety (WH&S)

Legislation

Consideration must be given to the following legislation before goods are exported and AOs

must ensure that the legislation is abided by throughout the exporting process:

Export Control Act 1982

Export Control (Prescribed Goods – General) Order 2005

Export Control (Plants and Plant Products) Order 2011

Export Control (Fees) Order 2001

The legislation listed above are all accessible via the ComLaw website at:

http://www.comlaw.gov.au/

http://www.daff.gov.au/biosecurity/export/plants-plant-products/plantexportsmanual/resources

http://www.comlaw.gov.au/




Conduct Pre-Inspection Tasks

Recording Inspection Results

Inspection details are recorded on the Export Compliance Record (ECR). The AOs must use

one ECR for each inspection conducted. It is mandatory for AOs to use the approved forms.

AOs may need to attach additional pages to the ECR.

Inspection Equipment Checklist

Waste bin and lid supplied by establishment for disposing of unwanted material found

during inspection.

Torch capable of being focused to a spot.

Sieves (large and pocket) for separating insects and contaminants from the samples.

Measure 0.5L and 2.25L for samples

Knife and scraper suitable for cutting and removing residue from places difficult to

access

A pair of tweezers suitable for collecting larger species

Hand lens x10 magnification or more for pest, weed seeds and contamination

identification.

Small painters brush for separating objects of quarantine concern and collecting small

insects from the grain samples being inspected.

Vials/tubes filled with methylated spirits or 80% ethyl alcohol (ethanol) for collecting

arthropod specimens.

Sealable plastic bags for larger specimens collection during inspection

Labels for specimens

Export Compliance Records (http://www.daff.gov.au/biosecurity/export/plants-plant-

products/plantexportsmanual/resources)

Pencils for labelling tubes (pens aren't suitable as alcohol dissolves most ink) and pen

for completing various forms.

Trier for inspection of bagged product.

Personal protective equipment such as hand gloves, apron, face mask, goggles, etc.

Calculator or mobile phone with a scientific calculator

Empty Container, Bulk Vessel or Packaging approval

Inspection of empty containers, bulk vessels and packaging ensures requirements have been

complied with in the transportation of prescribed goods and no cross contamination issues exist

with loading prescribed goods into inspected empty containers or bulk vessels. An AO must

ensure that a valid Container Approval or Bulk Vessel Approval Record has been issued.

Packaging material inspections

Materials to be used as packaging for prescribed goods and other materials applied to

prescribed goods at the time of packaging must be:

http://www.daff.gov.au/__data/assets/pdf_file/0011/2142785/PE100_Export_Compliance_Record.pdf






New or if previously used and intended for repeated use, must have been cleaned and

reconditioned to the satisfaction of an authorised officer i.e. unlikely to impart odour,

infest or contaminate goods and be free of holes/rips/tears

Used in a manner that is unlikely to place the acceptability of the prescribed goods at

risk

Sufficiently strong to withstand the handling incurred by the materials during transit

Otherwise appropriate to the goods

Free from any contaminants that could cross-contaminate the goods

Conduct Flowpath Inspection Tasks

Inspection Area

The AO must ensure the area to be used for the phytosanitary inspection is clean, well lit, free

from dust and sources of cross-infestation, cross-infection cross-contamination, and clear of

fumigant gases.

The inspection equipment must be clean, adequate and fit for purpose.

The AO must ensure there is adequate access to all goods to allow sampling in a safe manner

from the entire lot/consignment.

Commodity Flowpath

The commodity flowpath is deemed to be from the point of sampling to the point of loading.

The flowpath must be inspected prior to loading to ensure it is fit-for-purpose and free of

sources of cross contamination such as infested material and material capable of infecting the

commodity. In circumstances where the flowpath fails inspection, the AO must be advised

when the issue has been rectified and the flowpath is ready for reinspection.

Assess the consignment

The content of the entire lot/consignment to be inspected should match the details on the notice

of intention (NOI) to export (EX28 or RFP). It may be necessary to count packages if exact

quantity is not known.

The AO should only request a break-down into the pallet if in doubt or access to particular

samples is needed.

Do not proceed with the inspection if the lot/consignment presented does not match the NOI.

Trade Description

When a trade description is applied to prescribed goods, the export of those goods is prohibited

unless that trade description is adequate and accurate.

A trade description applied to goods is taken to be adequate if it:

contains sufficient information to enable the goods to be readily identified




is not ambiguous or unclear

satisfies any particular requirements under the Orders relating to the application of trade

descriptions

satisfies any requirements of the importing country.

AOs should note that the blending of different grades of grain, to arrive at a required grade, is

normal practice and acceptable.

Where an AO is concerned that a false trade description has been applied to prescribed goods,

the AO needs to contact the Regional Plant Export Manager. In the interim, AOs must withhold

export documentation and require exporters to produce documentary evidence to support the

description given. These may include declarations by the exporters/processors of the goods or

certificates of analysis from accredited laboratories for various parameters required by the

importing countries.

Conduct Goods Inspection Tasks

Inspection of prescribed goods must be carried out in accordance with the relevant work

instruction.

Pests and Contaminants

Volume 6A provides more information on the range of pests, including the definition of live

pests and insects, vermin and contaminants that an AO may encounter when sampling and

inspecting prescribed goods.

Tolerances

Tolerance levels imposed by the importing country takes precedence over any tolerances

listed in this manual.

There is a nil tolerance for live pest infestations, vermin (including rodents) and their waste for

prescribed goods unless a tolerance is specified in Table 1.

Table 1: General tolerances for prescribed plants and plant products

Contaminant Tolerance level

Datura spp. - seeds (thornapples) Not more than 10 seeds per

2.25 L in sorghum

Claviceps purpurea - ergots

(i) of ryegrass

(ii) of the cereal or seed

0.05 % or not more than 50

pieces per 5 L of grain

0.05% or not more than 3

pieces per 2.25 L in prescribed

grain




Contaminant Tolerance level

Carcases (i) Nil for goods for

consumption (reject

source) #

(ii) Nil for goods not for

consumption (50 tonne

rejection) #

Rodent and vermin droppings (i) In any single sample

(2.25 L or equivalent)

not more than seven

droppings

(ii) In any two consecutive

samples (each sample

2.25 L or equivalent)

not more than four

droppings in total

(iii) Nil in mungbeans

Non-injurious pests (Refer to Volume 6A Table 2) (i) In any single sample

(2.25 L or equivalent)

not more than two live

field species

(ii) In any three

consecutive samples

(each sample 2.25 L or

equivalent) not more

than two field species

in total

Soil and sand 0.2% by weight

Weed seeds of quarantine concern of the importing country,

as advised on MICoR

Nil

Weed seeds where importing country requires freedom from

‘weed seeds’ on their import permit without specifying

species

0.5% by weight

# Refer to rejection procedure

Rejection Procedure

If any pests or contaminants are found in excess of tolerances (including nil) the goods must be

rejected. This may be in the form of rejecting the source or applying a 50 tonne rejection (refer

below).

Upon rejection an AO must notify a responsible person on an ECR that treatment of the

rejected lot is required, and that person must give details of treatment carried out before the lot

is re-presented for inspection.




Detection of pests/contaminants requiring rejection of the source

Detection of live injurious pests and live insect pests of quarantine concern to the importing

country requires rejection of the source. For vertical storages e.g. silos and cells, the whole

storage is to be rejected. For horizontal storages e.g. bunkers and sheds, 5,000 tonnes of the

goods from the point of detection is to be rejected (Refer to Appendix 1 for a suggested method

on how to calculate tonnage to be rejected). Loading may recommence from the remaining

goods in the storage. Rejected goods must be treated prior to re-presenting for inspection.

Cumulative rejection limit - 20 per cent rule

To ensure the level of live injurious pest infestation in export shipments is kept to a

minimum, the amount of goods that have been loaded from sources subsequently

rejected for live injurious pest detections is not to exceed 20% of the total ships load.

This only applies to consignments greater than 10,000 tonne of one particular

commodity being loaded onto a vessel. There is no cumulative rejection limit on

tonnages of less than 10,000 tonnes.

When rejection occurs, AOs are to add up the total tonnage of goods from each

cell/storage that was loaded onto the vessel prior to rejection. Where such a vertical cell

or horizontal storage has a capacity greater than 2000 tonnes then a maximum of 2000

tonnes from that cell or horizontal storage will be added towards the cumulative figure

for the calculation of the 20% limit. When loading from two or more sources

simultaneously the maximum amount to be allocated towards the cumulative figure is

2000 tonnes.

If the same ship is loading at another Australian port, the cumulative total is to be

transferred and continued during the subsequent loading. If the cumulative total exceeds

20% of the ship load then loading is to cease and authorised officers are advised to

discuss the situation with the Regional Plant Export Program Manager and exporter

with the object of ensuring that grain subsequently loaded is free of live injurious insect

infestation.

Detection of pests/contaminants not requiring rejection of the source

50 tonne rejections are applicable after detections of non-injurious pests (not a quarantine

insect pest of the importing country or a stored product pest) or weed seeds or other

contaminants (refer to PEOM Volume 6 Part A) at levels above specified tolerances, including

nil, during the inspection of prescribed goods. This option may only be applied if loading

ceases without undue delay upon detection.

If more than 50 tonne of goods is loaded between the detection of non-injurious insect pests or

weed seeds or other contaminants and the loading ceasing, the AOs must verify that potentially

infested goods beyond the inspection point are redirected and rejected. AOs must record

rejection on the export compliance record. The rejected 50 tonne of goods must be segregated

from goods destined for export, and loading from the same source may recommence after the

50 tonne rejection has occurred.

A maximum of two 50 tonne rejections per 1,000 tonne inspected from a singular source is

permitted, allowing a maximum of 10% of each 1,000 tonne inspected to be rejected under this




procedure. However, a third detection of the same pest species or weed seed or other

contaminant from the same source within 1,000 tonne inspected indicates the

infestation/contamination is consistent throughout the source and the source is to be rejected (as

above). The 50 tonne rejection count reverts back to zero after each 1,000 tonne inspected.

Each 50 tonne rejection is a formal rejection for export. If the client wishes to re-present the

goods for export, the goods must have been treated in-line with the relevant work instruction.

Inspection of Resubmitted Goods after Treatment

The exporters must present treatment declaration or fumigation and gas free certificates for

fumigated goods to the AOs when resubmitting goods for reinspection. Goods must not be

resubmitted for reinspection until after the exposure and airing periods specified on the

registered label or treatment certificate has been achieved.

Treatment of rejected goods

If goods are rejected for reasons that will respond to treatment and there is an approved method

of treating the goods, the goods must not be re-presented for inspection unless they have been

treated in an approved manner. If there is no approved method of treating the goods, the goods

must not be re-presented for inspection unless they have been treated. The choice of treatment

is the responsibility of the owner of the goods and not the AO.

Resubmitted goods must be inspected in the normal manner and rejected if any live pests and

contaminants above the tolerance levels are detected.

Live Insect Infestations

Live insect infestations must be treated. If a client wants to resubmit the rejected goods for

export then the exporter or their agent must provide a treatment declaration or fumigation

certificate before the reinspection can commence. The AO must verify that the goods were

treated to control all insect life stages but is not responsible for the choice of this treatment.

An insecticide or fumigant must not be used unless it is registered for that particular use under

a law of the Commonwealth, a State or a Territory or registration under such a law is not

required.

Insecticides

If an insecticide is used, it must be:

used in accordance with its registered label

acceptable to the importing country

approved by the exporter.

Rejected goods treated with an insecticide must not be resubmitted for inspection until after the

exposure, airing periods and safety precautions specified on the registered label have been

observed.

Fumigants

If a fumigant is used, it must be:




used in accordance with its registered label

acceptable to the importing country

approved by the exporter.

If a fumigant is applied, then the person responsible for the goods must also provide a gas free

certificate, issued by a suitably accredited/licensed fumigator, before the reinspection can

commence to ensure that it is safe for the AO to conduct the inspection.

Rejected goods treated with fumigants must not be resubmitted for inspection until after

exposure, airing periods and safety precautions specified on the registered label have been

observed.

Contaminants

The tolerance levels for contaminants may vary from contaminant to contaminant. For

example, some contaminants have a nil tolerance and others may have some level of tolerance.

The following principles should be used for contaminants found in grain samples during

inspection:

1. For contaminants for which a nil tolerance applies, cleaning of the relevant goods must

be carried out to remove the contaminating material if the goods are to be resubmitted

for export.

2. For contaminants for which a numerical tolerance applies, cleaning or blending to

below the permitted tolerance may be carried out.

3. If contamination has occurred on the outside of packages, such contamination may be

removed by brushing or other mechanical means.

Screening of goods

Screening of goods rejected for live insect infestation is not permitted. Goods can be screened

to remove contaminants.

Blending of goods

Blending of goods rejected for live insect infestations is not permitted. If blending is being

carried out during the reweighing or loading of a ship and blended goods are rejected, all cells

or other sources feeding the blend must be included in the rejection.

Export compliance period

Prescribed goods that are inspected and passed as export compliant remain compliant for 28

days. In exceptional circumstances, the period of export compliance can be extended beyond

the 28 days.

To extend the period of compliance the exporter will need to provide details supporting the

request to the Department of Agriculture, Grain and Seed Exports Program before the end of

the initial 28 day period. The exporter must supply details of the exceptional circumstances for

which an extension is required, a justifiable period of extension, and information that gives

assurance that the condition of the goods has not changed since inspection and that there has

been no compromise of the phytosanitary status of the goods, including the security. Once a

decision is made the Grain and Seed Exports Program will inform the exporter of the decision




and the National or Regional Documentation Hub Manager or Supervisor will be informed to

make a record of the additional approved period.

Reinspection of consignments where export of consignment is delayed

Reinspection of prescribed goods is necessary if:

1. The time between inspection and export exceeds the period during which the prescribed

goods are passed as export compliant;

2. The maximum time between inspection and export permitted by the importing country

is exceeded.

When an importing country’s requirement is different from 28 days, or any time extension that

could be approved the importing country’s requirement takes precedence. Exporters must

request reinspection if any of the above conditions have occurred.

Related eLearning Module

Defensible Decision Making

Export Auditing: Grain

Export Communications: Governance

Export Communications: Techniques

Export Documentation – Electronic

Export Documentation – Manual

Export Inspections: Commodity Inspection – Grain (Part A)

Export Inspections: Export Registered Establishments

Export Inspections: Importing Country Requirements

Export Inspections: Product Identification, Pest & Diseases

Export Inspections: Ship Inspection

Export Inspections: Treatments

Export Inspections: Using MICoR

Export WH&S

Introduction to Empty Container Inspections

Plant Export Legislation

Questions

You can contact your Regional Plant Export Program Manager to clarify any aspects of

this volume in the first instance.

You can also direct a specific question or provide feedback to

[email protected]

mailto:[email protected]




Appendix 1

How to calculate the volume of 5000 tonnes of grain in horizontal storage

Bulk density of various grains

The bulk density and angle of repose of grain varies with type, variety, moisture content,

quality and contamination. Typical volumes for common grain and seeds are presented in Table

1.

Table 1: Typical bulk density and volume of 5000 tonnes of common grain and seeds

Grain/Seeds Density, t/m3 Volume of 5000t, m

3

(∆V)

Barley 0.62 8050

Canola 0.69 7250

Cottonseed 0.4 12500

Lupins 0.77 6500

Sorghum 0.73 6850

Chickpea 0.74 6750

Cowpea 0.75 6650

Maize 0.72 6950

Oats 0.48 10400

Wheat 0.77 6500




How to calculate the volume of 5000 tonnes grain

Figure 1: Schematic diagram of a bunker used for storing grain.

An AO may use the following formula to calculate the length (∆L) of grain from the bunker to

reject.

∆L = ∆V/[(B x W) + (0.5 x H x W)]

Where:

∆L = Length of bunker to be rejected, meter

∆V = Volume of 5000 tonnes of grain stored in a bunker, m3

(obtained from Table 1)

W = Width of the bunker, meter

B = Bank height, meter

H = Height of the triangular component of the bunker , meter

L = length of the bunker, meter

V1 = volume of horizontal component of the bunker, m3

V2 = volume of the triangular component of the bunker, m3

For example

When inspecting wheat with W=40 m, B=1.5 m and H= 4 m, ∆V is 6500 (table 1). Length of

grain to be rejected can be estimated using the above equation as follows:

∆L = 6500/[(1.5 x 40) + (0.5 x 4 x 40)]

= 46.43

Which means 46.4 m length should be rejected before recommencing loading of the grain.

Documents

Plant Export Operations Branch - Department of Agriculture ... · 29 September 2014 FINAL v3.2 Plant Export Operations Branch Page 7 of 12 Detection of pests/contaminants requiring