CONCLUSIONS AND RECOMMENDATIONS
Paragraph 2.11:
The Committee recommends that the Government amend the
Quarantine Act and place final responsibility for quarantine decisions in the hands of the
Minister and/or Government. The Committee recognises that Ministerial or Government
decisions must be consistent with the provisions of the Agreement on the Application of
Sanitary and Phytosanitary measures. Accordingly, the Minister and Government will
inevitably need to rely on appropriate advice from the Director of Quarantine and the
Ministers for Foreign Affairs and Trade in this regard.
Paragraphs 3.39 - 3.45:
The Committee, as non-scientists, do not consider that it is
appropriate or wise to arbitrate on the issue of whether the science underpinning AQIS's
proposal is sound.
AQIS has put forward a considerable amount of evidence supporting
the view that its science is sound. Reputable scientific opinions including those of most
of the state veterinary authorities, the Australian Animal Health Laboratory, the Bureau
of Resource Sciences and Dr Dennis Alexander, a renowned international virologist support
AQIS's view.
The Committee notes that Dr Alexander qualified his support with a
warning about the need for care when adapting scientific findings to a commercial
situation:
...some assessment of the closeness of the conditions in the
laboratory and the commercial processing should be made and the extent to which variations
are likely to affect the desired outcome.
Equally, however, scientists within the Australian poultry industry
have raised areas of doubt about some of the assumptions AQIS has made. The Committee is
reluctant to dismiss these concerns lightly.
The major areas of doubt appear to be a lack of specific knowledge
about the behaviour of Newcastle disease virus in chicken meat and the characteristics of
different strains of both IBD and ND. While considerable scientific opinion supports
AQIS's assumptions that ND is more susceptible to heat treatment than IBD, it is likely
that this will remain as a point of contention unless AQIS produces incontrovertible
evidence.
The Committee recommends that AQIS commission tests of the
thermal inactivation of Newcastle disease virus and infectious bursal disease virus in
chicken meat products. This study should be conducted in conditions that are as close as
possible to commercial processing conditions.
The Committee further recommends that AQIS collaborate
with industry in the design of this experiment so that there can be no further disputation
about the validity of the science underlying the protocols.
Paragraphs 4.68 - 4.83
The Committee notes that AQIS acknowledges that the cooking process
is very important to maintaining the importation protocols. It is therefore surprising
that AQIS has apparently not commissioned or conducted any trials of commercial oven
performance in order to determine methods of verifying thermograph calibration.
Dr MacKenzie's statement that "they have never been to have a
look at a further processed plant to understand it" is disturbing. If correct, this
statement indicates that AQIS may have failed to back up its theoretical knowledge with
practical field trials. The Committee considers that field trials of protocols would
provide valuable extra knowledge about the reliability of quarantine safeguards. They
would also fulfil the useful function of assuring industry that such safeguards are well
designed and reliable.
The Committee recommends that AQIS commission field trials
in a commercial cooking environment to determine appropriate methods of verifying
thermograph calibration and performance.
The Committee is satisfied that AQIS's approach to post processing
contamination is appropriate. The preventative approach embodied in quality assurance
systems such as HACCP is internationally recognised and should, if properly implemented in
the countries exporting chicken meat to Australia, provide substantial protection against
both avian disease incursion and pathogens of concern to human health.
The Committee notes that testing of product samples on arrival will
provide a measure of added protection with respect to pathogens of concern to human
health, for example, salmonella. However, the Committee considers that this sampling may
provide only partial protection against avian diseases, particularly Newcastle disease.
While the presence of these pathogens indicates the possibility of
contamination, it is by no means established that avian viruses will be absent if other
pathogens are not detected.
The Committee is, however, concerned that a lesser level of
confidence in Thai certification is acceptable, as indicated by Dr Kahn's statement quoted
at paragraph 4.55. The Committee is also concerned that AQIS has not visited the Thai
processing plants in respect of the proposed importation despite indicating that AQIS has
a lesser degree of knowledge about conditions in that country.
The Committee considers that AQIS should have conducted inspections
of the processing companies in Thailand at a much earlier stage in order to determine
whether certification procedures are reliable and processors can satisfy Australia's
quarantine requirements. The Committee finds it difficult to understand how AQIS could
properly complete its risk assessment without such visits.
The Committee notes that AQIS has indicated that officers will
inspect Thai processing plants before approving importation of cooked chicken meat from
that country. The Committee recommends that AQIS conduct inspections of processing
plants in all countries seeking to import cooked chicken meat into Australia. The
Committee further recommends that industry representatives accompany AQIS officers
on these visits.
Industry has not been without fault. For its part, the industry has
been slow to understand and accept the basis of certification procedures between trading
countries and the difficulties that Australian exporters would undoubtedly face if such
procedures were discontinued.
The Committee believes that AQIS is placing considerable if not
almost total reliance on the integrity of the cooking process to maintain its quarantine
objectives in respect of the cooked chicken meat proposal. The reasons the Committee has
come to this view are that:
- Virus may be present in healthy birds at low levels;
- Contamination does not have to occur for virus to be present;
- AQIS apparently places less emphasis on the importance of stringent
certification procedures in the case of cooked meat (see para 4.55)
- AQIS will not insist that poultry be sourced from disease free areas,
arguing that this is irrelevant because the product is cooked; and
- AQIS will not test the cooked meat for the presence of ND or IBD when
it arrives in the country.
The Committee notes that AQIS properly emphasises the use of quality
assurance procedures in production of cooked chicken meat. However, these are essential to
maintain the integrity of the cooking process.
Given that it is possible that very large quantities of cooked
chicken meat may enter the country if the importation proposal proceeds, it is possible
that some breakdowns of the protocol will occur.
The Committee fully understands that any breakdown of the cooking
and certification process will not necessarily result in disease outbreaks. However, the
Committee believes AQIS's reputation will be irretrievably damaged if IBD or ND enter the
country via a cooked chicken meat importation under its control.
There are currently no simple methods of detecting product that
contains IBD or ND once it arrives in Australia. While some testing will be done for
pathogens of human concern, these provide only partial indication that avian disease
viruses are present. The Committee believes AQIS has glossed over this issue, as the
testing that will take place will not reliably indicate that avian viruses are present.
The Committee therefore recommends that AQIS require area
certification from avian disease. The Committee believes that AQIS should follow
established international practice with regard to disease certification requirements.
Paragraph 5.14
The Committee acknowledges that ANZFA policy determines AQIS'
actions in this regard. However, the Committee questions the consistency of this approach
with local requirements. There seems little point in forbidding local producers access to
chemicals if Australia is to accept food produced overseas using these chemicals.
Paragraphs 6.8 - 6.11
The Committee is concerned about Mr Gascoyne's propositions
concerning the overall low probability of ND entering the native bird population if and
when cooked chicken meat is allowed into Australia. Although there is conflicting evidence
about how the 1930 and 1932 ND outbreaks occurred, it is not difficult to envisage
scenarios in which scavenging birds could provide a means for ND to enter the native bird
population and the Australian poultry flock.
The Committee notes that despite its assessment of the low
probability that disease would be introduced, AQIS saw fit to commission a study by ABARE
of the economic impact of introducing Newcastle disease. Mr Hickey explained that under
the terms of the SPS agreement, Australia is able to take account of the introduction of
the disease.
The Committee accepts that AQIS's approach to environmental
assessment is consistent with the terms of the EPIP Act. However, from an outsider's
perspective, this approach may seem somewhat inconsistent, as despite AQIS's assessment
that the risk of disease entry is low, it commissioned an economic impact study.
The real issue in relation to the possible introduction of NDV or
IBD relates back to the success or otherwise of the heat treatment and the post treatment
packing and handling. Therefore the Committee is of the view that implementing its
recommendations regarding the tests of heat treatment on chicken meat and the performance
of commercial ovens are the key to the potential risk to native bird life.
Paragraphs 7.52 - 7.55
As noted, the Working Group's report has been provided to the
Minister for consideration. The Committee has considered the options put forward in that
report, and canvassed several of them during its hearings.
The Committee believes that some form of adjustment assistance or
concession would be essential to the industry, should importation of cooked chicken meat
occur. The additional initiatives outlined in the Working Group report relating to
agribusiness programs and benchmarking are essential steps to preparing the industry for
the effects of an internationalised market and must be actively pursued.
The Committee recommends that the most appropriate
assistance measure available for government's consideration would be introduction of
appropriate safeguard action to allow the imposition of a tariff or quota restriction on
importation on a temporary and reducing basis. An industry assistance package, of
limited duration (similar to the citrus industry assistance package) would be a possible
adjunct to any such measure.
Any such action by government would, according to evidence before
the Committee, be possible and acceptable under the Uruguay Round Outcomes. Such measures,
in the Committee's view, should be considered as a means of allowing the Australian
poultry industry to adjust to changed trading conditions which importation of chicken meat
would bring.
Paragraphs 8.9 - 8.11
The Committee's principal observation is, in relation to the current
processing of application for importation of salmon meat - and to some extent with the
importation of cooked chicken meat - the assessment process is confused and lacks
transparency and coherence to an outside observer.
It is essential, in the Committee's view that this process be
clarified. It is now important, both from the point of view of Australian interests, and
from the point of view of other countries, that the Australian assessment process be clear
and well understood at all stages.
The Committee accordingly recommends that the Government
provide the Parliament and the community with a clear explanation of the assessment
process at the earliest possible time.