CHAPTER 4
APPLICATION OF THE PROTOCOL
Introduction
4.1 This chapter deals with the practical issues associated with AQIS's
proposed protocol for the importation of cooked chicken meat. Issues considered
by the Committee include:
- Performance of commercial ovens;
- Post processing contamination;
- Certification and Verification; and
- Health requirements.
Performance of commercial ovens
4.2 Industry representatives expressed doubts about whether AQIS had
adequately considered whether the time and temperature cooking protocols
for chicken meat developed in laboratory conditions could be accurately
applied in commercial cooking ovens.
4.3 Mr Luckhurst gave an example of where he considered the processing
protocol could break down because of temperature variations in commercial
cooking ovens. He advised the Committee of a memorandum from the group
general manager for product development at Ingams, Mr Mike Novoselac,
who said that variations in temperature of up to 8C degrees temperature
differential could occur in "state of the art" commercial ovens
when temperature readings were conducted at the same spot at different
times.
4.4 Mr Luckhurst indicated that Mr Novoselac, who has many years of experience
in the United States operating commercial cooking processes, held severe
reservations about the efficacy of the cooking process as a method of
preventing disease entry.(1)
4.5 Mr Graeme Bailey, Joint Managing Director, Chickadee Foods, confirmed
that variations in temperature in commercial cooking ovens is common and
also expressed doubts about the reliability of the cooking process in
a commercial environment:
You can get eight to 10 degrees variation across an oven belt in the
cooking process. So all that theory is fine but they are going to have
to test any product very thoroughly when it comes in, especially product
that does not receive further heat treatment.(2)
4.6 Dr Margaret MacKenzie, contended that AQIS had little understanding
of whether the heating protocol would work in a commercial environment:
AQIS does not understand the cooking protocols for further processed
products as the industry does. They have never been to have a look at
a further processed plant to understand it and they have not been able
to come up with any protocols to show us that the product will be reliably
cooked all the time.(3)
4.7 She argued that even with stringent processing protocols, there will
be instances of undercooked product entering Australia. She maintained
that this was a commercial reality due to the variables involved in cooking,
for example:
- portion size;
- oven cold spots;
- oven product flows;
- positioning; or
- human error.
4.8 Dr MacKenzie concluded that:
It is essential that we place other internationally accepted health
conditions on the source of raw material as a backup safeguard when
the time/temperature protocol fails.(4)
AQIS response
4.9 AQIS advised the Committee that the draft importation protocol contains
safeguards designed to monitor how adequately chicken meat is cooked.
A major component of these safeguards is a requirement that processors
fit automatic time and temperature recording devices known as thermographs
to all ovens producing cooked chicken for export to Australia.
4.10 AQIS will not require processors to send the thermograph record
to Australia. However, AQIS will require that the relevant records be
kept for at least a twoyear period and be made available to any AQIS request
for inspection.(5)
4.11 Dr Sarah Kahn noted that variations in the performance of commercial
ovens are well known but did not present insurmountable problems:
In commercial cooking operations of whatever sort it is pretty well
known that you can have colder spots in an overall heat chamber and
the normal way you would approach that is by having some system to calibrate.
You would work out where your coldest spot was, locate probes there
and then be able to calibrate that against the record that you were
getting. We are quite happy to look at detailed industry advice on the
best way to do that.(6)
4.12 Dr Kahn concluded that the industry had undertaken to provide advice
concerning appropriate means of calibrating recording devices but had
not yet done so. She said that AQIS would consider the industry advice
and if appropriate, "use that as a guideline or as a reference of
some sort when we advise foreign plants of the standards we must meet."(7)
Post processing contamination
4.13 Contamination of cooked food products after processing potentially
threatens the integrity of the quarantine protocol and provides a possible
means for exotic avian disease outbreaks. Contamination is also a very
serious human health issue in cooked products as consumers generally eat
such products without any further cooking. If bacteria such as salmonella
or listeria are present, the health consequences for affected persons
may be very severe, as the recent peanut butter and mettwurst contamination
cases demonstrate.
4.14 Contamination of packaging is a related issue. Contaminated packaging
may constitute a human health risk if the contaminated surface comes into
contact with the cooked product. Contamination of the outside packaging,
while less likely to threaten human health, may still constitute a quarantine
risk. It is well established that both IBD and ND are durable viruses
and could potentially be transported on packaging.
4.15 Dr Margaret MacKenzie and other industry representatives suggested
that AQIS had seriously underestimated the risks associated with contamination
of the product after cooking and contamination of packaging. Industry
representatives claimed that post-processing contamination of the product
or its packaging could lead to human health risks or the introduction
of poultry diseases. Dr MacKenzie stated:
...they do not understand postprocessing contamination. I am a microbiologist
and postprocessing contamination is serious and it is a risk that happens.
They have discounted it totally, not understanding it...(8)
4.16 Mr Luckhurst agreed that commercial manufacturing of chicken products
was "demonstrably fraught with control management and recontamination
problems and that is unverifiable after the event ". He submitted
that Australia would be accepting the product without any further monitoring
for the presence of poultry disease viruses once it arrives in Australia.(9)
4.17 Mr John Clarke, President, Chickenmeat Group, Victorian Farmers
Federation, told the Committee that he believed there was a very
real risk of importing virulent Newcastle disease as a result of the cooked
chicken meat imports. He identified three possible methods which the disease
could enter:
- incorrectly heat treated product;
- recontaminated product; or
- contaminated packaging.
4.18 Mr Clarke concluded:
This will inevitably lead to a catastrophic outbreak of Newcastle disease
within the local poultry industry and then devastate our native bird
population, which has no natural immunity to this deadly pathogen.(10)
4.19 The Australian Veterinary Association has also expressed concern
about the possibility that ND may be introduced on contaminated packaging.
The AVA noted that AQIS does not consider that contaminated packaging
represents a serious threat. However, the AVA speculated that Australian
poultry processors may become importers themselves to retain their competitive
position. Under such a scenario, the AVA considered imported and local
products would be stored together and contaminated material might be inadvertently
transported to Australian commercial poultry farms on vehicles or other
materials.(11)
4.20 Mr Luckhurst concluded that the industry remains unconvinced that
even Australian "best practice" standards are adequate to prevent
re-contamination with ND or IDB virus. He argued that AQIS were acting
on assumptions rather than objective data.
4.21 Mr Luckhurst identified two areas of concern. These were:
- AQIS's apparent refusal to require factories to be dedicated to processing
one species; and
- airborne contamination.
4.22 He questioned whether AQIS had given adequate consideration to the
possibility of airborne contamination and listed several areas that he
considered as requiring attention including:
- quarantine of staff from pre-cooked product and processing areas;
- separate requirements for post-cooking handling and storage;
- controlled airflows.(12)
AQIS view
4.23 Dr Sarah Kahn verified that in the case of cooked meat products,
contamination is a very important issue, as the product is likely to be
consumed without any further cooking. She said however that she considered
contamination was predominantly a human health issue:
I should say that postprocessing contamination is realistically far
more a public health concern, although potentially you cannot discount
perhaps the notion of these poultry viruses being transferred by that
means. But first and foremost, you are really looking at a public health
issue there.(13)
4.24 AQIS will rely substantially on a preventative approach to post
processing contamination to fulfil both food safety and quarantine objectives.
Dr Kahn advised that all regulatory authorities, in Australia and overseas,
emphasised strict controls on and segregation of cooked product from products
in the earlier stages of processing. She noted that most countries are
now introducing quality assurance programs such as Hazard Analysis Critical
Control Point Processing (HACCP).
4.25 HACCP programs require processors to detect and control critical
risk points where there is a possibility of accidentally exposing cooked
product to sources of contamination. Dr Kahn explained that an additional
benefit of HACCP is that it makes it easier for AQIS to audit and verify
the controls that are in those plants. This is because under HACCP, processors
must keep records and have a planned system of checks, inspections and
response actions.
4.26 Dr Kahn told the Committee that AQIS proposed that the processing
plants producing cooked chicken for export to Australia have internationally
recognised quality assurance systems such as HACCP in place. This requirement
is similar to other countries:
I think it is interesting to note that Thailand is a country which
has processing plants, for example, which are approved to export to
Japan and the countries of the European Union. Japan and the EU countries
do impose quite strict requirements on the import of meat into those
countries. So they, similar to Australia, have a great interest in quality
assurance systems and, again, this HACCP system is well recognised internationally.(14)
4.27 From a quarantine perspective however, these countries have less
at stake than Australia as most have some history of Newcastle disease.
4.28 Dr Kahn advised that AQIS emphasised strict controls and strict
prevention of postprocessing contamination, including contamination of
packaging material. Mr Hickey explained that it is standard procedure
to check how the plant controls packaging material in any review or inspection
of a foreign food processing plant:
As with any review of our meat plants, say, by USDA reviewers, there
are reviews of the stores in which packaging material is held to ensure
that there is no obvious fallout or contamination in there. They check
for adequate rodent protection, protection from flies and insects and
the like. Equally, in the review that is to be done of the Thai plants,
we would look for evidence of adequate control of packaging materials.(15)
4.29 While AQIS places substantial emphasis on a preventative approach
to post processing contamination, AQIS will also conduct a sampling program
of products arriving in Australia.
4.30 AQIS conducts this sampling program on behalf of the Australia New
Zealand Food Authority (ANZFA). The objectives of the sampling program
are primarily related to food safety issues. However, Dr Kahn noted that
it also assists with quarantine issues as the presence of organisms such
as salmonella provides an indication that contamination has occurred and
avian viruses like ND or IBD may also be present.:
we are proposing to test for contamination by which, if present on
the meat...would be an indicator that some faecal contamination had
occurred postprocessing....So that gives you an indication of whether
contamination is occurring, even though we are not specifically testing
for Newcastle disease.(16)
4.31 However, Newcastle disease virus may be present in uncontaminated
chicken meat. In previous evidence, the Committee notes that the virus
may be present in the tissues of clinically healthy, vaccinated birds,
although at lower levels than in birds exhibiting clinical evidence of
active disease.
4.32 Mr Stephen Bailey, Principal Executive Officer, Imported Food Inspection
Program, AQIS, advised the Committee that testing product on arrival in
Australia has significant limitations because of the uncertainties associated
with selecting samples for testing:
I would have to say as well from our point of view that the testing
of final product on arrival is far from the ideal because essentially
you are making pass or fail determinations based on a sample that you
hope to God is representative of the total consignment.(17)
4.33 ANZFA considers that the limitations associated with sampling may
be addressed by implementing a preventative approach to food safety. ANZFA
indicated that it is for these reasons that cooked chicken meat produced
for importation into Australia must be produced using a recognised quality
assurance program such as HACCP. Dr Gordon Burch, Scientific Director,
ANZFA, elaborated:
That is why the accreditation steps will be on the basis of full HACCP
systems being in place so that if an exporter seeks an application to
bring chicken into this country then they will have to be specifying
not only the mechanisms used in the production-the cooking, the slaughtering
and all the rest of it-but also the posthandling processing, including
storage temperatures, et cetera. They will all be on the basis of preventative
control.(18)
4.34 Mr Bailey concluded that accreditation by the authorities in the
exporting countries provided considerably higher levels of confidence
that the relevant standards were maintained:
It is because of that that, as far as we can, we maintain close dialogue
with the responsible agencies in the exporting countries and, as far
as possible, go through an accreditation process with them. That gives
us far greater confidence that the processes are under control and that
we are getting acceptable levels of compliance with their food safety
and food standards requirements.(19)
Certification and verification
4.35 The import protocols proposed by AQIS for the importation of cooked
chicken meat rely heavily on foreign government certification concerning
standards to be observed in the production of product for importation
into Australia.
4.36 The integrity of HACCP programs is ensured by a process of inspection
and audit carried out by accredited agencies. Mr Bailey advised the Committee
that the legislation enables AQIS to accredit a foreign government food
inspection agency. He explained that the process of accreditation is rigorous:
...we go through a very thorough process of evaluation. Do they have
a sound legislative base? Do they have a properly trained inspectorate?
What standards are they working to? What are their factory requirements?
To what extent have they adopted HACCP or quality assurance? So we go
through that process very rigorously before we accredit.(20)
4.37 Several witnesses and submissions questioned the reliability of
certification processes in the countries seeking to export chicken meat
into Australia, particularly Thailand.
Industry concerns
4.38 Witnesses focussed on what they perceived to be shortcomings in
aspects of Thai government regulatory activity. Witnesses suggested that
if such shortcomings existed, this brought the reliability of the Thai
certification process into question. They implied that hence, the reliability
of documentation certifying that the products had been produced in accordance
with the specifications of AQIS's import protocol may be doubtful.
4.39 Witnesses focussed on two areas of perceived shortcomings:
- Thai inspection requirements; and
- Thai health surveillance system.
4.40 Industry witnesses also questioned the adequacy of AQIS's procedures
for verifying that the certification process is reliable.
Thai inspection requirements
4.41 Dr Jeffory Fairbrother, Executive Director, Australian Chicken Meat
Association and Australian Poultry Industries Association, drew the Committee's
attention to Thai regulatory requirements for inspection of chickens during
processing. He pointed out that a literal reading of the Thai regulations
indicated a stringent inspection process, requiring inspectors to carry
out the following procedures:
- examine external surfaces for dressing defects, bruises or disease
lesions;
- palpate the tibia to detect bone diseases;
- examine the inner surfaces, the lungs and the kidneys in place;
- examine the viscera and palpate the liver, the heart and the spleen;
- the postmortem inspection must include investigation of abnormalities
in consistency, colour, smell and, where appropriate, taste.
4.42 Dr Fairbrother indicated that Thai chicken plants process between
6,000 and 8,000 birds an hour, or 1.6 to 2 birds a second. He concluded:
We have to believe on certification from a country that they are actually
examining each bird in accordance with their own regulations. What I
say is that, if we cannot believe that, what can you believe? We must
remember that AQIS is prepared to accept certification that these things
are being done,that is, certification from the overseas country.(21)
Thai health surveillance system
4.43 Dr MacKenzie told the Committee that Thailand has an inadequate
health surveillance system. She said that in response to AQIS's questionnaire
on the health status of the Thai poultry flock, Thai authorities indicated
that they had no information about whether salmonella enteriditis, a dangerous
organism associated with poisoning outbreaks overseas, was present. Similarly,
they had no information about the prevalence of salmonella pullorum.
4.44 Dr MacKenzie concluded that the Thai authorities lacked information
about the disease status of poultry in their own country and had to rely
on the poultry processing companies to supply this information for export.
4.45 The Australian Veterinary Association raised similar concerns to
AQIS in a letter dated 27 July 1994. The Association stated that they
were also concerned about the quality of disease surveillance in Thailand
as Thai representatives had acknowledged they did not know the status
of avian influenza, salmonella enteriditis or salmonella pullorum in Thai
commercial chicken flocks. Mr Philip Greenwood, the Chief Executive Officer
of the AVA concluded:
We believe such diseases are not difficult to monitor and therefore
question the credentials of the Thai authorities to provide assurances
that their standards meet Australian requirements.(22)
4.46 Dr Fairbrother advised the Committee that industry considered that
the relevant Australian authority should inspect overseas processing plants,
including the cooking plant, before AQIS permits importation to proceed.
He explained that the industry regarded certification by the exporting
countries' authority as insufficient, regardless of their previous performance,
because it will be the first time such products will be imported.
Verification
4.47 Industry representatives expressed the view that AQIS's proposals
for verifying that importation protocols had been properly observed by
the exporting countries are inadequate. Dr MacKenzie summarised the industry's
views:
(AQIS's) inspection system is `a visual inspection of cooked product
on arrival in Australia.' This is ridiculous. The first five shipments
it is going to check; then one in four, then one in 20. So there will
be 19 out of 20 shipments come in that will not even be visually inspected,
and a visual inspection does not tell you whether it is cooked anyway.
So the inspection system is totally inadequate for a high risk product
like this with both quarantine and public health risks.(23)
AQIS views
4.48 Committee members questioned AQIS officers about how AQIS proposed
to verify that the conditions specified for cooking meat were properly
carried out, including observation of procedures to prevent contamination
of either the product and or its packaging after processing.
4.49 Dr Kahn advised the Committee that verification of the protocol
is a key issue. She explained that verification relies on a system of
certification by the exporting health or veterinary authority. The certifying
veterinarian, who is usually employed by the government of the country
of export, signs a certification setting out the conditions that have
been complied with.
4.50 Certification is based on Government to Government understandings.
Dr Kahn assured the Committee that in accepting verification by foreign
veterinary authorities, AQIS checks the reliability of such certifications:
We reach agreement on a quarantine protocol and, before any exports
or imports start to occur, we satisfy ourselves that that exporting
country can meet the certification requirement and that they can reliably
attest, on a written certificate signed by a veterinary representative
of the government, that the quarantine conditions for any import have
been complied with.(24)
4.51 Dr Kahn advised that AQIS corroborates the reliability of its assessments
by conducting visits to the countries concerned:
Following on from that, we carry out joint visits. We review conditions.
We look at the conditions that apply in the exporting country and, from
time to time, we adjust those conditions as necessary if circumstances
change.(25)
4.52 AQIS emphasised that certification by foreign inspection authorities
that processors had adhered to Australia's requirements is used for a
wide range of products imported into Australia. Dr Kahn explained that
other countries to which Australia exports products use the same certification
system:
In the same way, we export meat products and other products, live animals,
hatching eggs, et cetera all around the world, and we do it on this
same basis.(26)
4.53 The Committee sought AQIS's views about the industry and Australian
Veterinary Association concerns about the credibility of the certification
process in Thailand and the apparent lack of knowledge about disease status
on the part of Thai authorities.
4.54 Dr Kahn acknowledged that it is important that AQIS has confidence
in the certification that the Thai veterinary authorities are going to
provide if importation proceeds. However, she considered that it was a
matter for the Thais to decide the nature of the health controls in their
own country. Dr Kahn concluded that it is not possible to draw a broad
assumption as to the validity of the health certification on the basis
of whether the Thais control certain diseases.(27)
4.55 Dr Kahn also drew a distinction between the need for stringent veterinary
certification in the case of uncooked meat as opposed to cooked meat.
She told the Committee
...if you are looking at uncooked meat imports, more emphasis is on
quality of veterinary services and the capacity of those services to
certify as to the health status of the poultry from which the meat is
being derived. If you are cooking the meat at 70C for ninety five minutes
you are doing a very different commodity in quarantine terms than raw
meat.(28)
4.56 AQIS has not yet conducted any visits to Thailand in respect of
the proposal to import cooked chicken meat. Mr Hickey emphasised that
any final approval to be given for permits for imports from Thailand is
subject to an AQIS review of the Thai processing industry.(29)
4.57 In respect of Denmark and the United States, however, AQIS will
be accepting certification of the relevant government authorities in those
countries subject to AQIS being able to undertake checks from time to
time on the adequacy of that system. Mr Hickey emphasised that is the
same system that other countries apply to products exported from Australia.(30)
4.58 While depending heavily on certification by foreign authorities,
AQIS does carry out random checks to verify that the certifications accompanying
goods conform with reality. Mr Bailey explained:
But, even after we go through that process and we start accepting certificates,
we are still obliged under the act to perform verification checks. So
there are spot checks carried out randomly to make sure that we get
a broad consistency between what our laboratories report to us and what
is reported on the certificate.(31)
4.59 The random sampling process is conducted by AQIS in accordance with
ANZFA requirements. The ANZFA requires samples to be tested for the following
agents:
- Salmonella ssp;
- Listeria monocytogenes;
- Campylobacter ssp;
- antibiotics;
- organochlorines;
- Eschericcia coli;
- coagulase-positive staphlococci.
4.60 This testing is conducted primarily for reasons of human health
rather than for quarantine purposes. AQIS does not propose to test for
the presence of viruses of quarantine concern such as ND and IBD. However,
AQIS considers the tests would provide "relevant and valid information"
to confirm the performance of processing plants and whether they had employed
"good manufacturing practices". AQIS advised that the presence
of any of the agents would provide a reliable indication that post processing
contamination had occurred.(32)
Health requirements
4.61 Industry maintains that it is essential that the general locality
from which birds are taken for processing should be free of ND and IBD.
The industry contends that this safeguard is required to provide reserve
protection in the event that any other link in the quarantine protocol
fails.
4.62 The industry contends that AQIS's proposed requirement that the
poultry be "clinically healthy" is insufficient as healthy birds
that have been vaccinated may act as carriers for the virus.(33)
4.63 Dr MacKenzie informed the Committee that it is standard practice
for other countries to require certification of freedom from disease.
She told the Committee that when Australian exporters send cooked or uncooked
chicken meat to countries such as Singapore, Japan and the United States,
these countries required the Australian Government to sign a health certificate
certifying that no cases of malignant poultry diseases have been diagnosed
within a radius of up to 50 kilometres from the premises of origin of
the birds during the preceding 90 days.
4.64 However, she said that AQIS had continually disagreed with industry
about requiring such a health certificate from countries seeking to import
product into Australia, despite clear evidence that the countries concerned
had Newcastle and other diseases.(34)
4.65 Mr Luckhurst told the Committee that :
By placing no restrictions on the disease status of the flocks of origin,
AQIS is clearly placing a total reliance on the cooking process for
quarantine integrity. One mistake occurring at any time in the years
to come could have the most devastating consequences.(35)
4.66 Mr Hickey addressed assertions made at the Maitland hearing by Dr
MacKenzie that countries including Thailand required Australia to certify
disease freedom. He confirmed that he believed that Thailand, Korea and
Japan do require such certification, but this requirement could be satisfied
by Australia relatively easily.
4.67 Mr Hickey maintained that a requirement to certify area freedom
could not be justified on technical quarantine grounds. He noted that
the importation proposal allows for cooked product only and the cooking
process would effectively eliminate quarantine risks potentially associated
with the presence of IBD or ND viruses in meat. Accordingly, AQIS considers
that it is not necessary to impose additional poultry health certification
in respect of cooked chicken meat.(36)
Committee's view
4.68 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.
4.69 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.
4.70 The Committee recommends that AQIS commission field trials
in a commercial cooking environment to determine appropriate methods of
verifying thermograph calibration and performance.
4.71 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.
4.72 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.
4.73 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.
4.74 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.
4.75 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.
4.76 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.
4.77 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.
4.78 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.
4.79 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.
4.80 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.
4.81 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.
4.82 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.
4.83 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.
Chapter 5
ENDNOTES
- Evidence, 13th September 1996, p. 123.
- Evidence, 13th September 1996, p. 203.
- Evidence, 13th September 1996, p. 131.
- MacKenzie, op. cit.
- Evidence, 28th August 1996, p. 20.
- Evidence, 30th September 1996, p. 271.
- Evidence, 30th September 1996, p. 271.
- Evidence, 13th September 1996, p. 131.
- Evidence, 13th September 1996, p. 124.
- Evidence, 13th September 1996, p. 189.
- D. Rayward, Submission No.12.
- Correspondence, Luckhurst, 23 October 1996.
- Evidence, 28 August 1996, p. 31.
- Evidence, 28th August 1996, p. 30.
- Evidence, 30th September 1996, p. 259.
- Evidence, 30 September 1996, p. 260.
- Evidence, 28th August 1996, p. 116.
- Evidence, 28th August 1996, pp 116-117.
- Evidence, 28th August 1996, p. 116.
- Evidence, 28th August 1996, p. 117.
- Evidence, 13th September 1996, p. 127.
- Rayward, op. cit.
- Evidence, 13th September 1996, p. 131.
- Evidence, 28th August 1996, pp 20-21.
- Evidence, 28th August 1996, p. 21.
- Evidence, 28th August 1996, p. 21.
- Evidence, 30th September 1996, p.245.
- Evidence, 30th September 1996, p. 255.
- Evidence, 30th September 1996 p. 254.
- Evidence, 30th September 1996, p 225.
- Evidence, 28th August 1996, p. 117.
- Evidence, 28th August 1996, pp 40 - 49.
- Evidence, 13th September 1996, p. 135.
- Evidence, 13th September 1996, p. 130.
- Evidence, 13 September 1996, p. 124.
- Evidence, 30th September 1996, p 222.