2005 · Web viewAs far as cut flower imports into Australia are concerned, Australia imports mainly...

International Plant Protection Convention 17_EWGCutFlowers_2014_JuneSpecification 56 – Australia’s response Agenda item: 4.1

INTERNATIONAL MOVEMENT OF CUT FLOWERS AND BRANCHES (2008-005)

Specification 56: Australia’s response

(Prepared by Dr Niranjani Saverimuttu, EWG member, Australia)

SPECIFICATION 56

International movement of cut flowers and branches (2012)

Reason for the standard

[1] A large volume of cut flowers and foliage/branches is moved in international trade. These may form a pathway for spread of quarantine pests as fresh cut flowers are natural hosts for a wide range of insect pests, and have a higher potential for insect infestation due to their complex structure providing hiding spots for pest development, as insects naturally feed on them and are attracted to flowers due to their colour and scent. Guidelines on how to minimise risks from quarantine pests present on cut flowers and branches (hereafter referred to as cut flowers) prior to importation could contribute to mitigating risks related to the international trade of these commodities and to reducing delays in clearing consignments at borders.

[2] Cut flowers also have a comparatively short shelf/vase life and are only intended to be used for ornamental display purposes until they are discarded, thus reducing the likely exposure as a potential source of disease transmission. Clearance and delivery of these perishable commodities may be delayed because of detection of live pests at points of entry which require identification of such pests and application of a suitable treatment.

[3] There is no international standard specific to cut flowers at present and Australia will benefit from this cut flower standard and scientific justifications regulating and minimising biosecurity risk on international trade of cut flowers. The IPPC standard to be developed for cut flowers will provide guidance to National Plant Protection Organizations (NPPOs) on identifying pest risks associated with this commodity.

Scope and purpose

[4] The standard under Specification 56 will provide guidance to NPPOs on identifying pest risks associated with cut flowers and on phytosanitary measures (including production practices, pest free areas and treatment options targeting specific pests/groups of pests) available to reduce the likelihood of pests of biosecurity concern being moved with these commodities in international trade. The standard will also provide guidelines to NPPOs on what factors should be considered when undertaking pest risk assessments.

Introduction

[5] As a significant trader in the international movement of cut flowers, through imports and exports, Australia is strongly supportive of the development of an international standard to harmonise the rules applied by global trading partners to address phytosanitary risks associated with this category of commodities.

International Plant Protection Convention of 19

17_EWGCutFlowers_2014_June Specification 56 – Australia’s response

[6] Australia has a well established biosecurity framework with a set of phytosanitary measures to ensure that quarantine pests are not introduced to Australia, or exported to other countries with the movement of cut flowers. In the absence of an international standard, Australia has applied measures on the movement of cut flowers in accordance with existing relevant IPPC standards (ISPM’s) such as ISPM 4 for “Establishment of pest free areas”, ISPM 10 for “Requirements for the establishment of pest free places of production and pest free production sites” and ISPM 2 for “Requirements for the establishment of areas of low pest prevalence”. Further, ISPM 2 for “Framework for Pest Risk Analysis”, ISPM 11 for “Pest risk analysis for quarantine pests including analysis of environmental risks and living modified organisms” and ISPM 20 for “Guidelines for a phytosanitary import regulatory system” provides the framework for analysing risk, while, ISPM 7 for “Phytosanitary certification system” and ISPM 12 for “Phytosanitary certificates” provide information on the obligations of the NPPOs.

[7] Whilst these and other international standards provide guidance on international plant quarantine that applies to cut flowers as a plant commodity, Australia agrees that the development of a cut flower specific international standard will help identify quarantine principles specific to the movement of cut flowers for the purpose of providing international guidance on developing appropriate and justified phytosanitary measures.

Tasks for EWG participants

[8] IPPC Specification 56 identifies several tasks for the expert drafting group to provide input, in order to aid the drafting of the standard for international trade in cut flowers. Australia has consulted with all relevant experts from government and responses are provided after each task below.

(1) Assess the importance of cut flowers and branches as pathways for quarantine pests in international trade.

[9] As stated above in the section ‘reason for the standard’, cut flowers are natural hosts for a wide range of insect pests, and have a higher potential for insect infestation due to their complex structure providing hiding spots for pest development, as insects naturally feed on them and are attracted to flowers due to their colour and scent. Guidelines on how to minimise risks from quarantine pests present on cut flowers and branches prior to importation could contribute to mitigating risks related to the international trade of these commodities and to reducing delays in clearing consignments at borders.

[10] Cut flowers also have a comparatively short shelf/vase life and are only intended to be used for ornamental display purposes. If international trade in cut flowers is left unmanaged, it could easily leak pests of significance in to the environment of importing countries and have serious economic impacts.

[11] Cut flowers and foliage have been imported into and exported by Australia on a commercial basis for about 40 years. As far as cut flower imports into Australia are concerned, Australia imports mainly roses, chrysanthemums, orchids, carnations and tropical foliage from various countries under the conditions of mandatory on-arrival inspection and appropriate treatment for non-compliance, including pest detection found during on-arrival inspection and clearance process. The major exporting countries are Colombia, Ecuador, Kenya, India, Ethiopia and China. During the past couple of years, Australia has imported about 76 million rose stems alone, on an average per annum. Taking cut roses as an example, between 2008 and 2012, there had been a steady increase in the number of rose stems imported each year (y-axis), as shown in the graph below.

of 19 International Plant Protection Convention

Specification 56 – Australia’s response 17_EWGCutFlowers_2014_June

2008 2009 2010 2011 20120

10,000,000

20,000,000

30,000,000

40,000,000

50,000,000

60,000,000

70,000,000

80,000,000

[12] Fresh cut roses are prohibited from countries that have sudden oak death (Phytophthora ramorum).

[13] Considering cut flower exports from Australia, major export commodities are wild flower species including foliage species (Australian natives), artificially propagated Geraldton Wax, kangaroo paws, Leucadendrons etc and cultivated, roses, lilies, orchids, yellow bells, carnations, chrysanthemums and orchids.

Below are some statistics on Australian flower exports between 2009-2013 obtained from Australia Bureau of Statistics (January 2013).

Unit : Australian Dollar thousand

Importing country

Exported value in

2009

Exported value in 2010




Netherlands 258.71 39.13 604.82 231.68 234.44

Germany 874.56 805.49 426.76 194.03 156.98

United States of America 32.81 0 0 0 55.77

Japan 122.41 163.05 75.48 20.27 23.75

United States Minor Outlying Islands 0 0 14.52 52.13 13.43

South Africa 0 0 0 51.16 10.33

New Zealand 10.1 0 1.94 4.83 7.23



Hong Kong, China 0 0 0 2.9 5.16

Korea, Republic of 0 0 4.84 0 0

Belgium 36.6 34.78 0 0 0

Canada 0 0 0 7.72 0

Cyprus 0 3.26 0 0 0

France 0 5.44 0 0 0

Italy 179.2 69.57 0 0 0

New Caledonia 0 0 3.87 4.83 0

Total 1514.39 1119.64 1133.2 570.52 506.06

Importing country

Exported quantity,

Tons

Exported quantity,

Tons

Exported quantity, Tons

Exported quantity, Tons

2009 2010 2011 2012

South Africa 0 0 0 12

Germany 85 Not available 89 52

Netherlands 25 Not available 77 53

United States Minor Outlying Islands 0 0 5 16

Japan 12 Not available 7 1

United States of America 3 0 0 0

New Zealand 1 0 0 0

Hong Kong, China 0 0 0 0

Korea, Republic of 0 0 0 0

Belgium 4 Not available 0 0

Canada 0 0 0 0

Cyprus 0 Not available 0 0

France 0Not available

0 0



Italy 17 Not available 0 0

Total 148 Not available 179 135

(2) Provide guidance on particular pest risk and risk mitigation factors pertaining to the class that may need to be taken into account when pest risk assessment is carried out by NPPOs and phytosanitary import requirements are determined.

[15] Australia's biosecurity policies aim to protect it against the risks that may arise from exotic pests entering, establishing and spreading in Australia through importation of cut flowers and, thereby threatening Australia's unique flora and fauna, as well as its agricultural industries that are relatively free from serious pests. Australia believes the pest risk analysis (PRA) process is an important part of biosecurity policies, while recognizing that the commodity class of cut flowers and branches has traditionally been considered low risk. It enables the NPPOs to formally consider the risks that could be associated with proposals to import products into their country. Australia has maintained a conservative but not a zero risk approach to the management of biosecurity risks. This approach is expressed in terms of Australia's “appropriate level or protection” (ALOP), which reflects community expectations through government policy and is currently described as providing a high level of protection aimed at reducing risk to a very low level, but not to zero.

[16] Each country determines its own ALOP from pests of biosecurity concern. If the risks are found to exceed Australia’s appropriate level of protection, risk management measures are proposed to reduce the risks to an acceptable level. But, if it is not possible to reduce the risks to an acceptable level, then no trade will be allowed.

Australian criteria for risk management of cut flower pathways:

[17] Australia has an established policy for the import of many species of cut flowers which have been permitted historically. The criteria that Australia uses for managing cut flower pathways consist of three key aspects for the management of biosecurity risk on imported consignments. These are discussed below, and are based on effective risk management principles in the absence of a pathway specific Import Risk Analysis, or a risk assessment, that identifies both the risk associated with the species at origin and possible mitigation measures for the identified risks.

These criteria are:

1). Freedom from live quarantine pests:

[18] Consignments of imported cut flowers for export must be free from any quarantine pests of concern to Australia. Australia has nil tolerance for any live pests (of all life stages) in the inspection sample.

[19] Until recently and since a major quarantine review in 1996 on cut flower imports, mandatory fumigation with methyl bromide (MB) gas has been in place for cut flowers as a mitigation measure against insect pests. Australia now moved away from mandatory methyl bromide fumigation towards managing pest risks offshore by encouraging suppliers to source cleaner flowers, and by constantly monitoring and building compliance history for supplier- importer pathways based on inspection outcomes by Department of Agriculture officers. Risk mitigation measures such as mandatory methyl bromide fumigation are only applied for non-compliant pathways.



[20] Alternative fumigants and alternative treatment options to fumigation, such as irradiation, should be explored and developed where treatment is absolutely necessary. Given that prevention is a better option, a systems approach for production of flowers and branches with in-field monitoring and control sprays or pest free areas/ pest free places of production/low pest prevalence areas for target pests identified on the pathway need to be developed. Presence of pathogens on cut flowers may pose a threat to importing countries including Australia, as some cannot be detected through visual inspection, or are present as non-symptomatic infections (which need to be addressed). These pathogen issues must be addressed through similar production systems, and if detected on arrival could lead to rejections if appropriate remedial actions (i.e. fungicide spray/dipping) are not available.

[21] While Australia’s policy also restricts presence of any contamination, often individual consignments are assessed on the level and type of contamination prior to corrective actions including sorting or rejection may be applied if necessary.

2). Consignments of cut flowers must be free of contaminants:

[22] Consignments of imported cut flowers for export must be free from any free from any contamination including non-permitted species, trash, soil, animal matter and non-commodity seeds. During inspection of a sample from the consignment, any non-compliance detected will be addressed through effective corrective actions.

3). Must be a permitted species:

[23] Australian quarantine policy for cut flowers excludes species prohibited by legislation propagatable species and close relatives of important crop plants, including Australian native plants and species of interest to the forest industries. All species of cut flowers imported into Australia have to be permitted species for this specificend use as only certain species/genera/ larger group (i.e. orchids) of cut flowers that are in “permitted species list” will be allowed entry. Australia’s current import policy for cut flowers excludes species prohibited by legislation. Any new species requests will be considered based on possible biosecurity risks related to the new species and the exporting country, pending provision of information on the production areas, cultivation practices, pests and diseases, climatic conditions etc.

[24] Any assessment for new species access may also involve agreement on timelines, and consultation, as well as audit and verification on the agreed phytosanitary measures for mitigation of risks prior to finalisation of trade. Australia believes that if conditions for a specific cut flower species are not already available, it will not be appropriate to translate existing conditions for other plant parts/products such as seeds for consumption, herbs, fruit and vegetables for consumption or tissue culture/nursery stock for managing risks on cut flowers without a risk assessment. However, existing information on the known biosecurity risk concerns on other forms of plant products or nursery stock may aid in the risk assessment of a new species of cut flowers.

[25] Cut flower imports into Australia are further supported by regulations in the Quarantine Legislation which relaxes the need for an Import Permit, recognising the end use of the product. Under the current criteria for imports, cut flowers qualify as a “plant product” that does not require an Import Permit as this has been “processed” to anextent that addresses the risk concerns, such as freedom from insect



pests and, to avoid providing a pathway for establishment of the cuttings in Australia and spread diseases of exotic nature. At the same time Australian Biosecurity Legislation prohibits importation of certain species.

(3) Identify particular pest risks associated with cut flowers and branches obtained from naturally occurring plants (i.e. collected in the wild) or cultivated.

[26] Australia agrees that there is a strong need to identify potential pests associated with the movement of cut flowers, along with the potential for the pests to establish and spread in the importing country. This issue has provided a lot of confusion in the past and led to inconsistent quarantine measures in international trade for this perishable type of commodity. The IPPC standard for cut flowers will assist in justifying import conditions.

[27] To provide guidance, pests associated with cut flowers should be divided into pest categories with detailed information to consider their likelihood to be present on the pathway and potential to establish and spread, for a pest risk analysis (PRA) to be formulated. Whilst considering pests likely to be on the cut flower pathway, there is also the need to make general considerations under ISPM 11 for ‘Pest risk analysis for quarantine pests including analysis of environmental risks and living modified organisms’, such as the volume and frequency of trade, pest management, cultural and commercial procedures applied at the place of origin and occurrence of the pest in a life-stage that would be associated with these commodities.

Pests associated with fresh cut flowers

1). Insect pests

Field insects

[28] Field insects are pests that feed on the flowers or foliage during the plant growth and flower development period, prior to harvest.

[29] Field insects that are likely be on the cut flower pathway:

- External feeders – Externally feeding plant insects are likely to be associated with cut flowers since the harvesting process may not be dislodge the pest during transport, processing and packing of cut flowers into cartons prior to trade.

- Internal feeders attacking the developing or developed seed/fruit/cone/nut in the cut flowers may be present during harvest and packing process.

- Furthermore consideration of whether these insects would be visibly obvious during quality grading or inspection is required. Consideration would also need to be given to the likelihood of poor field management conditions and whether an insect pest would survive the cool storage transport environment.

Storage insects

[30] Storage insects present on fresh cut flowers are out of scope compared to dried flowers. However, contamination by storage insects such as hitchhikers (i.e those hiding in the packaging, cartons etc.) must be addressed if these are exotic to the country of origin.



2). Fungi

[31] Cut flowers can be a host to many fungal species causing infections mostly superficially on the flowers, leaves, calyces or stems, and occasionally internal infections affecting seed/fruit/cone or nut if present. This may depend on the cut flower species. Many fungal species associated with cut flowers may not be considered to be pathogenic. However, there are species that can cause symptoms that affect the quality of the product, or even pose a threat to the importing as fungi of economic concern. Cut flower pathogens may be field pathogens or that cause postharvest decay. Unlike viruses, viroids and phytoplasmas, bacteria and fungi can be carried on cut flowers as external infection.

3). Bacteria[32] Bacteria may cause lesions on any part of the cut flower commodity, and could be an external

contaminant or cause internal infection. However, the primary consideration for bacteria as a pest of quarantine concern would be its potential for economic consequences for the importing country.

4). Viruses, viroids and phytoplasmas

[33] These pathogens are primarily known to be spread by infected propagation material and insect vectors. Therefore, transmission through flower and foliage may require vectors for spread and establishment in the importing country. However, virus infection and its impact in terms of the need for phytosanitary regulation is complicated due to several determining factors, such as the level of host infection and host resistance mechanisms, factors influencing entry, establishment and spread of viruses and the fact that even if vectors are available in the importing country, the infection may not establish in the natural environment.

5). Nematodes

[34] The majority of nematodes are known to be internal or external root parasites, though there are some species known to attack above ground plant parts such the base of stems and foliage. A complication that arises with the determination of nematodes as quarantine pests similar to pest identification issues for immature insect stagers and pathogens is the identification of pests to species level. The inability to identify a pest to species level would require action at a higher level rather than a lower level.

[35] In general, the need to identify a pest below species level should include evidence demonstrating that factors such as differences in virulence, host range or vector relationships are significant enough to affect phytosanitary status of cut flowers as justification, in accordance with ISPM 11.

6). Contaminants, non-commodity plants, plant parts and seeds as pests

[36] Australia stipulates that imported cut flowers should be not only free from live insects, disease symptoms but also free from other plant material, contaminant seeds, animal material and any other contamination of quarantine concern such as soil. Australia generally has a nil tolerance for any such material. However, Australia does review individual cases and explores alternate options before resorting the consignment or rejecting it.

[37] Guidelines for the risk assessment of plants as pests are provided in ISPM 11 – Annex 4 Pest risk analysis for plants as quarantine pests. Australia generally has a nil tolerance for any such plant material. Australia supports the prohibition of contaminant seed from species where there is sufficient evidence that it will become an invasive alien species in an NPPO’s PRA. Rejection (to resort to remove contaminants) is supported as the risk of a species becoming a weed is an inherent one.



Flower source – wild versus cultivated[38] Cultivated and wild flowers in Australia have equal share in export markets and most wild flower

species for export come from Western Australia. However the pest profile and pest loads on wild picked native flower species are expected to be relatively higher than that of cut flowers cultivated in secure controlled conditions. The additional factor needed to be considered is the unknown risk of wild flowers.

(4) Gather and analyse information related to current production and trade practices to identify how they influence pest risk and how they could be utilized in pest risk management, taking into consideration the following:

a. geographic location of the place of production

[39] Cut flowers are produced for international and domestic markets in different states and territories within Australia. However, the variety and types of flowers grown vary within the geographical areas. Most export flowers come from Western Australia, South Australia, Victoria and New South Wales.

[40] Australia has geographically separated areas such as Western Australia and Tasmania, and exports of cut flowers and other plant materials to international trading partners under certification of pest free areas is possible for specific pests of quarantine concern to importing counties for pests that may occur in other parts of Australia. Natural barriers such as desert and oceans physically separate these areas and pest free status can be maintained by effective movement controls of material in and out of these areas. Australia also maintains country freedom in the same manner, and these pest free areas are assured as an additional declaration on phytosanitary certificates for various plant material exports that include cut flowers, where importing country recognition of pest free areas is required.

[41] Assessing domestic production of rose cut flowers (within Australia), according to Australian industry, there are approximately 30 growers producing for the domestic market with a growing area of approximately 25 hectares (under cover). The domestic industry produces about 40 million stems a year. The rose varieties are mostly red and white whereas, roses with more exotic colours and long stem lengths (70-120 com) are typically imported ones.

[42] Domestic production is challenged by temperature and altitude requirements for high quality rose production.

b. production system types (open, closed) and components (water sources, growing medium conditions, seed and other planting material source and quality, climatic conditions, crop cycle)

[43] Australia is open to any production system for cut flowers that achieves the final outcome of a pre-harvest minimised level of infestation. This may be in open cultivation areas, green houses and glasshouses with simulated climatic conditions to encourage year-round production cycles and longer flowering times. However, good agricultural practices, pest monitoring, in-field controls and irrigation/watering practices that do not enhance disease development have always been an integral part of flower production in Australia for domestic and international markets.

[44] Other factors contributing to good quality and cleaner flowers include better hygiene and weed control in and around the farms/green and glasshouses. Frequent monitoring of the crop for pest levels



and disease symptoms (including virus symptoms) and timely remedial actions during the growing and flowering period keep the pests away. Integrated pest management practices are also being trialled.

[45] Planting of disease free material from tested and screened mother stock and raised in enclosed atmosphere and temperature controlled nurseries have added to the diseased free nature and quality of cut flowers.

c. pest management through growing practices and monitoring in field for insect pests and diseases

[46] There is a general expectation by Australia that productions systems and cultivation practices that monitor pest levels during the growing season prior to harvest are in place in flower growing areas around the world to minimise infestation levels in the fields/greenhouses/flower farms to begin with. Pest monitoring and insect spraying in field, integrated pest management practices or targetted pest surveillance in production sites have proven to be acceptable approaches to keep the pest levels on cut flowers to a low or minimum level at harvest. Australia exports plant materials including cut flowers to international trading partners under a declaration of pest freedom in the area of production where required by an NPPO for specific quarantine pests, under the guidelines from the relevant ISPM standards.

[47] Harvesting and production methods are a consideration for an NPPO when assessing a cut flower commodity for importation during a PRA process, and for establishing the overall risk throughout the supply chain. Best practice throughout the production process should be encouraged to ensure the movement of clean flowers, free from pest and other contamination.

[48] Australia has a few schemes from approved accredited sources for importation of cut flowers, through which pests of biosecurity concern are managed offshore prior to importation. Australia has always encouraged trading partners to establish such schemes to regulate pests in a formal phytosanitary system. These schemes are monitored and certified by the overseas authorities involved in the schemes and require effective surveillance, control and eradication measures to be maintained by NPPOs.

d. post-harvest treatments (e.g. physical, mechanical, chemical)

[49] This is aimed at reducing the pest infestation level to a minimum in cut flowers packed for international trade in the absence of any pre-harvest controls such as Integrated Pest Management, infield monitoring and control. This is only an alternative to pest management practices in-field (referred to in 4c) if these fail and cannot bring the pest levels to a minimum within the limits of the importing country’s ALOP.

Packing facility processes:

[50] Packing facility processes such as quality inspection, on receival of the product from the grower, will assist with the assessment of the pest status of the product initially. Other packing facility processes such as cleaning, shaking, grading and packing facility inspection prior to formal export inspection for certification will reduce any pest issues in packed boxes of flowers.

Visual inspection and remedial measures by exporting country:

[51] Australia follows importing country requirements to prepare the cut flowers and undertakes an inspection to verify the flowers meet destination requirements prior to issuance of phytosanitary



certificates. Consignments that do not meet the importing country requirements are not certified for export. Remedial measures are applied to consignments presenting any issues as appropriate to meet international obligations prior to export. Australia stipulates similar practices are in place in source countries as well.

Methyl bromide fumigation treatment to address presence of live pests of concern in export consignments:

[52] The methyl bromide fumigation dosage applied at 32 gms per cubic meter for 2 hours at 21 oC (or a sliding scale of this dosage) is found to be effective against the majority of the insect pest stages that are known to be associated with cut flowers, and is widely used as a corrective action treatment (remedial measure) in Australia and in various overseas countries. This appears to be effective against all life stages of external feeding insects with the exception of some mite species, snails and slugs, which may require higher doses.

[53] In addition to the information relating to current production and trade practices to identify how they influence pest risk and how they could be utilized in pest risk management to minimise infestation levels of imported consignments, the following additional verification activities are in place on arrival in Australia. (Note: the below information is best included here as there is no other relevant section for importing country on arrival clearance procedures).

On arrival procedures in Australia:

Document verification:

[54] On arrival of consignments, Australia verifies all documentation presented on behalf of the consignments to ensure the consignments have been prepared and certified to meet Australian requirements. Any issues with documentation (such as lack of documentation or inadequate or incorrect documentation) is referred to the NPPO for resolution. Due to the high perishable nature of the commodity and time differences between countries involved, the importer is encouraged to seek help from their suppliers to in resolving any issues.

Import inspection:

[55] The Australian Department of Agriculture inspects all cut flower and foliage consignments entering Australia to verify freedom from pests and diseases. Australia uses a combination of techniques during inspection to dislodge insect pests and to detect minute organisms. These inspection methodologies include use of fibulation (shaking/tapping) of flowers upside down, use of optical enhancements and dissection where required.

[56] There is nil tolerance for live quarantine pests and diseases of concern in the inspection sample during on arrival inspection. Any significant breaches to protocol agreements or treatment failures are reported back to the NPPO for corrective actions to be undertaken. The corrective actions applied in the importing country may include mandatory methyl bromide fumigation for live external feeding insects of concern



[57] Australia also regulates for contaminants such as non-permitted or non-declared species, trash or contaminant seeds in the consignment., The corrective actions for contamination may include sorting and removal of trash/contaminant seeds, destruction or re-export of consignments with risks that cannot be mitigated on arrival.

Sampling for inspection:[58] Australia inspects all cut flower consignments on a representative sample taken from each

consignment. The sample selected for inspection will be 600 stems (or a 100%/all stems for consignments consisting of less than 600 stems; it is an evidences-based sampling method used by Australia for all other fresh produce such as fresh fruit and vegetable where we have 95% confidence in detecting very low (0.5%) levels of infestation. Australia has confidence in its inspection techniques for perishables; a recent study to determine the effectiveness of detection (by CEBRA or the Centre of Excellence for Biosecurity Risk Analysis previously known as ACERA or Australian Centre of Excellence for Risk Analysis) has proven this.

Verification of compliance and any offshore/preshipment measures:

[59] Australia verifies any preshipment measures through on -arrival inspection to ensure all risk by pests of quarantine concern are addressed prior to release of the consignment. Any non-compliance is addressed appropriately prior to release. Any significant non-compliance issues are ideally reported back to the certifying NPPO for corrective actions. Further, the standard should allow confidence building through verification activities either by the importing NPPO or as a joint venture, as new protocols are established based on pest risk analysis or when significant and repeated non-compliance issues arise.

- Corrective actions for detection of live life stages of insect pests

[60] As discussed in section 4 d., any infestation, by external feeding insects on imported consignments or on flowers presented for export inspection and found infested, is addressed through fumigation at the required dosage. However, interceptions are referred to operational scientists (entomologists) initially to first attempt to determine the species level identification to see if action is required (by verifying the pest name in published/available list of pests of concern to the specific importing country (inAustralia or otherwise), prior to directing for treatment to mitigate the risk. Any suspect internal feeders that may be carried on fruit/nut/cone in cut flowers, or immature live life stages are followed up the same way to rear them out or to obtain identification information prior to determining a suitable treatment as the standard treatment for external feeding stages may not be adequate for internal insect stages.

[61] Standard setting for cut flowers should also consider developing commodity specific pest lists for different geographical areas where flowers are commercially grown/cultivated for international trade. Information on specific pests on the pathway, where possible, will aid in the quick identification of intercepted pests and will help minimise delays in clearing consignments at the border. Efficient offshore management of pests will reduce high costs involved with the on arrival fumigation treatments and save airfreight charges incurred by the flower industry in the event of a rejection, as



well as prove to be an environmentally friendly exercise. Tolerance levels for various types of contamination can be worked out as a guide for export and on arrival regulatory processes.

- Non-compliance due to diversion of end use of cut flower commodities

[62] End use breach of certain species of cut flowers with vegetatively propagatable stems is an ongoing issue in the international trade on cut flowers. This should be recognised and captured in the standard for cut flowers, as well as in any other commodity standard where similar diversion issues exist. It is the responsibility of each country to put appropriate measures in place to manage the risk of diversion.

e. practices in packing facilities and conveyances (e.g. screening, segregation of material (including avoidance of mixing material from different origins in consignments), time of loading, protection of cargo to prevent infestation, packaging system and materials, use of cooling systems)

Packing facilities:

[63] Packing facilities collecting, processing and packing flowers for export are expected to maintain basic hygiene and cleanliness and separate areas of different operations in the processing of flowers (i.e. receival area, cleaning and grading area, processing line which may or may not include any preconditioning treatments (insect dipping or washing in chlorine solution), quality inspection area (where processed flowers are quality checked trimmed and sleeved for order), and the packing area where flowers are labelled individually or in bunches and ‘boxed’ as per order and market preference.

[64] Apart from cleanliness, packing facility areas are generally expected to have a system for segregating flowers received from more than one source for maintaining segregation, traceability and to avoid mixing and cross contamination. Generally the packing facility areas require insect netting and trapping devices (insect trapping strips/zappers etc.), specifically in areas where flowers are packed in to boxes or stored. Consignments of packed flowers are expected to be segregated throughout the storage and transport process and the quarantine integrity and product security maintained, after treatment (where appropriate) or having undergone phytosanitary inspection for export.

Packaging and security of cut flowers:

[65] Australia requires that each consignment must be packed in clean new packaging, and must be secured (i.e. made insect proof) prior to shipment to maintain its quarantine integrity on arrival. Trading partners of Australia have similar requirements as well.

Secure packaging options: [66] One of the following secure packaging options are recommended by Australia for imported and

exported cut flowers to maintain the quarantine security of goods arriving in Australia.



Option a)- Integral cartons: [67] Produce may be packed in integral (fully enclosed) cartons (packages) with boxes having no

ventilation holes and lids tightly fixed to the bases.

Option b)- Ventilation holes of cartons covered: [68] Cartons (packages) with ventilation holes must have the holes covered/sealed with a mesh/screen of

no more than 1.6 mm pore size and not less than 0.16 strand thickness. Alternatively, the vent holes could be taped over.

Option c)- Polythene liners: [69] Vented cartons (packages) with sealed polythene liners within are acceptable (i.e. produce packed in

polythene bags – folded polythene bags are acceptable).

Option d)- Meshed or shrink wrapped pallets: [70] Cartons (packages) with vent holes or gaps that are packed on a pallet, the pallet must be covered or

wrapped with polythene/plastic/foil sheet or mesh/screen of no more than 1.6 mm diameter pore size and not less than 0.16 strand thickness.

Option e)- Produce transported in sealed air containers: [71] Cartons (packages) with holes as loose boxes or on pallets may be transported in sealed containers.

The container must be transported to the inspection point intact.

Labelling of product: The labelling information would include but not be limited to:- - Genus and species name

- - Grower name, lot number or farm reference (only where specific pest monitoring and infield control to minimise infestation level is required and has been agreed between the trading partners)

- - The packing facility name or reference- - The treatment facility name or reference (where a preshipment treatment has been agreed as

risk mitigation measures) and- - Country of origin

Cooling of flowers/consignments: [72] Australia does not have any specific requirements for cut flowers to be stored and transported in a

chilled environment. However, most packing facilities handling flowers for export in Australia and in the overseas are maintained at lower than ambient temperatures (to varying degrees of cold temperatures) during the packing process and storage. Most countries like Australia uses chilled transport vehicles purely to maintain flower quality and shelf/vase life, and to prevent any live insect pests moving within and in and out of the consignments.

[73] As cut flowers consignments are mostly air freighted to destinations due to the highly perishable nature of the commodity, packed flowers travel in cargo hold in aeroplanes at low temperatures ranging from 4-12oC.

Documentation:International phytosanitary certificate:

[74] Annex 1 of ISPM 12 Phytosanitary certificates provides a model phytosanitary certificate for export. This incorporates all information required for the movement of cut flowers and other plant materials. It may be useful to have the ISPM on cut flowers highlight particular information of importance for the international movement of cut flowers. This would include any treaceability related information



on what processes/ treatments the flowers in the specific consignments may have undergone recorded in the documentation (i.e. under the section for ‘Distinguishing marks’) and place of origin. This information helps in the verification of the agreed phytosanitary measures that the flowers have undergone.

[75] Australia requires documentation such as a phytosanitary certificate to accompany shipments, which provides evidence that the commodity has been prepared, inspected and certified to meet the requirements of the importing country. As confirmation of completion of any prerequisites such as sourcing flowers under a pest free area/pest free place of production or systems approach, inspection/and testing for specific pests or even any treatments applied, additional declaration statements can be included in the appropriate section of the phtosanitary certificates.

[76] Appendix 2 of ISPM 12 Phytosanitary certificates already details recommended wording for additional declarations on phytosanitary certificates. Australia considers this recommended wording as adequate for the international movement of cut flowers.

Import Permits:

[77] Requirement for an Import Permit is to be determined by the importing country’s NPPO based on their legislation and need to document entry conditions on a legal document for communication to the industry and the certifying authority in the exporting country and may be used also for compliance purposes. This is not a current requirement for Australia according to the Australian Biosecurity Legislation which categorises cut flowers and foliage as ‘adequately processed’ and as a ‘plant product’ with reduced shelf life (with key criteria mentioned elsewhere in this document), and as not requiring an Import Permit. Further Australian entry conditions for permitted cut flowers are published in the Department of Agriculture website and are readily available to public to comply with, and for certifying authorities where phytosanitary certificates are required.

Treatment certificates:

[78] Consignments of flowers that have undergone preshipment conditioning or treatment as agreed between the trading countries will carry evidence for this.

f. use and relative importance of industry practices on arrival.

[79] On arrival of consignments in Australia, importers arrange to move the consignment to the inspection location and maintain the cool chain throughout the inspection and clearance process, until the flowers are delivered.

[80] Flowers also are required to maintain their quarantine status until cleared by Australian Department of Agriculture officers at the border. This is achieved by secure packaging, transport and segregation arrangements (please refer to point 4e. for further details).

[81] Cut flower consignments will also need to be accompanied by documentation (such as phytosanitary certificate, airway bill, treatment certificates etc., as appropriate) as proof of origin and status of the consignment in meeting importing country requirements.

(5) Identify appropriate phytosanitary measures to minimize the risks of quarantine pests during the production, harvesting, treatment, packing and transport of cut flowers and branches, taking into consideration, for example, the following:



a. pest free areas, areas of low pest prevalence, pest free production sites or places of production

[82] The current pest freedom requirements for monitored production system accommodate (but are not limited to) pest free areas, pest free production sites or places of production or areas of low pest prevalence or use of a systems approach for one or more pests which will involve surveillance, trapping, infield monitoring and control or integrated pest management. The requirements for developing and maintaining such systems are detailed in ISPM 4 for “ Establishment of pest free areas”, ISPM 10 for “Requirements for the establishment of pest free places of production and pest free production sites“ and ISPM 22 for “Requirements for the establishment of areas of low pest prevalence”. Further, ISPM 2 for “ Framework for Pest Risk Analysis” and ISPM 11 for “Pest risk analysis for quarantine pests including analysis of environmental risks and living modified organisms” and ISPM 20 for “Guidelines for a phytosanitary import regulatory system” provides the framework for analysing the risk, while, ISPM 7 for “Phytosanitary certification system” and ISPM 12 for “Phytosanitary certificates” provide information on the obligations by the NPPOs.

[83] Approved accredited sources have always proven to be a better risk management measures for insect control, rather than a fumigation treatment that affects the quality of cut flowers in most instances and reduces the vase life drastically.

[84] For exports to various overseas markets, in accordance with ISPM 4 and 10, Australia establishes pest freedom in pest free areas/pest free production sites by pest trapping and surveillance, surveys in growing season and monitoring/inspection. As a stand-alone measure against a quarantine pest, the appropriateness of this measure would be heavily dependent on the biology of the pest and the confidence that it would be detectable in the crop on inspection. For example, it would be difficult to adopt this measure if a pathogen was known to be symptomless, had a latent infection period or only expressed symptoms under certain environmental conditions or periods of stress. Australia provides phytosanitary certification to support this measure.

[85] To manage the biosecurity risk of importing fresh chrysanthemum cut flowers which are hosts for the leaf miner species Chromatomyia horticola (an exotic pest for Australia), risk management measures such as sourcing from areas of low prevalence for leaf miners (ISPM 22) are currently being used. Australia does not strongly believe this is useful as a stand-alone measure for the international movement of cut flowers, as the expectation would be to keep the pest levels low in-field. However, the pest is expected to be completely absent in consignments. This is verified through an on arrival inspection of a sample which will be applied a nil tolerance for the specific pest. However, this measure can be useful when examining a commodity such as cut flowers which has been made “a lower risk commodity” under existing entry conditions such as those applied by Australia and that might not be a preferred host for the specific pest.

b. use of a systems approach

[86] This is discussed under 4c.

c. phytosanitary security and consignment integrity up to import clearance.

[87] Please note appropriate phytosanitary measures to minimise risks by quarantine pests during production, harvesting, treatment, packing and transport of cut flowers are discussed under point 4 c). and d). above.



[88] One key element of maintaining the phytosanitary measures for cut flowers once developed is to actively verify them and provide feedback for remedial action to be taken by the NPPOs in a timely manner to prevent recurrence of issues and to prevent similar incidences from repeating.

(6) Consider including a list of major pest groups associated with cut flowers and branches in international trade and of appropriate phytosanitary measures for each pest group.

[89] The pests that are associated with international trade on cut flowers and branches are broadly grouped and discussed under section 3 above. Possible phytosanitary measures for risk mitigation are discussed under Sections 3 and 4 c)., d). and e). above.

(7) Review relevant existing ISPMs, regional standards and available related agreements, and identify examples of procedures that could be considered during the development of this standard.

[90] Discussed in the introduction section and under section 4 c). above.

[91] In addition to the above mentioned ISPMs to harmonise pest risk assessments and risk mitigation strategies for cut flowers among international trading partners, additional procedures and standard are required to regulate the presence of wood/bark on branches of certain cut flower species.

(8) Provide guidance on how to manage the pest risk, particularly pertaining to fruit and other propagules for ornamental use that are associated with cut flowers and branches.

[92] Some of the cut flower/foliage species currently exported to various international markets from Australia contain fruits/berries (Berzelia sp. or pepper corn berry), nuts or cones (Leucadendrons) or other propagules such as bulbils (lilies) and seeds as part of many cultivated and wild picked flower species. Most of the time these commodities are popular for export markets due to the presence of these propagules that add colour and texture to the otherwise boring product as foliage. From time to time our trading partners raise issues with the presence of any of these “propagules” which in reality may not be actually propagatable or at the time flowers are picked for export, mature enough to be able to grow and produce new plants. The “cones” produced by Leucadendrons are actually nothing more than colourful bracts (calyces) clustered at the terminal branches to form pseudoflowers. When these cones were classified as “fruits” requiring fruit fly host measures, Australia intervened and proved there was no biosecurity risk associated with the commodity and regained market access.

[93] However, the standard should focus on identifying commonly traded cut flower species with fruit/berries which may attract fruit flies and internal pests for possible assessment and regulation. Australia has no restrictions on seeds carried by cut flower commodities currently permitted access. However, Australia at this stage has restrictions on Lilium spp. cut flower varieties that produce bulbils. Any new species access request will factor in presence of propagules and the biosecurity risks posed by the commodity in the pest risk analysis.

(9) Consider pest risks associated with dried cut flowers and branches.

[94] Dried cut flowers and foliage are considered by Australia as adequately processed and not carrying the same pest risks as freshly cut flowers. However, it is considered there may be a slight increase in other risks such as by thoroughly dried propagules on the commodity which under ideal conditions may become propagatable posing a biosecurity threat to the importing country. Another factor that



increases the risk is storage pests that creep into the consignment during long storage. Australian dried wild flowers are often treated with chemicals and dyes for colour enhancement, which help keep the pests away.

(10) Consider whether the standard could affect in a specific way (positively or negatively) the protection of biodiversity and the environment. If this is the case, the impact should be identified, addressed and clarified in the draft standard.

[95] In developing the standard, consideration needs to be given to the base minimum requirements necessary for NPPO’s to provide quarantine security for exported and imported cut flowers. NPPO’s vary greatly depending on their financial commitments or restrictions on resources such as personnel, or technical capabilities and available technology. Provision of guidance on bare minimum measures ensures that practical measures are available to all NPPO’s including those from developing countries.

[96] The development of the cut flower ISPM will aid in the protection of plant health and the environment of the importing countries by providing guidance and structure for risk mitigation and phytosanitary procedures and by providing biological protection from exotic and alien pest invasions through international trade on cut flowers.

[97] Similarly, alternate technologies for addressing interceptions of infestation by insect pests rather than applying fumigation with toxic gases (such as methyl bromide) may need to be explored. This will have a positive impact on the environment as well as save costs on chemicals for the parties involved.

[98] In addition to the mention in section 4 under “On arrival procedures for Australia”, the standard also must acknowledge the diversion issue, of the possibility of cut flower species which have stems that are vegetatively propagatable imported for the end use of decorative /display purposes being misused in the importing countries, increasing the risk profile of cut flowers. End use breach of certain species of propagatable cut flowers is an ongoing issue in the international trade on cut flowers. This should be recognised and captured in the standard for cut flowers, as well as in any other commodity standard where similar diversion issues exist. The standard should recognise that it is the responsibility of each country to put appropriate measures in place to manage the risk of diversion.

[99] One of the issues that Australia faces is that once consignments have landed, inspected and found to be infested or detected with pathogens/symptoms, there is not much time left to assess the situation and apply corrective actions/treatments to enable shipments to be released from quarantine in a timely manner so to reach the destinations such as the florists given that the highly perishable nature of the commodity. The assessment is to determine the status of the detected pest (or pathogen) to see if it requires action depending on its presence and absence in the importing country, the level and extent of infestation/infection and the impact it may have if the consignment is allowed untreated, rather than applying a mandatory blanket treatment at this point without knowledge of the risk.

[100] When it comes to identification of the pest, it is often the same scenario for Australia and our trading partners, identifying the pest down to species level before an assessment can be made to determine the corrective actions becomes a cumbersome task often with no timely conclusion or no progress at the end. This is due to lack of knowledge of exotic pests present overseas, lack of technology such as identification tools and taxonomy keys, lack of resources technological capacity to employ advanced PCR techniques and limited time. Costs associated with any such follow ups are often charged to the industry (importer) and sometimes are expensive and exceeds their expectation, setting a precedence to nominate default treatments that cover wide range of pests in the absence of specificities relating to the detected organism.



[101] Collation of information on different pest types specific to cut flower species and exporting countries and their geographical distribution will assist the importing country’s regulatory authorities to determine timely actions.

(11) Consider implementation of the standard by contracting parties and identify potential operational and technical implementation issues. Provide information and possible recommendations on these issues to the SC.

[102] The standard implementation should be flexible enough for NPPOs to focus on consideration of ‘best practice’ measures that are currently applied and available and those supported by existing international standards for harmonisation, rather than methods or technology in development. It could be possible to list these technologies as areas for further exploration.

[103] There are one or more external elements other than the NPPOs of the exporting and importing countries and industry representatives such as growers, packers, treatment providers, importers and exporters, who contribute to international trade; namely, the freight forwarders, the International Air Transport Association (IATA), the airlines, freight handlers in the importing country and the transport providers for movement of cut flower consignments, staff at locations where inspection and treatment occurs, that need to be aware of the principles of international cut flower trade in general and be aware of individual importing country specifications for transport security, for all the efforts to be fruitful.


2005 · Web viewAs far as cut flower imports into Australia are concerned, Australia imports mainly...

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