1.3.1 Contingency planning
1.3.2 Compliance inspection
1.3.3 Pest tolerance categories and maximum pest limits (MPL's)
Significant efforts are currently being made to liberalise agricultural trade by the removal of unjustified technical barriers to trade. It is seen that technical measures that restrict trade need to be open and comprehensible to the trade participants and supported by justifiable reasons for their implementation. In this context of transparent and justified phytosanitary measures, the use of blanket prohibitions is no longer appropriate. Quarantine agencies should move away from import prohibitions for plant products towards the use of import specifications only.
· Import specifications should be available to allow the export of any plant products from one country to another.· Import restrictions or prohibitions should only be used where specifications are not yet prepared and should be identified as interim measures.
The use of blanket import prohibitions is no longer acceptable. It will be necessary for nations to provide specifications, which cover all the concerns of the importing nation, for all products. This concept is a primary component in developing transparent and justified quarantine.
The presence or absence of a pest in a country, as defined by its political boundaries, has often been used for the construction of phytosanitary measures. In many cases, where a part or region of a country is pest free then such a measure excluding product from the whole country could be regarded as a form of trade barrier.
When an area freedom is announced by a quarantine agency it needs to have parameters and should be verified and monitored - in much the same way as a chemical on physical treatment. (In fact area freedom could be regarded, in the broadest sense, as a plant quarantine treatment),
The boundaries of the area, or the treatment limits, should be defined scientifically and not by political boundaries. There should be opportunities for nations to declare part of their country as free from a specific pest, and with appropriate monitoring and testing, have this accepted by the counterpart quarantine agencies.
· The assurance of pest freedom for an area or region within or between countries, with appropriate checks, should be accepted as a valid quarantine certification of equivalent standing as nation-wide certification.
This principle would apply particularly to pest outbreaks; the quarantine zones associated with such outbreaks would need to be defined and evidence presented to show that quarantine could be maintained.
A further aspect of export certification for quarantine purposes is the consequence of certification failure, i.e. where a pest, at an infestation rate above the permitted tolerance is found on the product by the importing nation.
The importing nation is concerned about the possible introduction of an important pest whilst the exporter has to know what would be the importing nation's reaction to such pest interception. One means of doing this is by describing the contingency actions to be taken by each partner in a formal document or agreement. The exporting nation can describe the actions to he taken when problems occur at any point during the production process or at inspection by the importing authority. The importing nation is able to encourage compliance with its import requirements by specifying what action it would take in the event of non-compliance. This could range from an immediate investigation by the exporting authorities to a suspension of imports for a defined period. Documenting contingency actions in this manner removes the uncertainty of pest interception and promotes compliance and rapid problem solving.
A formally structured Bilateral Quarantine Agreement (BQA) can be devised which lists the pest of concern, describes the treatment(s) in full, the inspection sampling procedures, the contingency measures to be applied by the trading partners, and names the officials accountable for the Agreement. The documentation of all these factors leads to better understanding between officials and producers and commercial importers, with a consequent improvement in trading patterns and protection.
The compliance inspection systems utilized by port inspectors must be related to the specifications provided to the exporting nation. If the inspection rates are too low, the importing nation is not-sure its measures are being complied with; if the inspection rates are too high the importing nation is to all intents and purposes, raising the level of import specifications.
· Import inspection sampling rates should relate to the import specification supplied to the exporting nation and this information should be available to that exporting nation.
It would facilitate trade and good relations if some effort was made by the agencies both in the importing and exporting nation to reach an understanding on the contingency measures applied if a product fails its compliance check. This is particularly so with products host to high risk pests where severe action on non-compliance is likely.
The implication then is that all nations trading in plant produce that take samples when inspecting product are taking risks with pests and are using tolerances, and hence a managed risk policy, whether or not it is recognised as such. If the concept of tolerances can be accepted, different tolerance levels can be devised for pests of differing importance. Pest categories, with standard criteria for their definition, can then be developed. Such a system promotes transparency and defines optimal disinfestation regimes for treatment procedures.
· Importing nations, should provide to exporting nations a description of the contingency actions applied if a product fails to comply with import specifications.
Present practices may allow the movement of product subject to high risk pests but does not adequately recognise the risks or describe the tolerances. The acceptance of tolerances will allow the construction of explicit parameters for import specifications.
· Risk assessments should he scientifically based and consist of biological pest evaluation supplemented by socio/economic studies as necessary.· Risk assessments should be available for scrutiny by the quarantine agency of the exporting party in a bilateral trade negotiation.
· The risk assessment should be regarded as an essential component of access negotiation and its discussion should assist in the solving of access problems.
Standard guidelines which would include all the factors in a biological evaluation of pest, and the evaluation of social or environmental aspects - all supported by an economic analysis would facilitate accurate and acceptable risk assessments. Different nations will give different values to the factor within a risk assessment as the problems each nation faces may differ markedly in degree or nature. This must be recognized. However, describing of these values in a Pest Risk Assessment (PRA) is essential to achieve understanding and to allow consideration and acceptance of them. Quarantine measures can only be justified on this basis.
A tolerance level should be developed from knowledge of a threshold establishment pest population. This is the critical minimum number of propagative units able to establish a population in an area hitherto uncolonized by that pest. Obviously, the tolerance level would be lower than the threshold population level. This remains a very difficult exercise - rarely having being accomplished. Additionally, in practice a pragmatic view of the likelihood of the simultaneous occurrence of the factors giving rise to the development of a threshold population and a consideration of the practicalities of the sampling process for the different grades of pest, needs to be introduced to the tolerance setting process.
Developing the concept of pest tolerance (maximum pest limits -thresholds) is one of the fundamental aspects of quarantine - the relative risk level of pests. It is necessary to be able to compare and contrast different pests and provide an indication of its risk level. One way of doing this is to use a system which groups all significant pests in categories such as:-
· Critical Quarantine pests - the pest of highest concern. These pests not only can cause economic loss or environmental damage but also lead to the loss of market access for exports.· Quarantine pest - significant pests not present in the importing country.
· Injurious pests - present in the importing country but, because they are subject to control measures, efforts are made to exclude further populations. This category can also include non-established pests of lesser significance.
· Contaminants - includes those organisms of no pest significance (such as predatory mites and spiders) and ubiquitous pests (such as pest of stored products).
The listing of pest in these categories by the importing nation makes its pests concerns very clear to the exporting nation, in the form of BQA's, or in plant importation permits (PIP's). For clarity, the lists of Quarantine and Injurious pests and Contaminants should be included along with the high risk. Critical Quarantine pests.
The term Maximum Pest Limit (MPL) is suggested for setting tolerance levels, and is the basis of the compliance level for product inspection at the port of entry. In other words, this is the average number of pests permitted entry with the product and this allows the development of a compliance cheek number - the number of defective units per inspection sample.
It is expected that the MPLS for critical quarantine pests will be designed for each pest and could be quite different. However, with the other categories, a standard MPL may be used.
