Ministry of Agriculture and Forestry: Managing biosecurity risks associated with high-risk sea containers.

Sea containers are large; they are usually full of goods and packaging materials, and a great many enter the country each year. Sea containers can carry unintended cargo – exotic pests and diseases that could threaten our primary production industries and our biodiversity. While it is critical that our borders are protected from the risks posed by exotic pests and diseases, it would take a great deal of time, and significant resources, to thoroughly inspect all the sea containers that arrive at our ports.

Instead, the Ministry of Agriculture and Forestry (the Ministry) uses “risk profiling” to identify the sea containers that are most likely to pose risks to our primary production industries and our biodiversity. The Ministry then inspects the sea containers identified as high risk to ensure that they are not contaminated with pests or diseases.

We sought to provide Parliament and the public with assurance that the Ministry accurately identifies the sea containers that pose the highest biosecurity risk, and then comprehensively inspects and decontaminates them.

The Sea Container Import Health Standard

The Ministry’s requirements for managing sea container biosecurity risks are set out in the Import Health Standard for Sea Containers from All Countries (the Sea Container Import Health Standard).

The Ministry issued the Sea Container Import Health Standard in September 2003, and planned to fully implement it by 31 December 2003. The Sea Container Import Health Standard requires all the systems and facilities associated with the biosecurity clearance of sea containers to be audited. However, the Ministry has not yet fully implemented the required auditing. The delays mean that the Ministry does not have all the information it needs to identify where improvements might be required.

In 2004, an internal audit by the Ministry of the implementation of the Sea Container Import Health Standard made several recommendations for improvement. The Ministry has carried out some of these recommendations, but not those involving amendments to the Sea Container Import Health Standard or operational documents.

Compliance with, and enforcement of, the Sea Container Import Health Standard

A small team within the Ministry investigates offences related to importing sea containers. While the Ministry prosecutes some offenders, it more commonly sends an educational letter to the person investigated, or takes no action. The Ministry does not deal consistently with non-compliance with the Sea Container Import Health Standard.

The auditing requirements of the Sea Container Import Health Standard were meant to provide additional incentives for compliance, because non-compliant importers would be subject to, and charged for, increased inspections. Because the required auditing has been delayed, there have been no additional incentives for industry groups to comply with the Sea Container Import Health Standard.

The Ministry is not always provided with a destination for sea containers once they leave the wharf, even though this information is required under the Sea Container Import Health Standard. In our view, the Ministry needs to investigate more effective ways to secure compliance with the Sea Container Import Health Standard.

Relationship management and communication

Implementing the Sea Container Import Health Standard put significant pressure on the relationship between the 2 groups within the Ministry responsible for managing sea containers – Biosecurity New Zealand (Biosecurity NZ), which wrote the standard, and the Quarantine Service, which implemented it. However, a relationship agreement between these 2 groups has been signed, and we saw evidence that this relationship is improving.

Overall, the Ministry’s relationships with its industry stakeholders are good. Industry stakeholders made a number of positive comments to us about their interaction with the Quarantine Service on operational issues. The Quarantine Service is also improving its day-to-day communication with industry stakeholders.

In our view, it would help if the Quarantine Service and Biosecurity NZ worked together when they involved industry groups in strategic and policy matters.

Risk profiling for sea containers

The Border Monitoring Group within Biosecurity NZ is responsible for setting risk profiles to identify high-risk sea containers. It uses various sources of information and intelligence to determine which sea containers should be considered high risk.

The risk profiling is not as effective as it could be, because of limitations in relation to electronic information. For example, the following information is not, or cannot be, provided electronically to assist risk profiling:

  • the country of origin of a sea container (the port at which the sea container was loaded onto a ship for the journey to New Zealand is provided, but it is the sea container’s port of origin that is of interest from a biosecurity perspective);
  • answers to questions about the type of treatment given to wood packaging (untreated wood packaging may be contaminated with pests or diseases);
  • the destination of the sea container once it leaves a New Zealand wharf; and
  • any information about empty sea containers (the risk associated with empty sea containers is manually determined).

A computer system of the New Zealand Customs Service is used to obtain the electronic information needed for risk profiling. The Ministry and the New Zealand Customs Service have discussed changing the computer system to improve the electronic information, but have not yet made progress in agreeing the scope of the project.

Quarantine declaration forms

For quarantine declarations to be useful in assessing risk, they need to accurately reflect the cleanliness of, and the type of packaging material used in, the sea containers they relate to. A quarantine declaration is a document signed by a manager of a packing or export facility in the country of origin. It states that the container was inspected internally and externally, was found to be free of contaminants, and what packaging material is used. Many people we spoke to questioned the accuracy of the information provided in quarantine declaration forms.

When the auditing requirements are fully implemented by the Ministry, this should help verify whether quarantine declarations accurately describe the biosecurity risks of sea containers. If quarantine declarations are found to be a valid tool for risk profiling, the Ministry should communicate this internally and to industry stakeholders.

Informing risk profiling

Ministry officials inspect high-risk sea containers. Non-Ministry personnel check lower-risk sea containers when they are unpacked. The Ministry uses the results of these inspections and checks to further inform the risk-profiling process. However, the results of checks are not always entered into the Ministry’s own computer system, QuanCargo, in a timely way. Information on any contamination found on or in sea containers that are cleaned or fumigated is not gathered. This means that the Ministry does not have access, or timely access, to information that could inform risk profiling.

The Ministry is responsible for staying informed of distributions and outbreaks of pests and diseases overseas that may change the risk of pests and diseases coming into the country in or on sea containers. This intelligence is regularly gathered from overseas, and specialist advice and observations from sea container inspectors are also used to inform risk profiles.

Monitoring and evaluating risk profiles

Ministry staff regularly query the data available on sea container inspections and checks. They use this information to assess changes over time, and levels of contamination. We also found evidence that the Ministry is responsive to new and emerging risks.

Biosecurity clearance for high-risk sea containers

Biosecurity clearance – effectively, permission for goods to enter New Zealand – is given by the Ministry’s inspectors once they are satisfied that the requirements of the Sea Container Import Health Standard have been met.

The Ministry recruits inspectors who hold a tertiary qualification. Training for new recruits includes both technical and on-the-job training. The technical training allows inspectors to work towards a Certificate in Biosecurity. On-the-job training complements the technical training, and includes using a buddy system for learning how to inspect sea containers. However:

  • on-the-job training is inconsistent throughout the country;
  • staff may not be available to train new recruits when workloads are high;
  • there is no written guidance on what to do when contamination is found;
  • documents used to guide staff are not up to date; and
  • inspectors are not subject to ongoing competency assessments.

Inspecting high-risk sea containers

The Sea Container Import Health Standard specifies that high-risk sea containers must be brought to a Quarantine Service inspection area within 8 hours of being unloaded from a ship. The Ministry extended this to 14 hours because 8 hours was difficult to implement if it meant inspecting containers at night – there was not enough light, and inspectors were not on duty. Most sea containers are imported into Auckland, where the 14-hour period is sometimes exceeded, and Tauranga, where it is frequently exceeded.

The 6-hour extension does not apply to sea containers at high risk of carrying highly mobile pests (for example, ants). However, no alternative arrangements have been made to guard against these types of pest. There are opportunities for highly mobile pests to move off sea containers and into surrounding environments before the containers are inspected.

Decontaminating high-risk sea containers

Decontamination means fumigating or cleaning sea containers. Very few sea containers are fumigated. The Ministry has produced standards and procedures for fumigation. Contracted operators fumigate sea containers, and they are subject to regular audit. However, the auditing does not test whether fumigation is effective in killing pests. Fumigation operators have not been audited as often as the Ministry’s procedures require.

Many empty sea containers are cleaned at transitional facilities. In 2005, the Ministry commissioned a review of cleaning practices at these facilities. The review highlighted several issues that required urgent action.

Equivalent systems for clearing high-risk sea containers

The Ministry and industry groups may set up arrangements other than those specified in the Sea Container Import Health Standard. These alternative arrangements are called “equivalent systems”. There is no guidance available for setting up an equivalent system, and no means to assess whether a proposed equivalent system will manage biosecurity risks to a level equal to the arrangements in the Sea Container Import Health Standard. Despite this lack of guidance, the Ministry has collaborated well with industry groups to set up equivalent systems.

We looked at 2 examples of equivalent systems. In both cases, the Ministry has monitored the equivalent systems to ensure that the biosecurity risks are managed. In one example we looked at, the equivalent system was revoked when monitoring showed that biosecurity risks were not being adequately managed.


We recommend that the Ministry of Agriculture and Forestry:

  1. enforce the requirement of the Import Health Standard for Sea Containers from All Countries for importers to provide information on the destination of a container once it leaves the wharf;
  2. investigate and implement measures to secure greater compliance with the Import Health Standard for Sea Containers from All Countries;
  3. ensure that processes are consistently followed for dealing with sea containers that arrive without a quarantine declaration or with an incorrect quarantine declaration;
  4. work with the New Zealand Customs Service to address existing limitations for the electronic recording of biosecurity information for sea containers, and the inability to confirm that all high-risk sea containers are being identified;
  5. enter the results of sea container checks by accredited persons into QuanCargo in a timely manner;
  6. ensure that information on the nature of contamination found by contractors during the decontamination of sea containers is recorded for risk-profiling purposes;
  7. prepare a national on-the-job training programme for use by trainer-assessors or people with this responsibility;
  8. make available to all its relevant worksites staff who are experienced in training, and that it support staff with training responsibilities so that on-the-job training is not compromised by the need to complete routine work;
  9. provide written guidance on the action to be taken when contamination is found on or in sea containers;
  10. keep import health standards and procedure documents up to date;
  11. take measures, where timeframes for inspecting sea containers cannot be met, to mitigate the risk of pests moving off sea containers and becoming established;
  12. investigate options for providing better assurance that fumigation is effective in eradicating pests;
  13. carry out audits of fumigation operators at the required intervals;
  14. improve management and monitoring of the practices of decontamination facilities; and
  15. prepare guidance and procedures for setting up equivalent systems under the Import Health Standard for Sea Containers from All Countries, which include monitoring requirements to ensure that the equivalent system is adequately managing biosecurity risks.
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