The audit objective was to examine how effectively the Department of Agriculture, Fisheries and Forestry (DAFF) manages the importation of live animals into Australia.
1. Australia's quarantine and biosecurity system aims to minimise the risk of the entry, establishment or spread of exotic pests and diseases that have the potential to cause significant harm to people, animals, plants and other aspects of Australia's unique environment. The importation of live animals potentially exposes Australia to exotic pests and diseases such as rabies, foot and mouth disease, Newcastle disease and avian influenza. Outbreaks of exotic animal diseases are not common in Australia, but when they do occur, such as the equine influenza outbreak in August 2007, they can be disruptive and costly.
2. Australia allows a range of live animals to be imported. DAFF advised that between 1 July 2007 and 31 December 2009, 30 031 consignments of live animals were imported into Australia. These included: 22 584 consignments of dogs and cats; 5050 consignments of ornamental finfish; 1263 consignments of reproductive material; 16 consignments of hatching eggs; 900 consignments of laboratory animals; and 30 consignments of zoo animals. The remaining 188 consignments included horses, pigeons and alpacas.
Administrative arrangements for live animals
3. The Department of Agriculture, Fisheries and Forestry's (DAFF) Biosecurity Services Group is responsible for managing Australia's quarantine and biosecurity system. Quarantine policy is developed nationally, with regional offices managing quarantine operations at the border, supported by instructional material and advice from national programs areas.
4. The Biosecurity Services Group was established on 1 July 2009 when the functions and responsibilities of the Australian Quarantine and Inspection Service, Biosecurity Australia and DAFF's Product Integrity, Animal and Plant Health division and the Quarantine and Biosecurity Policy Unit were integrated. Prior to 1 July 2009, quarantine risks presented by goods arriving at the border, including live animals, were managed by the Australian Quarantine and Inspection Service. Biosecurity Australia assessed quarantine risks and provided advice on the effective management of these risks.
Approach to managing quarantine risk
5. DAFF determines, through a risk assessment, the level of quarantine risk presented by the importation of a live animal. The assessment takes into account the country of export and the purpose of importation. Importation is possible if either the risk that the animal is carrying a quarantinable pest or disease is acceptably low or the risk can be managed through import conditions. Conditions can be applied: prior to importation to minimise the likelihood that quarantinable pests and diseases will be imported; on arrival at the border; and/or post entry. Conditions may include, for example, periods of quarantine isolation, testing for disease and treatments for pests such as ticks. Any import conditions are stated on the import permit and are publicly available on DAFF's website. The importation of live animals generally requires a permit. In 2008–09, DAFF issued 8195 import permits for live animals.
6. On arrival at the border, consignments and the accompanying documentation—a permit (if applicable) and a veterinary certificate from the exporting country confirming that pre-export conditions have been met—are examined by quarantine officers. Consignments are then either ordered into quarantine or released to the importer. A consignment is ordered into quarantine when post entry quarantine is required by the import conditions or when it is necessary to detain, treat, re export or destroy a consignment to manage identified quarantine risks. A consignment will be released if all import conditions are met. Officers may apply conditions of quarantine surveillance when releasing the animal that, for example, restrict the animal's contact with other animals and require the importer to provide a veterinary report on the animal's health after a specified period of time.
7. DAFF provides instructional material for officers responsible for managing the entry of live animals. This material outlines the processes to be followed and the documentation to be completed by quarantine officers.
Post-entry quarantine facilities
8. Periods of post entry quarantine allow DAFF to monitor an animal's health and identify any disease concerns prior to the animal's release into Australia. Most animals imported into Australia must spend time in isolation at a quarantine facility, which is either a quarantine station managed by DAFF or a Quarantine Approved Premises (QAP) managed by a private operator.
9. Quarantine facilities are designed to securely accommodate a particular species of animal and to limit the spread of quarantinable pests or diseases that may be present. Facilities for dogs and cats are designed to separate the animals. Animals are examined by a veterinarian on arrival and prior to being released from the quarantine station. Imported eggs are sealed in biological containment facilities and cannot be released until test results indicate they are free of quarantinable diseases. QAPs are approved by DAFF and their compliance against national standards is regularly assessed.
Reviews into quarantine arrangements
10. In recent years, there have been two major reviews of Australia's quarantine arrangements:
- the Callinan inquiry into the cause of the outbreak of equine influenza; and
- the Beale review of Australia's quarantine and biosecurity arrangements.
The Callinan inquiry into the cause of the outbreak of equine influenza
11. As previously noted, in August 2007, there was an outbreak of the equine influenza virus that the Callinan inquiry concluded had most likely escaped from the Eastern Creek Quarantine Station, which is managed by DAFF. Horses are imported for racing, breeding and recreational purposes, and generally require a period of post entry quarantine. Horses are quarantined on an ‘all in all out' basis and, while in quarantine, they are regularly accessed by the importer's grooms, farriers and veterinarians. The Australian Government spent more than $342 million eradicating the virus and providing financial assistance to affected individuals, organisations and businesses.
12. The inquiry into the cause of the outbreak was led by the Honourable Ian Callinan AC and found that the virus had most likely escaped due to systemic organisational weaknesses in the then Australian Quarantine and Inspection Service's approach to biosecurity and quarantine processes. The April 2008 inquiry report, Equine Influenza: the August 2007 outbreak in Australia, made 38 recommendations. These included establishing a position of Inspector General in charge of horse importation, revising the Quarantine Act 1908 and reviewing operational procedures and horse importation risk assessments. The Government agreed to all recommendations in June 2008.
The Beale review of Australia's quarantine and biosecurity arrangements
13. In February 2008, the Minister for Agriculture, Fisheries and Forestry appointed an independent panel, chaired by Roger Beale AO, to conduct a comprehensive review of Australia's quarantine and biosecurity systems. The panel's September 2008 report, One Biosecurity: A Working Partnership—The Independent Review of Australia's Quarantine and Biosecurity Arrangements Report to the Australian Government, made 84 recommendations aimed at extensively reshaping the framework and delivery of Australia's quarantine and biosecurity systems. The recommendations included reviewing the Quarantine Act 1908, DAFF's information technology systems and quarantine facilities (including quarantine stations). The review also recommended restructuring the areas responsible for biosecurity functions and moving to a risk-return approach for managing biosecurity and quarantine. The recommendations were agreed to in principle by the Government in December 2008, subject to Budget processes.
DAFF's response to the reviews
14. At the time of the audit, DAFF was taking steps to implement the recommendations made by the independent reviews. DAFF advised that, because the Callinan inquiry had clearly identified horses as a high biosecurity risk, additional resources were initially allocated to improving the biosecurity and quarantine processes for horses. The Government has engaged Professor Peter Shergold AC to provide the Minister for Agriculture, Fisheries and Forestry with assurance that the recommendations from the Callinan inquiry are being effectively implemented. Professor Shergold provided his fourth report to the Minister in March 2010, and he is scheduled to provide oversight until June 2010.
15. The findings of the reviews were also applicable across multiple commodities (including live animals). DAFF advised that as the work relating to the implementation of the Callinan inquiry recommendations nears completion, resources will be moved to support the work that is already underway to improve biosecurity and quarantine processes for other live animal species. In addition, the department is:
- drafting new biosecurity legislation;
- redesigning information technology systems;
- developing the methodology for a risk–return approach to biosecurity activities; and
- reviewing the status of quarantine stations and their future management arrangements.
Audit objective and scope
16. The audit objective was to examine how effectively the Department of Agriculture, Fisheries and Forestry (DAFF) manages the importation of live animals into Australia. Particular emphasis was given to the:
- assessment and approval of permit applications;
- management of quarantine risks associated with the importation of live animals;
- arrangements for post-entry quarantine; and
- approval and auditing of Quarantine Approved Premises.
17. The audit did not examine the development of quarantine policy, the assessment of import risks or the detection of illegally imported live animals.
18. To assess the effectiveness of DAFF's importation processes, the ANAO reviewed a sample of 207 consignments imported during the period 1 October 2007 to 30 September 2009. The consignments included dogs, cats, fish, hatching eggs, reproductive material and animals imported by zoos and laboratories. The sample covered consignments received during the following periods: two consignments in 2007; 14 consignments in 2008; and 191 consignments in 2009.
19. To examine DAFF's approval and ongoing management of Quarantine Approved Premises, the ANAO reviewed documentation for 131 audits undertaken at 39 Quarantine Approved Premises between 27 October 2004 and 9 November 2009.
20. DAFF's Biosecurity Services Group is responsible for managing the quarantine risks presented by goods arriving at Australia's border, including live animals. The importation of live animals exposes Australia to potential disease outbreaks, which can be disruptive and costly. Australia is presently free of many animal diseases, which have the potential to harm people, agriculture and the environment.
21. Australia's current disease-free status is an important indicator of the effectiveness of quarantine arrangements. However, as highlighted by the Callinan inquiry, this status does not provide forewarning of potential weaknesses in the quarantine and biosecurity system. The Callinan inquiry into the equine influenza outbreak and the Beale review into the broader arrangements for managing quarantine and biosecurity risks identified weaknesses in Australia's quarantine arrangements. Implementing the recommendations from these reviews will mean widespread changes and potential improvements to the management of Australia's quarantine system.
22. In relation to the importation of live animals, DAFF has established a sound framework for managing quarantine risks. The department assesses quarantine risks and imposes import conditions pre entry, at the border and post entry to mitigate these risks. Pre-entry conditions are aimed at addressing quarantine risks prior to an animal's arrival in Australia, and periods of post entry quarantine provide further assurance about an animal's health prior to its release from quarantine.
23. Instructional material outlines the processes underpinning Australia's quarantine arrangements. Following the Callinan inquiry, the department has focused on improving its instructional material for all imported live animals. Existing guidance has been progressively updated and new instructional material has been released for quarantine facilities and some animal groups. Verification programs were also implemented to provide assurance that instructional material is appropriate and being interpreted and implemented correctly. However, the Live Animal Import program's verification program does not include checking the completeness and accuracy of documentation.
24. The audit highlighted that the documentation of examinations and quarantine decisions that are required by departmental procedures was deficient for the majority of the 207 consignments reviewed by the ANAO. The absence of appropriate documentation undermines the department's ability to be confident that quarantine processes are being implemented effectively.
25. There was limited or no documentation to demonstrate that officers had examined either the import permit, veterinary certificate and/or the animal(s) for 133 (64 per cent) of the 207 consignments. In addition, for 34 consignments, the decision to order the consignment into quarantine was not documented, but the ANAO was able to locate some documentation to indicate that these animals had been in quarantine. For 29 consignments, the appropriate release from quarantine form was not completed as required by departmental instructions and, in five instances, the documentation to support the seizure and destruction of fish was missing.
26. The introduction of revised instructions and additional checklists in late 2009 means that officers should be documenting examinations for most imported live animals. These instructions outline officers' responsibilities, and the verification program is designed to confirm that instructions have been understood. The findings of this audit have identified the need for DAFF to reinforce to officers, and particularly those responsible for supervising and training staff, the importance of documenting quarantine processes and decisions. Extending the verification program to include checking the completeness and accuracy of documentation would provide assurance that procedures are also being effectively implemented.
27. Currently DAFF's electronic systems only provide information about imports, not the completion and outcomes of examinations. As a consequence, they do not support the analysis of data to inform compliance strategies and highlight emerging quarantine risks and operational issues. To collect and analyse data relating to importation and quarantine processes nationally, DAFF will need to develop an approach for recording examinations on a consistent basis.
28. Animals ordered into quarantine are sent to either a quarantine station or a QAP. There are arrangements in place for managing access to, and the security of, these facilities, monitoring animal health and wellbeing and controlling animal specific quarantine risks. DAFF approves QAPs and conducts audits to monitor QAPs' compliance with the conditions of approval and the criteria relevant to each QAP class.
29. Audit reports that detail the outcome of QAP audits have been a requirement since May 2009. However, for the 32 audits in the ANAO's sample that required reports, 22 reports had not been completed. Although audit checklists were available for all audits examined, they did not clearly record the extent of checking by the quarantine auditor. Also, there are no systems or processes in place to monitor corrective action where non compliance is identified, and follow up action is at the discretion of the individual quarantine auditor. As a consequence, DAFF has limited assurance that QAPs are meeting all requirements.
30. The ANAO has made two recommendations aimed at providing DAFF with greater assurance that import conditions are being met and QAPs are complying with the conditions of approval and the relevant criteria. Timely action on these recommendations is important, for the department to have confidence that its framework for managing quarantine risks is delivering the intended results.
Key findings by chapter
Preparing to import a live animal (Chapter Two)
31. Importers are required to comply with the import conditions applicable to the animal being imported. The department has clearly documented these conditions, which generally require importers to apply for an import permit and obtain a veterinary certificate from the exporting country prior to importing an animal into Australia.
32. Potential importers had access to sufficient information to enable them to understand importation requirements and the permit application process. The assessment and approval of import permits was effectively managed by DAFF and supported by instructional material.
Certificates provided by exporting countries
33. DAFF relies on assurances provided by exporting countries that pre import conditions have been met. A country's certifying authority is assessed and approved by DAFF as being able to provide informed and reliable certification that Australia's quarantine requirements have been met. DAFF monitors the pest and disease status of exporting countries through the World Organisation for Animal Health's monitoring framework. The department also obtains information through its agricultural counsellors (stationed at key diplomatic posts) and from informal sources such as media reports. If necessary, on site inspections are conducted.
34. Non-compliance by exporting countries is reported by the regions and dealt with on an individual consignment basis by the national program. DAFF did not collate these reports and analyse compliance trends by exporting countries until February 2009 when the national program began its Non compliance Project.
35. Data for dogs and cats imported from countries in categories two to five has been analysed for the periods February to May 2009 and July 2009 to February 2010. DAFF advised that, for these periods, 5530 dogs and cats had been imported and their certificates checked. Of these certificates, 824 (14 per cent) had been identified as non compliant. Issues identified ranged from minor administrative errors to major non compliance that had resulted in the animal being exported. DAFF advised that the data will be used to inform the risk assessments and the reviews of exporting countries' systems. The department further advised that feedback about repeated non compliance has been provided to one exporting country.
36. A new checklist was developed and implemented nationally in August 2009 to collect data about non-compliant veterinary certificates for imported live fish. With the inclusion of fish imports, DAFF now collects non compliance data for the majority of live animals imported into Australia. DAFF advised that the department is yet to finalise how it will analyse and report on the data for fish consignments.
Monitoring compliance with import conditions (Chapter Three)
37. Appropriately applied import conditions limit the likelihood that exotic pests and diseases will enter Australia. Quarantine officers in the regions are responsible for ensuring the importer complies with these conditions. When a consignment arrives at the border, the importer is required to present the import permit, the veterinary certificate from the exporting country and any other required documentation for examination. The consignment can be detained (in quarantine isolation), treated, re-exported or destroyed if there are any potential quarantine risks. If all import conditions have been met, the consignment will be released.
Guidance about the management of imported live animals
38. Following the Callinan inquiry, DAFF revised its instructional material for managing imported live dogs and cats, reproductive material, fish and animals imported by zoos and laboratories. New instructional material was released for managing imported hatching eggs in December 2009.
39. In addition, a verification program was implemented in 2008 09. The verification activities conducted to date have focused on providing assurance that instructional material is appropriate and officers are interpreting the guidance as intended. The completeness and accuracy of the documentation for imported consignments is not reviewed as part of this program. Extending the verification program to include a quality assurance check of the documentation for a sample of consignments would provide greater assurance that instructional material had not only been understood, but also properly implemented.
Managing quarantine risk on importation
40. Officers are to examine the permit, veterinary certificate and consignment to establish that the animal(s) is allowed to be imported and that no other material of quarantine concern is present. Officers must order the consignment into quarantine if the import conditions require the consignment to undergo post entry quarantine or if the import conditions have not been met. Alternatively, the consignment can be released if the import conditions have been met.
Documenting on arrival examinations
41. For 122 of the 207 consignments in the ANAO's sample, officers were required to use nationally consistent checklists or forms to record their examinations of the import permit, the veterinary certificate and the consignment. Of these, 48 (39 per cent) had missing or incomplete documentation.
42. For the remaining 85 consignments in the ANAO's sample, the department had not provided instructions about recording examinations. For these consignments, examinations had been recorded on a discretionary basis or no documentation was available to demonstrate that an officer had examined the consignment and confirmed that it was compliant with all import conditions. Officers had recorded notes in the comments field of the import's electronic record or kept discretionary hard copy records such as annotated certificates, personal checklists and notes in personal diaries.
Order into quarantine
43. From the ANAO's sample of 207 consignments, 168 were ordered into quarantine. Of these, post-entry quarantine was a condition of importation for 160 consignments. The remaining eight consignments were ordered into quarantine to manage potential quarantine risk or to allow time for officers to check documentation. There were 34 consignments that did not have a record of the consignment being ordered into quarantine. However, there was other documentation available, such as a release from quarantine, showing that the animal had been at a post entry quarantine facility.
Release without post entry quarantine
44. Of the 207 consignments, 39 were released on arrival as all import conditions were met. Of these, 15 consignments were released under quarantine surveillance. Quarantine surveillance allows DAFF to monitor animals and may require the importer to provide evidence that the animal's health has been checked by a veterinarian. The release from quarantine under surveillance was not documented in three instances.
45. Disability assistance dogs are to be under quarantine surveillance for at least 30 days. Although the conditions are part of the import permit, the dog's handler is required to sign a form agreeing to the conditions of surveillance. A signed form was not available for nine of the 16 dogs in the ANAO's sample. Importers are also required to provide a report from a veterinarian advising DAFF that the dog had a satisfactory health check at the completion of the surveillance period. DAFF finalised the quarantine surveillance period of three dogs in the ANAO's sample without evidence of a satisfactory health check.
Systems supporting the national management of live animals imports
46. Current electronic systems provide information about imports, not the completion and outcomes of examinations. As a consequence, they do not support the analysis of data to inform compliance activity and highlight emerging issues. To collect and analyse data relating to importation and quarantine processes nationally, DAFF will need to develop an approach for recording examinations on a consistent basis. Extending the verification program to include checking the completeness and accuracy of the documentation supporting examinations and quarantine decisions will provide assurance regarding the integrity of the data being collected.
Post entry quarantine arrangements (Chapter Four)
47. Most animals imported into Australia must spend time in quarantine isolation to ensure they are free of exotic pests and diseases. Animals ordered into quarantine must be transferred to the quarantine facility in a manner that maintains the integrity of quarantine. While in quarantine, an animal's health is monitored for potential quarantine risks and access to quarantined animals is restricted to minimise the potential risk of pests and diseases escaping quarantine. After the required period of quarantine isolation, consignments can be released if no pests or diseases of quarantine concern have been found. If pests or diseases are found, the consignment must be treated, detained for a further period, re exported or destroyed.
48. Periods of post entry quarantine are undertaken at either a quarantine station or a Quarantine Approved Premises (QAP). Of the 168 consignments in the ANAO's sample that were ordered into quarantine, 117 consignments were sent to quarantine stations and 51 consignments were sent to QAPs.
Managing animals during post-entry quarantine
49. Arrangements have been put in place at the quarantine stations and QAPs to manage the potential quarantine risks associated with imported live animals during post-entry quarantine. These arrangements cover transferring animals to quarantine facilities, controlling animal specific quarantine risks and monitoring animal health.
50. DAFF has been revising its instructional material, including overarching manuals for the quarantine stations. Non compliance with this new instructional material was identified through verification activities and a recent internal audit of the Byford and Spotswood quarantine stations. DAFF has taken steps to address the non compliance issues that were identified through the internal audit.
Releasing animals from quarantine
51. If an officer is satisfied that the import conditions have been met, the animal can be released from quarantine. Of the 168 consignments ordered into quarantine, 131 had been released (including the eight consignments discussed in paragraph 43). For three of these consignments there was no documentation to indicate that the pre-release veterinarian examination had been completed. There were also 26 instances where the release from quarantine form was not completed as required by departmental work instructions. Further, in five instances where officers seized and destroyed fish, documentation was missing.
Managing Quarantine Approved Premises (Chapter Five)
52. Under the Quarantine Act 1908, DAFF approves and annually renews businesses, universities, research organisations, zoological parks and government agencies as Quarantine Approved Premises (QAPs) to perform quarantine activities. More than 2500 QAPs have been approved for various quarantine related purposes. As of 30 September 2009, 148 QAPs (six per cent) were approved to house live animals including fish, zoo animals and laboratory animals during periods of quarantine isolation.
Monitoring QAP compliance
53. DAFF monitors QAPs to ensure that operators comply with the conditions of approval and the criteria relevant to each QAP class. Regional offices are responsible for undertaking regular audits and managing non compliance. In April 2009, DAFF commenced a verification program that includes periodic desk-based reviews of documentation for selected QAP audits. DAFF advised that the verification program focuses on whether quarantine auditors understand work instructions and are applying them correctly.
54. For the 39 QAPs in the ANAO's sample, the ANAO reviewed 131 audits covering the period October 2004 to November 2009. For this sample, the ANAO found that:
- 11 per cent of QAPs were overdue for audits;
- 85 per cent of audit checklists did not adequately document audit findings;
- 69 per cent of audit reports were not completed;
- 11 per cent of identified non compliance issues were overdue; and
- 62 per cent of identified non compliance issues had not been addressed in a timely manner.
55. The department collects data on audit completion, but it is not reliable and is not analysed. Consequently, information about overdue audits is not being shared with other relevant areas across the department.
56. Audit checklists are designed to assist quarantine auditors. For the majority of audits reviewed by the ANAO, checklists did not clearly record which criteria had or had not been checked and audit reports were not completed.
57. Non compliance matters identified in the ANAO's sample were not classified by severity or addressed in a timely manner. Officers had discretion as to how they tracked corrective action requests and the department had no oversight of this process. As a consequence, DAFF did not have adequate assurance at either the regional or national level that QAPs are being monitored effectively.
58. As of 31 May 2010, DAFF had undertaken two rounds of verification reviews. These reviews included 18 audits for 13 QAPs that house ornamental finfish. Non compliance with work instructions was identified for 17 of the 18 audits reviewed. The non compliance issues related primarily to inadequate documentation. Feedback from the verification reviews was provided to each region. DAFF advised that the results and follow-up actions from verification reviews are reported to DAFF's management on a quarterly basis.
New policy for QAPs
59. In January 2010, DAFF issued a new Audit and Sanctions Policy document. This policy outlined how QAP non-compliance would be classified—as minor, major or critical. In addition, the policy introduced variable audit rates for QAPs. The number of audits a QAP requires per year is to vary depending on the number and significance of the non compliance issues identified during audits. Higher risk QAPs are to be audited more frequently.
Summary of agency response
60. The ANAO provided a copy of the proposed report to DAFF. A response was received. A copy of the department's full response is included in Appendix One. The following summary comments were also provided:
The department agrees with the recommendations and findings of the ANAO audit report on the Management of Live Animal Imports. The recommendations and findings align with the priorities identified by the department. The department considers that the improvements recommended by the ANAO are already being addressed, or are part of the broader reforms recommended by the independent review of Australia's quarantine and biosecurity arrangements, One Biosecurity: A Working Partnership, chaired by Roger Beale AO.
The department welcomes the ANAO's acknowledgement that '...DAFF has established a sound framework for managing quarantine risk…in relation to the importation of live animals. The department assesses quarantine risks and imposes import conditions pre-entry, at the border and post entry to mitigate these risks.' The department acknowledges the primary findings of the ANAO, which focus on the need to better document the activities of examining animals and their accompanying import documentation. The department agrees that improved records will assist the auditability of the system, and will take steps to implement the ANAO's recommendation.
The ANAO audit report also usefully highlights areas to improve the effectiveness of monitoring of quarantine approved premises (QAPs). The department agrees that better national tracking of QAP audit outcomes and data analysis is needed to inform quarantine decision making and notes that work is already underway to improve both processes and documentation for auditing QAPs. The ANAO also notes that initiatives implemented by the department in 2009-10, which the ANAO was unable to fully take into account, improve the assurance capability of QAP monitoring by the department.