A review of AQIS's March 1999 draft import risk analysis for the import of bulk maize from the USA

Summary

In this review for Meat and Livestock Australia, ACIL Consulting Ply Ltd (ACIL) looks at the Draft Import Risk Analysis (Draft IRA) on Bulk Maize from the United States released for comment by the Australian Quarantine Inspection Service (AQIS), in March 1999. The Draft IRA is AQIS's response to an application by the feedlot industry nearly two years ago to import bulk maize direct to inland sites. Such imports would be used in when droughts caused shortages oflocal grain. Currently maize and other grains are being imported, but they are required to be processed at seaboard upon landing which imposes heavy quality costs if further transport is undertaken. Professionally and in legal terms, ACIL finds the Draft IRA to be inadequate. It is in breach of guidelines requiring the thorough consideration of costs and benefits.

From a professional viewpoint, the Draft is unnecessarily impressionistic. In particular: its analysis is insufficiently quantitative; and the investigation is not structured on an issue as important and controversial as this, costs and benefits, their probability and their timing need to be systematically and comprehensively assessed. Instead of undertaking a structured analysis which considers costs and benefits on both side of the equation, AQIS seems to have adopted the same 'zero risk' approach it has adopted on past occasions. In other words, it seems to have presumed that the local grain industries should bear no additional risks, no matter how intermittent or small or manageable, and no matter what the benefits to the rest of the country.

Moreover, a great deal of relevant evidence is not considered: recent quantitative analysis by the Centre for International Cost analysis has not been examined by AQIS; none ofthe new 'feedgrain security' literature has been cited; earlier conclusions reached on transport security by the Bureau of Resource Sciences seem to have been ignored; and there is no sign that possible retaliation by the US in regard to Australian exports has been considered, as it should be when import restrictions on any US agricultural products are under investigation. One reason for these gaps may be that the Technical Working Committees did not have people with sufficient Cost analysis expertise or sufficient direct overseas experience with the risks being assessed to do their jobs.

There is a question-mark also over whether stakeholders were given sufficient opportunity to present evidence. As for matters of detail presented in the Draft, ACIL has not attempted to check every point made by AQIS. However we have found a number of areas where the assessment is unbalanced. In particular, we consider:

from a biological and economic standpoint, the near-equal emphasis given in the Draft to the possible introduction of new pests and the introduction of pests of the type already here is unbalanced;

the great emphasis on Kamal bunt as a disease risk is unwarranted;

the likely quantity and infectiousness of any soil introduced with bulk maize imports has been greatly exaggerated;

less destructive but likely effective treatment methods involving infra-red and other forms of irradiation are not seriously considered but should have been;

the. lessons of experience by other countries, such as Chile, with imports of US maize have not been considered;

conflicting interpretations are given by two ofthe technical working groups of past BRS work on the risk of spillage of grain during transport; and

unduly heavy emphasis is given in the Draft to the risk posed by witchweed infestation in the United States (seen currently on less than 2000 acres in a quarantined area in two States of the US which import maize) and the true situation is inadequately reported.

In view of the Draft's general faults and the specific imbalances listed above, we conclude the Draft does not abide by the rules requiring a full and balanced consideration of the benefits and costs. We recommend that the defects be remedied and in particular that the Draft IRA be recast within a formal framework which recognises and treats consistently the issues concerned with levels of hazard, risk, timing, and economic cost and benefit to different sectors.