Final Import Risk Analysis Report for Fresh Mango Fruit from India

5. Pest risk management

Visual inspection alone is not considered to be an acceptable measure to verify the level of infestation of fresh mango fruit with mango pulp weevil, mango seed weevil or fruit flies and therefore another measure is required for these pests. This is because clear visual external signs of infestation (particularly in recently infested fruit) may not be present. Infestation in the egg or early instar stage is difficult to detect even when signs of infestation are being targeted during inspection.

The risks of entry, establishment and spread of mango weevils or fruit flies associated with the importation of fresh mango fruit from India would not achieve Australia’s ALOP if visual inspection was the only measure applied. This is because failure to verify the level of infestation of the fruit is likely to result in the presence of unacceptable levels of these pests in the fresh mango fruit.

The 2004 draft report (DAFF 2004) proposed vapour heat treatment or hot water treatment for fruit flies and the use of designated ‘pest free areas’ for mango weevils. Visual inspection and remedial action was proposed for red-banded mango caterpillar and mealybugs.

In October 2006, India requested that Australia allow irradiation as a measure for pests of fresh mango fruit. India also advised Australia in November 2006 that it was not in a position to establish areas free from mango weevils or fruit flies.

Australia has therefore considered the measure of irradiation, requested by India, to manage the identified quarantine pests for fresh mango fruit from India. Because the recommended irradiation dose rate (outlined below) is sufficient to mitigate the risks posed by all identified arthropod pests, the use of other alternative measures, including those proposed in the 2004 draft report (DAFF 2004) are therefore redundant under these circumstances.

The quarantine measures required to reduce the risks posed by all quarantine pests identified in this Report (Table 5.1) to achieve Australia’s ALOP are described in the following sections. This risk analysis and the recommended measures are based on India’s existing commercial production practices as set out in Chapter 3. The existing commercial production practice of a post-harvest fungicidal dip is a requirement for export to Australia.

The following measures will form the basis of the import conditions for fresh mango fruit from India. However, Biosecurity Australia does recognise that other risk management measures (including some of those identified above) may be suitable to manage the identified risks. Australia will consider measures proposed by India consistent with relevant international standards that would provide an equivalent level of protection.

5.1. Risk management measures

1. pre-export irradiation treatment at a minimum absorbed dose rate of 400 Gy for mango pulp weevil, mango seed weevil, fruit flies, red-banded caterpillar and mealybugs; and

2. operational systems for the maintenance and verification of the phytosanitary status of fresh mango fruit from India

5.1.1. Pre-export irradiation treatment at 400 Gy for mango pulp weevil, mango seed weevil, fruit fly species, red-banded caterpillar and mealybug species

Table 5.1: Phytosanitary measures proposed for quarantine pests for fresh mango fruit from India

Following existing commercial grading and sanitation procedures, all consignments of fresh mango fruit are to be irradiated prior to export. Irradiation as a phytosanitary measure for fresh mango fruit from India is to be applied to achieve a minimum response of sterility in the targeted pests.

Australia will require mango fruit to receive a minimum absorbed dose rate of 400 Gy and for this to be applied in accordance with ISPM 18 (FAO 2006c).

A minimum absorbed dose rate of 400 Gy is required for mango pulp weevil in view of the lack of specific data supporting a lower irradiation dose. The minimum absorbed dose rate of 400 Gy is considered sufficient to achieve sterility for all the quarantine arthropod pests identified in this IRA.

Note that lower irradiation doses would be appropriate for fruit flies (150 Gy) (Bustos et al. 2004; Follet and Armstrong 2004) and mango seed weevil (300 Gy) (Follett 2001). This is consistent with minimum dose rates approved by the USA (71 FR 4451-4464, Docket No. 03-077-2). In particular, the US has approved 150 Gy as a generic minimum dose rate for fruit fly, 300 Gy as a specific minimum dose rate for mango seed weevil and 400 Gy as a minimum generic dose rate for the class Insecta (except pupae and adults of the Order Lepidoptera).

India formally advised Australia in January 2007 that it is prepared to treat fresh mango fruit for export to Australia at the minimum absorbed dose rate of 400 Gy to mitigate the risk from arthropod pests. In November 2007, India advised that irradiation would take place in combination with a post-harvest fungicidal dip (prochloraz) undertaken for quality purposes (to control post-harvest storage rots and to extend shelf-life). Hot-water treatment of fruit is carried out in treatment tanks fitted with thermostatic controls to maintain a constant temperature of 52ºC.

Australia is prepared to review the minimum absorbed dose rate of 400 Gy if appropriate and acceptable efficacy data becomes available demonstrating that a lower dose is effective against the identified quarantine pests.

Approval for irradiation treatment is subject to availability of suitable equipment and facilities to carry out the treatment. All irradiation facilities must be accredited by AQIS.

Subject to appropriate verification of the integrity of the irradiation treatment system, the risk of entry, establishment and spread of arthropod pests associated with the importation of fresh mango fruit from India that has been irradiated at a minimum absorbed dose of 400 Gy would be negligible.

In the absence of appropriate verification of the integrity of the irradiation treatment system, the risk of entry, establishment and spread of arthropod pests associated with the importation of fresh mango fruit from India that has been irradiated at 400 Gy would not achieve Australia’s ALOP. This is because failure to adequately treat the mango fruit is likely to result in the presence of viable arthropod pests in the fruit.

5.1.2 Operational systems for the maintenance and verification of the phytosanitary status of fresh mango fruit from India

It is recommended that India’s NPPO, or other relevant agency nominated by the NPPO, prepare a documented Work Plan for approval by AQIS that describes the phytosanitary procedures for the pests of quarantine concern for Australia and the various responsibilities of all parties involved in meeting this requirement.

The components of the recommended operational system for inclusion in the work plan are described below.

Recognition of the competent authority

India’s Directorate of Plant Protection, Quarantine and Storage (PPQS), Ministry of Agriculture, is the designated NPPO under the International Plant Protection Convention (IPPC).

The objectives of the NPPO are to ensure that:

• 
  service and certification standards, and Work Plan procedures, are met by all relevant agencies participating in this program; and
  
• 
  the administrative processes are established that provide assurance that the requirements of the program are being met.
  

The objectives of the requirement for pre-clearance are to ensure that:

• 
  the quarantine measures, including product identification, direct verification of irradiation treatments, AQIS inspection requirements, product security and documentation are met.
  

The objectives of the requirement for packaging and labelling are to ensure that:

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  mangoes exported to Australia are not contaminated by quarantine pests or regulated articles (e.g. trash, soil and weed seeds);
  
• 
  unprocessed packing material (which may vector pests not identified as being on the pathway) is not imported with the mango fruit;
  
• 
  all wood material used in packaging of the commodity complies with AQIS conditions (see AQIS publication ‘Cargo Containers: Quarantine aspects and procedures);
  
• 
  secure packaging is used to prevent post-irradiation infestation;
  
• 
  the packaged mango fruit is labelled in such a way as to identify the treatment facility and other identifying features for the purposes of trace-back in the event that this is necessary; and
  
• 
  the pre-cleared status of mango fruit is clearly identified.
  

The objectives of the requirement for pre-export phytosanitary inspection are to ensure that:

• 
  fruit inspections undertaken by the NPPO, or other relevant agency nominated by the NPPO, and AQIS are completed after commercial grading and sanitation and before irradiation; and
  
• 
  visual inspection of fresh mango fruit focuses on soil, animal and plant debris and other quarantine contaminants rather than quarantine pests that will be sterilised by irradiation.
  

The objectives of the requirement for remedial action following pre-export phytosanitary inspection are to ensure that:

• 
  any quarantine risk associated with an identified quarantine pest that has not been identified in this PRA is addressed; and
  
• 
  the consignment is free from soil, animal and plant debris and other quarantine contaminants.
  

The objective of the requirement for accreditation of treatment providers and auditing of procedures is to ensure that:

• 
  treatment providers for the mandatory irradiation of mango fruit are accredited by AQIS and registered with the NPPO, or other relevant agency nominated by the NPPO, for this purpose before their export activity commences and comply with the current NPPO standards for export grade facilities and ISPM 18 (FAO 2006c).
  

The objective of the requirement for pre-export irradiation is to ensure that:

• 
  any quarantine pests assessed as being above Australia’s ALOP that may be present in a consignment of mango fruit for export to Australia are sterilised by an absorbed minimum dose of 400 Gy.
  

The objectives of the requirements for storage and movement are to ensure that:

• 
  product security is maintained during loading, transport, export consignment consolidation and shipping, sufficient to protect the consignment from pest contamination;
  
• 
  there is no substitution or cross infestation of the product following AQIS pre-clearance inspection and direct verification of irradiation treatment; and
  
• 
  consignments not shipped directly from one port or city in India to a designated port or city in Australia are in sealed containers.
  

The objectives of the requirements for phytosanitary certification by the NPPO, or other relevant agency nominated by the NPPO, are to ensure that:

• 
  an International Phytosanitary Certificate (PC) is issued for each consignment upon completion of pre-export inspection and treatment to verify that the relevant measures have been undertaken off-shore;
  

The objectives of the requirements for remedial action(s) for non-compliance during on-arrival verification are to ensure that:

• 
  any quarantine risk is addressed by remedial action, as appropriate, for consignments that do not comply with import requirements.
  

5.2. Review of policy

Australia is prepared to review the policy after a substantial volume of trade has occurred.

The NPPO, or other relevant agency nominated by the NPPO, must inform Biosecurity Australia and/or the AQIS immediately on detection of any new pests of mango that are of potential quarantine concern to Australia.

6. Conclusion

The recommendations of the Report are based on a comprehensive analysis of relevant scientific literature with reference to existing policy for the import of mangoes from Haiti, Mexico, the Philippines (Guimaras Island) and Taiwan, where relevant.

In the course of preparing the Report, Biosecurity Australia considered submissions from stakeholders on the 2004 draft report (DAFF 2004). All scientific issues raised in stakeholder submissions and material matters have been incorporated as appropriate.

The Report has identified fruit flies, mealybugs, red-banded mango caterpillar and mango weevils as pests that require quarantine measures to manage risks to a very low level in order to achieve Australia’s appropriate level of protection. The existing commercial production practice of a post-harvest fungicidal dip, as advised by India to support its market access application, is an underlying requirement for export to Australia.

The Report recommends pre-export irradiation treatment at a minimum absorbed dose rate of 400 Gy which will achieve sterility for the identified quarantine pests. The treatment will be supported by an operational system to maintain and verify quarantine status including pre­clearance inspection and direct verification of the irradiation treatment by the Australian Quarantine and Inspection Service.

Quarantine measures proposed in the 2004 draft report (DAFF 2004), including vapour heat treatment, hot water treatment and pest free areas, have not been further considered as India has requested irradiation.

Three pests (mango seed weevil and two mealybug species) that are present in eastern Australia have been identified as quarantine pests for the state of Western Australia only. The recommended quarantine measures take account of these regional differences for Western Australia.

Biosecurity Australia will recommend to Australia’s Director of Animal and Plant Quarantine that mango fruit be permitted entry into Australia from India subject to the above quarantine measures.