AN INTRODUCTION TO RISK MANAGEMENT

PRINCIPLES OF RISK MANAGEMENT

The conclusions from the risk assessment stage of a PRA are used to decide whether or not risk management is required to prevent the introduction and establishment of
identified quarantine pests.

If the risk assessment found that a particular pest presents an unacceptable pest risk, it becomes necessary to determine what options are available to manage the risk so as to achieve the importing country's Appropriate Level of Protection (ALOP, see below). The risk management options are then evaluated, taking account of their efficacy, feasibility and impact. The results of these analyses provide the basis for decisions concerning the phytosanitary measures that will be adopted to mitigate the pest risk. It is important to note that, under the SPS Agreement, measures must be based on a risk assessment and cannot be maintained without sufficient scientific evidence.

Level of Risk

The overall level of risk posed by a quarantine pest is determined by the outcomes of the risk assessment. If the risk is found to be unacceptable, then the first step in risk management is to identify possible phytosanitary measures that will reduce the risk to an acceptable level (i.e. a level that meets the importing country's ALOP). If the risk is already acceptable, then the management option would only be to recommend the measures necessary to ensure that future changes in the pest risk status are identified. No additional measures should be imposed if existing measures are effective.

When formulating phytosanitary measures, countries must decide what level of risk is acceptable to them. According to the SPS Agreement, Members should base risk management on a consistent level of acceptable risk, i.e. they should exercise a single ALOP (see Box). Quarantine measures are based on the ALOP and are designed to align with the ALOP - the ALOP is not derived from quarantine measures.

Conditions for Selecting Measures

The process of identifying and selecting risk management measures involves consi-deration of the following issues:

  • What options are available to manage the risk?
  • How effective are the options?
  • How feasible are the options?
  • What impacts do the options have?
  • What is the best option?

Box : What is an Appropriate Level of Protection?

There is no clear definition of an 'appropriate level of protection' or 'ALOP'. In the SPS Agreement, ALOP is defined as:

…the level of protection deemed appropriate…to protect human, animal or plant life or health….

A note attached to this definition states that:

Many Members otherwise refer to this concept as the 'acceptable level of risk'

References to ALOP in various articles of the SPS Agreement indicate that:

  • Sanitary and phytosanitary measures are established in order to achieve an ALOP;
  • Each country determines its own ALOP;
  • Countries should take into the account the objective of minimising negative trade effects when determining ALOP; and
  • ALOP should be applied with consistency.

The fact that ALOP is often referred to as the 'acceptable level of risk' suggests that a Member may apply measures that are sufficient to ensure that its ALOP is achieved, by reducing risk to an acceptably low level. It would then be up to each Member country to determine what level of risk they would be willing to accept, to choose the least trade restrictive means available to achieve this objective, and to apply this consistently. In the absence of a detailed statement from a Member describing its ALOP in precise terms, a guide to a Member's ALOP may be found in the protection afforded by existing quarantine requirements and practices developed and adopted over the years.

The requirement for consistency in the application of ALOP means that Members cannot, for example, take a more relaxed attitude to risk where imports are desired, or a more restrictive approach than normal in a situation where trade would create competitive pressure on a domestic industry. However, there are common difficulties in achieving consistency in the application of ALOP. Guidelines are currently being developed by the SPS Committee to assist Members in the implementation of their obligations with regard to consistency.

Depending on the ALOP it has set, a country may base its phytosanitary requirements on an international standard (e.g. as set out under the IPPC's International Standards for Phytosanitary Measures). Alternatively, if an international standard does not exist or if the importing country believes that the international standard does not meet its ALOP and a higher level of protection is required, the country may choose a different measure or combination of risk management measures. In such a case, the choice of appropriate measures should be based on the guiding principles set out in the SPS Agreement and affirmed in ISPM No. 1 Principles of plant quarantine as related to international trade, namely: minimal impact; equivalence; consistency; and non-discrimination.

Minimal Impact

In selecting phytosanitary measures, the importing country must take into account the objective of minimising negative trade effects. For a particular import proposal, there may be a number of alternative measures (e.g. treatment, inspection, field management) which, singly or in combination, may be used to achieve the importing country's ALOP. In choosing among such alternatives, the importing country needs to adopt those measures which are no more trade restrictive than required to meet its plant health objectives.

For example, one way to reduce the risk of entry of an exotic pest could be to prohibit imports of the commodity that the pest is associated with. But, if requiring treatment of the commodity could also reduce the risk to the level considered acceptable by the importing country, this would normally be a less trade restrictive requirement and the obligation would be on the importing country to adopt an appropriate treatment measure.

Equivalence and Regionalisation

The SPS Agreement requires countries to recognise that there may be more than one way to ensure a product is safe. This principle is particularly relevant to the evaluation of alternatives for risk management and requires the recognition of measures that are not identical but which have the same effect and provide the level of protection required. If an exporting country can demonstrate that the safety of its product is equivalent to that required by the importing country, then the product should be accepted even though it was not produced according to the processes normally required by the importing country. The initial burden is on the exporting country to provide the necessary evidence to show that its product is equally safe, and on the importing country to objectively assess this claim.

When considering the protection of plant health, the prevalence of particular pests and pathogens in the exporting country is of critical importance. However, pests or pathogens may occur only in part of a country and with proper controls, other areas of the country may be considered as pest- or disease-free. Conversely, a particular pest may pose a risk only for certain areas in the importing country and be of no concern to other areas due to lack of suitable hosts or climatic or geographical conditions. The SPS Agreement requires that importing countries adapt their measures according to the pest or disease status of the region from which the product is coming, and according to the conditions in the region to which the product is destined.

Consistency

While countries are free to adopt different measures for different commodities, they must be mindful of the need for consistency in the application of ALOP. An importing country should not set a high level of import protection against the entry of certain commodities (e.g. those that would compete with a domestic industry), while accepting a much lower level of protection in relation to other commodities (e.g. those considered to be economically beneficial, such as new genetic material, or commodities not produced domestically).

Non-Discrimination

Risk management measures should not unjustifiably discriminate between exporting countries of the same phytosanitary status. Likewise, under the national treatment provisions of the SPS Agreement, countries may not set different levels of protection between imported commodities and those produced domestically, where there are hazards in common. For example, if the pest under consideration is established in the importing country but is of limited distribution and under official control, the quarantine restrictions applied to an imported commodity against the pest should not be more stringent than those applied within the importing country.

RISK MANAGEMENT OPTIONS

An overview of the types of measures that are most commonly applied to traded plants or plant products to manage the risk posed by quarantine pests. These include measures:

  • applied to prevent or reduce original infestation in the crop;
  • to ensure the area or place of production is free from the pest;
  • that form a systems approach;
  • applied to the consignment; and
  • concerning the prohibition of commodities.

Depending on the level of risk, phytosanitary measures can range from total prohibition to permitting import of a commodity subject to visual inspection and certification. All such measures are designed to provide an appropriate level of protection against the introduction and establishment of plant pests or pathogens. In some cases, combinations of two or more measures may be required in order to reduce the risk to an acceptable level - the combined effects of the measures should be considered in terms of efficacy and overall risk. Where more than one quarantine pest is associated with a commodity, different risk management strategies may need to be developed for each pest or group of pests (see Box 2). It is important to remember that phytosanitary measures should be seen as additional to good crop management and handling procedures that also contribute to risk management.

Options for Preventing or Reducing Infestation in the Crop

Measures may include:

  • in-crop pest management and crop hygiene;
  • growing plants in a protected environment;
  • harvesting crops at a certain age or specific time of the year;
  • non-host status; or
  • production in a certification scheme.

These options for managing pest risk are discussed in more detail below.

In-Crop Pest Management and Crop Hygiene

Various control measures can be employed in the field to manage pests and diseases. These may include field sanitation practices, pest monitoring programs, use of chemical control agents (insecticides, fungicides etc), removal of alternate hosts, and bagging of fruit.

Growing Plants in a Protected Environment

Plants can be grown under specially protected conditions, such as in a glasshouse or other isolated environment, to prevent infestation in the crop.

Harvesting Crops at a Certain Age or Specific Time of the Year

This strategy involves harvesting the crop either at an age when it is less susceptible to infestation by a certain pest, or at a time of the year when conditions do not favour infestation of the crop. The example listed below illustrates the application of this risk management approach for the interstate movement of green bananas in Australia. To manage the risk of Medfly, bananas from Western Australia are permitted access into the eastern states (Victoria, New South Wales, Queensland) provided that they are harvested while still green. Green bananas are not a fruit fly host, and therefore fruit harvested at this stage is at low risk of infestation. However, because research shows that harvested bananas gradually become susceptible to fruit fly infestation, it is often necessary to pack the fruit in pest-proof containers or cartons for interstate movement as a measure of protection against possible infestation.

Non-Host Status

Some commodities may be traded on the basis that they are recognised as having 'non-host status' for a quarantine pest(s). Non-host status is an official control measure for pests that are known to occur on the commodity elsewhere but have not been recorded on the commodity in the country or region from which the produce is being exported. Because non-host status is an official treatment, pathway systems, such as packinghouse and exporter registration, are required and records must be kept documenting any movement of the commodity.

Production in a Certification Scheme

Certification schemes are used to ensure that seed and nursery stock are free from particular diseases. Crops are produced by approved growers and inspected for certain diseases at agreed intervals by qualified inspectors from government agencies. Controls must be in place to ensure that the integrity of the seed or nursery stock is maintained throughout the production and transport chain. Certification schemes are often a very effective means of maintaining planting stock of known health status and are frequently used to manage pathogens of potato, strawberry, beans, and budwood of various fruits, among others.

Area Freedom ('Pest Free Areas')

Area freedom can be used to underpin the export of various plants and plant products provided that these areas are established, maintained and verified as being pest free in a manner consistent with the ISPM No. 4. According to the ISPM, a pest free area is: an area in which a specific pest does not occur as demonstrated by scientific evidence and in which, where appropriate, this condition is being officially maintained. Thus scientific or technical information is required to support any claims of area freedom. Other requirements include:

  • procedures to establish freedom based on surveys for the pest(s) of concern and on-going monitoring;
  • Domestic quarantine on the movement of potential host material into the pest free area;
  • phytosanitary measures to maintain freedom;
  • checks to verify freedom has been maintained; and
  • systems for documentation and review.

There are several types of area freedom, from an entire country which is free from a specific pest to a small area (pest free places of production and pest free sites) which is pest free but situated in a country where the pest occurs. 'Small' free areas within larger areas that are not known to be free from a pest will generally be limited by readily recognisable biological or geographic barriers.

Area freedom is established by National Plant Protection Organisations (NPPOs) on the basis of general surveillance and/or specific surveys and is maintained by various phytosanitary measures, such as restrictions on the movement of host products or permanent trapping programs. Checking or auditing systems are used to verify the continuing quarantine security of an area, and all operational procedures for management of area freedom need to be adequately documented and subject to periodic review. There are many examples of the application of the concept of area freedom to support trade in plants and plant products, some of which are listed below. An example of trade involving area freedom is the importation of mangoes from the GuimasasIsland in the Philippines to Australia. The pests of concern are the mango pulp weevil (Sternochetus frigidus) and mango seed weevil (Sternochetus mangiferae). Mechanisms are in place to maintain area freedom include ongoing monitoring surveys and the enforcement of legislation to ensure that there is no movement of mango fruits and seeds from other areas of the Philippines into Guimaras Island.

Pest Free Places of Production or Production Sites

The concepts underpinning area freedom have been further developed in the ISPM No. 10, with an emphasis on pest management at the scale of production units (i.e. orchards, fields, glasshouses etc). A key distinction made between these two standards is that management of a pest free area is by the NPPO whereas a pest free place of production or production site is managed by the producer, with supervision by the NPPO.

Systems Approach

A systems approach to risk management uses a combination of risk mitigation measures that individually and cumulatively reduce the risk of entry of quarantine pests to achieve the ALOP for the importing country. It is a holistic approach to managing risks identified in a risk assessment, taking into account all stages in the production and export chain. Safeguards and pest mitigation measures can occur anywhere from the field to the consumer and may include practices that reduce pest incidence in the production area, at the packing facility, and during shipment and distribution of the commodity. The elements in a systems approach must all contribute to achieving the level of protection required by the importing country.

The components of a systems approach may be dependent and cumulative, but must include two or more measures that act independently. The combination of measures will normally provide a degree of redundancy. That is, safeguards in the system will continue to reduce risk if one mitigating measure fails or its efficacy is reduced.

Conditions that favour the success of a systems approach include:

-the pest and pest/host relationship is well defined;

-practical systems exist for pest detection in the field and in consignments;

-growing, harvesting, packing, transportation and distribution practices are well-known and standardised;

-the volume/value of the commodity offsets increased program costs;

-pest mitigation and safeguard measures can be identified, monitored and corrected; and

-phytosanitary security is apparent through either qualitative or quantitative assessment.

Systems approaches provide the opportunity to consider both pre- and post-harvest procedures, such as area freedom, cultural practices, sanitation, field treatment, postharvest disinfestation and inspection, that may contribute to the effective management of pest risk. Procedures that may be integrated in a systems approach could include two or more of the following:-

  • Pest free areas or places of production;
  • Registration - registration of export growers, export blocks, packing houses, etc
  • Cultural or field management;
  • Surveillance and monitoring - general or specific surveys; trapping and sampling; pest surveys at critical growth stages of a crop (see ISPM on surveillance);
  • Integrated pest management (IPM);
  • Restrictions -designated harvest or shipping periods; use of resistant hosts; limited distribution at the destination; sourcing commodity from production districts where pest is not prevalent; restrictions on the maturity, colour, hardness or other condition of the commodity;
  • Post-harvest handling - procedures to prevent contamination or re-infestation, e.g. accredited packing houses; packing line sanitation; specific packing requirements (pest-proof packaging, new cartons; screening packing areas); sorting and grading; elimination of trash; storage security (pest-proof storage facilities, labelling);
  • Post-harvest disinfestation treatment;
  • Phytosanitary inspection and certification;
  • Transport - transport by air/sea; cool storage; disinfestation treatment; and
  • On-arrival inspection - sampling (destructive and non-destructive); enhanced on-arrival inspection; check of container seals and documentation; identification of intercepted pests; treatment and corrective action, if necessary.

An examples of the Systems Approach for management of pest risk is the trade in Unshu oranges from Japan to the USA. The USA prohibits the entry of citrus from areas where citrus canker exists. For the past twenty years, Unshu oranges have been permitted entry into the USA under a systems approach. This requires: an established orchard of resistant varieties and surrounding buffer zone to be surveyed and verified as free from the bacterial disease; fruit to be surface treated post-harvest with a chlorine solution, inspected for verification of freedom from visual symptoms and limited distribution of fruit in the US.