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					        FINAL POLICY REVIEW–

 THE RISK POSED BY MANGO SCAB (Elsinoë
              mangiferae)




                                                STATE PEST RISK ANALYSIS


  ASSOCIATED WITH THE PATHWAYS OF MANGO
  FRUIT AND NURSERY STOCK IMPORTED INTO
            WESTERN AUSTRALIA
                                                 JUNE
                                                 2008


PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Department of Agriculture and Food (2007) Final Policy Review: A Pest Risk Analysis for the risk posed
by Mango Scab (Elsinoë mangiferae) associated with the pathways of mango fruit and nursery stock
imported into Western Australia. The Department of Agriculture and Food, Government of Western
Australia. 67 pp.




Contributors

Hammond, N.E. Research Officer, Plant Health Policy and Management, Biosecurity and Research
Kumar, S. Research Officer, Plant Health Policy and Management, Biosecurity and Research
Lukeis, G.W. Quarantine Inspector, Plant Health Policy and Management, Biosecurity and Research
Stuart, M. J. Research Officer, Plant Health Policy and Management, Biosecurity and Research
Tuten, S.J. Research Officer, Plant Health Policy and Management, Biosecurity and Research


Department of Agriculture and Food, Government of Western Australia
3 July 2008




For further information or additional copies of this document, please contact:

Simone Tuten
Plant Health Policy and Management, Biosecurity and Research
Department of Agriculture and Food
Locked Bag 4
Bentley Delivery Centre
Western Australia 6983
Telephone: (08) 9368 3434
Facsimile: (08) 9474 3814
Email: stuten@agric.wa.gov.au




Acknowledgement: Cover photograph from Crop Protection Compendium 2003
http://www.cabicompendium.org/cpc/home.asp
Final Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit and nursery stock                            Page 4 of 67




RECOMMENDATION

The following is my recommendation in relation to the Department of Agriculture and Food’s
policy pertaining to the importation into Western Australia of mango (Mangifera indica) fruit
and nursery stock to prevent the introduction, establishment and spread of mango scab
(Elsinoë mangiferae).

It will be recommended to the Director General of the Department of Agriculture and Food,
Western Australia and the Minister for Agriculture that the Plant Diseases Regulations 1989 be
amended to allow the entry of mango fruit and nursery stock into Western Australia under the
protocol outlined in this final report. It is further recommended that these conditions be
incorporated into the Biosecurity and Agriculture Management Act 2007 upon implementation.

I am satisfied that the entry of mango fruit and nursery stock into Western Australia, subject to
the conditions specified in this policy review, is in accord with Western Australia’s obligations
under the national Memorandum of Understanding on Animal and Plant Quarantine Measures
and maintains an appropriate level of biosecurity protection for Western Australia.

I am satisfied that the correct process has been followed in completing this analysis.




Dr Shashi Sharma

Director Plant Biosecurity

3 July 2008




                              PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Final Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit and nursery stock                                                             Page 5 of 67



                                                TABLE OF CONTENTS
EXECUTIVE SUMMARY............................................................................................................7
INTRODUCTION......................................................................................................................13
PART ONE ...............................................................................................................................13
  Analysis Scope .....................................................................................................................13
  Background ..........................................................................................................................13
PART TWO – RISK ANALYSIS METHODOLOGY ...................................................................15
  Stage 1: Initiation of the Pest Risk Analysis..........................................................................15
  Stage 2: Pest Risk Assessment ............................................................................................15
  Stage 3: Pest Risk Management ..........................................................................................15
PART THREE - PEST RISK ANALYSIS ...................................................................................16
  Stage 1: Initiation ..................................................................................................................16
  Stage 2: Risk Assessment ....................................................................................................16
     Pest Data Sheet ...............................................................................................................16
     Assessment of entry, establishment or spread.................................................................18
     Probability of Entry – Nursery Stock.................................................................................18
     Probability of Entry – Fruit ................................................................................................19
     Probability of Establishment .............................................................................................19
     Probability of Spread ........................................................................................................20
     Probability of entry, establishment or spread....................................................................20
     Economic Consequences.................................................................................................20
     Risk Assessment Conclusion ...........................................................................................21
  Stage 3: Pest Risk Management ..........................................................................................23
     Available Phytosanitary Measures ...................................................................................24
     Quarantine Conditions to Manage the Risk Posed by Mango Scab via the Pathways of
     Mango Fruit and Nursery Stock Imported into Western Australia.....................................26
  Conclusions ..........................................................................................................................30
  Review of Import Requirements ...........................................................................................30
PART FOUR – STAKEHOLDER COMMENTS ........................................................................31
  Biological issues ...................................................................................................................31
  Quarantine pest status..........................................................................................................31
  Determination of consequences ...........................................................................................33
  Regional freedom .................................................................................................................35
  Selective use of information..................................................................................................40
  Survey methodology .............................................................................................................43
  Import conditions ..................................................................................................................45
     Mango Fruit ......................................................................................................................46
     Mango nursery stock, vegetative propagating or other mango plant material other than
     tissue culture, seed and fruit. ...........................................................................................47
  Consultation..........................................................................................................................47
Variations to the Draft Policy Review .......................................................................................48
REFERENCES.........................................................................................................................50


                                                         APPENDICES
APPENDIX 1: GLOSSARY OF TERMS AND ABBREVIATIONS .............................................52
APPENDIX 2: MATRIX OF RULES (COMBINATION OF LIKELIHOODS) ..............................58
APPENDIX 3: RISK ESTIMATION MATRIX.............................................................................59
APPENDIX 4: METHOD FOR ASSESSING ECONOMIC CONSEQUENCES ........................60
APPENDIX 5: PRODUCT INSPECTION .................................................................................63




                            PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Final Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit and nursery stock                            Page 7 of 67




EXECUTIVE SUMMARY
Mango scab (Elsinoë mangiferae) was formally identified in the Northern Territory in 1997.
Although the disease had been observed earlier in the 1990’s in the Northern Territory and in
Queensland, it was thought to be a form of anthracnose (Colletotrichum gloeosporides).

In December 1997, the Department of Agriculture and Food, Western Australia (the
Department) responded to the Northern Territory outbreak with a temporary alternative
procedure (emergency measure) under the Plant Diseases Act 1914. The alternate procedure
provided restrictions on the importation of mango (Mangifera indica) plants and parts of plants
(including fruit) from other States and Territories, as an interim measure to protect Western
Australia from the disease until the risk was further investigated.

The alternative procedure prohibited the entry of mango plants and parts of plants (including
fruit) from other States and Territories unless certified by an officer from the exporting State or
Territory’s Quarantine Authority as:
     •    inspected and found free from the symptoms of mango scab; and
     •    in the case of cuttings - from a parent plant inspected and found free from mango scab
          symptoms; and
     •    treated with an approved fungicide (except fruit).
In August 2003, mango scab was isolated from a single sample from Bidyadanga in the
Broome Region (Western Australia) by the Northern Australia Quarantine Strategy (NAQS).
Bidyadanga is an isolated remote community approximately 170 km south of Broome with a
few non-commercial mango trees. The Department surveyed this site, following notification of
the identification of this pathogen by NAQS in July 2004. The follow up surveys conducted on
the infested property of all mango trees did not detect the presence of mango scab; however,
as a precautionary measure the decision was made to destroy all mango trees in the
neglected orchard. Subsequent surveys in northern Western Australia conducted by the
Department and NAQS including Broome and Kununurra have not detected mango scab.
Passive surveillance programs in other Western Australian mango growing regions have not
resulted in any detections of the disease.

In May 2005 the original detection site at Bidyadanga was re-inspected by the Departmental
surveillance team. Despite no evidence of the presence of mango scab in the original follow
up survey, the majority of trees had been removed and an action plan to destroy remaining
plants was developed with the Community Administrator, the trees were subsequently
destroyed.

In conjunction with the Department’s surveys NAQS re-inspected the site in August 2004,
September 2005 and October 2006. Again mango scab symptoms were not evident and all
samples tested returned negative for mango scab. Mango scab is a NAQS target species.

Despite the single detection originally reported by NAQS, no further symptoms have been
noted on mangoes in any of the subsequent surveys. As such the Department considers that
mango scab did not establish in Western Australia. The very early detection of mango scab
provides evidence of the value of the NAQS surveys conducted in northern Australia. Mango
scab will be a target for future surveys conducted by the Department and NAQS in northern
Western Australia. The passive surveillance program will continue.

A final policy review of the risk posed by mango scab to Western Australia has been
undertaken by the Department following consideration of stakeholder comments. The pest risk
analysis (PRA) undertaken using nationally recognised methodology and based on available


                           PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Final Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit and nursery stock                           Page 8 of 67



information has suggested that the unrestricted risk for the importation of fresh fruit is
‘negligible’ and the unrestricted risk for the importation of nursery stock is ‘low’.

This final policy review recommends that the import conditions for mango scab be amended
to:

Certification
(Fruit and nursery stock)
General (Note these are standard conditions for entry which were considered when
determining the unrestricted risk estimate and are not phytosanitary measures)

Each consignment to be accompanied by an Interstate Plant Health Certificate issued by the
quarantine authority in the exporting State or Territory or under a quality assurance
arrangement approved by the Director General of the Department of Agriculture and Food,
Western Australia, endorsed where required under specific requirements and as follows;

To be certified as follows –

     (i) The name of the commodity, identified by genus and species, and

     (ii) Name and address of property on which the product was grown; and

     (iii) Name and address of the packing house; and

     (iv) Name and address of the place where treatments were carried out; and

     (v) The date treatments were applied.

Specific Requirements
(nursery stock) (Note these do not apply to fruit)

Option 1: From a State of Territory where mango scab is not known to occur

To be certified as –

“Grown and packed in a State or Territory free from mango scab (Elsinoë mangiferae) under
an approved area freedom program”

An area freedom program will need to be approved by the Director General of the Department
of Agriculture and Food, Western Australia (DAFWA).

OR

Option 2: From a State or Territory where mango scab is known to occur

To be certified as –

“Grown and packed in an area free from mango scab (Elsinoë mangiferae) as established by
an approved area freedom program”

An area freedom programme is to be approved by the Director General of the Department of
Agriculture and Food, Western Australia (DAFWA)

OR



                              PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
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Importation into Western Australia of fruit and nursery stock                             Page 9 of 67


Option 3: From a pest free place of production

To be certified as –

“Grown and packed on a property free from mango scab (Elsinoë mangiferae) as established
by an approved pest free place of production”

A pest free place of production to be approved by the Director General of the Department of
Agriculture and Food, Western Australia (DAFWA).
OR
Option 4: Pre-shipment inspection and treatment
To be certified as –

“The above ground parts of all mango plants in the lot have been 100% inspected and found
free from mango scab (Elsinoë mangiferae) on (insert date of inspection)”

Note: inspection to occur within 14 days prior to arrival in Western Australia

and

“Treated with an approved fungicide (insert chemical name, concentration of active ingredient
and rate) on (insert date of application)”

Note: to be applied within 14 days prior to arrival in Western Australia

A pre-shipment treatment program approved by the Director General of the Department of
Agriculture and Food, Western Australia (DAFWA) as determined by:
     •    Treated with a mixture containing a chemical approved by DAFWA for the quarantine
          control of mango scab and
     •    Treatment details to be provided in the disinfection treatment section of the certificate.

          Note: A mixture of Mancozeb (800g/kg) plus Flusilazole (200g/kg) as per permit 4416
          has been approved.
OR
Option 5: Growth in Post Entry Quarantine

Growth in Post Entry Quarantine requires prior approval by the Director General of the
Department of Agriculture and Food, Western Australia (DAFWA) and may require:
     •    Growth under forced conditions in a post entry quarantine glasshouse facility for a
          period of 9 months,
     •    Plants may be released from quarantine following the 9 month period if found free from
          mango scab by the quarantine plant pathologist.
     •    Should mango scab be detected whilst the plants are undergoing post entry quarantine
          the plants may be re-exported or destroyed as approved by an inspector or treated in a
          manner approved by the quarantine plant pathologist.




                           PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Final Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit and nursery stock                         Page 10 of 67



General requirements
(Fruit and nursery stock) (Note these are standard conditions for entry which were
considered when determining the unrestricted risk estimate and are not phytosanitary
measures)
Western Australia’s border biosecurity legislation is being updated and incorporated into a new
Act titled the Biosecurity and Agriculture Management Act (2007). The following general
requirements will be required under the Biosecurity and Agriculture Management Act (2007)
upon enactment. Other State quarantine authorities have been advised of these intended
changes in a letter from the Director Plant Biosecurity Department of Agriculture and Food
Western Australia, dated 19 July 2007. Until the Biosecurity and Agriculture Management Act
(2007) is implemented it is proposed that these general conditions will apply. It should be
noted that these conditions were considered as part of the standard quarantine practices for
Western Australia in determining the unrestricted risk estimate in the pest risk analysis.

Fruit
(except where otherwise specified in the “Specific Requirements”) –

     1. Must be a permitted plant if propagable (including seed)

     2. Must be packed in clean new packaging and containers and shall have the following
        details printed on an external surface in letters not less than 5mm in height:

          (i) An approved registration number,

          or

          (ii) The name of the commodity, identified by genus and species. Alternatively the
               name (genus and species) of the commodity can be placed on the Plant Health
               Certificate (PHC) or Plant Health Assurance Certificate (PHAC); and

               The name and address of the property on which the product was grown; and

               The name and address of the packing house at which the product was packed.

               Note: if the name and address of the property on which the product was grown is
               not provided corrective action will be taken at the level of the pack-house.

     3. Must be free of live non-permitted invertebrates, plant pathogens, plant material,
        seeds, soil and any other non-permitted organisms and prescribed potential carriers
        (i.e. quarantine risk material, QRM) prior to arrival in Western Australia.

     4. Must be presented for inspection, immediately upon entry into the State, for inspection
        by an Inspector, at a prescribed inspection point.

     5. All consignments must be imported into Western Australia in a manner that prevents
        the escape of pests and remain in this state until unloaded for inspection at a premise
        registered by quarantine for this purpose or as directed by an Inspector.

     6. The prescribed inspection points (e.g. checkpoints such as at the South Australia and
        Northern Territory border) may have limited facilities for inspection, cleaning or
        treatment, Consignments may be directed under quarantine security to a quarantine
        registered premise or other destination as directed by an Inspector for inspection,
        cleaning, treatment or other action as determined by an Inspector.




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Importation into Western Australia of fruit and nursery stock                          Page 11 of 67


     7. The Director General may approve importation of prescribed potential carriers and
        organisms under conditions other than those specified here provide the Director
        General is satisfied that they can be imported under conditions where the risk can be
        managed. For example, approval may be issued for items to be imported for growth in
        post entry quarantine, experimental purposes, testing, processing or re-export out of
        the State.

Nursery Stock
(except where otherwise specified in the “Specific Requirements”) –

     1. Plants of any kind in pots of more than 20L in size are not permitted entry.

     2. Must be a permitted plant.

     3. Must be packed in clean new packaging and containers and shall have the following
        details printed on an external surface in letters not less than 5mm in height:

          (i) An approved registration number,

          or

          (ii) The name of the commodity, identified by genus and species. Alternatively the
               name (genus and species) of the commodity can be placed on the Plant Health
               Certificate (PHC) or Plant Health Assurance Certificate (PHAC); and

               The name and address of the property on which the product was grown; and

               The name and address of the packing house at which the product was packed.

               Note: if the name and address of the property on which the product was grown is
               not provided corrective action will be taken at the level of the pack-house.

     4. Must be free of live non-permitted invertebrates, plant pathogens, plant material,
        seeds, soil and any other non-permitted organisms and prescribed potential carriers
        (i.e. quarantine risk material, QRM) prior to arrival in Western Australia.

     5. Must be presented for inspection, immediately upon entry into the State, for inspection
        by an Inspector, at a prescribed inspection point.

     6. All consignments must be imported into Western Australia in a manner that prevents
        the escape of pests and remain in this state until unloaded for inspection at a premises
        registered by quarantine for this purpose or as directed by an Inspector.

     7. The prescribed inspection points (e.g. checkpoints such as at the South Australia and
        Northern Territory border) may have limited facilities for inspection, cleaning or
        treatment. Consignments may be directed under quarantine security to a registered
        premise or other destination directed by an Inspector for inspection, cleaning,
        treatment or other action as determined by an Inspector.

     8. The Director General may approve importation of prescribed potential carriers and
        organisms under conditions other than those specified here provide the Director
        General is satisfied that they can be imported under conditions where the risk can be
        managed. For example, approval may be issued for items to be imported for growth in
        post entry quarantine, experimental purposes, testing, processing or re-export out of
        the State.



                           PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Final Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit and nursery stock                         Page 12 of 67



The pest risk analysis has shown that the risk associated with the importation of mango fruit
for fresh eating (not including immature fruit) originating from States and Territories where
mango scab is known to occur, subject to standard quarantine practices for Western Australia
including 600-unit inspection, provides the appropriate level of protection for Western
Australia. Likewise the pest risk analysis has shown that the risk associated with the
importation of mango nursery stock from States and Territories where mango scab is known to
occur can be managed by the application of the measures described in this document. The
application of these measures provides the appropriate level of protection for Western
Australia.

It is recommended that the current Plant Diseases Regulations 1989 be amended to reflect
the conditions recommended in this final policy review and that the current temporary alternate
procedure is not renewed. It is further recommended that these conditions be incorporated
into the Biosecurity and Agriculture Management Act 2007 upon implementation.

This analysis does not consider the immature fruit, cut flowers/foliage, tissue culture or seed
pathways nor does it consider the risks associated with any other pests of mango fruit or
nursery stock. Identifying and assessing the risks posed by other pests on these pathways
and other pathways will be undertaken as part of the Department’s review of interstate
measures.




                              PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Final Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit and nursery stock                          Page 13 of 67




INTRODUCTION
This document contains four parts.

Part one describes the events leading up to the initiation of the analysis and scope of the
analysis.

Part two describes the methodology used by the Department of Agriculture and Food,
Western Australia (the Department) for State Pest Risk Analyses (PRA). The methodology
used conforms to the International Standards for Phytosanitary Measures (ISPM) and is
similar to and consistent with the methodologies identified by Biosecurity Australia in the
Guidelines for Import Risk Analysis (Biosecurity Australia 2001) for plants and plant products.

Part three is the pest initiated risk analysis. The main pathways are identified and assessed
for the likelihood of entry, establishment and spread, together with the potential economic
consequences. A pest data sheet and risks associated with all pathways are evaluated and
the need for risk mitigation determined. Risk mitigation measures are proposed for pathways
that exceed Western Australia’s appropriate level of protection.

Part four deals with stakeholder consultation and variations to the draft analysis. It provides a
synopsis of stakeholder comments and the Department’s response and summarises any
variations that have been made and incorporated into the final analysis.


PART ONE

Analysis Scope
In this final policy review the Department of Agriculture and Food, Western Australia (the
Department) has considered the movement of mango (Mangifera indica) nursery stock, and
fruit for fresh eating from States and Territories where the pathogen, Elsinoë mangiferae, is
known to occur and distributed to Western Australia as the entry pathways. This analysis does
not consider the immature fruit, cut flowers/foliage, tissue culture or seed pathways nor does it
consider the risks associated with any other pests of mango fruit or nursery stock. Identifying
and assessing the risks posed by other pests on these pathways and other pathways will be
undertaken as part of the Department’s review of interstate measures.

For the purpose of this analysis, fruit is defined as a part of a plant that could or does contain
a seed (including pseudo fruits or accessory fruits such as strawberry, fig and cashew) and
excludes the peduncle (the stalk of the fruit cluster) but includes the pedicel (the stalk of a
single fruit),

Nursery stock is defined as any potted or bare rooted plant or bulb and any cuttings or any
above or below ground part used for vegetative propagation, but does not include plant tissue
culture or seed.

Background
This pest initiated final policy review followed the confirmation in 1997 that the fungal
pathogen Elsinoë mangiferae, the cause of mango scab, was formally identified in the
Northern Territory. The disease had been observed earlier in the 1990’s in the Northern
Territory and in Queensland, although it was thought to be a form of anthracnose
(Colletotrichum gloeosporides).



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Importation into Western Australia of fruit and nursery stock                           Page 14 of 67



In December 1997, the Department issued a temporary alternative procedure (emergency
measure) under the Plant Diseases Act 1914, to implement restrictions on mango (Mangifera
indica) plants and parts of plants including fruit from other States and Territories. This was an
interim measure to protect Western Australia from incursions of the disease.

The temporary alternative procedure stated:

“Prohibit the entry of mango plants and parts of plants (including fruit) from other States and
Territories except if certified by an officer from the exporting State or Territory’s Quarantine
Authority as:
          •    inspected and found free from the symptoms of mango scab; and
          •    in the case of cuttings - from a parent plant inspected and found free from mango
               scab symptoms; and
          •    treated with an approved fungicide (except fruit).
NOTE: Off label approval has been approved for Flusilazole to be used on mango plants.”

In August 2003, mango scab was detected on a single twig of one plant in Western Australia
following a routine survey undertaken by the Northern Australia Quarantine Strategy (NAQS)
in Bidyadanga, a remote community, with a few non-commercial mango trees, approximately
170 km south of Broome. The Department surveyed the site, following notification of the
identification of this pathogen by NAQS in July 2004. The follow up surveys conducted on the
infested property of all mango trees did not detect the presence of mango scab; however, as a
precautionary measure the decision was made to destroy all mango trees in the neglected
orchard. Subsequent surveys in northern Western Australia conducted by the Department and
NAQS including Broome and Kununurra have not detected mango scab. Passive surveillance
programs in mango growing regions of Western Australian have not resulted in any detections
of the disease.

In May 2005 the original detection site at Bidyadanga was re-inspected by the Departmental
surveillance team. Despite no evidence of the presence of mango scab in the original follow
up survey, the majority of trees had been removed and an action plan to destroy remaining
plants was developed with the Community Administrator, the trees were subsequently
destroyed.

In conjunction with the Department’s surveys NAQS re-inspected the site in August 2004,
September 2005 and October 2006. Again mango scab symptoms were not evident and all
samples tested returned negative for mango scab. Mango scab is a NAQS target species.

Despite the single detection originally reported by NAQS, no further symptoms have been
noted on mangoes in any of the subsequent surveys. As such the Department considers that
mango scab did not establish in Western Australia. The very early detection of mango scab
provides evidence of the value of the NAQS surveys conducted in northern Australia. Mango
scab will be a target for future surveys conducted by DAFWA and NAQS in northern Western
Australia. The passive surveillance program will continue.

The mango industry in Western Australia is predominately distributed from Kununurra through
to Gingin with almost continuous production from September to April. However, mango trees
are grown in Perth and surrounding areas such as Carabooda. Harvest begins in Kununurra
and is followed by Broome, Carnarvon and Gingin. In 2001 mango production in the
Kimberley and Central regions of Western Australia approximated 1890 tonnes; with an
approximate value of $5.9 million (ABS 2002). These two regions produce approximately 97%
of Western Australian mangos (White 1997). In 2004/2005 mango production in Western
Australia was 2950 tonnes; with a value of approximately $10.5 million (Australian Bureau of


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Importation into Western Australia of fruit and nursery stock                             Page 15 of 67


Statistics and Department of Agriculture and Food 2007). Over the next four to five years
production is expected to increase to 7000 tonnes per year (DAFWA 2007). Western
Australian mango export destinations include Singapore, Malaysia, Hong Kong, Europe,
Brunei and the Middle East (White 1997).


PART TWO – RISK ANALYSIS METHODOLOGY
The methodology adopted by the Department of Agriculture and Food, Western Australia for
State Pest Risk Analyses (PRA) conforms to the International Standards for Phytosanitary
Measures (ISPM) and is similar to and consistent with the methodologies identified by
Biosecurity Australia in the Guidelines for Import Risk Analysis (Biosecurity Australia 2001) for
plants and plant products.

Stage 1: Initiation of the Pest Risk Analysis
The aim of Stage 1 is to identify the objectives of the pest risk analysis (PRA) including
identifying the initiation point, the PRA area, that is, the area in relation to which a PRA is
conducted and endangered area, that is, the area where ecological factors favour the
establishment of a pest.

An important facet of the initiation stage is to identify the pest(s), their current distribution and
association with host plants and commodities and their presence on the pathway.

Stage 2: Pest Risk Assessment
Stage 2 describes the process of identifying pathways of quarantine concern from those
identified in Stage 1 and estimating the risk associated with each.

Stage 3: Pest Risk Management
The conclusions from the pest risk assessment are used to determine whether risk
management is required and if the existing measures meet the appropriate level of protection
(ALOP). Since zero risk is not a reasonable nor achievable option, the guiding principle for risk
management should be to manage risk to achieve the required degree of safety that can be
justified and is feasible within the limits of available measures and resources.

Prohibition of Commodities

If no satisfactory measure can be found to reduce the risk to a level of ‘very low’, the final
option can be to prohibit importation of the commodity. This is viewed as a measure of last
resort. As it is highly trade restrictive there needs to be clear scientific evidence to justify such
a measure. Prohibition may not be as efficacious as expected, especially in instances where
the incentives for illegal import may be significant.

Monitoring and Review of Phytosanitary Measures.

The implementation of phytosanitary measures is not considered to be permanent. After
application, the success of the measures in achieving their aim will be determined by
monitoring during use. This is often achieved by inspection of the commodity on-arrival, noting
any interceptions or any entries of the pest to the PRA area. The information supporting the
pest risk analysis will be periodically reviewed to ensure that any new information that
becomes available will be used to evaluate the need to modify any phytosanitary measures in
place.




                           PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Final Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit and nursery stock                            Page 16 of 67




PART THREE - PEST RISK ANALYSIS

Stage 1: Initiation
The aim of Stage 1 is to identify the objectives of the Pest Risk Analysis (PRA), including
identifying the initiation point, the PRA area, that is, the area in relation to which a PRA is
conducted and the endangered area, that is, the area where ecological factors favour the
establishment of a pest.

This pest initiated analysis followed the confirmation in 1997 that Elsinoë mangiferae, the
cause of mango scab, had been formally identified in the Northern Territory and is a review of
the emergency measure (temporary alternate procedure) under the Plant Diseases Act 1914,
prior to a permanent change to the Regulations.

In August 2003, mango scab was detected on a single twig from one plant in Western
Australia following a routine survey undertaken by the Northern Australia Quarantine Strategy
(NAQS) in Bidyadanga, a remote community, with a few non-commercial mango trees,
approximately 170 km south of Broome. The Department surveyed the site, following
notification of the identification of this pathogen by NAQS in July 2004. The follow up surveys
conducted on the infested property of all mango trees did not detect the presence of mango
scab; however, as a precautionary measure the decision was made to destroy all mango trees
in the neglected orchard. Subsequent surveys in northern Western Australia conducted by the
Department and NAQS including Broome and Kununurra have not detected mango scab.
Passive surveillance programs in mango growing regions of Western Australian have not
resulted in any detections of the disease.

In May 2005 the original detection site at Bidyadanga was re-inspected by the Departmental
surveillance team. Despite no evidence of the presence of mango scab in the original follow
up survey, the majority of trees had been removed and an action plan to destroy remaining
plants was developed with the Community Administrator, the trees were subsequently
destroyed.

In conjunction with the Department’s surveys NAQS re-inspected the site in August 2004,
September 2005 and October 2006. Again mango scab symptoms were not evident and all
samples tested returned negative for mango scab. Mango scab is a NAQS target species.

Despite the single detection originally reported by NAQS, no further symptoms have been
noted on mangoes in any of the subsequent surveys. As such the Department considers that
mango scab did not establish in Western Australia. The very early detection of mango scab
provides evidence of the value of the NAQS surveys conducted in northern Australia. Mango
scab will be a target for future surveys conducted by the Department and NAQS in northern
Western Australia. The passive surveillance program will continue.

The “PRA area” in this analysis is defined as the State of Western Australia. The “endangered
area” is defined as any area within Western Australia, where susceptible hosts are present,
and in which ecological and environmental factors favour the establishment mango scab. The
pathways under consideration in this policy review are mango (Mangifera indica) nursery stock
and fruit for fresh eating (and does not consider immature fruit) from States and Territories
where the pathogen is known to occur and distributed to the PRA area.

Stage 2: Risk Assessment
Pest Data Sheet
Common name(s): Mango scab.


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Scientific name: Elsinoë mangiferae Bitancourt & Jenkins, anamorph Denticularia
mangiferae (Bitanc. & Jenkins) Alcorn, Grice & R.A. Peterson.

Synonyms and changes in combination: Sphaceloma mangiferae Bitancourt & Jenkins.
Alcorn et al. (1999) suggested a name change of Sphaceloma mangiferae to Denticularia
mangiferae as the Australian isolates do not have the same morphological characteristics of
those placed into the Sphaceloma group. Australian isolates of mango scab have been
identified as an anamorphic stage of mango scab, D. mangiferae; however, association of
D. mangiferae and the telomorphic stage Elsinoë mangiferae has not yet been confirmed.
However, this proposed name change has not been widely recognised by the scientific
community and may result in some confusion as to the identity of the causal pathogen of
mango scab.

Hosts: Mango (Mangifera indica) is the only known host.

Plant part affected: Young leaves, twigs, flowers and fruit are all susceptible to infection.

Distribution:
World distribution: Mango scab was first described from Cuba and Florida specimens in 1942.
Mango scab has since been recorded from most mango producing areas, including Mexico,
the West Indies (including Dominican Republic, Antigua and Bahamas), Guatemala, Honduras
and El Salvador in Central America; Brazil, Venezuela and Colombia in South America; Guam
in the Pacific; India and Taiwan in Asia; Thailand and the Philippines in South-East Asia; and
in Africa including Ghana, Guinea and the Côte d'Ivoire (CABI 2003).

Australian Distribution: Mango scab has been identified in Queensland and the Northern
Territory. Mango scab was first officially identified near Darwin in the Northern Territory in
1997 (Condé et al. 1997a). Symptoms have been recorded from this region as early as 1992
and observed from Queensland in the early 1990’s; however, it was thought to be a form of
anthracnose (Colletotrichum gloeosporides). In August 2003 mango scab was isolated from
one sample from an isolated neglected orchard in Bidyadanga (an isolated community 170 km
south of Broome). As a precautionary measure the mango trees in the neglected orchard were
destroyed. Surveys conducted by the Department of Agriculture and Food, Western Australia
(the Department) and the Northern Australia Quarantine Strategy (NAQS) of the suspect site
and other areas of Western Australia have resulted in no detections of mango scab. Mango
scab is considered not to have established in Western Australia.

Biology: There are no reports of Elsinoë mangiferae infecting plants other than mango.
Young, succulent tissues of the host are preferentially infected. In general host tissues
become increasingly resistant as they mature (Ploetz 1994).

Elsinoë mangiferae produces two types of spores: ascospores and conidia. The sexual stage
of mango scab has rarely been detected; thus ascospores appear to play a minor role in
infections and spread of the disease. This stage is characterised by brownish ascomata (30-
48 x 80-160 μm) formed in the epidermis. Globular asci (10-15 μm wide) are dispersed
irregularly and contain one to eight hyaline ascospores (10-13 x 4-6 μm). Ascospores are
three septate, constricted at the median septum and the sub-apical cell is longitudinally
septate (Ploetz 1994).

Condia are produced during the asexual stage of the mango scab fungus (Denticularia
mangiferae) and can only infect young tissue of leaves, stems, flowers, fruit stalks and young
fruit. Conidiophores are erect, sinuous, 12-35 x 2.5-3.5 μm, and wider at the base. The brown,
elongate, unicellular to one-septate conidia are 6-29 x 2-4 μm (Ploetz 1994). Temperatures in
the range of 12-37°C (optimum 28°C) and the presence of free water (RH 100%) is required




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for germination of conidia. Sporulation occurs in the temperature range of 12-33°C (optimum
28°C) (ShengQiang & Peikun 1997).

The conidia are spread by rain splash and periods of free water are required for the conidia to
germinate and for new infections to occur. Under sheltered conditions, when it is wet and
windy, the disease has been reported to spread approximately 4.25 m (Condé et al. 1997a), it
is assumed that this distance would be greater in situations were there is no shelter.

Symptoms may vary slightly depending on the mango cultivar.

Leaves: Leaf lesions commonly appear as small dark brown spots, 1-2 mm in diameter, and
commonly have a lighter coloured halo around the lesion. These may occur on the edge of the
leaf and can form corky lesions on the undersides of the leaves. During wet weather the
fungus sporulates on the corky lesions giving them an olive-tan colour and felt-like
appearance. Leaf symptoms include dark lesions along the main veins of the leaf. Leaf
symptoms of severe infection include shot-hole like lesions, leaf distortion and defoliation of
young leaves. During dry conditions, leaf lesions tend to be smaller, reduced in number and of
a black colouration, and subsequently may not be detected (CABI 2003).

Stems and Stalks: Symptoms of mango scab on stems and fruit stalks of mango plants are
generally numerous small grey lesions, 1-2 mm in diameter. Lesions are slightly raised and
irregular in shape. Large, tan, corky areas resembling scar tissue may be present on the
stems of infected host plants. During dry climatic conditions, the lesions may be smaller and
darker in colour; these lesions may be confused with those of anthracnose (Colletotrichum
gloeosporides).

Fruit: Symptoms on fruit vary depending on the cultivar. Lesions on new fruit are small and
dark, fruit drop occurs when fruit are heavily affected. On Kensington Pride fruit lesions
develop into light coloured cracked, corky scabs; the scabs of multiple lesions may coalesce
to form large irregular scars. The lesions on the fruit of the Irwin cultivar range from small
black spots to scarred areas of varying size. Depression of the area surrounding the larger
lesions may occur, causing fruit distortion. Only young tissue is susceptible to infection and
fruit is no longer susceptible after it reaches about half size (Condé et al. 1997b).

The appearance of mango scab fruit lesions differs from those of anthracnose, under moist
conditions the spore masses of mango scab are grey-brown in colour compared to the pink
colour associated with anthracnose. In addition, unlike anthracnose, mango scab lesions are
not associated with fruit rot (Condé et al. 1997b).

Assessment of entry, establishment or spread
Throughout the development of this risk assessment the unrestricted risk estimate has been
derived taking into account standard quarantine practices for Western Australia. Basic
standards of production for the production of plant-derived commodities in the exporting area
have been considered. Likelihoods and consequences are described using the processes and
nomenclature outlined in AFFA (2001).

Probability of Entry – Nursery Stock
Probability of importation - High
If a host commodity can carry all life stages of a pathogen an ambit claim of a ‘High’ probability
of importation is warranted. Mango scab infects fruit, flowers, leaves and stems of its host and
mango scab could be considered to be endemic in mango production areas within eastern
Australian States and Territories. Whilst heavily infected juvenile fruit usually fall to the ground,
infected flowers, leaves and stems are retained. Small lesions upon leaves and stems may not
be easily detectable especially in dry conditions; furthermore, symptomatic expression may be


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masked by the application of fungicides (mango seedlings require weekly sprays for
protection). For these reasons a ‘High’ probability of importation of mango scab has been
assigned, that is, the importation of mango scab on nursery stock would be very likely to occur
if no corrective phytosanitary action is undertaken.

Probability of distribution – Virtually certain
For most commodities considered under the PRA process, it is necessary for a pathogen to
move off the commodity in question and onto a susceptible host for their continual
development and survival. However, nursery stock is significantly different from other
commodities such as fruit and vegetables, in that pathogens are able to develop, reproduce
and complete their life cycle without leaving the imported commodity and to spread according
to their natural habits. As nursery stock would be distributed for direct planting throughout the
PRA area and planted directly into suitable habitats there is no need for the pathogen to be
transferred to a suitable host. A ‘virtually certain’ probability of distribution has therefore been
assigned, that is, the distribution of mango scab to the endangered area and subsequent
transference to a suitable host would be almost certain to occur from infected host nursery
stock imported into Western Australia.
Probability of Entry - Nursery Stock: - High

Probability of Entry – Fruit
Probability of importation – Low
If a host commodity can carry all life stages of a pathogen an ambit claim of a ‘High’ probability
of importation is warranted. However, the potential of introduction on fruit intended for fresh
eating is limited, largely due to the fact that juvenile, heavily infected fruit usually falls to the
ground. New infections are limited to young fruits and symptoms on mature fruit are visible,
although if only a few fruit are infected or growing conditions have been dry, lesions may be
confused with those of C. gloeosporiodes (anthracnose), which is present in Western
Australia, or abrasion injury. Only young tissue is susceptible to infection and fruit is no longer
susceptible after it reaches about half size (Condé et al. 1997b). Most infected mature fruit are
likely to be detected and rejected prior to packing and shipment although some fruit with minor
symptoms may not be observed and would be exported. Therefore, the likelihood of mango
scab being imported on mature fruit is considered unlikely and a probability of ‘Low’ has been
assigned.
Probability of distribution - Low
The mango scab pathogen is likely to survive storage and transportation. Mango fruit imported
for human consumption as a fresh fruit will result in the generation of waste material. Mango
scab infections occur on the skin and would be disposed of through normal waste disposal
processes and most likely end up at municipal waste sites. Even though it is recognised that
fruit is likely to be distributed within the Perth Metropolitan Region, and that there are backyard
mango trees in the Perth Metropolitan Region, the overall likelihood that waste material is
applied to (as compost) or disposed of in the vicinity of a mango tree is considered low, that is,
the event would be unlikely to occur. As it is unlikely that importation of mango fruit will be
counter seasonal to Western Australian production it is considered unlikely that mango fruit
will be distributed to production areas. The likelihood that mango fruit will be distributed to
mango production areas is considered to be low. A ‘Low’ probability of distribution has
therefore been assigned, that is, the distribution of mango scab to the endangered area and
subsequent transference to a suitable host would be unlikely to occur from fruit imported into
Western Australia.
Probability of Entry – Fruit: - Very Low

Probability of Establishment
Based on the world distribution of the pathogen, it is clear that the pathogen can survive,
persist and establish under a broad range of environmental conditions. Studies of the


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biological characteristics of mango scab indicate that it is able to survive and reproduce under
a wide range of conditions. Vegetative growth has been shown to occur between 4 and 37°C
and sporulation and germination of conidia can occur at 12 to 37°C. Environmental conditions
in mango production areas of Western Australia would not limit the establishment of mango
scab. Therefore, a ‘High’ probability of establishment for mango scab has therefore been
assigned, that is, the perpetuation for the foreseeable future (establishment) would be very
likely to occur.
Probability of Establishment - all pathways: - High

Probability of Spread
Assuming that mango scab successfully establishes in Western Australia, there is no reason
to suggest that the disease would not spread efficiently and widely. Conidia can spread
approximately 4.25 m in sheltered conditions under wet and gusty conditions. It is assumed
that this distance would be greater in situations were there is no shelter. Long distance
dispersal is most likely to occur from the movement of nursery stock. Tropical and subtropical
environments in Australia would be suitable for the spread of mango scab if hosts are
available. There are no intrastate restrictions on the movement of mango nursery stock in
Western Australia, although the irregular distribution of host plants would slow the rate of
spread of the disease. However, spread within mango growing regions would be facilitated by
the presence of naturalised mango plants. A ‘Moderate’ probability of spread of mango scab is
therefore recognised, that is, spread would occur with an even probability should mango scab
establish in Western Australia.
Probability of Spread - all pathways: - Moderate

Probability of entry, establishment or spread
The overall likelihood that Elsinoë mangiferae will enter Western Australia as a result of trade
in nursery stock and fresh mango fruit (not immature fruit), be distributed in a viable state to
suitable hosts, establish in that area and subsequently spread within Australia:
Nursery Stock: Moderate
Fruit: Very Low

Economic Consequences
FAO (2004a) indicates that the analysis of economic consequences is made using “a
hypothetical situation where a pest is supposed to have been introduced and to be fully
expressing its potential economic consequences (per year) in the PRA area”. Biosecurity
Australia and the Department interpret these criteria as an unabated incursion. However, it is
acknowledged that existing control regimes for similar species may impact on this expression.
In light of this interpretation, comments on specific impacts are discussed below.

Table 1: Economic consequences of entry, establishment and spread.

Criterion                         Estimate

Direct consequences

Plant life or health              C ⎯ Fruit with disease symptoms are not marketable. The disease has a higher
                                      impact in nurseries than commercial orchards where mango seedlings require
                                      weekly sprays for protection. However, in an unabated incursion situation
                                      without chemical control, losses as high as 90% may be observed (CABI 2003).
                                      Therefore in an unabated incursion the impact is likely to be significant in
                                      affected districts.




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Any other aspects of the          A ⎯ There are no known direct consequences of this pathogen on any other aspects
environment                           of the environment.

Indirect consequences

Eradication, control etc.         C ⎯ Copper sprays used in the control of anthracnose are known to control mango
                                      scab, although this is not used at flowering due to its potential to burn plants.
                                      Other chemical controls that are effective against mango scab and in use for
                                      control of anthracnose are not used in all mango producing areas of the State,
                                      therefore additional sprays may be required in these areas. Furthermore, there
                                      are additional costs associated with the development and delivery of education
                                      and eradication campaigns. The presence of feral mango plants in the
                                      endangered area would contribute to an increase in the cost of the eradication
                                      campaign. It is estimated that the impact of mango scab would be significant at a
                                      district level.

Domestic trade                    B ⎯ The imposition of internal controls to limit the spread of this pathogen may be
                                      required. The presence of this pathogen in commercial mango production areas
                                      of the State is estimated to have minor consequences on domestic trade at the
                                      district level.

International trade               B ⎯ The presence of this pathogen is estimated to have minor consequences at the
                                      district level due to limitations in access to overseas markets.

Environment                       A ⎯ Fungicides required to control mango scab are estimated to have consequences
                                      that are unlikely to be discernible at the regional level and of minor significance
                                      at the local level.

Economic Consequences – all pathways: - Low

Risk Assessment Conclusion


Nursery stock: Low
Fruit: Negligible

The unrestricted risk estimate for mango scab, determined by combining the overall
‘probability of entry, establishment or spread’ with the ‘consequences’ using the risk estimation
matrix (Error! Reference source not found.).

Nursery stock sourced from States and Territories where the pathogen Elsinoë mangiferae is
known to occur and distributed into Western Australia, subjected to standard quarantine
practices for Western Australia including on arrival inspection, would not provide an
appropriate level of protection for Western Australia against this pathogen. As such, any
nursery stock grown in regions infested with mango scab and transported into Western
Australia would require the application of additional phytosanitary measures undertaken at
some point on the pathway to achieve an appropriate level of protection.

Mango fruit for fresh consumption sourced from States and Territories where the pathogen
Elsinoë mangiferae, is known to occur and distributed to Western Australia, subjected to
standard quarantine practices for Western Australia including on arrival 600-unit inspection,
would provide an appropriate level of protection for Western Australia horticultural production
against this pathogen.




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Table 2: Unrestricted Risk Assessment Summary

                                                                Probability of -
                                                                                                                 Overall
                                                                                                                                Economic      Unrestricted
        Commodity                                                                                             probability of
                              Importation X Distribution =          Entry          Establishment   Spread                      consequences      Risk
          pathway                                                                                                 entry
                                                                                                              establishment
                                                                                                               and spread
                                                   Virtually
          Nursery stock            High                             High               High        Moderate     Moderate           Low            Low
                                                   certain

                     Fruit         Low                Low         Very Low             High        Moderate     Very Low           Low         Negligible




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Stage 3: Pest Risk Management
Certification and general requirements are systems ensuring that the phytosanitary status of
plants and plant material is maintained during the process of production and export to Western
Australia. These certification and general requirements were considered when determining the
unrestricted risk for mango scab.

The conclusions from the pest risk assessment are used to decide whether risk management
is required and the strength of measures to be used. Since zero risk is not a reasonable or
achievable option, the guiding principle for risk management should be to manage risk to
achieve the required degree of safety that can be justified and is feasible within the limits of
available options and resources.

Quarantine measures aim to reduce the likelihood that the importation of host material would
lead to the entry, establishment and spread of mango scab in Western Australia. The primary
methods of achieving this result is by reducing the likelihood that mango scab will reach the
endangered area by imposing conditions on the population from which host material are
sourced, or on other steps in the importation chain.

The unrestricted risk estimate indicates that the fresh fruit pathway does not exceed the
appropriate level of protection for Western Australia; therefore, only standard quarantine
practices for Western Australia are required. The nursery stock pathway requires risk
management measures as this pathway exceeds the appropriate level of protection for
Western Australia.

The measures described below will form the basis of the import conditions for mango scab,
and are detailed in the section entitled “Quarantine Conditions to Manage the Risk Posed by
Mango Scab via the Pathways of Mango Fruit and Nursery Stock Imported into Western
Australia”. The recommendation for the use of the risk management measures described
below does not preclude consideration of other risk management measures should they be
proposed by stakeholders.

Certification and General Requirements
(except where otherwise specified in the “Specific requirements”)

Certification

     •    For nursery stock and fresh fruit

               o    Must have Interstate Plant Health Certificate or Plant Health Assurance
                    Certificate

               o    Certified as meeting general requirements for entry into Western Australia

               o    Certified as meeting specific requirements for mango scab

General Requirements

     •    General requirements for entry into Western Australia for fruit and vegetables in
          accordance with Legislative requirements and include requirements addressing

               o    Must be a permitted organism if propagable

               o    Product is appropriately identified



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               o    Must be packed in clean new packaging and containers

               o    Must be free of live non-permitted organisms, soil and prescribed potential
                    carriers

               o    Must be presented for inspection, immediately upon entry into the State

               o    Consignments may be directed to a quarantine registered premise or other
                    destination as directed

               o    The Director General may approve importation of prescribed potential carriers
                    and organisms under conditions other than those specified here

     •    General requirements for entry into Western Australia for nursery stock

               o    Plants of any kind in pots of more than 20L in size are not permitted entry

               o    Must be a permitted organism

               o    Product is appropriately identified

               o    Must be packed in clean new packaging and containers

               o    Must be free of live non-permitted organisms, soil and prescribed potential
                    carriers

               o    Must be presented for inspection, immediately upon entry into the State

               o    Consignments may be directed to a quarantine registered premise or other
                    destination as directed

               o    The Director General may issue a permit for the importation of this prescribed
                    potential carrier under conditions other than those specified

Available Phytosanitary Measures
Phytosanitary measures are applied to strategic points along the identified pathway for pests
determined to have an unrestricted risk level exceeding Western Australia’s appropriate level
of protection (ALOP).

The measures described below form the basis of the import conditions for mango scab, and
are detailed in the section entitled ‘Quarantine Conditions to Manage the Risk Posed by
Mango Scab via the Pathways of Mango Fruit and Nursery Stock Imported into Western
Australia’ These risk management measures described below do not preclude the
consideration of alternative risk management measures should they be proposed by
stakeholders.

1. Pest free area from mango scab

A “pest free area” is described as 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 (FAO 1995; FAO 1999). In accordance with ISPM No. 4 (FAO 1995) there
are three main components in the establishment and maintenance of a pest free area (PFA):
     •    systems to establish freedom;



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     •    phytosanitary measures to maintain freedom; and
     •    checks to verify freedom has been maintained.
The declaration of pest free area for mango scab may be either within a State or Territory or
for the whole of the State or Territory.

Whole of State/Territory pest free area

Whole of State/Territory pest free area is considered acceptable if the pest has not been
recorded from the State or Territory, there are phytosanitary measures in place to maintain
freedom and there are checks in place to verify ongoing freedom.
Pest free area within a State or Territory
In order for a pest free area to be recognised within a State or Territory an inspection program
will be required to demonstrate freedom within a State or Territory. This phytosanitary measure
will require nursery stock to be grown and packed in a pest free area from mango scab. Area
freedom is to be determined by inspection and requires phytosanitary measures in place to
maintain freedom and checks in place to verify ongoing freedom.

2. Pest free place of production (property freedom)

A ‘pest free place of production’ is described as a place of production in which a specific pest
does not occur as demonstrated by scientific evidence and in which, where appropriate, this
condition is being officially maintained for a defined period (FAO 1999). Again the pest free
place of production phytosanitary measure reduces the likelihood of importation.

3. Pre-shipment inspection and fungicide treatment
Nursery stock sourced from a property infected with mango scab may be imported following a
pre-shipment inspection and a fungicide treatment registered or permitted by the Australian
Pesticides and Veterinary Medicines Authority (APVMA) and approved by DAFWA. Note that
a mixture of Mancozeb (800g/kg) plus Flusilazole (200g/kg) as per permit 4416 has been
approved.
4. Post entry quarantine

Mango nursery stock may be imported without certification for mango scab (subject to
approval by the Director General of the Department of Agriculture and Food, Western
Australia). However, this material will be required to be grown in a post entry quarantine
glasshouse facility for a period of 9 months, under forced growth conditions (optimum
temperature and moisture conditions). The forced growth conditions ensure flushes of new,
young growth that is susceptible to mango scab. Plants may be released from quarantine
following the 9 month period if found free from mango scab by the quarantine plant
pathologist. Should mango scab be detected whilst the plants are undergoing post entry
quarantine the plants are to be re-exported or destroyed as approved by an inspector or
treated in a manner approved by the quarantine plant pathologist.




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Quarantine Conditions to Manage the Risk Posed by Mango Scab via the Pathways
of Mango Fruit and Nursery Stock Imported into Western Australia
Definitions
Consignment – A quantity of plants, plant products and/or other regulated articles being
moved from one area to another and covered by a single plant health certificate. A
consignment may be composed of one or more lots.

Fruit – a part of a plant that could or does contain a seed (including pseudo fruits or accessory
fruits such as strawberry, fig and cashew) and excludes the peduncle (the stalk of the fruit
cluster) but includes the pedicel (the stalk of a single fruit).

Lot – A number of units of a single commodity, identifiable by its homogeneity of composition,
origin, etc., forming part of a consignment.

Nursery Stock – means any potted or bare rooted plant or bulb and any cuttings or any
above or below ground part used for vegetative propagation, but does not include plant tissue
culture or seed.

Pest Free Area – 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.

Pest Free Place of Production – Place of production in which a specific pest does not occur
as demonstrated by scientific evidence and in which, where appropriate, this condition is being
officially maintained for a defined period.

Mango– means Mangifera indica

Mango scab – means Elsinoë mangiferae

Certification
(Fruit and nursery stock)
General (Note these are standard conditions for entry which were considered when
determining the unrestricted risk estimate and are not phytosanitary measures)

Each consignment to be accompanied by an Interstate Plant Health Certificate issued by the
quarantine authority in the exporting State or Territory or under a quality assurance
arrangement approved by the Director General of the Department of Agriculture and Food,
Western Australia, endorsed where required under specific requirements and as follows;

To be certified as follows –

          (i) The name of the commodity, identified by genus and species, and

          (ii) Name and address of property on which the product was grown; and

          (iii) Name and address of the packing house; and

          (iv) Name and address of the place where treatments were carried out; and

          (v) The date treatments were applied.




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Specific Requirements
(nursery stock) (Note these do not apply to fruit)

Option 1: From a State of Territory where mango scab is not known to occur

To be certified as –

“Grown and packed in a State or Territory free from mango scab (Elsinoë mangiferae) under
an approved area freedom program”

An area freedom program will need to be approved by the Director General of the Department
of Agriculture and Food, Western Australia (DAFWA).

OR

Option 2: From a State or Territory where mango scab is known to occur

To be certified as –

“Grown and packed in an area free from mango scab (Elsinoë mangiferae) as established by
an approved area freedom program”

An area freedom programme is to be approved by the Director General of the Department of
Agriculture and Food, Western Australia (DAFWA)

OR

Option 3: From a pest free place of production

To be certified as –

“Grown and packed on a property free from mango scab (Elsinoë mangiferae) as established
by an approved pest free place of production”

A pest free place of production to be approved by the Director General of the Department of
Agriculture and Food, Western Australia (DAFWA).
OR
Option 4: Pre-shipment inspection and treatment
To be certified as –

“The above ground parts of all mango plants in the lot have been 100% inspected and found
free from mango scab (Elsinoë mangiferae) on (insert date of inspection)”

Note: inspection to occur within 14 days prior to arrival in Western Australia

and

“Treated with an approved fungicide (insert chemical name, concentration of active ingredient
and rate) on (insert date of application)”

Note: to be applied within 14 days prior to arrival in Western Australia

A pre-shipment treatment program approved by the Director General of the Department of
Agriculture and Food, Western Australia (DAFWA) as determined by:


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     •    Treated with a mixture containing a chemical approved by DAFWA for the quarantine
          control of mango scab and
     •    Treatment details to be provided in the disinfection treatment section of the certificate.

          Note: A mixture of Mancozeb (800g/kg) plus Flusilazole (200g/kg) as per permit 4416
          has been approved.
OR
Option 5: Growth in Post Entry Quarantine

Growth in Post Entry Quarantine requires prior approval by the Director General of the
Department of Agriculture and Food, Western Australia (DAFWA) and may require:
     •    Growth under forced conditions in a post entry quarantine glasshouse facility for a
          period of 9 months,
     •    Plants may be released from quarantine following the 9 month period if found free from
          mango scab by the quarantine plant pathologist.
     •    Should mango scab be detected whilst the plants are undergoing post entry quarantine
          the plants may be re-exported or destroyed as approved by an inspector or treated in a
          manner approved by the quarantine plant pathologist.
General requirements
(Fruit and nursery stock)

Western Australia’s border biosecurity legislation is being updated and incorporated into a new
Act titled the Biosecurity and Agriculture Management Act (2007). The following general
requirements will be required under the Biosecurity and Agriculture Management Act (2007)
upon enactment. Other State quarantine authorities have been advised of these intended
changes in a letter from the Director Plant Biosecurity Department of Agriculture and Food
Western Australia, dated 19 July 2007. Until the Biosecurity and Agriculture Management Act
(2007) is implemented it is proposed that these general conditions will apply. It should be
noted that these conditions were considered as part of the standard quarantine practices for
Western Australia in determining the unrestricted risk estimate in the pest risk analysis.

Fruit
(except where otherwise specified in the “Specific Requirements”) –

     1. Must be a permitted plant if propagable (including seed)

     2. Must be packed in clean new packaging and containers and shall have the following
        details printed on an external surface in letters not less than 5mm in height:

          (iii) An approved registration number,

          or

          (iv) The name of the commodity, identified by genus and species. Alternatively the
               name (genus and species) of the commodity can be placed on the Plant Health
               Certificate (PHC) or Plant Health Assurance Certificate (PHAC); and

               The name and address of the property on which the product was grown; and

               The name and address of the packing house at which the product was packed.




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               Note: if the name and address of the property on which the product was grown is
               not provided corrective action will be taken at the level of the pack-house.

     3. Must be free of live non-permitted invertebrates, plant pathogens, plant material,
        seeds, soil and any other non-permitted organisms and prescribed potential carriers
        (i.e. quarantine risk material, QRM) prior to arrival in Western Australia.

     4. Must be presented for inspection, immediately upon entry into the State, for inspection
        by an Inspector, at a prescribed inspection point.

     5. All consignments must be imported into Western Australia in a manner that prevents
        the escape of pests and remain in this state until unloaded for inspection at a premise
        registered by quarantine for this purpose or as directed by an Inspector.

     6. The prescribed inspection points (e.g. checkpoints such as at the South Australia and
        Northern Territory border) may have limited facilities for inspection, cleaning or
        treatment, Consignments may be directed under quarantine security to a quarantine
        registered premise or other destination as directed by an Inspector for inspection,
        cleaning, treatment or other action as determined by an Inspector.

     7. The Director General may approve importation of prescribed potential carriers and
        organisms under conditions other than those specified here provide the Director
        General is satisfied that they can be imported under conditions where the risk can be
        managed. For example, approval may be issued for items to be imported for growth in
        post entry quarantine, experimental purposes, testing, processing or re-export out of
        the State.

Nursery Stock
(except where otherwise specified in the “Specific Requirements”) –

     1. Plants of any kind in pots of more than 20L in size are not permitted entry.

     2. Must be a permitted plant.

     3. Must be packed in clean new packaging and containers and shall have the following
        details printed on an external surface in letters not less than 5mm in height:

          (iii) An approved registration number,

          or

          (iv) The name of the commodity, identified by genus and species. Alternatively the
               name (genus and species) of the commodity can be placed on the Plant Health
               Certificate (PHC) or Plant Health Assurance Certificate (PHAC); and

               The name and address of the property on which the product was grown; and

               The name and address of the packing house at which the product was packed.

               Note: if the name and address of the property on which the product was grown is
               not provided corrective action will be taken at the level of the pack-house.

     4. Must be free of live non-permitted invertebrates, plant pathogens, plant material,
        seeds, soil and any other non-permitted organisms and prescribed potential carriers
        (i.e. quarantine risk material, QRM) prior to arrival in Western Australia.


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     5. Must be presented for inspection, immediately upon entry into the State, for inspection
        by an Inspector, at a prescribed inspection point.

     6. All consignments must be imported into Western Australia in a manner that prevents
        the escape of pests and remain in this state until unloaded for inspection at a premises
        registered by quarantine for this purpose or as directed by an Inspector.

     7. The prescribed inspection points (e.g. checkpoints such as at the South Australia and
        Northern Territory border) may have limited facilities for inspection, cleaning or
        treatment. Consignments may be directed under quarantine security to a registered
        premise or other destination directed by an Inspector for inspection, cleaning,
        treatment or other action as determined by an Inspector.

     8. The Director General may approve importation of prescribed potential carriers and
        organisms under conditions other than those specified here provide the Director
        General is satisfied that they can be imported under conditions where the risk can be
        managed. For example, approval may be issued for items to be imported for growth in
        post entry quarantine, experimental purposes, testing, processing or re-export out of
        the State.

Conclusions
The findings of this final pest risk analysis are based on a comprehensive analysis of available
information.

The Department of Agriculture and Food, Western Australia considers that the measures
proposed in this PRA will provide an appropriate level of protection against mango scab. Other
management measures may be suitable to manage the risk associated with the importation of
mango nursery stock and the Department of Agriculture and Food, Western Australia will
consider any other measures suggested by stakeholders that provide an equivalent level of
phytosanitary protection.

Review of Import Requirements
The trade in mango nursery stock and fruit will be monitored and may be reviewed at the end
of the first season. These measures may be revised should the situation change or new
information becomes available.




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PART FOUR – STAKEHOLDER COMMENTS
Following the release of the draft policy review for consultation, four (4) submissions were
received. One stakeholder had no technical objection/issue with the draft policy review for
mango scab. The Department of Agriculture and Food, Western Australia’s responses to the
points raised in the various stakeholder submissions are provided below.

Biological issues
1) Stakeholder comment: The occurrence of the disease mango scab in NSW is unlikely
because it is a distinctly tropical disease.

Department response: The crop protection compendium (CABI 2006) indicates that mango
scab has been recorded from Australia (Northern Territory, Queensland), Brazil, Canada,
China, Cuba, Dominican Republic, Haiti, India, Jamaica, Kenya, Nepal, Panama, Philippines,
Puerto Rico, Taiwan, United States of America. Mango scab is located in most mango growing
areas. Based upon the available literature there appears to be no evidence to suggest that
mango scab would be more restricted in range than the host. The Department notes that
mango scab has not been recorded from New South Wales.

Quarantine pest status
2) Stakeholder comment: There is a lack of justification that mango scab is a quarantine pest.
We do not agree that Western Australia can declare mango scab a quarantine pest under the
definitions provided in ISPM#1 – Principles of plant quarantine as related to international
trade.

This stakeholder argues that mango scab:-

     a. is very widely distributed within Australia but generally causes insignificant damage to
        mango crops either in this country, or around the world,

     b. occurs infrequently in those areas where it has been recorded,

     c. is effectively controlled by the fungicides commonly and widely used in mango disease
        management systems,

     d. has not been identified as significant in any international trade, and

     e. has none or very little economic consequence in any of the countries or regions where
        it is found around the world.

Department response: The International Standards for Phytosanitary Measures (ISPMs)
defines a quarantine pest as ‘a pest of potential economic importance to the area endangered
thereby and not yet present there, or present but not widely distributed and being officially
controlled’ (FAO 2006). The Department considers that mango scab meets the definition of a
quarantine pest for Western Australia. Following the detection of mango scab by NAQS from
one branch in a neglected non-commercial orchard in an isolated community (170 km south of
Broome) and the subsequent destruction of mango trees from the neglected orchard as a
precautionary measure and the failure to detect mango scab by the Department and NAQS
over a series of surveys including Bidyadanga, Broome and the ORIA, it is believed that
mango scab did not establish in Western Australia. The potential for economic importance has
been indicated in several reports including the National Mango Industry Biosecurity Plan



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(Plant Health Australia 2006) which indicated that the economic impact of mango scab is ‘high’
and reports such as Condé et al. (1997b). Additionally, Biosecurity Australia recognises that
mango scab is a quarantine pest for Western Australia (Biosecurity Australia 2006b).

Specific response to point 2a - in response to the stakeholder comment “is very widely
distributed within Australia but generally causes insignificant damage to mango crops either in
this country, or around the world” the Department acknowledges that mango scab is widely
distributed within Australia; however, as mentioned in the first part of this response mango
scab is considered not to have established in Western Australia. Literature clearly indicates
that this pathogen may have significant impacts (Condé et al. 1997b) and the National Mango
Industry Biosecurity Plan (Plant Health Australia 2006) which indicated that the economic
impact of mango scab is ‘high’. The stakeholder argues that insignificant damage to mango
crops may occur as a result of the application of fungicides specifically targeting mango scab.
FAO (2004b) indicates that the analysis of economic consequences is made using “a
hypothetical situation where a pest is supposed to have been introduced and to be fully
expressing its potential economic consequences (per year) in the PRA area”. Biosecurity
Australia and the Department interpret these criteria as an unabated incursion. However, it is
acknowledged that existing control regimes for similar species may impact on the pests
capacity to fully express economic (which includes environmental) consequences. This has
been considered in the consequence assessment.

Specific response to point 2b – no evidence was provided to substantiate the claim that
mango scab occurs infrequently in those areas where it has been recorded. Additionally, this
point does not have any bearing upon determining whether a pest meets the definition for a
quarantine pest.

Specific response to point 2c - this point does not have any bearing upon determining whether
a pest meets the definition for a quarantine pest.

Specific response to point 2d – this point does not have any bearing upon determining
whether a pest meets the definition for a quarantine pest. However, mango scab has been
identified by other countries as a quarantine pest including New Zealand for mangos from
Australia where mango scab is a regulated pest. Additionally, Biosecurity Australia recognises
mango scab to be a quarantine pest for Western Australia.

Specific response to point 2e – the definition for a quarantine pest stipulates that a pest needs
to have a “potential economic importance to the area endangered”. The potential for economic
importance has been indicated in several reports including the National Mango Industry
Biosecurity Plan (Plant Health Australia 2006) which indicated that the economic impact of
mango scab is ‘high’.

3) Stakeholder comment: One stakeholder does not believe that mango scab is such a
significant disease that it can be categorised as a disease of quarantine significance within
interstate quarantine classification. This stakeholder was also concerned that potential export
markets may be jeopardised by DAWA classing mango scab as a pest of quarantine concern.

Department response: Refer to comments above for point 2. Considering the impact on
potential export markets is a trade issue and is not applicable for consideration in the PRA
process. However, other countries such as New Zealand already consider mango scab to be a
regulated pest of mangos from Australia.




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Determination of consequences
4) Stakeholder comment: One stakeholder believes that the calculations made in Table 1,
pages 17-18 of the draft PRA, are incorrect and that this affects the risk assessment
conclusions derived from these calculations.

     a. Under the direct consequences for plant life or health, this stakeholder considers that
        the rating of “C” (significant at a district level) should be recalculated as “A” (unlikely to
        be discernible). This stakeholder does not believe that the rating should be at the “B”
        rating (minor at the district level). For the following reasons:

          The first statement that “Fruit with disease symptoms are not marketable” is incorrect.
          Information in CABI (2002) reported that “If controlled, mango scab should cause little
          economic damage” and “Scab is considered a very minor disease in Florida and the
          Philippines”. Similarly it is not regarded as important in Florida where sprays are
          applied (Crane and Campbell 1994). These three localities are considerably wetter
          and more conducive for disease expression that the PRA. The disease is easily
          controlled using fungicides when necessary and the quote of “losses as high as 90%”
          (CABI 2002) applied only to one orchard without fungicide control as quoted from the
          initial investigations in Darwin. The “higher impact” in a nursery situation is due to
          overhead watering providing suitable climatic conditions for disease expression (and
          again only in one orchard) as reported in the email to Nicole Burges of 26 November
          2004. From the WA Bulletin 4348, “anthracnose is present in most growing regions of
          WA … but conditions during flowering and fruit development are generally not
          favourable for the disease”. We believe that the same situation will apply to mango
          scab disease. The conclusion drawn “Therefore in an unabated incursion the impact is
          likely to be significant in affected districts” is inaccurate since climatic conditions would
          rarely be conducive for the disease to express itself and now that the symptoms can
          be recognised, it is easily managed with copper based fungicides as is anthracnose

     b. Similarly, in the indirect consequences for eradication, control etc. this stakeholder
        believes that the rating should be reduced from “C” to “A”. Copper sprays used to
        manage the disease during damp weather at flowering do not cause burning on plants.
        As clearly stated in CABI (2002), copper fungicides ”mixed with certain other chemicals
        can cause phytotoxic burning symptoms”. However, mancozeb is effective against
        both anthracnose and mango scab and is recommended in both the WA and the NT
        extension bulletins. The impact of mango scab at district level would not be significant
        for the same reasons as argued in the paragraph above.

     c. This stakeholder also believes that the ratings of “B” for both domestic and
        international trade should be lowered to an “A” because, except for WA, there have
        been no restrictions imposed on these trading situations. WA did not impose internal
        (intra-state) restrictions on mangoes after it became evident that the disease was
        present at Bidyadanga in 2003.

The lowering of the consequence categories to “B” would change the economic assessment of
all pathways from “low” to at least “very low” (rule 10 on page 41). This would change the
“unrestricted risk” assessment for nursery stock on Table 2 (page 19) from “low” to “very low”
for nursery stock and the fruit would remain at a “negligible” risk.

This stakeholder believes that all consequence categories for the PRA should be rated at “A”
levels in Table 1 (pages 17-18) for the reasons presented in the above paragraph. This “all A”
ranking would change the economic assessment of all pathways from “low” to “negligible” (rule
11 on page 41), and the “unrestricted risk” assessment for nursery stock on Table 2 (page 19)
from “low” to “negligible” which corresponds with the “unrestricted risk” assessment for fruit.


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Department response: ISPM 11 stipulates that the analysis of economic consequences is
made using a “hypothetical situation where a pest is supposed to have been introduced and to
be fully expressing its potential economic consequences (per year) in the PRA area.” In
determining the consequences of a pest’s entry, establishment and spread the unabated
scenario is considered. However, it is acknowledged that existing control regimes for similar
species may impact on this expression of consequences.

Specific response to point 4a – The information cited by this stakeholder describes a scenario
where mango scab is controlled. As previously pointed out ISPM 11 considers consequences
in the scenario where the pest is introduced and fully expressing its potential consequences.
The impact of any existing practices, such as the application of sprays for anthracnose upon
mango scab was considered in the PRA when determining economic consequences. In the
unabated scenario under consideration the literature indicates that fruit may be unmarketable
for example the Northern Territory’s Agnote titled mango management – flowering to market
(Poffley et al. 1999). Additionally, the potential for economic importance has been indicated in
several reports including the National Mango Industry Biosecurity Plan (Plant Health Australia
2006) which indicated that the economic impact of mango scab is ‘high’ and reports such as
Condé et al. (1997b). These factors are reflected in the ‘C’ rating allocated to this
consequence criterion. Additionally, this rating is consistent with Biosecurity Australia’s draft
revised import policy for mangos from India.

Specific comments to point 4b – as mentioned previously, the assessment of consequences is
based upon an unabated scenario where the pest is fully expressing its consequences.
Indirect consequences for eradication, control etc refers to indirect pest effects including
changes to producer costs or input demands, including control costs; feasibility and cost of
eradication or containment; capacity to act as a vector for other pests and resources needed
for additional research and advice (Biosecurity Australia 2006a; FAO 2004a) .The justification
for rating this criterion ‘C’ has been modified to better reflect the indirect pest effects.

Specific comments to point 4c – the stakeholder’s statement that no restrictions have been
imposed on domestic or international trade in response to mango scab is incorrect. Mango
scab is considered to be a regulated pest for New Zealand (that is those pests for which
measures and actions would be undertaken if they were intercepted or detected) (MAF
2007).The suitability of intrastate restrictions in the event of an incident is assessed on a case
by case basis. The application of intrastate measures resulting from the report of mango scab
from Bidyadanga was determined to be unnecessary due to the isolation of this remote
community; the detection in a neglected non commercial orchard where as a precautionary
measure all trees where destroyed; and the failure of follow up surveys conducted by the
Department and NAQS to isolate further samples of mango scab. In the event of another
mango scab incident occurring in Western Australia the requirement for intrastate measures
may be considered, bearing in mind the conditions of the incident.

5) Stakeholder comment: as you would be aware, late in 2004 BA released the draft document
mangoes from India; draft revised import policy for stakeholder comment. The DAWA provided
comments on the draft document however no comments were received regarding the
differences in assessments for the indirect consequence eradication control etc for mango
scab.

This stakeholder is of the opinion that assigning the indirect consequence of eradication,
control etc a “significant” consequence rating at the district level is excessive. To be significant
the indirect consequence would need to threaten economic viability through a moderate
increase in mortality/morbidity or a moderate decrease in production not just in mango
production but in all industries in the district. The effect at the district level could be considered
“minor”



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Department response: This stakeholder suggests a novel approach to assess the
consequences across all industries in the area (whether affected by the pest or not) which is
not consistent with the approach taken by Biosecurity Australia in the Guidelines for import risk
analysis (Biosecurity Australia 2001), ISPM 11 or with the SPS agreement. ISPM 11 states
that “Requirements described in this step indicate what information relevant to the pest and its
potential host plants should be assembled, and suggest levels of economic analysis that may
be carried out using that information in order to assess all the effects of the pest…” The SPS
agreement states “Members shall take into account as relevant economic factors; the potential
damage in terms of loss of production or sales in the event of entry, establishment or spread
of a pest or disease; the costs of control or eradication in the territory of the importing
Member; and the relative cost-effectiveness of alternative approaches to limiting risk”.

The indirect consequences of eradication, control etc considers the impact of a pest in terms
of changes to the producer costs or input demands, including control costs;; feasibility and
cost of eradication or containment; capacity to act as a vector for other pests and resources
needed for additional research and advice (Biosecurity Australia 2006a; FAO 2004a). Given
this information the Department fails to see how it could be interpreted that the indirect
consequence of eradication, control etc would apply to all industries in the district. However,
the justification for rating this criterion ‘C’ has been modified to better reflect the indirect pest
effects.

Regional freedom
6) Stakeholder comment: The fact that mango scab has been detected at Bidyadanga within
the last two years invalidates the claim by WA that the disease is exotic to WA.

WA does not provide details on:

     a. How many mango trees were growing in the vicinity of Bidydanga

     b. How many mango trees were in the community

     c. How many were growing under a commercial arrangement

     d. How many of the mango trees were removed

     e. When were these trees removed.

     f.   How many trees remain in the community, or.

     g. Whether there was any movement of mango fruit or planting material from this
        community to any other location.

With regard to the fourth question (d) above, WA has only indicated that ‘the majority’ of trees
had been removed by May 2005, and that a ‘plan to destroy the remaining plants was
developed’. This wording indicates the some trees may still remain on the Bidyadanga
community, and this impression is reinforced by a photograph published on the ABC website
on 1st July 2005 (www.abc.net.au/kimberley/stories/s1405187.htm), which appears to depict a
mango tree behind the Bishop and MLA at Bidyadanga. In the Plant Health Committee (PHC)
26 WA State report dated 01-03 June 2005, there is a statement that “The neglected mango
trees at this site have been pushed over and will be burnt”. There is no indication of the fate
of other “non-neglected” trees. This stakeholder suggests that the removal of all trees
indicates a concern for possible latent infections in the orchard yet the time frame for removal
does not reflect this concern.



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Department response: Following the detection of mango scab by NAQS from one branch in a
neglected non-commercial orchard in an isolated community (170 km south of Broome), the
site has been re-inspected several times by both the Departmental surveillance team and
NAQS staff, mango scab symptoms were not evident and the pathogen was not isolated from
any samples collected from the implicated tree and others in the neglected orchard (Kumar
2006). All trees in the neglected orchard were destroyed and the site monitored a number of
times from the detection to October 2006. One tree which re-sprouted following the
destruction of the neglected orchard has been inspected on a number of occasions.
Symptoms of mango scab have not been detected. As mango scab was detected on one tree
in a neglected non-commercial orchard in an isolate community, it is unlikely that any
movement of mango fruit or planting material from this community occurred. Surveys of other
mango growing areas in Western Australia including Bidyadanga, Broome and the ORIA did
not detect mango scab.

The Department maintains a high level of awareness of this disease and has conducted some
surveys during the time of the year in Western Australia which would be conducive to the
detection of mango scab. The Department considers mango scab to be a quarantine pest and
that mango scab did not establish and spread in Western Australia. The very early detection of
mango scab provides evidence of the value of the NAQS surveys conducted in northern
Australia. Mango scab will be a target for future surveys conducted by the Department and
NAQS in northern Western Australia. The passive surveillance program will continue.

7) Stakeholder comment: Although the detection of the disease in August 2003 is described in
the PRA, WA authorities did not publicise that fact, nor the results of their follow up surveys at
Bidyadanga until June 2005 (DAWA Biosecurity in Agriculture newsletter, June Edition). In
spite of imposing phytosanitary measures on the importation of mango plants and parts of
plants in December 1997, there appears to be no “official” notification of the detection or the
surveys to affected jurisdictions apart from the above and general state reports to members
(no mention at PHC 24 meeting of 02-04 June 2004, but mentioned at PHC 25 of 04-05
November 2004 and PHC 26 of 01-03 June 2005).

Department response: This stakeholder provided this comment as part of a claim that mango
scab is not exotic to Western Australia. The Department does not see how reporting
processes relate to the determination of a quarantine pest or whether a pest is exotic to an
endangered area or not. The use of the term “exotic” disease in the draft PRA has been
removed to better reflect the Department’s intention and to prevent confusion with the term
“exotic” as defined in ISPM 5 which relates to the introduction of biocontrol agents from one
country to another.

Following the detection of mango scab by NAQS from one branch in a neglected non-
commercial orchard in an isolated community (170 km south of Broome), the site has been re-
inspected several times by both the Departmental surveillance team and NAQS staff, mango
scab symptoms were not evident and the pathogen was not isolated from any samples
collected from the implicated tree and others in the neglected orchard (Kumar 2006). Surveys
of other mango growing areas in Western Australia including Bidyadanga, Broome and the
ORIA did not detect mango scab. All trees in the neglected orchard were destroyed and the
site monitored a number of times from the detection to October 2006. Symptoms of mango
scab have not been detected. The Department maintains a high level of awareness of this
disease and has conducted some surveys during the time of the year in Western Australia
which would be conducive to the detection of mango scab. The Department considers mango
scab to be a quarantine pest and that mango scab did not establish and spread in Western
Australia. The very early detection of mango scab provides evidence of the value of the NAQS
surveys conducted in northern Australia and the subsequent incident response actions led to
the successful containment and eradication of mango scab. Mango scab will be a target for



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future surveys conducted by the Department and NAQS in northern Western Australia. The
passive surveillance program will continue. Adequate surveillance and monitoring procedures
are in place to detect mango scab if it re-surfaced in Western Australia.

8) Stakeholder comment: There has been no scientific data provided to the other jurisdictions
to consider and assess eradication of the disease from the PRA. To our knowledge, until the
June 2005 Biosecurity in Agriculture newsletter, WA has never claimed that the disease was
eradicated from Bidyadanga, nor has it requested that eradication be considered by the
jurisdictions trading mangoes to that State.

Department response: Following the detection of mango scab by NAQS from one branch in a
neglected non-commercial orchard in an isolated community (170 km south of Broome), the
site has been re-inspected several times by both the Department and NAQS staff, mango
scab symptoms were not evident and the pathogen was not isolated from any samples
collected from the implicated tree and others in the neglected orchard (Kumar 2006). Surveys
of other mango growing areas in Western Australia including Bidyadanga, Broome and the
ORIA did not detect mango scab. All trees in the neglected orchard were destroyed and the
site monitored a number of times from the detection to October 2006. Symptoms of mango
scab have not been detected. The Department maintains a high level of awareness of this
disease and has conducted some surveys during the time of the year in Western Australia
which would be conducive to the detection of mango scab. The Department considers mango
scab to be a quarantine pest and that mango scab did not establish and spread in Western
Australia. The very early detection of mango scab provides evidence of the value of the NAQS
surveys conducted in northern Australia and the subsequent incident response actions led to
the successful containment and eradication of mango scab. Mango scab will be a target for
future surveys conducted by the Department and NAQS in northern Western Australia. The
passive surveillance program will continue. Adequate surveillance and monitoring procedures
are in place to detect mango scab if it re-surfaced in Western Australia.

9) Stakeholder comment: WA should have determined the pest status of mango scab within
the state as per section 3.1.2 in ISPM 8 and conducted and verified the eradication program
as outlined in ISPM 9. There is no indication in the draft policy review that these procedures
were followed.

Department response: Following the detection of mango scab by NAQS from one branch in a
neglected non-commercial orchard in an isolated community (170 km south of Broome), the
site has been re-inspected several times by both the Department and NAQS staff, mango
scab symptoms were not evident and the pathogen was not isolated from any samples
collected from the implicated tree and others in the neglected orchard (Kumar 2006). Surveys
of other mango growing areas in Western Australia including Bidyadanga, Broome and the
ORIA did not detect mango scab. All trees in the neglected orchard were destroyed and the
site monitored a number of times from the detection to October 2006. Symptoms of mango
scab have not been detected. The Department maintains a high level of awareness of this
disease and has conducted some surveys during the time of the year in Western Australia
which would be conducive to the detection of mango scab. The Department considers mango
scab to be a quarantine pest and that mango scab did not establish and spread in Western
Australia.

It should be noted that ISPM 9 recognises that “in an emergency situation, the benefits of
speed of action in preventing spread may outweigh the benefits normally achieved through a
more structured approach”

10)    Stakeholder comment: This stakeholder also considers that the surveillance conducted
around Bidyadanga and in other mango plantations around WA was not conducted at to an



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intensity level or at a time period that would provide an optional chance of detecting the
disease.

Department response: Aside from NAQS surveys the Department has conducted three follow
up surveys after the detection of mango scab from one branch from a neglected tree in the
isolated Bidyadanga community. Prior to the destruction of the mango trees in the neglected
orchard all trees were surveyed, mango scab was not detected. Mango scab was not detected
on subsequent surveys conducted by NAQS or the Department. The Department maintains a
high level of awareness of this disease and has conducted some surveys during the time of
the year in Western Australia which would be conducive to the detection of mango scab. The
Department considers mango scab to be a quarantine pest and that mango scab did not
establish and spread in Western Australia. The very early detection of mango scab provides
evidence of the value of the NAQS surveys conducted in northern Australia. Mango scab will
be a target for future surveys conducted by the Department and NAQS in northern Western
Australia. The passive surveillance program will continue.

11)     Stakeholder comment: There is no mention of WA conducting surveillance on mango
scab in the most recent update (September 2005) of the National Surveillance Database
which is being developed by DAFF, and which was circulated to surveillance coordinators in
each jurisdiction on 22 September 2005. This database was intended to identify all plant
health surveillance activities undertaken by all jurisdictions around Australia.

Department response: The Department does not see how this reporting process is relevant to
the review of the draft mango scab PRA or to the determination of a quarantine pest.
Reporting to the National Surveillance Database is not mandatory and there are many
examples of surveillance activities which are conducted by various jurisdictions which have
not been recorded in this database. However, Western Australia will endeavour in the future to
record more surveillance activities in this database. The Department did provide reports
regarding the mango scab incident to the Plant Health Committee.

12)     Stakeholder comment: The analysis scope in the PRA considers that the movement of
mango (Mangifera indica) plants and parts of plants and fruit from commercial production
orchards and nurseries originating from States and Territories where the pathogen is known to
occur poses a risk. However, the assumption in the PRA, and as stated in the Executive
Summary is that mango scab is ‘Exotic to Western Australia’ ie known not to occur. This
indicates that all the risk to WA emanates from sources external to the PRA. Similarly, the
assumption that the detection of mango scab at Bidydanga was isolated, had never spread
from there and that surveys could verify the eradication or absence from that community or
conclusively exclude the possibility of its presence elsewhere within the PRA are blatantly
untenable. The arguments used to reach these conclusions were based on claims of freedom
because of both active and passive surveillance – but no details are provided on these
surveys. This stakeholder argued that the surveillance in the PRA is unlikely to detect the
presence of mango scab in many mango plantations or backyard trees across the growing
areas of WA.

Department response: The use of the term “exotic” disease in the draft PRA has been
removed to better reflect the Department’s intention and to prevent confusion with the term
“exotic” as defined in ISPM 5 which relates to the introduction of biocontrol agents from one
country to another.

Following the detection of mango scab by NAQS from one branch in a neglected non-
commercial orchard in an isolated community (170 km south of Broome), the site has been re-
inspected several times by both the Department and NAQS staff, mango scab symptoms
were not evident and the pathogen was not isolated from any samples collected from the



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implicated tree and others in the neglected orchard (Kumar 2006). Surveys of other mango
growing areas in Western Australia including Bidyadanga, Broome and the ORIA did not
detect mango scab. All trees in the neglected orchard were destroyed and the site monitored a
number of times from the detection to October 2006. Symptoms of mango scab have not been
detected. The Department maintains a high level of awareness of this disease and has
conducted some surveys during the time of the year in Western Australia which would be
conducive to the detection of mango scab. The Department considers mango scab to be a
quarantine pest and that mango scab did not establish and spread in Western Australia. The
very early detection of mango scab provides evidence of the value of the NAQS surveys
conducted in northern Australia. Mango scab will be a target for future surveys conducted by
the Department and NAQS in northern Western Australia. The passive surveillance program
will continue.

13)     Stakeholder comment: This stakeholder also suggests that although the removal of
trees at Bidyadanga indicates a concern by DAWA for possible latent infections of an “exotic”
disease in the orchard, the lack of urgency of these actions is not reflected in the supposed
significant quarantine status of the organism.

Department response: The Department is satisfied that the action taken was appropriate for
this incident. It should be noted that all trees at Bidyadanga were inspected and found free of
mango scab by both NAQS and DAFWA. However, as a precaution, all the trees in the
neglected orchard were destroyed.

14)     Stakeholder comment: This stakeholder does not believe that the Department of
Agriculture, Western Australia –DAWA- has demonstrated that Western Australia is free of
mango scab. Indeed for many years, planting material was sent from the Northern Territory
and eastern States to WA. Surely mango scab, if present in the eastern States and the NT
would now be present in WA.

Department response: Once the Department became aware of the detection of mango scab in
Australia, the Department implemented risk minimisation measures to reduce the potential for
the disease to enter Western Australia. Mango nursery stock sent to Western Australia is
subjected to various quarantine procedures. Currently the entry of mango plants and parts of
plants (including fruit) from other States and Territories is prohibited unless certified by an
officer from the exporting State or Territory’s Quarantine Authority as:
     •  inspected and found free from the symptoms of mango scab; and
     •  in the case of cuttings - from a parent plant inspected and found free from mango scab
        symptoms; and
     • treated with an approved fungicide (except fruit).
Prior to the implementation of emergency measures, nursery stock and propagative material
was subjected to on-arrival inspection. Any disease symptoms detected would have resulted
in the consignment being re-exported, destroyed or treated.
15)    Stakeholder comment: Can DAWA demonstrate to an internationally recognised
standard that thorough surveys have been implemented over a number of years to
demonstrate that WA is free of mango scab.

Department response: Following the detection of mango scab by NAQS from one branch in a
neglected non-commercial orchard in an isolated community (170 km south of Broome), the
site has been re-inspected several times by both the Department and NAQS staff, mango
scab symptoms were not evident and the pathogen was not isolated from any samples
collected from the implicated tree and others in the neglected orchard (Kumar 2006). Surveys
of other mango growing areas in Western Australia including Bidyadanga, Broome and the



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ORIA did not detect mango scab. All trees in the neglected orchard were destroyed and the
site monitored a number of times from the detection to October 2006. Symptoms of mango
scab have not been detected. The Department maintains a high level of awareness of this
disease and has conducted some surveys during the time of the year in Western Australia
which would be conducive to the detection of mango scab. The Department considers mango
scab to be a quarantine pest and that mango scab did not establish and spread in Western
Australia. The very early detection of mango scab provides evidence of the value of the NAQS
surveys conducted in northern Australia. Mango scab will be a target for future surveys
conducted by the Department and NAQS in northern Western Australia. The passive
surveillance program will continue.

As indicated above surveys conducted by NAQS and the Department support the
Department’s stance that mango scab did not establish in Western Australia. It is common
practice that surveys are not required for pests which are not known to occur in an area. This
is consistent with the approach taken by Biosecurity Australia for international pests.

16)    Stakeholder comment: Also, following the detection of mango scab at Bidyadanga, has
the source of mango scab been ascertained and have all mango trees within this region been
destroyed?

Department response: As with any incursion the source is often very difficult to determine.
Subsequent surveys were conducted in the region and other regions and mango scab was not
identified. As a precaution, all mango trees in the neglected orchard at Bidyadanga have been
destroyed.

17)     Stakeholder comment: Has DAWA implemented long term surveys and testing to
demonstrate freedom of mango scab? As mango scab symptoms may only be evident in
years when climatic conditions are suitable, we believe technically valid surveys should be
conducted over a number of years in all Western Australian mango production regions before
legitimate claims of mango scab freedom could be justified.

Department response: Following the detection of mango scab by NAQS from one branch in a
neglected non-commercial orchard in an isolated community (170 km south of Broome), the
site has been re-inspected several times by both the Department and NAQS staff, mango
scab symptoms were not evident and the pathogen was not isolated from any samples
collected from the implicated tree and others in the neglected orchard (Kumar 2006). Surveys
of other mango growing areas in Western Australia including Bidyadanga, Broome and the
ORIA did not detect mango scab. As a precaution all trees in the neglected orchard were
destroyed and the site monitored a number of times from the detection to October 2006.
Symptoms of mango scab have not been detected. The Department maintains a high level of
awareness of this disease and has conducted some surveys during the time of the year in
Western Australia which would be conducive to the detection of mango scab. The Department
considers mango scab to be a quarantine pest and that mango scab did not establish and
spread in Western Australia. The very early detection of mango scab provides evidence of the
value of the NAQS surveys conducted in northern Australia. Mango scab will be a target for
future surveys conducted by the Department and NAQS in northern Western Australia. The
passive surveillance program will continue.

Selective use of information
18)     Stakeholder comment: This stakeholder believes that there are a number of other
deficiencies in the PRA which arise from misinterpretation and selectivity of information used
or issues that should have been considered but were not. For example, the media release
issued by DAWA on 25 August referred to “the destructive disease mango scab”. Considering



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the negligible economic status that this disease has in the NT and in all other mango growing
areas in Australia, the adjective used is both inappropriate and misleading.

Department response: No examples relevant to the draft PRA were provided by the
stakeholder. The example cited by the stakeholder refers to a media release. Furthermore, the
determination of consequences in Pest Risk Analysis considers the scenario where the pest is
introduced and fully expressing its potential consequences (FAO 2004a), that is an unabated
scenario, the current situation in the Northern Territory and other mango growing areas in
Australia represents the consequences in an abated situation where this pathogen is
controlled. In an unabated situation In the unabated scenario under consideration in the PRA
process the literature indicates that fruit may be unmarketable for example the Northern
Territory’s Agnote titled mango management – flowering to market (Poffley et al. 1999).
Additionally, the potential for economic importance has been indicated in several reports
including the National Mango Industry Biosecurity Plan (Plant Health Australia 2006) which
indicated that the economic impact of mango scab is ‘high’ and reports such as Condé et al.
(1997b).

19)     Stakeholder comment: The expert NT Plant Pathologist in this field corresponded with
the DAWA following a request for information regarding the prevalence of the disease and any
other relevant information. Two examples will demonstrate that information was provided to
the review team but only selectively used in the review.

Distribution of mango scab within Australia, in the email, it was stated that:

“Basically we found that mango scab has spread over much of the mango growing areas in
Australia, via infected scion or bud wood. We found mango scab on scion wood imported
from Ayr, Qld grafted onto rootstock in Darwin. “ and “On the basis of our experience with
mango scab, eg, its long distance spread via infected bud-wood and the requirement for
freedom from fungicides and adequate moisture for it to show symptoms which can be
observed, I expect that its actual distribution in Australia is much more widespread than
indicated here and in published literature. I wouldn’t be surprised if it (mango scab) occurs in
most mango growing areas in Australia, including Gingin in the SW of Western Australia”.

However, in the Pest Data Sheet distribution information (page 14), this information was not
presented, nor was the WA detection even listed. There was establishment of mango scab
within the PRA at Bidyadanga in at last one mango tree for an unknown period of time.

Department response – In response to the first comment regarding the distribution of mango
scab, the pest data sheet provides information on the broad distribution of a pest and in this
case includes the Northern Territory and Queensland where mango scab has been recorded.
The presence and history of mango scab in Western Australia was clearly described in two
other sections of the PRA; however, for clarification the pest data sheet has been updated to
reflect the status of mango scab in Western Australia.

The Department acknowledges the ability of mango scab to be transported over long
distances via nursery stock; hence the implementation of emergency measures following the
identification of mango scab in the Northern Territory. The emergency measures were
implemented and provided restrictions on the importation of mango plants and parts of plants
(including fruit) from other States and Territories, to protect Western Australia from the disease
until the risk was further investigated. The procedure prohibited the entry of mango plants and
parts of plants (including fruit) from other States and Territories unless certified by an office
from the exporting State of Territory’s Quarantine Authority as:
     •    Inspected and found free from the symptoms of mango scab; and



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     •    In the case of cuttings – from a parent plant inspected and found free from mango
          scab symptoms; and
     •    Treated with an approved fungicide (except fruit).
Furthermore, following the detection of mango scab by NAQS from one branch in a neglected
non-commercial orchard in an isolated community (170 km south of Broome), the site has
been re-inspected several times by both the Department and NAQS staff, mango scab
symptoms were not evident and the pathogen was not isolated from any samples collected
from the implicated tree and others in the neglected orchard (Kumar 2006). Surveys of other
mango growing areas in Western Australia including Bidyadanga, Broome and the ORIA did
not detect mango scab. All trees in the neglected orchard were destroyed and the site
monitored a number of times from the detection to October 2006. Symptoms of mango scab
have not been detected. The Department maintains a high level of awareness of this disease
and has conducted some surveys during the time of the year in Western Australia which would
be conducive to the detection of mango scab. The Department considers mango scab to be a
quarantine pest and that mango scab did not establish and spread in Western Australia. The
very early detection of mango scab provides evidence of the value of the NAQS surveys
conducted in northern Australia. Mango scab will be a target for future surveys conducted by
the Department and NAQS in northern Western Australia. The passive surveillance program
will continue.

20)     Stakeholder comment: Distribution of the disease into new areas. The review does
indicate that the probability of disease transfer by the movement of infected plant material is
“almost certain” and that ‘there is no reason to suggest the disease would not spread
efficiently and widely’ should mango scab establish in WA (page 17). However, there is no
mention of the import of such infected material into WA over the years prior to restrictions
being placed in 1997, nor to the possible spread from the known established diseased location
of Bidyadanga to other areas within Western Australia. This is particularly important in light of
the statement that there “are no intrastate restrictions on the movement of nursery stock”
within the PRA (page 17). The italicised quotes in the paragraph above that are concerned
with the distribution of the disease in WA, would strongly suggest that the disease has been
distributed at least partly through the PRA area, but that it is not evident on mango trees.

Department response – prior to implementation of emergency measures in 1997, nursery
stock and propagative material was subjected to on-arrival inspection. Any disease symptoms
detected would have resulted in the consignment being re-exported, destroyed or treated.

The suitability of intrastate restrictions in the event of an incident is assessed on a case by
case basis. The application of intrastate measures resulting from the report of mango scab
from Bidyadanga was determined to be unnecessary due to the isolation of this remote
community; the detection in a neglected non commercial orchard where as a precautionary
measure all trees were destroyed; and the failure of follow up surveys conducted by the
Department and NAQS to isolate further samples of mango scab. In the event of another
mango scab incident occurring in Western Australia the requirement for intrastate measures
may be considered, bearing in mind the conditions of the incident.

21)      The probability of importation in the PRA (page 15) has been determined to be ‘high’
for this pathogen. The infection of trees with mango scab at Bidyadanga was probably from
infected planting material sourced from NT or Queensland. Conde et al. (1999) reported that
in Darwin, “very small scab lesions have been observed on leaves and young stem tissues
and on mangoes grafted with scion tissue from Ayr in Queensland”. The NT has had a long
history of trading mango propagating material with WA during and prior to 1997 when
symptoms of the disease were first observed and thought to be a form of anthracnose
(Colletotrichum gloeosporides). This pathway through infected planting material would have



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been the most likely means of legally spreading the disease into Bidyadanga and other
growing areas in WA.

Department response – Prior to the implementation of emergency measures in 1997 nursery
stock and propagative material was subjected to on-arrival inspection. Any disease symptoms
detected would have resulted in the consignment being re-exported, destroyed or treated.

Survey methodology
22)    Because of the difficulties in recognising the disease, the relatively drier climate of the
PRA which reduces the visible expression of the disease and the masking effects of copper
based fungicidal treatments used against other mango diseases, the claim of freedom for WA
based on the passive surveillance practiced within the PRA cannot be justified.

Department response – The passive surveillance program was used in conjunction with
targeted surveillance conducted by the Department and NAQS. It is a good indication of the
efficacy of work conducted by NAQS and DAFWA that inspectors were able to locate the only
infected twig in the infected orchard. For a disease that has never established in Western
Australia, DAFWA believes that current integrated surveillance methodology used should
detect the disease in Western Australia if it were more widely distributed.

23)     In the NT, symptoms of mango scab were first observed and reported during the early
1990’s. These occurrences were linked to periods of fogs, heavy dews or rain during the mid
“dry” season when fruit were less than about 45 days post-flowering and set. These
conditions do not occur each year and initially the symptoms were thought to be a form of
anthracnose (Colletotrichum gloeosporides) which was known to occur in Queensland.
Mango scab was misidentified as anthracnose by Lim (1985) in his book on diseases and
disorders of mango in Malaysia. In an email to the review team (dated 23 June 2004), Mr
Conde referred to (and then forwarded) a Conference Proceedings paper (Conde et al. 1999)
that explained how difficult mango scab symptoms were to recognise and the difficulties of
isolating and identifying the causal organism. There is no indication in the PRA that WA plant
pathologists have undertaken the rigorous inspection and laboratory techniques necessary to
detect the disease within their state.

Department response – The Department acknowledges that the identification of mango scab
may be tricky in the field; consequently both the Department and NAQS collected and
submitted suspect samples from surveys and any samples submitted as a result of the
Department’s passive surveillance program for laboratory testing. DAFWA regularly uses the
skills of national diagnostic experts where ever necessary.

24)     Western Australian surveillance would not necessarily indicate the presence of this
disease unless suitable climate conditions existed. The WA Bulletin 4348 states that
“conditions…(in 3 areas) are generally not favourable for (anthracnose)”. A similar situation
would occur for mango scab and the NT provided information to WA (email dated 26/11/2004
entitled: Mango scab information) stating that the disease was ‘extremely hard to detect,
infections wont be apparent unless climatic conditions (moisture) was suitable to allow
infections to develop.’ These conditions would rarely occur within the PRA. In the NT, the
disease has not been detected in orchards south of Adelaide River (about 13.3 °S). This is
further north than the northernmost grown mangoes in Western Australia at Kalumburu (about
14.1 °S) and climatic conditions generally become drier as latitudes and the distance from the
coastal influences increase.

Department response – This stakeholder appears to have misquoted the email the phrase
“extremely hard to detect, infections wont be apparent unless climatic conditions (moisture)
was suitable to allow infections to develop” does not appear in the email referred to.


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Furthermore, the expert cited in the email expressed an opinion that “I wouldn’t be surprised if
it [mango scab] occurs in most major mango growing areas in Australia…” This expert’s
opinion that mango scab can occur in most major mango growing areas in Australia supports
the argument that there is no evidence in the literature that mango scab would have a more
restricted distribution than the host plants. This appears to contradict the second part of this
stakeholder’s comment. .However, the Department acknowledges that the identification of
mango scab may be tricky in the field; consequently both the Department and NAQS collected
and submitted suspect samples from surveys and any samples submitted as a result of the
Department’s passive surveillance program for laboratory testing. Additionally, the Department
has conducted surveys during a time of the year in Western Australia which would be more
conducive to the detection of mango scab. Mango scab will be a target for future surveys
conducted by the Department and NAQS in northern Western Australia. The passive
surveillance program will continue.

25)     Symptoms of mango scab are extremely diverse, but only young tissue is susceptible
to infection and the development of symptoms is dependent on the availability of free water at
that time (CABI 2002). If the mango scab symptoms were exhibited under the rare occasions
when climatic conditions and moisture were favourable within the PRA, it is likely that they
would be confused and even identified as anthracnose or other causal agents (CABI 2002),
since that scenario had occurred in Queensland and Malaysia. It is virtually impossible to
isolate the fungus from older tissue (CABI 2002).

Department response – Whilst identification of mango scab reliant only upon physical
symptoms may be difficult the Department and NAQS have sent suspect samples to interstate
experts for identification. Furthermore, the mango scab sample submitted from Bidyadanga
was isolated from older plant tissue. It should be noted, as pointed out previously by this
stakeholder, that conditions in “(in 3 areas) [of Western Australia] are generally not favourable
for (anthracnose)”. As such copper sprays are unlikely to be used therefore mango scab
suppression of symptoms is not likely to occur and it is very unlikely that copper sprays would
not be used in neglected orchard or wild plants, secondly it is unlikely that anthracnose would
be present and therefore it is easier to eliminate anthracnose as the causal agent of any
symptoms observed in surveys.

26)     Where copper fungicides are used against flowering anthracnose, mango scab may be
undetectable (CABI 2002). Protective measures imposed by WA commenced in 1997 and
involved inspections for scab symptoms (which we now recognise as very difficult except
under suitable climatic conditions) and an approved treatment (which we now recognise as
masking symptoms). In the November 2004 email, Mr Conde indicated to WA that copper
sprays will suppress, rather than control mango scab. Since copper sprays may ‘mask’ the
scab symptoms, surveillance as detailed in the Executive Summary (page 7-8) Section 4(c) for
the disease on ‘mango vegetative propagating material’ would be ineffective in detecting the
disease.

Department response – Earlier in this stakeholders response to the PRA they state that
mango scab “is effectively controlled by the fungicides commonly and widely used in mango
disease management systems” and that “…now that the symptoms can be recognised, it is
easily managed with copper based fungicides…” these statements appear to contradict the
argument presented by the same stakeholder that “that copper sprays will suppress, rather
than control mango scab. Since copper sprays may ‘mask’ the scab symptoms…”

However, the draft PRA recommended modification to the conditions developed for mango
scab in the alternative procedures implemented following the identification of mango scab in
eastern Australia. These changes include the use of mancozeb and flusilazole or other
proposed treatments which will be considered on request and demonstration of efficacy.



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27)     Again, there is no indication that WA regulatory authorities have undertaken the
required surveillance at the times most suitable for symptom expression to clearly indicate that
the PRA can be declared free of the disease. Similarly, there is no indication that either the
active or passive surveillance that WA has undertaken in the PRA is to the same intensity and
frequency as that suggested to be carried out by its trading partners in order to gain access for
mango fruit and vegetative material to the WA market.

Department response – It has been acknowledged by this stakeholder that mango scab is
very widely distributed in Australia; however, the situation in Western Australia is very different.
As indicated previously mango scab is considered to be a quarantine pest and that it did not
establish in Western Australia. The situation in Western Australia is vastly different to the
situation in other Australian States and Territories where mango scab is present and widely
distributed. Consequently, the appropriate requirements which may include surveillance
methodology are justifiably different.

28)    There was also no suggestion that any sampling was conducted in the field to check
potential disease symptoms that could be confused with anthracnose, a disease that is
present within the PRA. Survey results would understandably return negative results, even in
the orchard at Bidyadanga from where one infected mango tree was detected by a NAQS
pathologist during a survey if such samples were not taken and plated for laboratory
diagnosis.

Department response – Suspect samples collected by the Department and NAQS were sent
for laboratory diagnosis. The expertise of Dr Shivas from Queensland Department of Primary
Industries and Fisheries has been regularly sought.

29)    This stakeholder understands the symptoms of mango scab are difficult to identify and
may not be evident in many commercial orchards due to the fungicide management programs
already in place. We would request that DAWA provide evidence of their intensive survey
regime and verify that Western Australia does not have mango scab.

Department response – Following the detection of mango scab by NAQS from one branch in a
neglected non-commercial orchard in an isolated community (170 km south of Broome), the
site has been re-inspected several times by both the Department and NAQS staff, mango
scab symptoms were not evident and the pathogen was not isolated from any samples
collected from the implicated tree and others in the neglected orchard (Kumar 2006). Surveys
of other mango growing areas in Western Australia including Bidyadanga, Broome and the
ORIA did not detect mango scab. All trees in the neglected orchard were destroyed and the
site monitored a number of times from the detection to October 2006. Symptoms of mango
scab have not been detected. The Department maintains a high level of awareness of this
disease and has conducted some surveys during the time of the year in Western Australia
which would be conducive to the detection of mango scab. The Department considers mango
scab to be a quarantine pest and that mango scab did not establish and spread in Western
Australia. The very early detection of mango scab provides evidence of the value of the NAQS
surveys conducted in northern Australia. Mango scab will be a target for future surveys
conducted by the Department and NAQS in northern Western Australia. The passive
surveillance program will continue.

Import conditions
30)     This stakeholder is concerned over the proposed amendments to the quarantine
protocol for the movement of mangoes into Western Australia. This stakeholder does not
believe the proposed protocol is in the best interest of the Australian industry and that it
creates a negative impression internationally at a time when the industry is seeking to expand
its export markets


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Department response: The Department notes the stakeholders concern. However, determining
the impact on potential export markets is a trade issue and is not applicable for consideration
in the PRA process. It should be noted that other countries such as New Zealand already
consider mango scab to be a regulated pest of mangos from Australia.

Mango Fruit
31)      The draft review does not propose any risk management measures for mango scab on
the fruit pathway but does propose a certification system and verification of mango scab
freedom by inspection on arrival. This stakeholder argues against the imposition of any
certification system for mango scab on fruit destined for WA.

Department response: The standard quarantine procedures including 600-unit inspection on
arrival and other operational procedures were considered in the evaluation of the unrestricted
risk. This is consistent to the Biosecurity Australia approach where phytosanitary procedures
including verification procedures are applied to all pests irrespective of their assessed risk.
However, to reduce ambiguity and to facilitate transfer of the import conditions to the new
Biosecurity and Agriculture Management Act 2007 part three of the final document has been
modified to provide a clear distinction between phytosanitary measures and general
conditions.

32)     The draft document proposes the application of phytosanitary regulations to the
movement of mango fruit into Western Australia even though the results of the pest risk
analysis rate the unrestricted risk of the entry, establishment and spread of mango scab on
this pathway as “negligible”. The draft document proposes that the following phytosanitary
regulations should be applied to mango fruit moving into Western Australia:

               a. Inspection and registration of the exporting property with the Quarantine
                  Authority of the export Territory;

               b. Packing house registration with the quarantine authority of the exporting
                  Territory;

               c. Each consignment accompanied with a interstate plant health certificate; and

               d. Inspection of consignments on arrival in Western Australia

Department response: The proposed phytosanitary procedures are those that are considered
in the evaluation of the unrestricted risk and so are not additional. This is consistent to the
Biosecurity Australia approach where phytosanitary procedures including verification
procedures are applied to all pests irrespective of their assessed risk. However, to reduce
ambiguity and to facilitate transfer of import conditions to the new Biosecurity and Agriculture
Management Act 2007 part three of the final document has been modified to provide a clear
distinction between phytosanitary measures and general conditions.

33)       The South Koreans have undertaken a pest risk analysis on the pathway of mango
scab moving with fruit. The outcome of the assessment, as reflected in the import conditions
proposed by the South Koreans, highlight that even though the South Koreans consider
mango scab a quarantine pest there is a very low probability that mango scab will move with
fruit in international trade and therefore the South Koreans require no phytosanitary measures
for mango scab. Additionally, the New Zealand Ministry of Agriculture and Forestry has also
conducted an assessment with the same outcome.

Department response: This is consistent with the Department’s findings for the movement of
mango fruit into Western Australia from commercial production orchards, where the


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unrestricted risk for mango fruit was determined to be negligible. The certification and
verification procedures are consistent with the Biosecurity Australia approach where
phytosanitary procedures including verification procedures are applied to all pests irrespective
of their assessed risk. However, to reduce ambiguity and to facilitate transfer of import
conditions to the new Biosecurity and Agriculture Management Act 2007 part three of the final
document has been modified to provide a clear distinction between phytosanitary measures
and general conditions.

34)     The application of phytosanitary regulation on the movement of mango fruit
domestically may result in importing countries applying similar, technically unjustified,
phytosanitary regulations to Australian exporters. This would ultimately have a detrimental
effect on all Australian exporters of mango fruit.

Department response: The Department has not applied additional phytosanitary measures on
the movement of mango fruit into Western Australia. The certification and verification
procedures are consistent with the Biosecurity Australia approach where phytosanitary
procedures including verification procedures are applied to all pests irrespective of their
assessed risk. However, to reduce ambiguity and to facilitate transfer of import conditions to
the new Biosecurity and Agriculture Management Act 2007 part three of the final document
has been modified to provide a clear distinction between phytosanitary measures and general
conditions.

Mango nursery stock, vegetative propagating or other mango plant material other
than tissue culture, seed and fruit.
35)     WA imposed conditions relating to mango scab on the entry of mango plants and parts
of plants (except seed) in 1997. Entry was restricted to certified product that had been
inspected and found free of mango scab symptoms and additionally treated with an approved
fungicide. Cuttings were to be sourced from a parent tree inspected and found free of mango
scab symptoms.

In the NT, mango scab disease has not been detected in orchards south of Adelaide River
where climatic conditions are generally drier than further north. There are only a few nurseries
which are likely to attempt to become accredited to supply mango planting material to WA and
these would be in the Katherine region.

Department response: Noted.

Consultation
36)     This stakeholder is also concerned that DAWA has apparently failed to consult with the
Australian mango industry nor apparently with Federal and State agriculture and primary
industry departments in developing the draft policy and has relied on word of mouth to seek
comment and input from sources external to Western Australia.

Department response: The draft pest risk analysis was forwarded to all known stakeholders,
members of the Domestic Quarantine and Market Access Working Group, AQIS and
Biosecurity Australia. The Department understood that it was normal practise that information
was sent to DQMAWG members for dissemination to their industry as this was the process
Western Australia had been following for many years. Once it became apparent that this
established process had not worked in this case extensions were granted to stakeholders at
their request. Stakeholders responding to the draft PRA have been added to the mango
stakeholder contact list. .




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37)     This stakeholder is seriously concerned that the draft policy review has not been
distributed widely enough to industry. It is disappointing that the review does not follow
acceptable protocols in providing extensive industry stakeholder consultation. We would
request that the draft policy review be recirculated throughout Australia and that all industry
stakeholders have an opportunity to comment.

Department response: The draft pest risk analysis was forwarded to all known stakeholders,
members of the Domestic Quarantine and Market Access Working Group, AQIS and
Biosecurity Australia. The Department understood that it was normal practise that information
was sent to DQMAWG members for dissemination to their industry as this was the process
Western Australia had been following for many years. However, due to the confusion
experienced at the time stakeholders requesting an extension to the consultation period were
accommodated. Once it became apparent that this established process had not worked in this
case extensions were granted to stakeholders at their request. Responding stakeholders have
been added to the mango stakeholder list.

38)     We would suggest the relevant industry organisations are included in your initial
distribution list for future reviews since there is a requirement for wide consultation on Import
Risk Analysis issues under the World Trading Organisation’s codified arrangements and for
courtesy and consistency, similar arrangements should be apply within Australia.

Department response: The draft pest risk analysis was forwarded to all known stakeholders,
members of the Domestic Quarantine and Market Access Working Group, AQIS and
Biosecurity Australia. The Department understood that it was normal practise that information
was sent to DQMAWG members for dissemination to their industry and was the process
Western Australia had been following for many years. Once it became apparent that this
established process had not worked in this case extensions were granted to stakeholders at
their request. Responding stakeholders have been added to the mango stakeholder list.


VARIATIONS TO THE DRAFT POLICY REVIEW
     1. Modifications required in relation to the Biosecurity and Agriculture Management Act
        2007 and regulations in development (BAMA) upon implementation, have been
        included through out the policy review. These modifications do not change the intent of
        the draft policy review.

     2. Title change to “A Pest Risk Analysis for the risk posed by Mango Scab (Elsinoë
        mangiferae) associated with the pathways of mango fruit and nursery stock imported
        into Western Australia”. The title was modified to reflect the definition of nursery stock.

     3. Addition of the final policy review recommendation.

     4. The policy review has been modified to reflect the inclusion of additional survey
        information and provide clarity of the pathways under consideration. Some changes to
        phrasing has occurred to reflect the latest policy review template.

     5. Scope has been modified to clarify the pathways under consideration and to take into
        account terminology changes required under BAMA, specifically the adoption of the
        term ‘nursery stock’ as opposed to ‘plants and parts of plants’ and changed definition of
        ‘fruit’. This nomenclature has been used throughout the policy review.

     6. Pest Data Sheet Australian distribution section has been modified to clarify the status
        of mango scab in Western Australia.



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     7. Additional information has been added to the indirect consequences for eradication
        and control to improve clarity. The rating has not been modified.

     8. Pest risk management section formatting has been modified in preparation for the
        implementation of BAMA and to make the distinction between specific measures for
        mango scab from general requirements for entry into Western Australia clearer.

     9. Formatting changes have been made to available phytosanitary measures in
        preparation for the implementation of BAMA. This section has been condensed to
        reduce repetition. There has been a modification to the option for pre-shipment
        inspection and fungicide treatment to reflect one of the options available under the
        general requirements for the importation of nursery stock into Western Australia.

     10. The Department response to stakeholder comments has been included.




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REFERENCES
ABS (2002). AGSTATS Database. Australian Bureau of Statistics, Australian Government
Publishing Service, Canberra.
Alcorn, J.L., Grice, K.R.E. and Peterson, R.A. (1999). Mango scab in Australia caused by
Denticularia mangiferae (Bitanc. & Jenkins) comb.nov. Australasian Plant Pathology, 28: 115-
119.
Australian Bureau of Statistics and Department of Agriculture and Food, W.A. (2007). Agrifood
Infonet. Accessed: 7 March 2007. http://www.agric.wa.gov.au/pls/portal30/url/page/amc_home
Biosecurity Australia (2001). Guidelines for Import Risk Analysis. September 2001. Biosecurity
Australia (BA). Department of Agriculture, Fisheries and Forestry, Australia.
Biosecurity Australia (2005). Biosecurity Australia’s Response to Stakeholder Comments on
the Draft Extension of Existing Policy Report for Sweet Oranges from Italy. Biosecurity
Australia (BA). Department of Agriculture, Fisheries and Forestry, Australian Government, pp.
46.
Biosecurity Australia (2006a). Final Import Risk Analysis Report for Apples from New Zealand
Part B. Commonwealth of Australia, pp. 388.
Biosecurity Australia (2006b). Policy for the Importation of Fresh Mangoes (Mangifera indica
L.) from Taiwan. Commonwealth of Australia, pp. 210.
CABI (2003). Crop Protection Compendium. CAB International, Wallingford, UK. Accessed:
2004. http://www.cabicompendium.org/CABI/start.asp
CABI (2006). Crop Protection Compendium. CAB International, Wallingford, UK. Accessed:
2006. http://www.cabicompendium.org/CABI/start.asp
Condé, B.D., Pitkethley, R.N., Smith, E.S.C. and Kulkarni, V.J. (1997b). Mango scab and its
control. Agnote 709. Northern Territory of Australia.
Condé, B.D., Pitkethley, R.N., Smith, E.S.C., Kulkarni, V.J., Thiagalingam, K. and Ulyatt, M.L.
(1997a). Identification of mango scab caused by Elsinoe mangiferae in Australia. Australasian
Plant Pathology, 26: 131.
DAFWA (2007). Western Australia's agri-food, fibre and fisheries industries 2007: market
information for investors, traders and businesses Bulletin 4702. Department of Agriculture and
Food, Western Australia, pp. 120.
http://www.agric.wa.gov.au/pls/portal30/docs/FOLDER/IKMP/AMT/AGB/BULLETIN2005_WAA
FFI.HTM.
FAO (1995). International Standards for Phytosanitary Measures - Requirements for the
Establishment of Pest Free Areas. No. 4. Secretariat of the International Plant Protection
Convention, Food and Agriculture Organisation of the United Nations.
FAO (1999). International Standards for Phytosanitary Measures - Requirements for the
Establishment of Pest Free Places of Production and Pest Free Production Sites. No. 10.
Secretariat of the International Plant Protection Convention, Food and Agriculture
Organisation of the United Nations.
FAO (2004a). International Standards for Phytosanitary Measures - Pest Risk Analysis for
Quarantine Pests including Analysis of Environmental Risks and Living Modified Organisms.
No. 11 (2004). Secretariat of the International Plant Protection Convention, Food and
Agriculture Organisation of the United Nations.




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FAO (2004b). International Standards for Phytosanitary Measures - Pest Risk Analysis for
Quarantine Pests including Analysis of Environmental Risks and Living Modified Organisms.
No. 11. Secretariat of the International Plant Protection Convention, Food and Agriculture
Organisation of the United Nations.
FAO (2006). International Standards for Phytosanitary Measures - Glossary of Phytosanitary
Terms. No. 5. Secretariat of the International Plant Protection Convention, Food and
Agriculture Organisation of the United Nations.
Kumar, S. (2006). Samples collected from mango trees in Bidgidanga Oct 06. Personal
Communication. 26 October 2006. Email.
MAF (2007). Biosecurity Organisms Register for Imported Commodities. Ministry of Agriculture
and Forestry. Accessed: 7 February 2007. http://www.maf.govt.nz/biosecurity/pests-
diseases/registers-lists/boric/
Plant Health Australia (2006). National mango industry biosecurity plan: final September 2006.
pp. 171.
Ploetz, R.C. (1994). Mango diseases caused by fungi - scab. In: Compendium of tropical fruit
diseases. (Eds. Ploetz, R.C., Zentmyer, G.A., Nishijima, W.T., Rohrbach, K.G. & Ohr, H.D.).
APS Press, Minnesota.
Poffley, M., Owens, G., Kulkarni, V., Smith, E.S.C. and Condé, B. (1999). Agnote 301 - Mango
Management – Flowering to Market. Primary Industry - Northern Territory.
https://www.transact.nt.gov.au/ebiz/dbird/TechPublications.nsf/Main?OpenForm&RefId='EMD
C-6K3AF5'.
ShengQiang, H. and Peikun, Q. (1997). The biological characteristics of Sphaceloma
mangiferae. Acta Phytopthologica Sinca, 27(2): 149-155.
White, K.F. (1997). The mango industry in Western Australia a situational analysis. Agriculture
Western Australia, pp. 55.




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APPENDIX 1: GLOSSARY OF TERMS AND ABBREVIATIONS

                         Appendix 1: Glossary of terms and abbreviations

ALOP                               Appropriate Level of Protection;
                                   the level of protection deemed appropriate for establishing sanitary or
                                   phytosanitary measures to protect human, animal or plant life or
                                   health.

AQIS                               Australian Quarantine and Inspection Service, a section within AFFA.

Area                               An officially defined country, part of a country, or all or parts of several
                                   countries.

Biosecurity Australia              A branch within the Commonwealth Department of Agriculture,
                                   Fisheries and Forestry – Australia responsible for conducting import
                                   risk analyses for plants, animals and their products from overseas.

Buffer zone                        An area in which a specific pest does not occur or occurs at a low
                                   level and is officially controlled, that either encloses or is adjacent to
                                   an infested area, an infested place of production, a pest free area, a
                                   pest free place of production or a pest free production site, and in
                                   which phytosanitary measures are taken to prevent spread of the
                                   pest.

Clearance (of a                    Verification of compliance with phytosanitary regulations.
consignment)

Commodity                          A type of plant, plant product or other regulated article being moved
                                   for trade or other purposes.

Consignment                        A quantity of plants, plant products and/or other regulated articles
                                   being moved from one area to another and covered by a single plant
                                   health certificate. A consignment may be composed of one or more
                                   lots.

Cut flowers/foliage                means any part of a plant without roots, excluding fruit, nursery stock
                                   and seed, not used for human consumption

DAFF                               Commonwealth Department of Agriculture, Fisheries and Forestry –
                                   Australia

DAFWA                              The Department of Agriculture and Food, Government of Western
                                   Australia

Delimiting survey                  A survey conducted to establish the boundaries of an area considered
                                   to be infested by or free from a pest.

Detection survey                   A survey conducted in an area to determine if pests are present.

Distribution                       Distribution of a pest from the imported commodity to the endangered
                                   area, and subsequently be transferred to a suitable host.




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                         Appendix 1: Glossary of terms and abbreviations

Distribution potential             The probability that the pest will be distributed (as a result of the
                                   processing, sale or disposal of the commodity) to the endangered
                                   area, and subsequently be transferred to a suitable host.

Eastern Australia or               All other States and Territories of Australia other than Western
Eastern States                     Australia (New South Wales, Victoria, Queensland, South Australia,
                                   Tasmania and the Northern Territory).

Endangered area                    An area where ecological factors favour the establishment of a pest
                                   whose presence in the area will result in economically important loss.

Entry (of a pest)                  Entry of a pest resulting in its establishment.

Entry potential                    Likelihood of entry of a pest, i.e. the likelihood that a quarantine pest
                                   species will enter the PRA area as a result of trade in a given
                                   commodity, and be distributed in a viable state to the endangered
                                   area where it may establish.

Establishment                      The perpetuation, for the foreseeable future, of a pest within an area
                                   after entry.

Establishment                      Likelihood of the establishment of a pest.
potential

FAO                                Food and Agriculture Organisation of the United Nations.

Field                              A plot of land with defined boundaries within a place of production on
                                   which a commodity is grown.

Free from (of a                    Without pests (or a specific pest) in numbers or quantities that can be
consignment, field or              detected by the application of phytosanitary procedures.
place of production)

Fruit                              Means a part of a plant that could or does contain a seed (including
                                   pseudo fruits or accessory fruits such as strawberry, fig and cashew)
                                   and includes the pedicel (the stalk of a single fruit) and the peduncle
                                   (the stalk of the fruit cluster)

GATT                               General Agreement on Trade and Tariffs.

Harmonisation                      The establishment, recognition and application by different countries
                                   of phytosanitary measures based on common standards.

Host plant                         A plant species capable of sustaining spiraling whitefly and includes
                                   but is not limited to nursery stock and parts of plants.

Importation (of a                  Movement of a pest into an area where it is not yet present, or
pest)                              present but not widely distributed and being officially controlled.

Importation potential              The probability that a pest will enter the PRA area when a given
                                   commodity is imported



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                         Appendix 1: Glossary of terms and abbreviations

IPHC                               Interstate Plant Health Certificate;
                                   a document attesting to the health status of plants and plant products
                                   for interstate trade, analogous to the international phytosanitary
                                   certificate.

IPHRWG                             Interstate Plant Health Regulatory Working Group; a working group
                                   under the Standing Committee on Agriculture and Resource
                                   Management’s (SCARM) Plant Health Committee.

IPM                                Integrated pest management

IPPC                               International Plant Protection Convention.

IRA                                Import Risk Analysis;
                                   the process through which quarantine policy is developed or
                                   reviewed, incorporating pest risk assessment, pest risk management
                                   and risk communication.

ISPM                               International Standards for Phytosanitary Measures.

Leafy Vegetables                   Means all leafy parts of plants eaten as food by humans, whole or in
                                   part.

Lot                                A number of units of a single commodity, identifiable by its
                                   homogeneity of composition, origin, etc., forming part of a
                                   consignment.

Mango scab                         Elsinoë mangiferae Bitancourt & Jenkins

Monitoring survey                  An ongoing survey to verify the characteristics of a pest population.

MOU                                Memorandum of Understanding on Animal and Plant Quarantine
                                   Measures (MOU) between the Commonwealth and States/Territories
                                   signed in December 1995.

National Plant                     Official service established by a government of a country to discharge
Protection                         the functions specified by the IPPC (AFFA is Australia’s NPPO).
Organisation (NPPO)

Nursery stock                      means any potted or bare rooted plant or bulb and any cuttings or any
                                   above or below ground part used for vegetative propagation, but does
                                   not include plant tissue culture or seed.

Official                           Established, authorised or performed by a National Plant Protection
                                   Organisation.

Parts of plant                     Includes any detached above ground parts of host plants of spiraling
                                   whitefly including fruit, cut flowers/foliage and including leafy
                                   vegetables for human consumption.

Pathway                            Any means that allows the entry or spread of a pest.



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                         Appendix 1: Glossary of terms and abbreviations

Pest                               Any species, strain or biotype of plant or animal, or any pathogenic
                                   agent, injurious to plants or plant products.

Pest free area                     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.

Pest free place of                 Place of production in which a specific pest does not occur as
production                         demonstrated by scientific evidence and in which, where appropriate,
                                   this condition is being officially maintained for a defined period.

Pest free production               A defined portion of a place of production in which a specific pest
site                               does not occur as demonstrated by scientific evidence and in which,
                                   where appropriate, this condition is being officially maintained for a
                                   defined period, and that is managed as a separate unit in the same
                                   way as a pest free place of production.

Pest of quarantine                 Any species, strain or biotype of plant or animal, or any other
concern                            biological agent that will or could cause significant damage to human
                                   beings, animals, plants, other aspects of the environment or
                                   economic activities. A “quarantine pest” (as defined by the IPPC) is a
                                   group of organisms within “pests of quarantine concern” that are
                                   injurious to plants or plant products.

Pest risk analysis                 Pest risk assessment and pest risk management.
(PRA)

Pest risk assessment               Determination of whether a pest is a quarantine pest and evaluation
                                   of its introduction potential.

Pest risk                          The processes by which information and opinions regarding risks are
communication                      gathered from potentially affected and interested parties prior to and
                                   during a risk assessment and the process by which the results of the
                                   risk assessment and proposed risk management measures are
                                   communicated to the decision-makers and interested parties.

Pest risk                          The decision making process of reducing the risk of introduction of a
management                         quarantine pest.

Phytosanitary                      Any legislation, regulation or official procedure having the purpose to
measure                            prevent the introduction and/or spread of quarantine pests.

Phytosanitary                      Official rule to prevent the introduction and/or spread of quarantine
regulation                         pests, by regulating the production, movement or existence of
                                   commodities or other articles, or the normal activity of persons, and
                                   by establishing schemes for phytosanitary certification.

PIRSA                              Primary Industries and Resources South Australia.

Place of production                Any premises or collection of fields operated as a single production or
                                   farming unit. This may include production sites, which are separately



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                         Appendix 1: Glossary of terms and abbreviations
                                   managed for phytosanitary purposes.

PRA                                Pest risk analysis - Pest risk assessment and pest risk management.

PRA area                           An area in relation to which a pest risk analysis is conducted.

Production site                    A defined portion of a place of production

QDPIF                              Queensland Department of Primary Industries and Fisheries,
                                   Government of Queensland

Quarantine pest                    A pest of potential economic importance to the area endangered
                                   thereby and not yet present there, or present but not widely
                                   distributed and being officially controlled.

Restricted risk                    Restricted risk estimates are derived following that application of
                                   specific phytosanitary measures.

SPRA                               State Pest Risk Analysis; a process for assessing the risk and
                                   determining measures needed for the movement of plants and
                                   animals and their products into and within Western Australia.

Spread                             Expansion of the geographical distribution of a pest within an area.

Spread potential                   Likelihood of the spread of a pest.

SPS Agreement                      An agreement under the WTO on the application of Sanitary and
                                   Phytosanitary Measures.

Survey                             An official procedure conducted over a defined period of time to
                                   determine the characteristics of a pest population or to determine
                                   which species occur in an area.

Unrestricted Risk                  ‘Unrestricted’ risk estimates are those derived:
                                   (a) in the complete absence of risk management;
                                   (b) using only internationally accepted risk management strategies,
                                   or,
                                   (c) with reference to normal standards of practice for the production of
                                   a given plant-derived commodity in the exporting area.

WAQIS                              Western Australian Quarantine and Inspection Service. The group
                                   with the Department of Agriculture and Food providing interstate and
                                   intrastate quarantine operational functions.

WTO                                World Trade Organisation.

Source: (FAO, 2006a); (FAO, 2006b); (FAO, 2006c); (FAO, 2006d); (AFFA, 2000); (AQIS,
1997)




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References

AFFA (2000). Draft Import Risk Analysis on the Importation of Apples (Malus x domestica
      Borkh.) from New Zealand. Agriculture, Fisheries and Forestry - Australia, Biosecurity
      Australia, Canberra. pp.

AQIS (1997). The AQIS Import Risk Analysis Process Handbook. Australian Quarantine and
      Inspection Service. Agriculture, Fisheries and Forestry - Australia. pp.

FAO (2006a). Glossary of Phytosanitary Terms (ISPM 5). IN. International Standards for
      Phytosanitary Measures 1 to 27 (2006 Edition). Secretariat of the International Plant
      Protection Convention, Food and Agriculture Organisation of the United Nations. 59-
      79pp.

FAO (2006b). Guidelines for Pest Risk Analysis (ISPM 2). IN. International Standards for
      Phytosanitary Measures 1 to 27 (2006 Edition). Secretariat of the International Plant
      Protection Convention, Food and Agriculture Organisation of the United Nations. 59-
      79pp.

FAO (2006c). Pest Risk Analysis for Quarantine pests including analysis of Environmental
      Risks and Living Modified Organisms (ISPM 11). IN. International Standards for
      Phytosanitary Measures 1 to 27 (2006 Edition). Secretariat of the International Plant
      Protection Convention, Food and Agriculture Organisation of the United Nations. 129-
      154pp.

FAO (2006d). Requirements for the establishment of Pest Free Places of Production and Pest
      Free Production Sites (ISPM 10). IN. International Standards for Phytosanitary
      Measures 1 to 27 (2006 Edition). Secretariat of the International Plant Protection
      Convention, Food and Agriculture Organisation of the United Nations. 121-127pp.




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APPENDIX 2: MATRIX OF RULES (COMBINATION OF LIKELIHOODS)

Table 1: Matrix of rules (Combination of likelihoods)


                                                                Likelihood 2

                                   Virtually                                                           Extremely
                                                  High          Moderate       Low        Very low                  Negligible
                                   certain                                                                low

               Virtually certain   v. certain

                          High       high         high
Likelihood 1




                     Moderate      moderate     moderate           low

                           Low        low          low             low         v. low

                      Very low      v. low       v. low          v. low       v. low       e. low

                Extremely low       e. low       e. low          e. low       e. low       e. low      negligible

                     Negligible    negligible   negligible      negligible   negligible   negligible   negligible    negligible




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APPENDIX 3: RISK ESTIMATION MATRIX

Table 1: Risk estimation matrix

                              Virtually   Negligible   Very low     Low risk     Moderate     High risk        Extreme
                               certain      risk         risk                      risk                          risk

                                  High    Negligible   Very low     Low risk     Moderate     High risk        Extreme
                                            risk         risk                      risk                          risk
  establishment and spread




                             Moderate     Negligible   Very low     Low risk     Moderate     High risk        Extreme
     Probability of entry,




                                            risk         risk                      risk                          risk

                                  Low     Negligible   Negligible   Very low     Low risk     Moderate         High risk
                                            risk         risk         risk                      risk

                              Very low    Negligible   Negligible   Negligible   Very low     Low risk        Moderate
                                            risk         risk         risk         risk                         risk

                             Extremely    Negligible   Negligible   Negligible   Negligible   Very low         Low risk
                                   low      risk         risk         risk         risk         risk

                             Negligible   Negligible   Negligible   Negligible   Negligible   Negligible       Very low
                                            risk         risk         risk         risk         risk             risk

                                          Negligible   Very low       Low        Moderate       High           Extreme
                                           impact       impact       impact       impact       impact           impact

                                                 Economic consequence of entry, establishment and spread




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Importation into Western Australia of fruit and nursery stock                           Page 60 of 67




APPENDIX 4: METHOD FOR ASSESSING ECONOMIC CONSEQUENCES

In order to estimate the potential economic importance of the pest, information is obtained
from areas where the pest currently occurs. Consideration is given to whether the pest
causes major, minor or no damage; frequently or infrequently. The situation in the PRA area is
then carefully compared with that in the areas where the pest occurs. Case histories
concerning comparable pests can also be considered. Expert judgement is then used to
assess the potential economic consequences should the pest establish and spread in the PRA
area.

Economic assessments carried out for each quarantine pest are based on available
information regarding each of the direct and indirect consequences outlined below. It should
be noted that, in many instances, information regarding the likely consequences of incursions
of the identified quarantine pests is often limited. In addition, it is often the case that the
consequences of a pest in one country or environment are different to those in another. Given
these limitations, the economic assessment should be based on information available for each
identified quarantine pest, or on information obtained for similar pests. In some cases, this
means that a subset of the direct and indirect criteria listed below should be considered in the
assessment.

The direct consequences considered include:

         •    crop losses (yield and grade);
         •    control and surveillance measures; and
         •    environmental effects.
The indirect consequences considered include:

         •    effects on domestic and export markets - this should include a consideration of any
              phytosanitary measures imposed by trading partners in the event of a pest
              incursion;
         •    changes to producer costs or input demands;
         •    changes to domestic or foreign consumer demand for a product resulting from
              quality changes;
         •    environmental or other undesired effects of control measures;
         •    feasibility and cost of eradication or containment;
         •    capacity to act as a vector for other pests;
         •    resources needed for additional research and advice; and
         •    social and other effects.
If the pest has no significant economic consequence in the PRA area then it does not satisfy
the definition of a quarantine pest and does not need to be considered any further.

In assessing the economic consequences the following nomenclature and criteria are used:

The relevant examples of direct and indirect consequences from ISPM 11 (FAO 2004) are
considered for each of the broad groups (as listed above) and estimates of the consequences
are assigned.

The direct and indirect consequences are estimated based on four geographic levels. The
terms ‘local’, ‘district’, ‘regional’ and ‘PRA area’ are defined as:




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Importation into Western Australia of fruit and nursery stock                                               Page 61 of 67



Local:                    An aggregate of households or enterprises — e.g. a rural community, a town or a
                          local government area

District:                 A geographically or geopolitically associated collection of aggregates — a
                          recognised section of a State, such as the Northern Rangelands, Southern
                          Rangelands, Northern Agricultural, Central Agricultural, Southern Agricultural and
                          South-West Agricultural.

Region:                   A geographically or geopolitically associated collection of districts — e.g. Northern,
                          central and Southern regions

PRA area: Western Australia

The consequence is described as ‘unlikely to be discernible’, of ‘minor significance’,
significant’ or ‘highly significant’:

                      •   an ‘unlikely to be discernible’ consequence is not usually distinguishable from
                          normal day-to-day variation in the criterion;
                      •   an consequence of ‘minor significance’ is not expected to threaten economic
                          viability, but would lead to a minor increase in mortality/morbidity or a minor
                          decrease in production. For non-commercial factors, the consequence is not
                          expected to threaten the intrinsic ‘value’ of the criterion — though the value of the
                          criterion would be considered as ‘disturbed’. Effects would generally be reversible;
                      •   a ‘significant’ consequence would threaten economic viability through a moderate
                          increase in mortality/morbidity, or a moderate decrease in production. For non-
                          commercial factors, the intrinsic ‘value’ of the criterion would be considered as
                          significantly diminished or threatened. Effects may not be reversible; and
                      •   a ‘highly significant’ consequence would threaten economic viability through a
                          large increase in mortality/morbidity, or a large decrease in production. For non-
                          commercial factors, the intrinsic ‘value’ of the criterion would be considered as
                          severely or irreversibly damaged.
The values are translated into a qualitative score (A–F) using the schema outlined in Table 1

Table 1: the assessment of local, district, regional and PRA area consequences

                      F    -                    -                        -                    Highly significant

                      E    -                    -                        Highly significant   Significant
  Consequence score




                      D    -                    Highly significant       Significant          Minor

                      C    Highly significant   Significant              Minor                Unlikely to be
                                                                                              discernible

                      B    Significant          Minor                    Unlikely to be       Unlikely to be
                                                                         discernible          discernible

                      A    Minor                Unlikely to be           Unlikely to be       Unlikely to be
                                                discernible              discernible          discernible

                           Local                District                 Regional             PRA area

                                                                 Level



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Importation into Western Australia of fruit and nursery stock                            Page 62 of 67



The overall consequence for each pest was achieved by combining the qualitative scores (A–
F) for each direct and indirect consequence using a series of decision rules. These rules are
mutually exclusive, and were addressed in the order that they appeared in the list — for
example, if the first rule did not apply, the second rule was considered. If the second rule did
not apply, the third rule was considered and so on until one of the rules applied:
     1. Where the consequences of a pest with respect to any direct or indirect criterion is ‘F’,
        the overall consequences are considered to be ‘extreme’.
     2. Where the consequences of a pest with respect to more than one criterion is ‘E’, the
        overall consequences are considered to be ‘extreme’.
     3. Where the consequences of a pest with respect to a single criterion is ‘E’ and the
        consequences of a pest with respect to each remaining criterion is ‘D’, the overall
        consequences are considered to be ‘extreme’.
     4. Where the consequences of a pest with respect to a single criterion is ‘E’ and the
        consequences of a pest with respect to remaining criteria is not unanimously ‘D’, the
        overall consequences are considered to be ‘high’.
     5. Where the consequences of a pest with respect to all criteria is ‘D’, the overall
        consequences are considered to be ‘high’.
     6. Where the consequences of a pest with respect to one or more criteria is ‘D’, the
        overall consequences are considered to be ‘moderate’.
     7. Where the consequences of a pest with respect to all criteria is ‘C’, the overall
        consequences are considered to be ‘moderate’.
     8. Where the consequences of a pest with respect to one or more criteria are considered
        ‘C’, the overall consequences are considered to be ‘low’.
     9. Where the consequences of a pest with respect to all criteria are ‘B’, the overall
        consequences are considered to be ‘low’.
     10. Where the consequences of a pest with respect to one or more criteria are considered
         ‘B’, the overall consequences are considered to be ‘very low’.
     11. Where the consequences of a pest with respect to all criteria is ‘A’, the overall
         consequences are considered to be ‘negligible’.



References

FAO (2004). International Standards for Phytosanitary Measures - Pest Risk Analysis for
Quarantine Pests including Analysis of Environmental Risks and Living Modified Organisms.
No. 11 (2004). Secretariat of the International Plant Protection Convention, Food and
Agriculture Organisation of the United Nations.




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Importation into Western Australia of fruit, nursery stock and propagation material       Page 63 of 67




APPENDIX 5: PRODUCT INSPECTION

Fruit inspection

Inspection is a practical measure for pests that are visible, or which produce visible symptoms
on plants and plant products. To ensure consistency with imports from overseas for similar
pests, inspection of fruit is to be carried out following AQIS fruit inspection guidelines, outlined
in ‘Sampling procedures for non-protocol fresh fruit and vegetables’, otherwise referred to as
the National Sampling Plan. This plan is consistent with internationally accepted procedures
and applies to imports as well as exports (AQIS 2003).

The sampling protocol (Table 1) is designed to detect the presence of any quarantine pest in
the sample beyond a certain level of infestation. The sample rates achieve at a 95%
confidence level that no more than 0.5% of the units (a unit being a single cherry fruit) in the
consignment are infested. This equates to an acceptance level of zero units infested by
quarantine pests in a random sample from homogenous lots in the consignment. To put it
another way, an inspection utilising 600 units is capable of detecting an infestation level of 1
infested unit per 200 units, 95% of the time. This level of confidence depends on each fruit in
the ‘lot’ having about the same likelihood of being infested by a quarantine pest (homogeneity)
and the inspection technique being able to reliably detect all quarantine pests in the sample.

                                           Table 1: Sample sizes for inspection

                                                                        Sample size
                                          Lot size (units)
                                                                      required (units)
                                             1,000-1,600                      450
                                             1,600-4000                       500
                                            4,000-10,000                      550
                                               10,000+                        600

                                        Adapted from(Cannon & Roe 1982).

Note: Sample size has been rounded to the nearest ten for ease of use.

A lot is the quantity of units (single fruit) identifiable by its homogeneity of composition, origin,
etc. A lot may form part of a consignment or comprise the entire consignment (AQIS 2003).
To maintain the confidence level it is important that the sample is taken at random and applied
to every lot in a consignment.

Where a pest of quarantine concern is intercepted in a sample, the lot from which it is drawn
will be rejected and corrective action required, such as treatment, re-export or destruction.

Sequential Sampling

The Department of Agriculture has also investigated methods to reduce the number of
inspections or sample size while still maintaining the effectiveness of quarantine (Vijayan et al.
2003). The method that has been adopted for use in quarantine inspection of some fresh fruit
and vegetables is sequential sampling. This type of sampling allows for a reduced sample
size to be taken based on previous clean inspection history.

This system, provided by (Vijayan et al. 2003), allows for a normal (600-unit) inspection
sample to be split into separate components that are then spread over a range of consecutive
lots. A benefit of this type of sampling is that it reduces the cost of inspection and provides
financial incentive to producers and suppliers of clean produce, free from quarantine pests.


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Importation into Western Australia of fruit, nursery stock and propagation material                        Page 64 of 67



This sampling procedure is an interim arrangement until a further review of the risks and
effectiveness of various measures and sampling procedures can be undertaken and is applied
at the discretion of Plant Biosecurity Program of the Department of Agriculture, Western
Australia.

The sampling and inspection process will follow the following steps.

     1. Inspection of a lot at the 600-unit level. For lots containing 600-units or less all units
        will be inspected;

     2. If free from quarantine pests subsequent lots to be inspected at 200-units irrespective
        of the lot size. For lots of 200-units or less all the units will be inspected;

     3. When a quarantine pest is detected (at either steps 1 or 2) the number of units in the
        sample that are infested by the quarantine pest(s) (called f) will determine the number
        of consecutive lots to be inspected at the normal 600-unit level before reverting back to
        reduced sampling (i.e. 200-units). For example if 4 (f = 4) inspection units (clusters) in
        a lot are infested by a quarantine pest, then subsequent lots from that source will be
        inspected at the 600-unit level until 4 consecutive lots are found free from quarantine
        pests. Future lots from that source will then revert back to reduced sampling of 200-
        units. See example 1.

     4. If further quarantine pests are detected in lots inspected at the higher sampling rate
        (i.e. 600-units) and, the number of units in the sample that are infested by quarantine
        pest(s) (called g) will now determine the number of consecutive lots to be inspected at
        the normal 600-unit level before reverting back to reduced sampling (i.e. 200-units).

          If g is greater than 3 multiplied by f (i.e. g>3f) then the number of consecutive clean
          samples required before returning to step 2 should be increased to the smallest whole
          number greater than or equal to g divided by 3 (i.e. g/3). See example 2.

Table 2: Sequential sampling; example 1

                    Lot Number for                  Number Sampled                    Number of Infested
                       grower A                                                            Units
                              1                              600                              0
                              2                              200                              0
                              3                              200                              0
                              4                              200                              1
                              5                              600                              0
                              6                              200                              0
                              7                              200                              0
                              8                              200                              3
                              9                              600                              0
                             10                              600                              0
                             11                              600                              0
                             12                              200                              0
                             13                              200                              0
                             14                              200                              0

Example 1 shows the change in sample size when reduced inspection is in progress and
infested units are discovered. The initial (lot number 1) 600-unit inspection yields zero


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Draft Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit, nursery stock and propagation material                        Page 65 of 67



infested units. The next lot inspected from that source proceeds to reduced inspection as in
step 2 of the sampling plan. This reduced inspection is carried out until lot number 4 when 1
infested unit ( f = 1 ) is discovered.

Consequently 1 inspection ( f = 1 ) of 600-units must be carried out and found free from
quarantine pests before reverting to reduced sampling. This is seen with lot number 5 where
600-units are inspected and have zero infested units, allowing the move to reduced inspection
for lot number 6. This reduced inspection is carried out as before until one or more infested
unit is found. This occurs with lot number 8 where there are 3 infested units ( f = 3 ).
Consequently three consecutive 600-unit inspections must be carried out, without observing
one infested unit, in order to revert once again to reduced inspection.

Table 3: Sequential sampling; example 2
                    Lot Number for                  Number Sampled                    Number of Infested
                       grower B                                                            Units
                              1                              600                              1
                              2                              600                              1
                              3                              600                              0
                              4                              200                              0
                              5                              200                              0
                              6                              200                              1
                              7                              600                              5
                              8                              600                              0
                              9                              600                              0
                             10                              200                              0
                             11                              200                              0
                             12                              200                              0
                             13                              200                              1
                             14                              600                              0
                             15                              200                              0

Example 2 shows the process in the event of infested units being found when the inspection
process has already switched to the 600-unit inspection. Infested units were found with both
lot numbers 1 and 2. As a result, one clean inspection must be made at the 600-unit level to
enable reduced sampling to be introduced. Lot number 6 uncovers one infected unit at the
200-unit inspection level requiring one clean 600-unit inspection to be carried out to enable
reduced inspection to be reintroduced. Lot number 7 shows that while this 600-unit inspection
is being carried out 5 infested units ( g = 5 ) are detected. Since this number is greater than
 3 f where f = 1 then two consecutive clean inspections need to be carried out at the 600-unit
level before returning to reduced inspection. This is shown with clean inspections with lot
numbers 8 and 9 and reduced inspection reintroduced with lot number 10.




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Draft Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit, nursery stock and propagation material                                Page 66 of 67




Figure 1: Flow Chart to Describe a Unified Inspection Scheme1




                                             Step 1
                                   Inspect a 600 unit
                                        sample

         f>0                                           0                                                     0
      infested                                    infested                                              infested



                                                 Step 2
                                             Set sample
                                                size


                                                       f>0
                                                                                          f consecutive non-infested lots
                                                    infested                                        inspected



                                              Step 3
                                Set sample size to 600
                                        units



                                              infested units
                                                observed




1
    Note: This flow chart does not show the action taken if two or more consecutive infested consignments are observed at step 3



                               PROTECTING AGRICULTURE IS EVERYONE’S BUSINESS
Draft Policy Review: Pest Risk Analysis – Mango Scab
Importation into Western Australia of fruit, nursery stock and propagation material   Page 67 of 67




AQIS (2003). AQIS sampling for fresh fruit and vegetable inspection. Australian Quarantine
and Inspection Service, Australian Government.

Cannon, R.M. and Roe, R.T. (1982). Livestock disease surveys: A field manual for
veterinarians. Australian Bureau of Animal Health, Department of Primary Industry, Canberra.

Vijayan, K., Hazelton, M.L. and Murray, K. (2003). Sampling scheme for incoming
consignments of bananas from the Eastern States. Contract No. AGR061Q-02/03. University
of Western Australia, Statistical Consulting Group.




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