Commodity Inspections 鈥� Hay and Straw - Department of

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Commodity Inspections 鈥� Hay and Straw - Department of Powered By Docstoc
					            Plant Export Operations Branch
                     Plant Export Operations Manual

   Volume 8A: Commodity Inspections – Hay
                 and straw


                                                                    Contents

Introduction............................................................................................................................................3

Legislation...............................................................................................................................................3

Sampling, inspection and export certification of hay and straw .......................................................4

Compound feed ......................................................................................................................................4

ARGT Testing Requirements ...............................................................................................................4

   Background .............................................................................................................................................4

   Sampling methods for ARGT .................................................................................................................5

   Record Keeping.......................................................................................................................................5

   Registered establishments .......................................................................................................................5

   Laboratories.............................................................................................................................................5

   Exporters .................................................................................................................................................6

Hay and Straw Exports - General Requirements ...............................................................................6

   Export Establishment Registration status................................................................................................6

   Preparation for Inspection .......................................................................................................................6
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   In office ...................................................................................................................................................7

   Exporter’s responsibilities.......................................................................................................................7

   On site .....................................................................................................................................................7

   Inspection equipment ..............................................................................................................................8

   Establishment Hygiene............................................................................................................................8

   Hygiene inspection..................................................................................................................................8

   Commodity Inspection Methods .............................................................................................................9

   Inspection Facilities.................................................................................................................................9

   Containers..............................................................................................................................................10

Hay and Straw Exports .......................................................................................................................10

   Preliminary Paperwork – Export Requirements....................................................................................10

   Determination of Inspection Lots..........................................................................................................10

   Sampling and Inspection Techniques....................................................................................................10

   Inspection Tolerances............................................................................................................................10

   Inspection criteria for export hay for all countries other than China ....................................................11

   Inspection criteria for export hay for China ..........................................................................................11

   Completion of Paperwork .....................................................................................................................12

   Document Control .................................................................................................................................13

Audit......................................................................................................................................................13

Hay and Straw Exports – China.........................................................................................................13

   Quality Management System ................................................................................................................13

   Preliminary Paperwork – Export Requirements....................................................................................14

   Export compliant goods ........................................................................................................................14

   Rejection Procedures.............................................................................................................................14

References.............................................................................................................................................15

Attachment1. Checklist of Requirements for Registration of Establishment for Hay and Straw
Export ...................................................................................................................................................16

   Establishments Exporting Hay and Straw to China ..............................................................................18

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Introduction
This volume covers information relating to requirements for the preparation, sampling,
inspection and certification of hay and straw for export. Hay and straw means a pasture or
cereal plant (either whole or after harvesting seed) that is cut and dried. In particular, hay is
from any pasture plant, wheat, oat, barley, rye, or triticale, whereas straw is from a cereal plant
including wheat, oat, barley, rye and triticale but not including straw from rice.
Hay and straw are important export commodities and oaten hay is the largest component of
exported hay. Australia strives towards production of high quality hay to sustain Australia’s
import markets and also to ensure that the exported hay does not pose a threat to animal health.
All export hay must be free from pests, diseases, contaminants, noxious weeds, foreign material
and animal material (carcasses) according to importing countries requirements.
Definitions of terminology used in this volume are located in the Plant Export Operations
Manual Glossary.

Legislation
DAFF Biosecurity regulates hay and straw exports through the Export Control Act, 1982 and
subordinate legislation—Export Control (Prescribed Goods – General) Order 2005; Export
Control (Plants and Plant Products) Order 2011; Export Control (Fees) Orders 2001. Refer to
Volume 2 of this manual for more information on related legislation.

The legislation together with this volume of the Plant Export Operations Manual (PEOM)
outlines the conditions and requirements for the export of prescribed goods. Therefore hay and
straw is prohibited from export unless it has been sampled, inspected and tested according to
procedures approved in this document.

In relation to the above, Section 7 of the Plant Order allows for the delegate of the Secretary of
the Department of Agriculture, Fisheries and Forestry to require specified tests and certificates.
This determination is used to ensure that exports of stock feed including hay and straw do not
pose any animal health threat to live stock.

This volume is to be read in conjunction with:

        The Australian export legislation located on the comlaw website.
        The ‘Standard for Minimising the Risk of Corynetoxin Contamination of Hay’ which
         outlines the methods for sample and test for the presence of Corynetoxin (CT) in hay
         and straw exports located in the Resources tab of the PEOM.
        The relevant work instruction located in the Resources tab of the PEOM. This work
         instruction provides the instructional material on how to conduct sampling, inspection
         and certification of export hay and straw.
        The AQIS Methyl Bromide Fumigation Standard provides in depth detail to assist in
         understanding the fundamental principles of fumigation. An Authorised Officer (AO)
         will need to refer to this document to monitor fumigations if required and observe
         WH&S obligations.

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Note: A Standard specifies materials, methods, processes and practices to ensure that consistent
and acceptable levels of quality, performance, safety and reliability are achieved.

Sampling, inspection and export certification of hay and straw
This section outlines the overarching principles relating to phytosanitary sampling, inspection
and export certification of hay and straw, encompassing:
        Annual ryegrass toxicity (ARGT) testing for corynetoxins
        Export Hay Inspection.

Requirements for preparation, sampling and inspection of hay and straw may differ according
to importing countries requirements.

In summary, all hay and straw for export must meet the following requirements:
        be prepared in a registered export establishment—establishment hygiene requirements
         must be met
        have a valid Notice of intention to export (NOI/RFP)
        be tested for the presence of annual rye grass toxicity (ARGT) and found negative
        be inspected and passed as export compliant

Compound feed
Compound feed is a composite product made of a minimum of 80% hay and/or straw with an
additive to increase protein levels. Additives can include, but are not limited to, pulse and
oilseed (whole, cracked and meal) and mineral supplements. Compound feeds are subject to
ARGT testing and must be sampled and inspected as per hay and straw in accordance with
work instruction HAS3001 ‘Inspection and certification of hay and straw’.

ARGT Testing Requirements

Background

ARGT is caused by toxins produced by the bacterium Rathyibacter toxicus that infect the seed
heads of ryegrass. The bacterium is transferred to ryegrass seed heads by nematodes (Aguina
spp.). The nematode, which only has one lifecycle each year, invades the ryegrass during
winter and produces a gall in spring that replaces a developing seed in the immature seed head.
If the bacterium is present, it quickly multiples during early spring, swamping the nematode
and taking over the gall. After the ryegrass flowers, the bacterium begins to produce a powerful
tunicamycin-like poison toxin called corynetoxin. Toxin production increases rapidly just
before the grass hays-off and persists in dry pasture or hay and if ingested by livestock it causes
annual rye grass toxicity, resulting in death.
All hay intended for export must be tested for ARGT, not just consignments requiring
phytosanitary certification. As a prescribed good under Export legislation, export hay and straw
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must undergo laboratory analysis to test for ARGT contamination. Australia has well
established procedures to ensure examination of field product for the presence of corynetoxin
contamination of all export cereal hay and straw. DAFF Biosecurity has produced a set of
standards for minimising the risk of corynetoxin contamination in export hay and straw. For the
most up to date information on sampling protocols access the “Standard for Minimising the
Risk of Corynetoxin Contamination of Hay and Straw” on the DAFF Biosecurity website.
The Standard allows producers or exporters to test for corynetoxin directly using a test for
corynetoxin or indirectly using a test for R. toxicus. A test for R. toxicus is useful because
samples of hay and straw tested for R. toxicus and found to be negative cannot contain CT.
The test must show negative results for corynetoxin or R. Toxicus before the hay is allowed for
export. Results of these tests must accompany a notice of intention to export (NOI).

Sampling methods for ARGT

For detailed information on sampling for ARGT refer to the “Standard for Minimising the Risk
of Corynetoxin contamination of Hay and Straw for Export”.

Record Keeping
Records must be retained for a period of no less than two years. Records are needed to trace
hay and straw samples from the point of sampling (paddock or shed) to the point of loading for
export.

Registered establishments

With regard to ARGT sampling and testing, the occupier of a registered establishment must
retain records showing, in relation to each consignment of hay or straw that the establishment
prepares for export:
        the details of the person who supplied the hay or straw
        the date on which the hay or straw was prepared for export
        the date on which the sample of hay or straw was drawn for testing
        the means of identifying the group of bales from which the sample was drawn
        the sampling method used (of those methods listed under ‘sampling methods’ in the hay
         and straw export standard)
        the details of the laboratory that tested the hay or straw
        the test method used (of those methods listed under ‘testing methods’ in the hay and
         straw export standard)
        the test results (whether the samples are negative or positive to CT or R. toxicus.
        the details of the person who took delivery of the hay or straw after it had been prepared
         for export, if it was not the person who supplied it or the exporter
        the details of the exporter, if known.

Laboratories

A laboratory undertaking testing of hay or straw for export must retain records, for each sample
as follows:

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        a unique identifier
        the details of the person who submitted the sample to be tested
        the date testing was done
        the method of testing
        the test results (whether the samples are negative or positive to CT or R. toxicus.
        a statement that testing was conducted in accordance with the hay and straw export
         standard
        a statement that the person who submitted the sample to be tested was given written
         notice of the test results
        a copy of the written notice.

Exporters

An exporter of hay or straw must retain records showing, in relation to each export of hay or
straw that the exporter conducts:
     the date of export
     the destination of the export
     the full contents of each shipping container of hay or straw exported
     the test results relevant to each consignment of hay or straw that is in the shipping
        container
     the details of the immediately preceding source of the hay or straw (that is, details of the
        registered establishment, agent or other person who provided the hay or straw to the
        exporter).

Hay and Straw Exports - General Requirements
The inspection and export certification of prescribed goods (hay and straw) can only be
undertaken at export registered premises.

Export Establishment Registration status

Establishments intending to export hay must be registered for export, and must be registered for
the plant or plant products that are to be inspected (in this case hay and straw). Guidelines for
registering establishments are detailed in Volume 7 – “Registration of establishments for
export” of the Plant Export Operations Manual. In addition, a checklist is provided in
Attachment 1 with requirements that have to be met by export packing facilities for hay and
straw before they can be registered. Authorised Officers (AO) will need to verify that these
requirements have been met in order to register an establishment.

Preparation for Inspection

The inspection of hay and straw is dependent on the AO being satisfied that the goods are
export compliant, as outlined in HAS3001 Inspection and certification of hay and straw.




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In office

The AO must check the following information prior to the inspection:
    establishment’s registration status
    inspection location
    date and time for the inspection
    name and contact details of the exporter and/or freight forwarder
    commodity
    importing country requirements
    details of the consignment such as the number of containers
    booking reference number (if applicable)
      Note: This information may be in the form of a Notice of Intention to export (NOI),
      Request for permit (RFP) or a Phytosanitary certificate.
    exporter’s responsibilities (see below)

Exporter’s responsibilities

The exporter must:

        ensure hay/straw has been sampled and tested by a DAFF approved laboratory for the
         presence of Corynetoxin (CT) and found negative
        ensure hay/straw is processed at a registered export establishment
        ensure hay/straw is packed into containers that have been issued with a container
         approval
        ensure hay/straw is fumigated in a container. Note: fumigation is a commercial decision
         that is not mandated by DAFF Biosecurity however it may be an importing country
         requirement
        provide NOI, phytosanitary certificate, fumigation certificates
        ensure product meets the requirements of the importing country
In order to acquire an export permit, all hay for export requires a NOI/RFP and ARGT test
certificate.
Prior to starting the inspection, the AO will determine the importing country requirements for
hay and straw by checking the latest information on the MICoR database. If an Import permit is
required it must be made available prior to the inspection.
Note: If a valid import permit is provided and the information is different to the MICoR
Database conditions then the Import permit should be sent to the DAFF Biosecurity Regional
Plant Export office for advice.

On site

An Authorised Officer will need to present themself at the establishment office to sign in (if
required) and discuss any Work Health and Safety issues and check their Personal Protective
Equipment (PPE) and any inspection equipment deemed necessary to carry out the inspection.



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Inspection equipment

Examples of equipment that may be useful include:

        Pen
        Pocket knife
        Plastic buckets
        Scraper – metal
        10X magnifying glass
        Torch in working order
        Resources for insect and weed seed identification
        White inspection tray – for checking contaminants
        Specimen kit – paintbrush, vials with ethanol, tweezers, plastic zip lock bags
        Sieve – with an appropriate screen size to allow separation of pests and contaminants
         from product
        Personal Protective Equipment (PPE) – safety vest, dust masks, safety boots, hard hat
         and ear muffs

Establishment Hygiene

The operator of a registered establishment must maintain the establishment in a condition that
does not contaminate, infect, infest or cross-contaminate export compliant goods; and have a
defined program of hygiene and pest control. Animals (including birds, cats, rodents and
vermin) must not be present in the establishment where preparation of prescribed goods takes
place.

Hygiene inspection

The Authorised Officer must conduct a hygiene inspection of the nominated areas that are to be
used, including the product inspection area, flow path, container storage area, cross infestation
areas etc and record the result of the inspection on an approved export compliance record.
The flow path will differ at each establishment but generally consists of the pathway from
when hay is received from the producer at the registered establishment for preparation and
processing, through to final packing to meet the importing country specifications for export.
This path may include storage prior to processing (X-ray, teasing, compression, baling and
loading) and packing into empty containers.

The entire flow path including the area where containers are kept prior to loading must be
inspected to ensure they are free from pests, contaminants, vermin and any potential for cross
contamination of the hay. The empty containers need to be inspected and passed as fit for
purpose prior to loading.
If any live insects are detected or a risk of cross infestation exists, the Authorised Officer must
stop the inspection, inform the client and record a rejection.
An additional hygiene inspection will be required after treatment. Any such treatment will be
recorded on the approved export compliance record. Refer to the relevant work instruction for
how to pass or fail a flowpath and how to record these details.
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Commodity Inspection Methods

There are three sampling options for treated and untreated hay:
In-line sampling: bales are removed at random from the production line before packing.
In-line sampling using loose hay and straw: hay and straw can be sampled after the process
of teasing and slicing of hay and straw in-line. For this option the establishment must have a
conveyor system which catches the excess hay and straw which has been generated after the
process of teasing and slicing hay and straw. The sample must directly link to the container in
which the sample is being loaded. The sample must be taken in-line at the time of processing
for the specific container.
End point sampling: of treated hay, one bale is removed from the first row and one from
either the second or third row. For end point sampling of untreated hay, bales are removed in a
‘V’ formation away from the doors.
There are two inspection techniques for bales, the biscuit technique or the coring technique
Coring technique: Coring must be undertaken by a suitably trained industry AO using a
hollow coring tube to ensure the corer maintains sample integrity to allow identification of any
insects collected. For non-compressed hay, the tube must have a minimum diameter of 30mm
and length of 450-500mm to collect samples. For compressed hay, the tube must have a
minimum diameter of 50mm and length of 200 mm to collect samples. The average straw
length of the samples is to be at least 10-15 mm.
Note: The use of a solid drill bit is not permitted and a coring tube must be used. This is
required to prevent live insects or contaminants being shredded.
Biscuit technique: the straps of the bale are cut and the bale is split into a minimum of three
subsamples (‘biscuits’). The biscuits are shaken out over the inspection bench/sieve.
Alternative sampling regimes to that outlined in this document for inspection of hay for export
may be considered at the discretion of the Assistant Secretary Plant Export Operations branch.
For any alternative sampling methodology to be considered suitable, the methodology must be
based on sound scientific evidence, and must be proven to be equivalent to that already
provided by existing sampling and inspection methods.

Inspection Facilities

The Authorised Officer should ensure that adequate inspection facilities are available and that
they are fit for use.
These facilities should include:
        adequate access to take samples for inspection
        adequate lighting - natural or artificial
        safe and ready access around stacks of bales or a method that demonstrates suitable
         hygiene and rodent control inspections
        sampling/inspection area free from cross infestation and away from the elements (e.g.
         rain, wind etc.).



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Containers

Hay and straw exported in containers also require empty container inspection and container
approval. Containers must have passed an empty container inspection in the 28 days prior to
loading hay and straw for export. Refer to Volume 11: Empty Container Inspections for more
information.

Note: Importing country requirements must also be checked to ensure the validity of the
container approval. Certain importing country destinations only accept container inspections to
be valid for 14 days (Japan accepts 21 days) after the date of inspection.

Hay and Straw Exports
Procedures described in this document are subject to any changes in importing country
requirements.
The exporter will determine whether or not the product is to be treated prior to inspection for
export according to importing countries requirements.
If the product requires fumigation then this must be carried out by a licensed fumigator and a
gas free certificate must be provided to the AO.

Preliminary Paperwork – Export Requirements

The Authorised Officer shall, prior to commencing the export inspection of the hay, ensure that
the following information/documentation is available and valid:
        Import permit (if required) – check the conditions stated on the permit
        Treatment certificate(s) – for treated hay, confirm that the certificate and the treatments
         stated on it are valid.
        Empty container inspection (Container approval) - verify that the container/s were
         inspected and passed fit for use within the 28 days prior to loading.


Determination of Inspection Lots

The Authorised Officer shall determine the size and identification of the inspection lots, and
record the number of containers forming each inspection lot on the approved export compliance
form.

Sampling and Inspection Techniques
Sampling and inspection procedures for hay and straw must be carried out in accordance with
work instruction HAS3001 ‘Inspection and certification of hay and straw’.

Inspection Tolerances

Where visual signs of infestation and or contamination are found during inspection, the
Authorised Officer will undertake a more detailed inspection to determine that no live pests are
present. A nil tolerance for live insect pests will be applied, irrespective of whether the pests
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are found on the outside of the bales, inside or outside of the container, or from the samples
inspected.

The following inspection tolerances are applicable for hay:

Inspection criteria for export hay for all countries other than China

A. REJECT consignments if any of the following are detected:

        True to description: The description of the product does not truly reflect (as it must)
         the product carried inside the container.

        Live insects and pests: This includes live insects in all stages of the life cycle – egg,
         larvae, pupae and adult. In particular, look for rodents, psocids (which feed on moulds
         and mildews found on damp hay) beetles (which may leave webbing or frass, a
         substance similar in look and texture to sawdust) and bugs (which are sucking insects).
         Training programs will show you how to identify insects commonly found in hay.
         Note: under normal phytosanitary inspections, consignments would not be rejected for
         ‘hitch hikers’ such as spiders and mites (which are not classified as insects), but since
         the importing country is likely to reject for them, you should do the same.

B. Contaminants may constitute a rejection, depending on importing country
   requirements. Officers are to inform the exporter as soon as possible if any of the
   following are detected:

        Mallee roots: Or other wood/timber, greater than 50 mm square.

        Ergot infestation of ryegrass seed: Ergots are purple-black, horn-like fungal bodies,
         produced by the fungus Claviceps purpurea, which replace one or more grains in the
         heads of ryegrass and wheat. Ergots can be up to four times larger than normal grain
         and may contain toxins harmful to humans and animals.

        Moisture: Moist hay is combustible, and therefore dangerous. Psocids or book lice also
         thrive in damp hay.

        Other miscellaneous contaminants: Sheep dung, rags, hessian bags, tools etc.

Inspection criteria for export hay for China

A. REJECT consignments when any of the following are detected:



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       True to description: The description of the product on the supporting documentation,
        does not truly reflect (as it must) the product that is carried inside the container.

       Live Insects and Pests: This includes live insects in all stages of the life cycle – egg,
        larvae, pupae and adult. Officers should look for rodents, psocids (which feed on
        moulds and mildews found on damp hay) beetles (which may leave webbing or frass, a
        substance like sawdust).

       Animal Parts: This includes animal parts, limbs, including rodent or other animal
        carcasses.

       Soil: Nil tolerance unless Import Permit states otherwise.

       Weed Seeds: As stipulated by Importing country requirements.

       Other contaminants: Any animal faeces.

B. DO NOT REJECT consignments when any of the following are detected. But inform
   the exporter as soon as possible:

       Timber: Wood/timber, greater than 50 mm square.

       Ergot infestation of ryegrass seed: Ergots are purple-black, horn-like fungal bodies,
        produced by the fungus Claviceps purpurea, which replace one or more grains in the
        heads of ryegrass and wheat. Ergots can be up to four times larger than normal grain
        and may contain toxins harmful to humans and animals.

       Moisture: Moist hay is combustible, and therefore dangerous. Psocids also thrive in
        damp hay.

       Other miscellaneous contaminants: Rags, hessian bags, tools, rocks etc.

Completion of Paperwork

The Authorised Officer will record the results of the inspection on the approved export
compliance record, including:
    container number(s)
    any rejection details and whether product was treated and re-presented or replaced
    the Phytosanitary Certificate number of the inspected consignment.




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Document Control

The Authorised Officer will ensure that all inspection records/export documentation relating to
the inspection is forwarded to the local DAFF Biosecurity office.

Audit
DAFF Biosecurity will monitor registered establishments and Authorised Officers for
compliance with meeting the outcomes, prerequisites and requirements of DAFF Biosecurity
under the governance of current export legislation. Audit and verification must be carried out
by a qualified person who is an Authorised Officer and an employee of the government of the
Commonwealth or State or Territory (hereafter DAFF Biosecurity auditor) according to
existing Audit Policy and Audit Procedures.

Hay and Straw Exports – China
Prior to inspection, the Authorised Officer must ensure that they are aware of and know the
export requirements and/or phytosanitary requirements of China.
The Authorised Officer must ensure that the exporter has a valid import permit and is on the
register of companies approved to export hay to China. The occupier of a registered
establishment commits an offence under the Export Control Act if the current certificate of
registration for the establishment is not displayed prominently in the establishment. The AO
should ensure the certificate is prominently displayed and current.
Establishments exporting hay and straw to China are required to meet specific conditions in
addition to what is required for hay establishments exporting to other countries. In particular,
establishments exporting hay to China must be approved by DAFF Biosecurity and listed as
suitable by the Chinese authorities. A list of approved and suitable premises is available on the
MICoR database.

Quality Management System

The establishment must implement a quality management system based on the Hazard Analysis
Critical Control Point (HACCP) concept. The HACCP concept is internationally recognised as
a method for defining and managing requirements for effective control of product safety and
hygiene. HACCP facilitates the identification and maintenance of "critical control points"
which limit risks to the consumer. Occupiers of establishments should consult with DAFF
Biosecurity to determine if they have adequately identified all critical control points, and have
addressed them adequately. Once they have drafted their quality management plan they will
need to submit a copy for approval by DAFF.
The Authorised Officer must be aware of and understand the quality management system and
HACCP concept and should check that, in accordance with the system, the establishment
ensures that:

        prior to processing and packing of hay for export to China, the processing establishment
         is clean and swept thoroughly
        hay is decontaminated before compressing and packaging. Hay should not be
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         contaminated with regulated pests (at all life stages), toxic plants, roots, seeds declared
         on the import permit, metal, soil (nil tolerance), animal carcasses and animal waste
        hay processed for export to China is isolated from other processed hay. Effective
         measures must be in place to prevent re-infestation and control storage pests and birds
        any packaging materials that are used are new and clean.
        shipments of hay exported to China are labelled, refer to relevant work instructions


Preliminary Paperwork – Export Requirements
The Authorised Officer shall, prior to commencing the export inspection of the hay, ensure that
the following information/documentation is available and valid:

        Import Permit (mandatory) – check the conditions stated on the permit
        Treatment Certificate(s) – For treated hay, these must be provided by a licensed
         fumigator or company, fumigating to the AQIS Methyl Bromide Fumigation Standard.
        Verification that the container/s were inspected and passed fit for use within the 28 days
         prior to loading and that there is a Container Approval or an inspected sticker.
         Note: If evidence is not available, the authorised officer will fail that lot
        RFP number (on EXDOC as all documentation for China is electronic).

Inspection of treated hay requires additional inspection steps above what is required for
untreated hay and is outlined in the relevant work instruction in the Resource tab of the Plant
Export Operations Manual.

Inspected and passed product must be stored in secured conditions, clearly identified and
isolated from processed hay destined for other markets.
Under conditions where 28 days have elapsed or phytosanitary conditions have not been
maintained, re-inspection must be carried out.

Export compliant goods
Integrity of export compliant goods must be maintained – including segregation from
uninspected product, failed product or processed product for other destinations – by use of
physical barriers and the clear identification as passed product.

Rejection Procedures
The Authorised Officer will clearly identify the rejected lot, record the details of the rejection
on the approved export compliance record and notify the company that the lot has been
rejected.
The exporter will ensure that the rejected lot is removed from the inspection area.
The Authorised Officer will ensure that inspection of other lots in the area will not commence
until the rejected lot has been removed from the inspection area and a satisfactory hygiene
inspection has been completed of all cross-infestation areas.
The Authorised Officer will record the method employed by the exporter to rectify the cause of
rejection on the approved export compliance record for all re-inspected lots.

 Title: Volume 8A: Commodity Inspections - Hay and Straw
 Date Published                               Current Version Number   Program                          Page Number
 11 December 2013                                  FINAL V3.2          Plant Export Operations Branch   Page 14 of 18
References
        Export Control Act 1982
        Export Control (Prescribed Goods - General) Order 2005
        Export Control (Plants and Plant Products) Order 2011
        Work instructions
        Standard for Minimising the Risk of Corynetoxin of Hay and Straw for Export
        AQIS Methyl Bromide Fumigation Standard

Note: The Export Control Act 1982 and its subordinate legislation are all accessible via the
ComLaw website




 Title: Volume 8A: Commodity Inspections - Hay and Straw
 Date Published                               Current Version Number   Program                          Page Number
 11 December 2013                                  FINAL V3.2          Plant Export Operations Branch   Page 15 of 18
Attachment1. Checklist of Requirements for Registration of Establishment
for Hay and Straw Export

Authorised Officers are to inspect the establishment and verify that the following requirements
have been met before endorsing the EX26 (the application for Application for Registration or
Notification to the Secretary of Change of Details of an Establishment) available on the DAFF
website:

    □ Authorised officers must check that the EX026 has been filled out correctly and all
         associated documentation has been attached.

    □ The establishment is a place where hay or straw is prepared for export.
    □ The occupier of a registered establishment must comply with the hay and straw export
         standard at all times when preparing hay or straw for export.

    □ The equipment available or to be available in the establishment is adequate for carrying
         out operations in a hygienic manner.

    □ The flow path and internal workings of the machinery transporting the hay must be
         easily accessible.

    □ The export operations to be carried out in the establishment are compatible with one
         another, i.e. the operation of one export operation must not compromise the export
         certification integrity of the other.

    □ The establishment’s operations must be compliant with export legislation, importing
         country requirements and hygiene requirements.

    □ Operations, other than export operations, that are to be carried out in the establishment
         will not affect the hygienic preparation of prescribed goods

    □ For the purposes of registration, plans or diagrams giving the general structural and
         operational layout of the establishment have been provided.

    □ Plans are sufficiently detailed to allow evaluation of the establishment in accordance
         with this work instruction.

    □ Provision has been made for the disposal and removal of all waste material, including
 Title: Volume 8A: Commodity Inspections - Hay and Straw
 Date Published                               Current Version Number   Program                          Page Number
 11 December 2013                                  FINAL V3.2          Plant Export Operations Branch   Page 16 of 18
        liquids and solids, from a registered establishment in an efficient and hygienic manner.

   □ The occupier of the registered establishment is capable of maintaining the establishment
        in a hygienic condition to control pests, including vermin, and have a defined program
        of hygiene and pest control.

   □ The occupier of the registered establishment must keep records of cleaning and pest
        control measures in sufficient detail to enable an authorised officer to determine the
        effectiveness of pest control measures and demonstrate compliance with AQIS
        requirements. Records should document non-conformities and address corrective action.

   □ Site buildings:
             (a) must be constructed, designed and maintained to prevent the introduction of
                 contaminants and pests
             (b) receival and despatch areas must be well separated from the external surrounds
             (c) goods that have been passed or failed must be able to be isolated and segregated
                 to avoid cross-contamination
             (d) must have adequate drainage to avoid unnecessary water build up.


   Floor of processing areas must be:

   □ a solid, impervious surface
   □ able to be cleaned easily
   The occupier of the establishment provides a safe working environment and has a
   designated area for export inspection to take place, including:

   □ inspection benches of solid surface, preferably white in colour and kept clean at all
        times

   □ as a guide, inspection benches must be a minimum height of 900cm x a minimum width
        of 2m

   □ authorised officers must have access to a desk and phone to complete inspection
        documents

   □ a minimum of 600 lux lighting must be provided at the inspection table
   □ male and female toilets and change rooms must be accessible for authorised officers to
        use and kept clean at all times by the occupier of the establishment.


Title: Volume 8A: Commodity Inspections - Hay and Straw
Date Published                               Current Version Number   Program                          Page Number
11 December 2013                                  FINAL V3.2          Plant Export Operations Branch   Page 17 of 18
    The occupier of a registered establishment must retain records showing, in relation to each
    consignment of hay or straw that the establishment prepares for export:

    □ The details of the person who supplied the hay or straw
    □ The date on which the hay or straw was prepared for export
    □ The date that the sample of hay or straw was drawn for testing
    □ The means of identifying the group of bales from which the sample was drawn
    □ The sampling method used (of those methods listed under ‘sampling methods’ in the
         hay and straw export standard)

    □ The details of the laboratory that tested the hay or straw for the purposes of these Orders
    □ The test method used (of those methods listed under ‘testing methods’ in the hay and
         straw export standard)

    □ The test results
    □ The details of the person who took delivery of the hay or straw after it had been
         prepared for export, if it was not the person who supplied it or the exporter

    □ The details of the exporter, if known.
Establishments Exporting Hay and Straw to China

In addition to the above, for establishments exporting hay and straw to China:

    □ Must have suitable facilities, processes and systems in place, and be approved by AQIS
         to export hay to China:

    □ Must be registered with AQSIQ China
    □ The establishment must have a Hazard Analysis Critical Control Point (HACCP)
         management system or quality management system based on the HACCP concept to
         manage contamination and hygiene risks associated with preparing hay for export.

    □ Must have facilities that enable segregation/isolation of processed product for China
         from other processed hay.




 Title: Volume 8A: Commodity Inspections - Hay and Straw
 Date Published                               Current Version Number   Program                          Page Number
 11 December 2013                                  FINAL V3.2          Plant Export Operations Branch   Page 18 of 18

				
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