BMSB UPDATE 42 - FTA seeking member feedback for reforms

Monday, January 14, 2019

Freight & Trade Alliance (FTA) continue to meet and advocate for improvements and transparency with the Department of Agriculture and Water Resources. (DAWR) and other Government Agencies.

On Thursday 10 January 2019, FTA representatives participated in a teleconference with members of the Department of Agriculture Cargo Consultative Committee (DCCC).

FTA, on behalf of our members, has been invited to table items and issues for the DCCC to review as part of the current BMSB season.

Below is a list of items already submitted for consideration and we ask members to provide commentary on these and / or outline other issues to me atacrawford@FTAlliance.com.au by 5pm AEDT, Wednesday 16 January 2019.

FTA will collate and submit feedback as a part of our ongoing engagement with the DCCC and will also keep members duly updated as we continue to advocate to gain continual operational improvements.

Reduce intervention of low risk goods
Expansion of AEPCOMM to other commodities currently not in scope
Consideration of mandatory BMSB offshore treatment of LCL containers
Consideration of mandatory BMSB offshore treatment for all goods
Separate BMSB entries from other biosecurity entries
Target BMSB intervention at a lower tariff level (not tariff chapters)
Permit inspection of low risk goods to be conducted by approved persons under AAs
Reduced intervention on highly compliant importers
Increase the usage of automation
Stop holding containers for 'supervised seals intact' inspections, and allow unpack prior to officer attending the inspection.
Limit the random BMSB surveillance inspection until such time DAWR has available inspectors to undertake the inspections as ISG are way outside service standards of 3 days, which is the DAWR service standard and not industry.
Provide clear policy advice, support, work instructions to ASG staff as they are taking longer to process entries due to the BMSB complexity and charging industry more as they may exceed the 15 min assessment block.
Review the number of ASG entries for re-assessments to determine if more training is required, as re-assessments is double handling the entry and we should aim at getting the direction right the first time, reducing phone calls, emails etc.
Provide a dedicated BMSB hotline for customs brokers to be able to reach ASG staff to address any post entry assessment issues as mistake are made on both sides and ASG and customs brokers need to work in partnership to achieve best outcome as our assessment goals are the same, and that is to come up with correct assessment/direction to manage the biosecurity risks.
Consider COLS enhancements that provide better visibility and integration between ASG and customs brokers. Develop a dashboard that provides status of entry processing as this may reduce the number of calls by industry chasing directions as ASG has been outsider service standards since BMSB season commencement.
Consideration as to COLS interaction with third party software may deliver time saving benefits for customs brokers as it may reduce the duplication of date entry. COLS should be a self-serve portal for customs brokers just like the bank Apps we all use and less reliance of ASG for low risk functions.
Review the documentary requirements and look to reduce the number of documents required for assessment, this may result in faster assessment and processing times.
If the BMSB risk are too high DAWR may need to consider expanding the requirements for offshore treatment with industry consultation.
Review the service standards and move with the times as importers, customs brokers, forwarders operate in a fast paced and demanding environment, and compete on supply chain efficient getting their goods from origin to customer. DAWR while managing the biosecurity risks, also have an obligation to facilitate trade as biosecurity is a shared responsibility, and it's often industry that acts as the frontline reporting biosecurity risk to the DAWR based on detections at the AAs.
Provide a dedicated phone, email or Account Manager for customs brokers to reach senior assessment officers to address direction issues. The 1800 central number is a waste of time for customs brokers who can spend up to 30-40 minutes before they can reach someone. Time is money and we need to reduce the time it takes to reach an officer.
ASG is your frontline but at the same time jobs in this area are seen as low level and less incentive for officers to stay long term resulting in loss of knowledge. If DAWR ASG model remains same and based on assessment this area need significant resourcing, automation, remuneration that will allow ASG to provide the service industry deserves and pays for as not many in our industry can charge $30 per 15 minutes assessment block for their service.
Where possible the policies of Australia and New Zealand be aligned as these markets are served by (generally) the same services using the same embarkation ports/terminals (especially for vehicles).
That the list of risk countries in Europe be expanded to cover all the real risk areas and not have artificial exclusions such as Belgium/Netherlands which have already proven to have BMSB. As you have stated, BMSB don't respect borders and don't have passports.
Where a vessel has complied with all DAWR requirements and a contamination is found to exist, then an onshore treatment option be allowed for that cargo and that they where practicable the treatment requirement is commensurate with the evidence of infestation. This is an important initiative to recognise the good faith with which vessels have self-reported and complied with DAWR requirement, rather than punishing them.
SAL members would like to continue to work together with DAWR to develop an on-board fumigation regime which can meet the BMSB risk reduction. This is considered to be the only viable long term option if the BMSB spread to become a global all year risk.
There are other known BMSB risk vectors in mail, personnel movements and air cargo which do not appear to have attracted the same focus as shipping. We do not like to see the shipping industry hit with all the costs while BMSB are "flying in" through open doorways in other transport sectors.
Allowing importers who have a FICA (incorporating an AA) and/or are a Trusted Trader the ability to have an Authorised Officer (importer employee trained by DAWR) to inspect consignments rated as low by the department. On a low/medium/high rating scheme as designed by DAWR. Commodities rated as medium/high – importers would be listed as a priority for biosecurity inspections.

BMSB UPDATE 42 - FTA seeking member feedback for reforms

Reduce intervention of low risk goods

Expansion of AEPCOMM to other commodities currently not in scope

Consideration of mandatory BMSB offshore treatment of LCL containers

Consideration of mandatory BMSB offshore treatment for all goods

Separate BMSB entries from other biosecurity entries

Target BMSB intervention at a lower tariff level (not tariff chapters)

Permit inspection of low risk goods to be conducted by approved persons under AAs

Reduced intervention on highly compliant importers

Increase the usage of automation

Stop holding containers for 'supervised seals intact' inspections, and allow unpack prior to officer attending the inspection.

Limit the random BMSB surveillance inspection until such time DAWR has available inspectors to undertake the inspections as ISG are way outside service standards of 3 days, which is the DAWR service standard and not industry.

Provide clear policy advice, support, work instructions to ASG staff as they are taking longer to process entries due to the BMSB complexity and charging industry more as they may exceed the 15 min assessment block.

Review the number of ASG entries for re-assessments to determine if more training is required, as re-assessments is double handling the entry and we should aim at getting the direction right the first time, reducing phone calls, emails etc.

Review the documentary requirements and look to reduce the number of documents required for assessment, this may result in faster assessment and processing times.

If the BMSB risk are too high DAWR may need to consider expanding the requirements for offshore treatment with industry consultation.

Where possible the policies of Australia and New Zealand be aligned as these markets are served by (generally) the same services using the same embarkation ports/terminals (especially for vehicles).

That the list of risk countries in Europe be expanded to cover all the real risk areas and not have artificial exclusions such as Belgium/Netherlands which have already proven to have BMSB. As you have stated, BMSB don't respect borders and don't have passports.

SAL members would like to continue to work together with DAWR to develop an on-board fumigation regime which can meet the BMSB risk reduction. This is considered to be the only viable long term option if the BMSB spread to become a global all year risk.

There are other known BMSB risk vectors in mail, personnel movements and air cargo which do not appear to have attracted the same focus as shipping. We do not like to see the shipping industry hit with all the costs while BMSB are "flying in" through open doorways in other transport sectors.

Andrew Crawford - FTA / APSA