AQIS response to APL claims in Productivity Commission Review of Regulatory Burdens on Business – Primary Industry

Claim:  that the pesticide screen under the Imported Food Inspection Scheme is less stringent that the NRS pig monitoring scheme and that imported meat is not subject to the same standards as domestic meats.

IFP comment:  

Imported food is subject to the same food standards as food produced domestically.  This is because all food sold in Australia, whether produced domestically or imported, must comply with the standards in the Australia New Zealand Food Standards Code.  

The testing that occurs for imported pigmeat is a chemical screen applied to consignments referred to AQIS at a rate of 5 %.  No comparable regulatory inspection and testing regime occurs domestically.  The NRS program is not regulatory testing but is a residue monitoring program designed to facilitate market access.

Much of the testing done under the NRS program would not be valid on imported pigmeat, as it is generally done on offals which are not imported into Australia.

Background
•	Under the Imported Food Inspection Scheme, imported pigmeat is referred to AQIS at a rate of 5% of consignments and screened for 49 agricultural chemicals.  These goods are only referred at this 5% rate because it is not regarded by Food Standards Australia New Zealand (FSANZ) as a food that poses a medium to high risk to public health. 
•	Residues of agricultural and veterinary compounds, especially at low levels, are not generally a medium to high risk to public health and are therefore monitored at the random surveillance rate of inspection.  If detected, they may represent a compliance breach.
•	This calendar year 146 pesticide screens have been conducted on imported uncooked pig meat.  No failures have been detected.  
•	Carbadox testing was applied to Canadian pigmeat until December 2006.  This was removed because the chemical was no longer permitted to be used in Canada and there had been no failures in the testing under the Imported Food Inspection Scheme.
•	The monitoring done by the National Residue Survey (NRS) does not perform the role of a regulatory authority for the states and territories.  The NRS monitoring of some agricultural products is done to facilitate access to Australia’s key export and to a lesser degree, domestic markets.  
•	Most chemical testing under the NRS scheme is applied to pork offals and not to muscle tissue because offals contain the highest concentration of the residues being tested.  Under the current import risk assessment, muscle tissue is the only tissue permitted to be imported and therefore most tests applied by the NRS will not be relevant to imported pigmeat.
•	Some countries may permit the use of chemicals for which Australia doesn’t have permissions for use.  Provided the residues are not present in the food, there is no breach of Australian food standards if the chemicals are used in other countries. 
•	As MRLs are set to reflect the conditions in the country of production, use in other countries of chemicals not permitted in Australia is acceptable practice.  There are also internationally agreed levels (i.e. Codex) for some chemicals which many countries automatically adopt.  
•	The detection of residues above the limit set in the Food Standards Code leads to the pig meat failing to meet Australia’s standards.  Any food failing to meet Australia’s standards will be subject to further action and 100% of comparable consignments are referred to AQIS and tested until compliance has been demonstrated.