Joe Ludwig, Minister for the Department of Agriculture, Fisheries and Forestry

Biosecurity Australia has just finalised their draft on all imported Iridoviruses affecting all imported ornamental finfish in the varieties of all Cichlids, all Gouramis, and all Livebearers. They have had this on the watch for almost 3.5 years and have now released the final draft report to the public on 23/7/10.

Their final report recommends that all Cichlids, all Gouramis, and all Livebearers as well as all Betta spp, and paradise fish species will each have to be batch-tested post arrival in Australia. Under the current proposal the number of fish to be removed and tested depends on the batch size of the shipment. For a shipment of 20 fish, 19 (95% of the batch size) require testing. For a batch size of 60 fish 38 (63%) would require testing. Current testing techniques kill the fish.

There are major concerns with some of the assumptions that are made or inferred in the report, seemingly without evidence or scientific backing. It is clearly indicated that the basis for screening incoming livestock is to minimize risks of viral exposure to Australian native fish and fisheries, however the report provides no evidence of measures undertaken to ascertain the presence or extent of the viruses in question in Australia. This is surprising given that an outbreak has been recorded in Australia. Surely the significant numbers of aquarium fish already imported warrant a proper investigation of our existing fish stocks to ensure that screening is worthwhile before inflicting the costs across commercial operators and hobbyists.

Should the proposed testing go ahead, many hobbyists who have invested hundreds or thousands of dollars in equipment will no longer be able to purchase fish through the channels they use currently, with costs of a number of these species expected to increase beyond the reach of a majority of hobbyists. The Pet Industry Association currently estimates the testing regime could cost the industry more than 50% of its turnover in the short to medium term. The Australian Pet Industry is currently valued at $6.02 billion and employs in excess of 47,627 people. The proposed testing regime would devastate the industry.

The report was completed without a large number of stakeholders being made aware of any opportunity to participate until now. Those who were consulted represented the largest importers of fish for Australia wide distribution and large commercial breeding facilities. The majority of aquarium fish importers import much smaller quantities and will be put at a severe competitive disadvantage.

Under current legislation stakeholders who believe there was a significant deviation from the Import Risk Analysis (IRA) process that adversely affected their interests may appeal to the Import Risk Analysis Appeals Panel (IRAAP). Outlined in the IRA handbook are grounds for appeal, which clearly state “The IRAAP does not consider matters relating to the scientific merits of the IRA or the merits of the recommendations made or the conclusions reached by Biosecurity Australia or the Eminent Scientists Group (ESG)”.

It is deeply concerning that despite the numerous errors contained within the report the IRAPP will not consider any appeals based on scientific merit, especially considering there is no reference to suggest the ESG has even reviewed this particular IRA.

We the undersigned are concerned citizens who urge our elected members of Parliament to act now to delay the introduction of recommendations laid out in the Biosecurity Report to allow:

1. An additional round of consultative process be undertaken, which is open to stakeholders across the full range of commercial and recreational interests, allowing comment on the incorporation of the scientific advice to the development of the proposed procedures.

2. A survey of a selection of wild native and feral ornamental fin fish populations and all commercial ornamental fin fish breeding facilities be undertaken Australia wide to determine the presence of Iridoviruses in existing fish stocks.

3. A detailed economic and social impact assessment for the implementation of the proposed batch testing procedures, and a consideration of the cost/benefit outcomes for the Ornamental Fish Industry and its constituent workers.

We also urge an immediate review to the Import Risk Analysis (IRA) handbook be undertaken, specifically the appeal process. The current handbook precludes appeals based on the scientific merits of the IRA, allowing flawed assumptions and conclusions to remain unchallenged. A fair appeal process would allow all aspects of an IRA, especially the science behind it, to be open to public scrutiny and appeal. This is not only of concern for this particular IRA but for all those completed in the future.

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