Federated Farmers Submission on Processed Animal Manure Products Draft Import Health Standard and Guidance Document
Federated Farmers is not convinced that the measures outlined in this proposed Import Health Standard are sufficiently robust to adequately address the risks associated with the importation of these products.
Federated Farmers opposes this Import Health Standard unless all our recommendations are met and the measures outlined adequately address the associated risks.
Summary of Recommendations
- Federated Farmers recommends that any annual audit and inspection is a thorough and whole systems audit rather than a desktop audit.
- Recommends that a list of regulatory requirements that sit outside the Import Health Standard should be included in the preamble section of the Import Health Standard.
- Recommends that MPI monitors the Competent Authority for compliance with the requirements of the Import Health Standard.
- Recommends that a scientifically based temperature map study of the load should be undertaken at least three times, to show that the required temperature is reached.
- Recommends that MPI reconsider the temperature thresholds and time to ensure that all biosecurity threats posed by this material are in fact eliminated.
- Recommends that any validation of new temperature and time thresholds should be achieved by using a simulated pathogen study to show that all the risk pathogens are neutralised by the process.
- Recommends that samples of the material are drawn and checked for the presence of seeds or parts of seeds. A germination test should be undertaken on any seeds or parts of seeds detected.
- Recommends that if the germination test is positive, no further consignments should be cleared for entry into New Zealand.
- Federated Farmers supports a review of the proposed Import Health Standard by an independent New Zealand based pest plants scientist.
- Federated Farmers submits that MPI officials should view the entire consignment upon arrival.
For more information, see the full submission