Prepared in response to the question: are there observable changes in the way biosecurity is being handled, any increase or decrease in insect detections, and any views on how the system is performing and how it might be improved?
My opinion is that the biosecurity system is performing adequately at present. Inspection rates are relatively consistent, intervention levels and clearance timeframes are generally proportionate, and there is no evident pattern of inspection failures or contamination issues arising across the consignments I’ve seen, or colleagues have mentioned to me. I’d suggest that the major opportunities for improvement are not in the intervention required by DAFF, but in the quality of the evidence used to assess container risk and in the consistency in knowledge and technical depth of DAFF officers.
Processing turnaround has substantially improved. Document processing through the Cargo Online Lodgement System (COLS) has been noticeably faster in my experience, and I understand that biosecurity assessment turnaround times have substantially improved, now typically running at one to three days. The test of whether that continues of course will be whether it is sustained through peak season.
I have not seen or heard of any increase in insect and pest detections, although have been advised of two instances reported by a colleague over a recent two-week period. Contamination, based on my own operational experience across the consignments handled, appears to be decreasing, although this should not be taken as an observation of anything other than my own experience, and not as a broad industry finding.
Suggestions for Improvement
Reform of the Packing Declaration Process
Although packing declarations consume a considerable amount of time across the supply chain, I’d suggest that it is questionable whether the current document-based approach consistently provides the department, importers or brokers with reliable evidence as to the actual condition of the container. This is because the use of standard templates tends to produce declarations completed as an administrative exercise rather than as a meaningful assessment of potential risk.
In discussions with colleagues, I have had suggested to me that a more effective approach may be to require packers to take dated photographs of the container at the time of packing. Such a record could reasonably include:
The internal container surfaces — floor, walls and ceiling
The container doors
The packed cargo, photographed prior to the container being sealed
Brokers would then be in a position to review the photographic evidence and form a considerably better-informed assessment as to whether a container should be referred to the department.
This does not need to replace packing declarations but just a suggestion for a more practical and independently verifiable risk-assessment tool than reliance on answers recorded in a standard declaration. There are negatives to it of course as its usefulness would depend on the quality of the photos.
Training and Accreditation of DAFF Officers
A recurring issue is the apparent variation in the experience and training of DAFF officers. In some cases brokers are required to provide considerable guidance or explanation to assist officers in interpreting documents, directions or operational circumstances.
Additional technical and operational training for officers would be likely to improve consistency, reduce unnecessary referrals and requests for information, save costs, and produce more efficient decision-making for both the department and industry.
A related point arises at depot level. Where attending officers hold accreditation across only a limited range of commodities, a second officer must be booked to inspect the balance of the cargo. This delays release of goods that could and should be cleared by a single attendance. Broadening the range of commodities across which individual officers are accredited would remove an avoidable source of delay.
Conclusion
The current system is functioning adequately, and recent improvements in processing turnaround are worth acknowledging. The opportunities that remain are practical rather than structural: improving the quality of the evidence on which container risk assessment is based and strengthening the training of officers. Both would deliver benefits to DAFF and to industry without any reduction in the level of biosecurity protection.