Busting Congestion for Plant Exports

The department wants to streamline government regulatory activities across the domestic and export plant agriculture sector. We are working with states and territories to find opportunities to standardise, harmonise and recognise – to better ‘align’ our regulations. Through the project, we will:

• harmonise regulation between the Commonwealth, states, and territories, which will reduce duplication of work
• provide an opportunity for mutual recognition and data sharing
• improve processes to enhance market access negotiations.

Proposed benefits

This project will achieve the most benefits for industry participants, working across more than one pathway (export, import and interstate trade) through:

• standardised controls making it easier to understand and meet requirements
• saving time due to less duplication of work
• reducing administrative processes
• saving money due to reduced cost of compliance.

Priorities for reform

In August 2021, state and territory representatives in the plant sector were consulted to:

• identify areas where regulations overlap
• decide which areas to start working on first.

The plant regulations identified and agreed upon for harmonisation across exports and domestic trade are:

• automating state-issued area freedom certificates for exports
• standardising treatment regulation.

Progress so far

We are now partnering with two state governments to develop a proof of concept for the identified project ideas:

• Tasmanian Government - the automation of area freedom certification
• Victorian Government - standardising treatments.

If a project outcome is successful in one state, we can scale it up to other jurisdictions.
The horticulture industry will be updated through industry associations and our consultative committees.

This project aims to deliver efficiencies in the horticulture industry by recognising existing food safety and quality assurance schemes and their alignment with plant export regulatory requirements. This will involve industry collaboration and we may be able to recognise these schemes and make improvements to the plant export regulatory framework.
We may be able to utilise existing schemes to:

• recognise commercial food safety and quality assurance schemes
• gain assurance that departmental requirements have been met
• reduce the time taken to collect evidence during accredited property and registered establishment audits
• explore third-party auditing arrangement options.

Proposed benefits

Our aim is to reduce the time and cost of departmental export audits without compromising the required level of assurance. This project will be most beneficial to accredited growers and packers through recognition of current food safety and quality assurance schemes at use.
By streamlining horticulture export audit processes, growers and packers will benefit from:

• reduced costs
• time saved
• less pressure during peak periods.

Current audit processes

Horticulture establishments undergo many audits from various organisations. These include food safety certifying bodies and various levels of government.
These audits often cover the same activities in relation to:

• cleanliness
• waste management
• pest management
• chemical use and storage
• product labelling
• traceability.

Opportunities to streamline our audits

We are assessing commercial food safety schemes against export requirements to identify duplication. These include Freshcare, Global Gap, Safe Quality Food (SQF) and Brand Reputation Compliance Global Standards (BRCGS) food safety standard certification.
Where overlapping requirements are identified we aim to recognise the scheme and associated audits, reducing the level of evidence required at departmental audits. Longer term, we are also considering the use of third-party auditors.

Working with industry

To gain a comprehensive understanding we will engage with:

• key commodity groups in the horticulture industry
• food safety standard owners
• certification bodies.

As part of our assessment, we will observe food safety audits being completed in field. This will assist us to understand how auditors assess and manage compliance against requirements.
The horticulture industry will be updated through industry associations and our consultative committees.

New technology is changing the future of agriculture. This project will create a framework focused on harnessing and adopting new technology, providing potential for modernised, faster and easier phytosanitary processes in the plant export supply chain. We are seeking to encourage development and adoption of new technology that can provide the same or greater level of assurance. Through the project, we will:

• create a framework for the recognition of new technology for assurance
• trial and adopt real time monitoring and reporting technology
• reduce or remove the need for manual checks such as audits and inspections.

Proposed benefits

If successful, this project will achieve benefits for industry by:

• instilling confidence to develop innovative technology that suits their needs
• adopting new technology to certify goods more quickly, speeding up the export supply process
• saving producers and exporters costs on manual processes
• implementing real-time monitoring technology, resulting in less onsite auditing, faster certification, and lower costs for industry
• creating and adopting a technology for assurance framework, where new technologies implemented by industry may be recognised as alternative methods of assurance.

Emerging technology solutions

Technology is currently in use for quality assurance in plant production. This could include:

• grading and quality assessment of fruit and vegetables
• assessing grain quality
• satellite imaging for crop and harvest monitoring.

New technologies are emerging that may be able to support or replace existing manual processes in the export supply chain. These could include:

• imaging technology and machine learning for inspecting goods
• drones for crop monitoring
• data capture-and-transfer software for treatment monitoring.

Building a framework

We will build a framework to provide guidance on how we could accept and certify new technology for plant health certification purposes.
The framework will cover:

• how we measure the effectiveness of new technology
• how we recognise new technology that meets regulatory requirements.

Once established, we can determine if the framework encourages industry to develop and implement the new technology.
We hope industry will increasingly utilise technology to show they meet the requirements of Australia’s trading partners.

How industry is contributing

This is an exciting opportunity for industry members to shape processes that will affect them in the future.
We are working with treatment providers, crop monitors, registered export establishments, industry associations and universities, CSIRO and other technology providers.
Industry will be kept up to date on progress through industry associations and our consultative committees.

This project aims to reduce government presence on-farm by recognising a packhouse’s grower management system. We are aware some packhouses have commercial arrangements with growers to ensure good on-farm practices are in place. We are assessing whether these arrangements meet our legislative and trading partners requirements for exporting produce free from pests and diseases. If achievable, this will deliver efficiencies to industry and the department.
Through the project we will:

• test the recognition of a packhouse’s management system over the grower supply base
• look to change our audit approach for industry who meet the criteria.

Proposed benefits

If our trading partners accept commercial arrangements between a packhouse and their growers, it will benefit growers as they will experience a reduction in government presence on-farm.
Some proposed benefits include:

• packhouses saving time by not having to coordinate grower audits
• packhouses ability to utilise existing grower management systems to meet departmental requirements
• growers saving on the cost of audits and spending less time with auditors.

How we currently meet importing country requirements

Our trading partners require proof that Australia’s exports are free from pests and diseases. On-farm audits help us certify that produce meets importing country requirements.
Some commercial arrangements already ensure that:

• pests and diseases are well controlled
• farm hygiene is maintained
• growers meet chemical application requirements.

We are assessing whether these types of commercial arrangements could meet the requirements of our trading partners and Australia’s export legislation.

What the trial involves

Currently, we are trialling the use of a citrus packhouse’s grower management system to check

• pest monitoring activities
• chemical applications
• farm hygiene.

We developed the trial with Citrus Australia and included 6 citrus packhouses in NSW, South Australia and Victoria to take part in the trial from March until August 2022.

Post-trial outcomes

If the trial is successful and trading partners accept the model, we will look to change our audit approach for the citrus industry to recognise packhouses who meet certain criteria to manage the on-farm practices of their supply growers.

An opportunity for change

This is an exciting opportunity to streamline Australia’s export practices. If the trial is successful, it could mean fewer on-farm audits while maintaining confidence that we meet our trading partners requirements.
We may also be able to implement the changes to other horticultural industries that have appropriate commercial grower supply management systems.

The project will develop and introduce a new Grain Trade Australia (GTA) Grain Storage Assets and Management Standard that meets export requirements. The Standard developed will help to maintain Australia’s reputation as a reliable supplier of safe and high-quality grain.
Through the project we will:

• work with GTA and industry to co-design an industry standard which recognises existing commercial quality systems and new technology 
• recognise the new standard to reduce the departments audit and inspection activities.

Proposed benefits

Industry assured grain storages with improved processes and procedures for grain management, as outlined in the Standard, will provide benefits for industry and the department, including:

• having a standard that demonstrates assurance to the department
• reduction in departmental audits and inspections for those who adopt and are compliant with the standard
• strengthen the confidence of overseas and domestic consumers in the quality of Australian grain
• improved level of assurance and confidence for the department in Export Registered Establishments (EREs) and their storage, management, and quality systems in the export grain supply chain
• providing a tool for demonstrating greater assurance to the department on industry compliance, which can lead to a reduction in the department’s level of regulatory intervention
• increased confidence for the financial services industry leading to improved access to finance and insurance
• improved interface with the logistics supply chain and reduced remediation cost for out of specification grain
• decreased exposure to inventory loss and contractual risk
• providing [evidentiary] records that will support quality control and niche marketing opportunities 
• demonstrated compliance with WH&S and other regulatory requirements.

An industry-led Standard

GTA has a comprehensive strategy to make the Australian grain industry more competitive through to 2030.  A key part is to develop a Grain Storage Assets and Management Standard (the Standard) for Australian grain industry participants. The Standard recognises that specifications for storage facilities are needed by both the domestic and export grain market. This will meet expectations in terms of grain quality, food safety and phytosanitary reputation. 

Role of the department

The department regulates grain exported from Australia. Our role is to ensure that Australian grain exports are:

• fit for purpose
• accurately described
• free of live stored grain insects
• free of any other pests or contaminants of quarantine concern to importing countries. 

We have released a Plant Export Operations Strategic Plan for 2030. Both GTA’s and our strategies aim to modernise and increase efficiencies in the grain industry supply chain. We can achieve that by working together.

How the Standard will work

Both GTA and the department are pursuing a shared goal to deliver efficiencies to Australian grain industry participants through recognition of the Standard to meet our regulatory requirements. We both believe this will deliver efficiencies to Australian grain industry participants.
The Standard will set out how industry will meet our regulatory goals. We must be able to assess the Standard against the Commonwealth’s legislative export requirements for entities involved in the grain export supply chain. This will provide increased clarity, simplicity, and confidence in the export grain supply chain, from both a commercial and a regulatory perspective.
While the Standard will be voluntary, through defining the requirements for compliance via different levels of operation, the Standard will also be able to be adopted by the domestic industry. In those instances, the requirements of the department will not be applicable.

Using new technology for better outcomes

As part of other government initiatives, the project to develop the Standard has highlighted opportunities for industry to adopt new technology to sample and test grain for quality and phytosanitary purposes. This will help make assessment more accurate, improve confidence in the inspection process and could also reduce costs to industry and the department. This Standard will include elements of technology adoption that may be realised during the project timeline by us and industry, or alternatively after the project.
Longer term the Standard will be the basis for an alternative assurance arrangement, in which we recognises the GTA Standard and the proposed auditing and assurance framework in meeting the regulatory requirements.  We will consider intervening less as the level of assurance increases. Industry will show higher levels of assurance through:

• meeting the standards
• using nationally recognized technology
• the compliance history of establishments
• industry quality management systems.

A tiered approach for using the Standard

The following diagram shows the tiered approach for the Standard. Our aim is to progressively intervene less in regulating export grain when industry shows enhanced industry quality assurance systems. As noted above, we do not regulate domestic grain.