Okra from India: biosecurity import requirements final report

March 2023

© Commonwealth of Australia 2023

Inquiries about the licence and any use of this document should be emailed to copyright@aff.gov.au.

GPO Box 858 Canberra ACT 2601

Telephone 1800 900 090

Acknowledgement of Country

We acknowledge the Traditional Custodians of Australia and their continuing connection to land and sea, waters, environment and community. We pay our respects to the Traditional Custodians of the lands we live and work on, their culture, and their Elders past and present.

1.2 This risk analysis 1

2 Commercial production practices for okra in India 7

2.5 Harvesting and handling procedures 15

2.6 Post-harvest 16

3.3 Overview of pest risk assessment 25

3.4 Peach fruit fly and melon fly 27

3.9 Pest risk assessment conclusions 42

4 Pest risk management 45

4.5 Meeting Australia’s food laws 53

5 Conclusion 55

References 184

Figures

Figure 2.3 Typical okra crop 13

Figure 2.4 Okra being harvested 16

Figure 3.1 Overview of the PRA decision process for okra from India 44

Figure A.1 Decision rules for determining the impact score for each direct and indirect criterion, based on the level of impact and the magnitude of impact 64

Table 2.4 Peak okra growing periods in major okra producing states 23

Table 3.1 Quarantine pests and regulated articles associated with okra from India, and requiring further pest risk assessment 25

Table 3.6 Risk estimates for quarantine thrips 35

Table 3.7 Risk estimates for emerging quarantine orthotospoviruses vectored by regulated thrips 35

Table A.3 Decision rules for determining the overall consequence rating for each pest 65

Table A.4 Risk estimation matrix 65

Map 4 Top 10 production states of okra in India 2017 to 2018 8

Map 1 Map of Australia

Source: AgriFutures Australia (2017)

Summary

Nine quarantine pests have been identified in this risk analysis as requiring risk management measures to reduce the biosecurity risk to an acceptable level. These pests are:

• fruit flies: peach fruit fly (Bactrocera zonata) and melon fly (Zeugodacus cucurbitae)

The 2 quarantine thrips were also assessed as regulated articles for all of Australia, as they are capable of harbouring and spreading emerging orthotospoviruses that are quarantine pests for Australia.

An additional species, chilli thrips (Scirtothrips dorsalis), has been assessed as a regulated article for Australia as it is capable of harbouring and spreading emerging orthotospoviruses that are quarantine pests for Australia.

• • pest free areas, pest free places of production or pest free production sites; or

  • fruit treatment (such as irradiation)

• addition of Appendix C ‘Stakeholder comments’, which addresses a technical issue raised by a stakeholder in this final report.

1. Introduction

   1. Australia’s biosecurity policy framework

Australia’s biosecurity policies aim to protect Australia against the risks that may arise from exotic pests entering, establishing and spreading in Australia, thereby threatening Australia’s unique flora and fauna, as well as those agricultural industries that are relatively free from serious pests.

Further information about Australia’s biosecurity framework is provided in the Biosecurity Import Risk Analysis Guidelines 2016, located on the department website at agriculture.gov.au/biosecurity-trade/policy/risk-analysis/guidelines.

2. This risk analysis

   1. Background

The Indian Government Department of Agriculture and Farmers Welfare formally requested market access to Australia for fresh okra fruit for human consumption in a submission received in February 2017. This submission provided information on the pests associated with okra in India, including the plant parts affected. Information was also provided on the standard commercial production practices for okra in India.

Scope

Figure 1.1 Morphology of okra fruit

Existing policy

International policy

The department has reviewed all the pests and pest groups previously identified in existing policies and, where relevant, the information in those assessments has been considered in this risk analysis. The department has also reviewed the latest scientific literature and other information to ensure that the previous assessments are still valid.

The biosecurity risk posed by thrips and the orthotospoviruses they transmit was previously assessed for all countries in the Final group pest risk analysis for thrips and orthotospoviruses on fresh fruit, vegetable, cut-flower and foliage imports (thrips Group PRA) (DAWR 2017).

Domestic arrangements

Contaminating pests

In addition to the pests of okra from India that are assessed in this risk analysis, other organisms may arrive with the imported commodity. These organisms may include pests considered not to be associated with the fruit pathway, pests of other crops, or predators and parasitoids of arthropods. The department considers these organisms to be contaminating pests (‘contaminants’) that could pose sanitary (to human or animal life or health) or phytosanitary (to plant life or health) risks. These risks are identified and addressed using existing operational procedures that require an inspection of all consignments during processing and preparation for export. Consignments will also undergo a verification process on arrival in Australia. The department will investigate whether any pest identified through import verification processes may be of biosecurity concern to Australia and may thus require remedial action.

Consultation

On 21 February 2021, the department notified stakeholders, in Biosecurity Advice 2021-P02, of the commencement of a review of biosecurity import requirements to assess a proposal by India for market access to Australia for okra for human consumption.

Overview of this pest risk analysis

A pest risk analysis (PRA) is 'the process of evaluating biological or other scientific and economic evidence to determine whether an organism is a pest, whether it should be regulated, and the strength of any phytosanitary measures to be taken against it' (FAO 2017a). A pest is ‘any species, strain or biotype of plant, animal, or pathogenic agent injurious to plants or plant products’ (FAO 2022). This definition is also applied in the Biosecurity Act 2015.

The department conducted this PRA in accordance with Australia’s method for pest risk analysis (Appendix A), which is consistent with the International Standards for Phytosanitary Measures (ISPMs), including ISPM 2: Framework for pest risk analysis (FAO 2019a) and ISPM 11: Pest risk analysis for quarantine pests (FAO 2019b), and the WTO Agreement on the Application of Sanitary and Phytosanitary Measures (the SPS Agreement) (WTO 1995).

1. Initiation—identification of:

   • the pathway being assessed in the risk analysis

3. Pest risk management—the process of identifying and proposing/recommending required phytosanitary measures to reduce the biosecurity risk to achieve the ALOP for Australia where the URE is determined as not achieving the ALOP for Australia. Restricted risk is estimated with these phytosanitary measure(s) applied.

A phytosanitary measure is ‘any legislation, regulation or official procedure having the purpose to prevent the introduction or spread of quarantine pests, or to limit the economic impact of regulated non-quarantine pests’ (FAO 2022).

• initiation and pest categorisation see: Appendix B

• pest risk assessments for pests/pest groups identified in Appendix B as requiring further pest risk assessment see: Chapter 3

• 1. Next steps

Commercial production practices for okra in India

Considerations used in estimating unrestricted risk

India provided a technical market access submission to Australia that included information on commercial production practices of okra in India.

Officers from the department visited okra farms, packing houses and treatment (e.g., irradiation) facilities in the Indian states of Maharashtra and Gujarat in December 2022. The objective of the visit was to observe commercial production, pest management and other export practices. The observations during the visit and additional information provided confirmed the production and packing procedures described in this chapter as standard commercial production practices for okra for export from India.

Production areas of okra

Climate in production areas

India has a wide range of climatic conditions, including high-rainfall tropical areas in the south-west, temperate conditions in the north to north-east, montane-alpine environments in the far north and arid to semi-arid areas in the central-western regions (Beck et al. 2018).

The 4 seasons experienced in India are:

As a result of the large geographic range of India, different parts of the country experience different ranges of temperature and rainfall even during the same month or season.

Okra is grown in tropical, sub-tropical and warm temperate regions, with year-round production in the states of Gujarat, Odisha and West Bengal (APEDA 2015). Okra is highly susceptible to low temperatures and frost, failing to germinate at temperatures below 20°C (Reddy 2019a). Temperatures above 42°C slow plant and fruit growth (Dhankhar & Mishra 2005).

Figure 2.1 Mean monthly minimum and maximum temperatures and mean monthly rainfall in the main okra production states in India

1. Pre-harvest

   1. Cultivars

A brief description of the fruit and yield potential of the widely grown okra varieties developed in India is given in Table 2.1.

Table 2.1 Main commercial okra varieties cultivated in India

Cultivation practices

Planting season

Farm preparation and planting

Figure 2.2 Okra crop using plastic mulch to preserve water and manage weed growth

Pest management

Okra fields are registered with the respective state agriculture department and crop management is supervised by the respective state agriculture department and the National Plant Protection Organisation (NPPO), the Department of Agriculture and Farmers Welfare (DAFW). Official inspections are undertaken in the place of production at appropriate times during the growing season to check for the presence of pests and diseases in okra crops. Field inspections are primarily carried out by officials from the respective state agriculture department and, if required, by officials from DAFW (Government of India 2021).

Okra farmers implement a wide range of pest control regimes. Chemical control and cultural practices are commonly applied in an integrated program to reduce pest incidence, and bio-control agents such as Beauveria bassiana may also be used (Government of India 2017a; Kedar, Kumerang & Thodsare 2013; Sushil et al. 2020). Government programs are in place that aim to educate farmers in the proper use of control techniques and integrated pest management procedures (Satyagopal et al. 2014). Surveillance of pest and disease hotspots is undertaken periodically by private institutions and by state and federal government officials (Government of India 2017a). Table 2.2 outlines some control methods used for common pests of okra.

Table 2.2 Example of pest management techniques for okra in India

Source: Chittora and Singh (2016); Government of India (2017a); Samnotra et al. (2016); Sushil et al. (2020)

Harvesting and handling procedures

Source: Tuskegee University (2009)

Post-harvest

Source: Infonet (2019)

Packing houses which receive okra intended for export are inspected and certified by the Pack House Inspection Committee constituted by the Agricultural and Processed Food Products Export Development Authority (APEDA). The Pack House Inspection Committee consists of a member of the horticulture division from APEDA head office, a member from the regional APEDA office, a member from the Directorate of Marketing and Inspection, and a member of the state agriculture department (APEDA 2014). To obtain certification, a packing house must meet prescribed standards of quarantine safety, including a separate plant quarantine area for phytosanitary inspection at the point of export (APEDA 2014). The suitability of packing house infrastructure for safe commodity handling and storage, including facilities for pre-cooling and cool storage, are covered by the certification process, and internal quality assurance systems are validated for storage and hygiene practices, and record keeping and traceability (APEDA 2014).

Packing house processes

Sorting and grading

Figure 2.6 Okra being sorted and graded

Packing

Source: Government of India (2021)

Phytosanitary inspection

Transport

4. Export capability

   1. Production statistics

India is the largest producer of okra in the world, producing 6,075,900 t during the 2017–18 growing season. A summary of okra production for major okra producing Indian states is provided in Table 2.3.

Table 2.3 Okra production in major okra producing states of India (2017-18 growing season)

Export statistics

Export season

Peak (■), lean (■), and year-round (■) growing seasons in major okra producing states. Adapted from: APEDA (2015)

2. Pest risk assessments for quarantine pests

   1. Summary of outcomes of pest initiation and categorisation

The initiation process (Appendix B) identified 219 pests as being associated with okra in India.

In applying the Group PRAs, 3 thrips, 2 mealy bugs and a scale insect were identified on the import pathway and listed in the pest categorisation (Appendix B). However, if any other quarantine thrips or regulated articles, mealy bugs or scale insects not included in this risk analysis and/or in the respective Group PRAs are detected at pre-export inspection or on arrival in Australia, the appropriate Group policy will also apply to those pests. The application of the Group PRAs to this risk analysis is outlined in Appendix A in section A2.7.

Pests requiring further pest risk assessment

The 10 pests, associated with commercially produced okra for export from India, identified as requiring further pest risk assessment, are listed in Table 3.1. Of these 10 pests:

Table 3.1 Quarantine pests and regulated articles associated with okra from India, and requiring further pest risk assessment

Overview of pest risk assessment

This chapter assesses, for each of the pests or pest groups identified in Table 3.1, the likelihoods of entry, establishment and spread, and the magnitude of the associated potential consequences these species may cause if they were to enter, establish and spread in Australia.

All of the pests or pest groups in Table 3.1 have been assessed previously by the department. Where appropriate, the outcomes of the previous assessments for these pests have been adopted for this risk analysis, unless new information is available that suggests the risk would be different. The acronym ‘EP’ is used to identify species assessed previously and for which import policy already exists. The process relating to the adoption of outcomes from previous assessments is outlined in Appendix A in section A2.6.

A summary of the likelihood, consequence and URE ratings obtained in each pest risk assessment is provided in Table 3.8. An overview of the decision process at the initiation, pest categorisation and pest risk assessment stages of this PRA is presented diagrammatically in Figure 3.1.

Peach fruit fly and melon fly

Bactrocera zonata (EP) and Zeugodacus cucurbitae (EP)

Bactrocera zonata (peach fruit fly) and Zeugodacus cucurbitae (melon fly) belong to the Tephritidae family, a group of fruit flies considered to be among the most damaging pests of horticultural crops. These fruit fly species have not been reported in Australia and therefore are quarantine pests for all of Australia.

Bactrocera zonata has been assessed previously in the existing policies for pomegranates from India (DAWE 2020a) and mangoes from Indonesia, Thailand and Vietnam (DAWR 2015). Zeugodacus cucurbitae has been assessed previously in existing policies (as B. cucurbitae and Z. cucurbitae) in jujubes from China (Department of Agriculture 2020), lychees from Taiwan and Vietnam (DAFF 2013), and longans and lychees from China and Thailand (DAFF 2004). In those policies, the UREs for B. zonata and Z. cucurbitae were assessed as not achieving the ALOP for Australia and specific risk management measures were required.

The current assessment of these fruit flies builds on the previous assessments. However, there may be differences in commercial production practices, climatic conditions, fruit biology, and pest prevalence between the previously assessed commodity/country pathways and okra from India. These differences make it necessary to reassess the likelihood that these fruit flies will be imported into Australia with okra from India.

Likelihood of entry

The likelihood of entry is considered in 2 parts: the likelihood of importation and the likelihood of distribution, which consider pre-border and post-border issues, respectively.

Likelihood of importation

• Bactrocera zonata and Z. cucurbitae are present in India, and India produces okra throughout the year (EPPO 2021; Government of India 2017a).

• Okra has been reported to be a viable host for B. zonata and Z. cucurbitae, although fruit fly infestation of okra in the field has never been reported in India and is rarely reported in other countries (El-Gendy 2017; Kumagai, Tsuchiya & Katsumata 1996; Syed, Ghani & Murtaza 1970; Wong et al. 1989).

• Okra grows best in temperatures of 22°C to 35°C (Government of India 2017a), which are favourable temperatures for the development of fruit flies. Therefore, it is possible that fruit flies could infest okra in India prior to harvest.

• There are no reports available on what stage(s) of okra fruit (e.g., immature, mature and/or hardened) is able to be infested by these fruit flies, considering okra is harvested when fruit are immature.

Fruit fly eggs and larvae may remain viable during cold transport and storage.

• The development time of fruit flies is inversely dependent on temperature, with development time increasing at lower ambient temperature (Duyck, Sterlin & Quilici 2004; Fletcher 1989; Mkiga & Mwatawala 2015).

Likelihood of distribution

The likelihood that the assessed fruit flies will be distributed within Australia in a viable state as a result of the processing, sale or disposal of okra from India, and subsequently transfer to a susceptible part of a host, is likely to be similar to B. zonata and Z. cucurbitae on previously assessed pathways. The same rating of High for the likelihood of distribution for these fruit flies in previous assessments is adopted for okra from India.

Likelihoods of establishment and spread

Overall likelihood of entry, establishment and spread

The overall likelihood of entry, establishment and spread is determined by combining the individual likelihoods of entry, of establishment and of spread using the matrix of rules in Table A.2.

The overall likelihood that fruit flies will enter Australia as a result of trade in okra from India, be distributed in a viable state to a susceptible part of a host, establish in Australia and subsequently spread within Australia is assessed as Very Low.

Consequences

Unrestricted risk estimate

Papaya mealybug and Madeira mealybug

Two mealybug species on the okra from India pathway, Paracoccus marginatus (papaya mealybug) and Phenacoccus madeirensis (Madeira mealybug), were identified as quarantine pests for Australia.

The indicative likelihood of entry for all mealybug species is assessed in the mealybugs Group PRA as Moderate (DAWR 2019). Phenacoccus marginatus and P. madeirensis are reported from India and have been associated with okra (Ben-Dov 1994; Kedar, Kumerang & Thodsare 2013; Sakthivel et al. 2012; Shylesha & Joshi 2012). Standard packing house processes and transportation are not expected to eliminate these mealybugs from the pathway. After assessment of relevant pathway-specific factors (sections A2.6 and A2.7) for okra from India, likelihoods of entry of Moderate were verified as appropriate for these mealybug species on this pathway (Table 3.2).

This risk assessment, which is based on the mealybugs Group PRA, applies to all quarantine mealybugs on the okra from India pathway, irrespective of their specific identification in this document. This process is further described in section A2.7.

Mulberry scale

Pseudaulacaspis pentagona (GP, WA)

As assessed in the scale insects Group PRA, the indicative URE for scale insects is Low (Table 3.4), which does not achieve the ALOP for Australia. This indicative URE is considered to be applicable for the quarantine scale insects on the okra from India pathway. Therefore, specific risk management measures are required for the quarantine scale insect pests on this pathway.

This risk assessment, which is based on the scale insects Group PRA, applies to all quarantine scale insects on the okra from India pathway, irrespective of their specific identification in this document. This process is further described in section A2.7.

Eurasian flower thrips, chilli thrips and melon thrips

Scirtothrips dorsalis is present in Australia and is not under official control and, therefore, is not a quarantine pest for Australia.

Frankliniella intonsa, S. dorsalis and T. palmi are identified as regulated articles because they are capable of harbouring and spreading (vectoring) emerging orthotospoviruses that are quarantine pests for Australia, as detailed in the thrips Group PRA (DAWR 2017).

A summary of the risk assessment for quarantine thrips is presented in Table 3.6 for convenience.

Table 3.6 Risk estimates for quarantine thrips

As assessed in the thrips Group PRA, the URE for emerging quarantine orthotospoviruses transmitted by regulated thrips is Low (Table 3.7), which does not achieve the ALOP for Australia.

This URE is considered to be applicable for the emerging orthotospoviruses known to be vectored by the thrips species present on the okra from India pathway. Therefore, specific risk management measures are required for the regulated thrips to mitigate the risks posed by emerging quarantine orthotospoviruses.

Okra spider mite and okra mite

Tetranychus macfarlanei has been reported from India, Bangladesh, Madagascar, Mauritius and the Canary Islands (Bolland, Gutierrez & Flechtmann 1998; Jeppson, Keifer & Baker 1975; Ullah et al. 2012; Vacante 2016). Tetranychus truncatus is widely distributed in Southeast Asia, including India (Bachhar et al. 2019; Srinivasan et al. 2012) and Indonesia, and extends to Japan and Korea in the east, and to Iran in the west (Bolland, Gutierrez & Flechtmann 1998; Vacante 2016).

Tetranychid mites have 5 distinct life stages: egg, larva, protonymph, deutonymph and adult. At the end of the active larval stage there is a quiescent phase called nymphochrysalis, and at the completion of each nymphal stage, the quiescent phases are deutochrysalis and teliochrysalis (Sakunwarin, Chandrapatya & Baker 2003). After the teleiochrysalis quiescent phase, the deutonymph moults into the adult stage.

Tetranychus macfarlanei and T. truncatus have not been previously assessed by the department. However, a pest group of tetranychid mites has previously been assessed by the department and import policies for tetranychid mites already exist. Tetranychus canadensis, T. mcdanieli, T. pacificus and T. turkestani have been assessed in the final import risk analysis report for stone fruit from California, Idaho, Oregon and Washington (stone fruit from the USA) (Biosecurity Australia 2010).

Tetranychus macfarlanei and T. truncatus have similar biological characteristics to 2 of those spider mite species - T. pacificus and T. turkestani - including:

The assessment of spider mites on stone fruit from the USA (Biosecurity Australia 2010) rated the likelihood of distribution as Moderate. Okra fruit are expected to be distributed in Australia as a result of the processing, sale or disposal of the imported produce in a similar way to stone fruit from the USA. Fruit that are unmarketable are likely to be disposed of as municipal waste, from where it is unlikely that spider mites will be distributed into the environment. From domestic situations, fruit waste disposed of as litter may be deposited into urban or peri-urban situations, as well as areas of natural vegetation. Spider mites on both pathways have a polyphagous habit. They can infest a wide range of agricultural and horticultural crops and hosts that can be found in domestic gardens, as well as in urban environments as amenity plants or weeds. Therefore, the time of year when importation occurs will not affect the likelihood of distribution for these spider mites. On the basis outlined, the likelihood of distribution of Moderate previously assessed for spider mites on the stone fruit from the USA pathway has been adopted for spider mites on the okra fruit from India pathway.

The likelihoods of establishment and spread of spider mites on okra from India will be comparable with spider mites on stone fruit from the USA because these likelihoods relate specifically to events that occur in Australia and are independent of the import pathway. The consequences of entry, establishment and spread of spider mites in Australia are also independent of the import pathway. The existing ratings for the likelihoods of establishment and spread, and the rating for the overall consequences for spider mites on the stone fruit from the USA pathway have been adopted for spider mites on the okra from India pathway.

Likelihood of entry

The likelihood that the assessed spider mites will arrive in Australia in a viable state with the importation of okra from India is assessed as High.

The likelihood of importation is assessed as High because T. macfarlanei and T. truncatus are present in India and the okra plant is known to be a viable host for completion of development. Okra is a perishable fruit that requires careful handling during post-harvest processing to avoid damage to the fruit surface. Therefore, spider mite adults, juveniles or eggs residing on the fruit surface may not be dislodged during postharvest handling. Sorting and grading procedures in packing houses may not detect and remove these development stages as they are small and difficult to observe without a magnification device such as a hand lens. Some adults, nymphs or eggs may survive the low temperatures during storage and transportation of okra. Various spider mite species have been intercepted numerous times on imported fresh produce on arrival in Australia.

• Okra grows best at temperatures of 22°C to 35°C, which covers the optimal temperature ranges for development of T. macfarlanei (Borkar, Kolhe & Undirwade 2020; Latha et al. 2019; Ullah et al. 2012) and T. truncatus (Sakunwarin, Chandrapatya & Baker 2003; Win et al. 2018). All immature stages and adults would likely be present in okra fields during pod development and harvest.

Spider mites are primarily pests of leaves but can also be found on fruit. Spider mite adults, juveniles or eggs present on fruit are unlikely to be completely removed during harvesting and post-harvest processes.

• Okra fruit provide some points, such as the remnant of the peduncle, and base of ridges and spines/hairs on the surface (often present on heirloom varieties), where spider mites may reside.

Storage and transport conditions are unlikely to kill all life stages of spider mites.

• The larval period is relatively short, up to 2 days (Borkar, Kolhe & Undirwade 2020; Pang et al. 2004; Sakunwarin, Chandrapatya & Baker 2003), and larvae enter the nymphochrysalis quiescent stage in a shorter time as ambient temperatures increase (Ullah et al. 2012; Win et al. 2018). Following their emergence from eggs on the leaves, larvae need to migrate to fruit and are unlikely to survive an extended period of cool conditions during postharvest storage.

• Eggs are not reported to be laid on okra fruit. However, at high population densities, adult females may disperse to the fruit and incidental egg laying may occur. At low temperatures (7°C to 10°C), the viability of eggs is low and the mortality rate of emerging larvae is high (Sakunwarin, Chandrapatya & Baker 2003; Ullah et al. 2012).

The likelihood that the assessed spider mites will be distributed within Australia in a viable state as a result of the processing, sale or disposal of okra from India and subsequently transfer to a susceptible part of a host, is likely to be similar to the spider mite species previously assessed on the stone fruit from the USA (Biosecurity Australia 2010). The same rating of Moderate for the likelihood of distribution for spider mite species in the previous assessment is adopted for the assessed spider mites for okra from India.

Overall likelihood of entry

Likelihoods of establishment and spread

Overall likelihood of entry, establishment and spread

The overall likelihood that spider mites will enter Australia as a result of trade in okra fruit from India, be distributed in a viable state to a susceptible part of a host, establish in Australia and subsequently spread within Australia is assessed as Moderate.

Consequences

The potential consequences of the entry, establishment and spread of T. macfarlanei and T. truncatus in Australia are similar to those in the previous assessments of spider mite species for stone fruit from the USA (Biosecurity Australia 2010). The overall consequences in the previous assessments were assessed as Low. The overall consequences for spider mites on the okra from India pathway are also assessed as Low.

Unrestricted risk estimate

Pest risk assessment conclusions

• The UREs for the 9 quarantine pests were assessed as not achieving the ALOP for Australia, and thus specific risk management measures are required for these quarantine pests on this pathway. These pests are:

  • peach fruit fly (Bactrocera zonata)

  • Eurasian flower thrips (Frankliniella intonsa)

  • melon thrips (Thrips palmi)

Table 3.8 Pest risk assessment conclusions for pests, and pest groups, associated with the pathway of okra from India

EP: Species has been assessed previously and import policy already exists. GP: Species has been assessed previously in a Group PRA and the Group PRA has been applied. RA: Regulated article. WA: Regional quarantine pest for Western Australia. SA: Regional quarantine pest for South Australia. EES: Overall likelihood of entry, establishment and spread. URE: Unrestricted risk estimate. a: Quarantine thrips species that is also identified as a regulated article for Australia as it can vector emerging quarantine orthotospoviruses, and this table presents the risk estimates for these viruses from the thrips Group PRA (DAWR 2017a). N/A: not applicable, as S. dorsalis is present in Australia and is not a quarantine pest.

Pest risk management

Pest risk management measures and phytosanitary procedures

Historical trade and pest interception data of other similar pathways, as described in section 4.1.1, have been considered in determining the appropriate risk management measures for the importation of okra from India.

Analysis of pest interception data

Australia currently allows imports of fresh okra fruit from Fiji. However, there have been no imports of okra from Fiji since 2018. Between 2013 and 2017, Fiji exported a total of 3.6 t of okra to Australia. Interception data of okra from Fiji showed 2 detections of larvae of noctuid moths, which were appropriately actioned.

Risk management measures for quarantine pests and regulated articles associated with okra from India

a: PFA is pest free area, PFPP is pest free place of production and PFPS is pest free production site. b: Remedial action may include treatment of the consignment to ensure that the pest is no longer viable, or withdrawal of the consignment from export to Australia. c: Quarantine thrips species that is also identified as a regulated article for Australia as it vectors emerging quarantine orthotospoviruses, assessed in the thrips Group PRA (DAWR 2017) as posing an unrestricted risk that does not achieve the ALOP for Australia. EP: Species has been assessed previously and import policy already exists. RA: Regulated article. GP: Species has been assessed previously in a Group PRA and the Group PRA has been applied. SA: Regional quarantine pest for South Australia. WA: Regional quarantine pest for Western Australia.

• for mealybugs, scale insects, thrips and spider mites

  • pre-export visual inspection and, if detected, remedial action.

Measures for fruit flies

Recommended measure 1: Pest free area, pest free place of production or pest free production site

Recommended measure 2: Fruit treatment such as irradiation

Fruit treatment known to be effective for all life stages of fruit flies such as irradiation applied pre-export may be used as a phytosanitary measure for B. zonata and Z. cucurbitae. The requirements for using irradiation as a phytosanitary measure are set out in ISPM 18: Guidelines for the use of irradiation as a phytosanitary measure (FAO 2019c). Irradiation is recognised as an effective method for pest risk management when performed in approved facilities and at specific dose rates recognised as effective for target pest groups. Food Standards Australia New Zealand permits irradiation dose rates up to a maximum of 1000 gray for quarantine purposes for fresh fruits and vegetables including okra (FSANZ 2017).

The department recommends a treatment schedule of 150 gray minimum absorbed dose, consistent with ISPM 28 Annex 7: Irradiation treatment for fruit flies of the family Tephritidae (generic) (FAO 2017b) for B. zonata and Z. cucurbitae.

Measures for mealybugs, scale insects, thrips and spider mites

Recommended measure: Pre-export visual inspection and, if found, remedial action

Consideration of alternative measures

Operational system for the assurance, maintenance and verification of phytosanitary status

A system of operational procedures is necessary to ensure recommended specific risk management measures (section 4.1) are effectively applied, the phytosanitary status of okra from India is maintained, and these can be verified.

A system of traceability to source farms

The objectives of this recommended procedure are to ensure that:

Where a pest risk management measure involving pest monitoring and controls during production and at harvest (such as PFA, PFPP, PFPS or systems approach) is used, export farms must be registered with DAFW before commencement of each harvest season. Records of registered farms and DAFW audits must be kept by DAFW and must be made available to the department upon request.

Registration of packing houses and treatment providers, and auditing of procedures

The objectives of this recommended procedure are to ensure that:

The approval of treatment providers by DAFW must include verification that suitable systems are in place to ensure compliance with treatment requirements. This may include:

• documented procedures to ensure okra are appropriately treated and safeguarded post treatment

The department provides final approval of facilities, following review of regulatory oversight provided by DAFW and the capability demonstrated by the facility. Site visits may be required for the department to have assurance that treatment can be applied accurately and consistently.

The department requires final approval for irradiation facilities.

Packaging, labelling and containers

• secure packaging is used for export of okra from India to Australia to prevent re-infestation during storage and transport and prevent escape of pests during clearance procedures on arrival in Australia. Packaging must meet Australia’s secure packing options published on BICON

• consignments are made insect-proof and secure by using at least one of the following secure consignment options:

  • produce transported in fully enclosed containers: cartons (packages) with holes as loose boxes or on pallets may be transported in fully enclosed containers. Enclosed containers include 6-sided containers with solid sides, or ULDs with tarpaulin sides that have no holes or gaps. The container must be transported to the inspection point intact.

• packaged okra from India must be labelled with sufficient identification for the purposes of traceability. This may include:

Export packing houses and treatment providers (where applicable) must ensure packaging and labelling are suitable to maintain phytosanitary status of the export consignments.

Specific conditions for storage and movement

The objective of this recommended procedure is to ensure that the quarantine integrity of the okra is maintained during storage and movement.

Freedom from trash

Pre-export phytosanitary inspection and certification by the Indian Government Department of Agriculture and Farmers Welfare

All consignments must be inspected prior to export in accordance with official procedures for all visually-detectable quarantine pests and regulated articles (including trash). Sampling and inspection methods should be consistent with ISPM 23 (FAO 2019d) and ISPM 31 (FAO 2016b) and provide a 95% level of confidence that infestation greater than 0.5% will be detected. For a consignment equal to or greater than 1 000 units (one unit being a single okra fruit), this is equivalent to a 600-unit sample randomly selected across the consignment. Any netting or artificial wrapping material must be removed during the inspection. The inspection technique must be capable of detecting all life stages of quarantine pests.

A phytosanitary certificate must be issued for each consignment upon completion of pre-export inspection and treatment to verify that the required risk management measures have been undertaken prior to export and that the consignment meets Australia’s import requirements.

Some treatments (such as irradiation) may also require treatment certificates that accompany the phytosanitary certificate. BICON will describe where treatment certificates are required.

Phytosanitary inspection by the Department of Agriculture, Fisheries and Forestry

The objectives of this recommended procedure are to ensure that:

• assess documentation to verify that the consignment is as described on the phytosanitary certificate, that required phytosanitary actions have been undertaken, and that product security has been maintained

• verify that the biosecurity status of consignments of okra from India meet Australia’s import requirements. When inspecting consignments, the department will use random samples of 600 units, or equivalent per phytosanitary certificate and an inspection method suitable for the commodity.

  1. Remedial action(s) for non-compliance

Other actions, including partial or complete suspension of the import pathway, may be taken depending on the identity and/or importance of the pest intercepted, for example, fruit flies of economic importance or pests for which PFAs, PFPPs or PFPSs are established.

In the event that consignments of okra from India are repeatedly non-compliant, the department may require enhanced risk management measures, including mandatory phytosanitary treatment. The department reserves the right to suspend imports (either all imports, or imports from specific pathways) and to conduct an audit of the risk management systems. Imports will be allowed to recommence only when the department is satisfied that appropriate corrective action has been undertaken.

Uncategorised pests

Review of processes

Verification of protocol

Review of policy

DAFW must inform the department immediately on the detection of any new pests of okra in India that might be of potential biosecurity concern to Australia.

Meeting Australia’s food laws

In addition to meeting Australia’s biosecurity laws, imported food for human consumption must comply with the requirements of the Imported Food Control Act 1992, as well as Australian state and territory food laws. Among other things, these laws require all food, including imported food, to meet the standards set out in the Australia New Zealand Food Standards Code (the Code).

Certain imported food, including some minimally processed horticulture products, must be covered by a food safety management certificate to be imported into Australia. The certificate provides evidence that a food has been produced through a food safety management system. This system must have appropriate controls in place to manage food safety hazards. More information about the foods that require a food safety management certificate and how to comply is available at agriculture.gov.au/biosecurity-trade/import/goods/food/lodge/safety-management-certificates.

Conclusion

This final risk analysis report was conducted to assess the proposal by India for market access to Australia for fresh okra fruit for human consumption.

All fresh fruit, including okra fruit from India, have been determined by the Director of Biosecurity to be conditionally non-prohibited goods under s174 of the Biosecurity Act 2015. Conditionally non-prohibited goods cannot be brought or imported into Australia unless they meet specific import conditions.

This report, upon its finalisation, provides the basis for import conditions for fresh okra fruit from India for human consumption. The import conditions will be communicated on BICON. The publication of import conditions on BICON is subject to India being able to demonstrate that processes and procedures are in place to implement the required risk management measures.

Appendix A: Method for pest risk analysis

Restricted risk is estimated with phytosanitary measure(s) applied. A phytosanitary measure is ‘any legislation, regulation or official procedure having the purpose to prevent the introduction or spread of quarantine pests, or to limit the economic impact of regulated non-quarantine pests’ (FAO 2022).

A PRA is conducted in 3 consecutive stages: initiation (A1), pest risk assessment (A2) and pest risk management (A3).

Stage 1: Initiation

• the identification of a pathway that presents a potential pest hazard. For example, international trade is requested for a commodity not previously imported into the country or a commodity from a new area or new country of origin

• the identification of a pest that may require phytosanitary measures. For example, a new pest risk is identified by scientific research, a pest is repeatedly intercepted, a request is made to import an organism, or an organism is identified as a vector of other pests

• potential association of each pest with the pathway being assessed.

The identity of the pests is presented at species level by the species’ scientific name in most instances, but a lower taxonomic level may be used where appropriate. Synonyms are provided where the current scientific name differs from that provided by the exporting country’s National Plant Protection Organisation (NPPO) or where the cited literature used a different scientific name.

Stage 2: Pest risk assessment

• pest categorisation (A2.1) and

• further pest risk assessment, which includes evaluation of the likelihood of the introduction (entry and establishment) and spread of a pest (A2.2) and evaluation of the magnitude of the associated potential consequences (A2.3).

Pest categorisation

• potential for entry, establishment and spread in the PRA area

• potential for economic consequences in the PRA area.

Assessment of the likelihood of entry, establishment and spread

Likelihood of entry

• Likelihood of importation—the likelihood that a pest will arrive in Australia in a viable state when a given commodity is imported

• Likelihood of distribution— the likelihood that the pest will be distributed in a viable state, as a result of the processing, sale or disposal of the commodity, in the PRA area and subsequently transfer to a susceptible part of a host.

• • mode of trade (for example, bulk, packed)

  • volume and frequency of movement along each pathway

• • vulnerability of the life-stages of the pest during transport or storage

  • prevalence of the pest likely to be associated with a consignment

• dispersal mechanisms of the pest, including vectors, to allow movement from the pathway to a suitable host

• whether the imported commodity is to be sent to a few or many destination points in the PRA area

Likelihood of establishment

Establishment is defined as the ‘perpetuation for the foreseeable future, of a pest within an area after entry’ (FAO 2022). In order to estimate the likelihood of establishment of a pest, reliable biological information (for example, lifecycle, host range, epidemiology, survival) is obtained from the areas where the pest currently occurs. The situation in the PRA area can then be compared with that in the areas where it currently occurs and expert judgement used to assess the likelihood of establishment.

Factors to be considered in the likelihood of establishment in the PRA area may include:

• • whether a vector, if needed for dispersal of the pest, is already present in the PRA area or likely to be introduced

• suitability of environment in the PRA area

• • potential for adaptation of the pest

  • minimum population needed for establishment.

Likelihood of spread

• potential for movement with commodities, conveyances or by vectors

• intended use of the commodity

Assigning likelihoods for entry, establishment and spread

Combining likelihoods

The likelihood of entry is determined by combining the likelihood that the pest will be imported into the PRA area and the likelihood that the pest will be distributed within the PRA area, using a matrix of rules (Table A.2). This matrix is then used to combine the likelihood of entry and the likelihood of establishment, and the likelihood of entry and establishment is then combined with the likelihood of spread to determine the overall likelihood of entry, establishment and spread.

For example, if a descriptor of Low is assigned for the likelihood of importation, Moderate for the likelihood of distribution, High for the likelihood of establishment and Very Low for the likelihood of spread, then the likelihood of importation of Low and the likelihood of distribution of Moderate are combined to give a likelihood of Low for entry. The likelihood for entry is then combined with the likelihood assigned for establishment of High to give a likelihood for entry and establishment of Low. The likelihood for entry and establishment is then combined with the likelihood assigned for spread of Very Low to give the overall likelihood for entry, establishment and spread of Very Low. This can be summarised as:

Time and volume of trade

One factor affecting the likelihood of entry is the volume and duration of trade. If all other conditions remain the same, the overall likelihood of entry will increase as time passes and the overall volume of trade increases.

The department normally considers the likelihood of entry on the basis of the estimated volume of one year’s trade. This is a convenient value for the analysis that is relatively easy to estimate and allows for expert consideration of seasonal variations in pest presence, incidence and behaviour to be taken into account. The consideration of the likelihood of entry, establishment and spread and subsequent consequences takes into account events that might happen over a number of years even though only one year’s volume of trade is being considered. This difference reflects biological and ecological facts, for example where a pest or disease may establish in the year of import but spread may take many years.

Assessment of potential consequences

• the life or health of plants and plant products

  This may include pest impacts on the life or health of the plants and production effects (yield or quality) either at harvest or during storage.

• This may include pest impacts on new or modified eradication, control, surveillance or monitoring and compensation strategies or programs.

• domestic trade

• This may include pest impacts on the community and environment, including reduced tourism, reduced rural and regional economic viability, loss of social amenity, and any ‘side effects’ of control measures.

For each of these direct and indirect criteria, the level of impact is estimated over 4 geographic levels, defined as:

For each criterion, the magnitude of impact at each of these geographic levels is described using 4 categories, defined as:

• Unlikely to be discernible–pest impact is not usually distinguishable from normal day-to-day variation in the criterion

The following are considered during this process:

• At each geographic level below 'National', an impact more serious than ‘Minor significance’ is considered at least 'Minor significance' at the level above. For example, a ‘Significant’ impact at the state or territory level is considered equivalent to at least a ‘Minor significance’ impact at the national level.

For each criterion:

• the level of impact is estimated over 4 geographic levels: local, district, regional and national

Table A.3 Decision rules for determining the overall consequence rating for each pest

Estimation of the unrestricted risk

Once the assessment of the likelihood of entry, establishment and spread and for potential consequences are completed, the unrestricted risk can be determined for each pest or each group of pests. This is determined by using a risk estimation matrix (Table A.4) to combine the estimates of the likelihood of entry, establishment and spread and the overall consequences of pest establishment and spread.

The appropriate level of protection (ALOP) for Australia

Adoption of outcomes from previous assessments

Outcomes of previous risk assessments have been adopted in this assessment for pests for which the risk profile is assessed as comparable to previously assessed situations.

The prospective adoption of previous risk assessment ratings for the likelihood of importation and the likelihood of distribution is considered on a case-by-case basis by comparing factors relevant to the pathway being assessed with those assessed previously. For assessment of the likelihood of importation, factors considered/compared include the commodity type, the prevalence of the pest and commercial production practices in the exporting country/region. For assessment of the likelihood of distribution of a pest the factors considered/compared include the commodity type, the ways the imported produce will be distributed within Australia as a result of the processing, sale or disposal of the imported produce, and the time of year when importation occurs and the availability and susceptibility of hosts at that time. After comparing these factors and reviewing the latest literature, previously determined ratings may be adopted if the department considers the likelihoods for the pathway being assessed to be comparable to those assigned in the previous assessment(s), and there is no new information to suggest that the ratings assigned in the previous assessment(s) have changed.

Application of Group PRAs to this risk analysis

• the Final group pest risk analysis for soft and hard scale insects on fresh fruit, vegetable, cut-flower and foliage imports (scales Group PRA) (DAWE 2021).

The Group PRA approach is consistent with relevant international standards and requirements–including ISPM 2: Framework for Pest Risk Analysis (FAO 2019a), ISPM 11: Pest Risk Analysis for Quarantine Pests (FAO 2019b) and the SPS Agreement (WTO 1995). ISPM 2 states that ‘Specific organisms may … be analysed individually, or in groups where individual species share common biological characteristics.’

Stage 3: Pest risk management

Pest risk management describes the process of identifying and implementing phytosanitary measures to manage risks to achieve the ALOP for Australia, while ensuring that any negative effects on trade are minimised.

The conclusions from pest risk assessment are used to decide whether risk management is required and if so, the appropriate measures to be used. Where the unrestricted risk estimate does not achieve the ALOP for Australia, risk management measures are required to reduce this risk to a very low level. The guiding principle for risk management is to manage risk to achieve the ALOP for Australia. The effectiveness of any proposed/recommended phytosanitary measures (or combination of measures) is evaluated, using the same approach as used to evaluate the unrestricted risk. This ensures the restricted risk for the relevant pest or pests achieves the ALOP for Australia.

• options ensuring that the area, place or site of production or crop is free from the pest—for example, pest-free area, pest-free place of production or pest-free production site

• options for other types of pathways—for example, consider natural spread, measures for human travellers and their baggage, cleaning or disinfestations of contaminated machinery

Appendix B: Initiation and categorisation for pests of okra from India

The Final group pest risk analysis for thrips and orthotospoviruses on fresh fruit, vegetable, cut-flower and foliage imports (DAWR 2017), the Final group pest risk analysis for mealybugs and the viruses they transmit on fresh fruit, vegetable, cut-flower and foliage imports (DAWR 2019) and the Final group pest risk analysis for soft and hard scale insects on fresh fruit, vegetable, cut-flower and foliage imports (DAWE 2021) have been applied in this risk analysis. Application of Group policy involves identification of up to 3 species of each relevant group associated with the commodity pathway. However, if any other quarantine pests or regulated articles not included in this risk analysis and/or in the relevant Group policies are detected at pre-export or on-arrival in Australia, the relevant Group policy will also apply.

The department is aware of the recent changes in fungal nomenclature which ended the separate naming of different states of fungi with a pleomorphic life cycle. However, as the nomenclature for these fungi is in a phase of transition and many priorities of names are still to be resolved, this report uses the generally accepted names and provides alternatively used names as synonyms, where required. The department is also aware of the changes in nomenclature of arthropod species based on the latest morphological and molecular reviews. As official lists of accepted fungus and arthropod names become available, these accepted names will be adopted.

Appendix C: Stakeholder comments

The department received a comment on the published draft report, suggesting that the above two spider mites are unlikely to be associated with okra fruit, as they are primarily foliage pests and are likely to be removed during packing house processes.

The department reviewed the evidence for the presence of spider mites in India and their association with okra fruit. Further examination of the literature supports the original assessment and the association of these pests with okra fruit; therefore, the originally assessed risk ratings have been retained.

Glossary, acronyms and abbreviations

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