By John Dawes

At press time, we are awaiting Biosecurity Australia’s response to stakeholders’ feedback regarding its Import Risk Analysis (IRA) document “Importation of freshwater ornamental fish: review of the biosecurity risks associated with gourami iridovirus and related viruses” (Draft Import Risk Analysis Report, March 2009). Among the respondents were the Pet Industry Association of Australia (PIAA), Ornamental Fish International (OFI) and the Agri-food and Veterinary Authority (AVA) of Singapore.

Only four cases of iridovirus infection were detected in cichlids during the 18-month testing period commissioned by BA. Credit: John Dawes

Since the AVA’s response was a government-to-government communication, the details are not openly accessible, but they are likely to mirror the sector’s organizations’ reservations. The fact is that, while the IRA sets out to protect Australia’s native fauna, some of the methods used and resultant conclusions are open to serious questioning.

Take, for instance, quarantine. If it has proven effective in detecting pathogens and preventing them from entering the country, the sector organizations question the logic of using such results to impose further legislative restrictions. Yet, this is precisely what it does by proposing measures that are considerably stricter than those in force. This, the trade maintains, is unwarranted.

According to the PIAA, more than 25 million fish were imported into Australia during the 18-month testing program commissioned by Biosecurity Australia. Only four cases of iridovirus infection were detected in cichlids “at the point of importation”, meaning the infection was detected while they were in quarantine. Since there are no data suggesting that any iridovirus-infected fish were released from quarantine, the current quarantine arrangements appear adequate. Further, the PIAA reports that there have not been any disease outbreaks “in more than 40 years.”

While reference is made in the IRA to the detection “of an iridovirus exotic to Australia in several species of gouramis held at two Sydney shops” in 2005, the PIAA questions the assumption that these fish were imported, noting, “It is the understanding from reading the available literature that there is no demonstrable proof that the suspect gouramis were or were not imported.”

The PIAA also questions the assumption that the fish were exotic, reporting, “…the data presented makes a fundamental assumption—that the virus is not already present in Australia. Data quoted…makes it clear that the virus has been present in Australia, and anecdotal reports by Department scientists during the consultation process suggest strongly that the virus is present within Australia. If the virus is endemic, or regionally endemic, in Australia, then the proposed changes…constitute a trade barrier in breach of Australia’s WTO obligations.”

This point is also argued by OFI, writing, “In nature, animals are not infected by injection, by an overdose of pathogens or by feeding heavily infected food. Basing legislation on susceptibility resulting from laboratory experiments only is addressing theoretical risks only. In the eyes of export countries, it may be seen as unjustified trade barriers under WTO-SPS agreements.”

The IRA lists Norman’s lampeye (Aplocheilichthys normani) as harbouring the African lampeye iridovirus. However, importing this species into Australia is banned, so whether or not it can infect other fish is irrelevant. Therefore, in the opinion of the PIAA, it should not be included in the IRA.

The PIAA questions many other aspects of the IRA, such as some of the procedures used as a basis for the document’s recommendations, including debatable experimental methods with regard to guppy iridovirus. It puts forward well-argued cases follow-up studies to confirm, revise or reject the IRA conclusions, making repeated pleas for “good science” to be applied before any legally binding decisions are made. It also submits its own recommendations in the hope that they will lead to a more accurate assessment than it believes is represented by the current situation.

Further, it “acknowledges the responsibility it has in partnering the Australian government in ensuring minimal risk to Australian biosecurity and biodiversity” and what it refers to as an “excellent” level of consultation between BA and the PIAA to date.

Such sentiments are echoed by OFI, noting that “OFI promotes the trade in healthy ornamental fishes and thus supports all initiatives to improve the health of the animal trade… We value it when regulations are based on sound scientific evidence, but also when the scientific basis…can be questioned if not sound, in our view, or the national stakeholder’s view… We also support measures where scientifically sound risk analyses indicate the necessity for such measures.”

It is too early to know how the industry’s comments have been received, or what influence they will have. However, bearing in mind the “excellent” level of consultation enjoyed between the PIAA and the Australian government to date, there must be some degree of optimism that commonsense and good science will significantly influence the final outcome.

ACKNOWLEDGEMENTS
I would like to extend my most sincere thanks to the Pet Industry Association of Australia and to Ornamental Fish International for their assistance during the preparation of this report. <HOME>

This article first appeared in the November 2009 issue of Pet Product News International.