Page Content
Appendix F: Major concerns of stakeholders
This appendix summarises the major concerns of stakeholders, as expressed to the Review Committee in written submissions and in consultative meetings and interviews.
Testing rates
Many importers, particularly smaller firms, complained that most of their shipments were inspected and that some foods were always inspected. The testing rates did not appear to be related to the potential food safety hazards associated with the food and there was no relief from testing rates, except for risk categorised foods or certified shipments.
Costs of testing
Costs of tests conducted by IFIP were overly high according to most stakeholders. There were also concerns about the slowness of results from AGAL, which can have a greater impact on importers costs, particularly if foods are held pending results.
Repetitive testing of same products
Most complaints were about foods that are in the active surveillance category, which, according to some importers, are continually tested even when there have been no failures. Importers were unable to get explanations from officers or management on why foods were being tested for particular tests.
Inappropriate tests on products
Many stakeholders commented on the number of occasions when officers selected inappropriate tests for the products they are inspecting. In their opinion, the resultant costs of these tests could not be justified and there were no avenues of redress available.
Inconsistencies in inspection regime throughout different ports
Inconsistency in treatment by inspectorate staff in different ports was a significant problem.
Importers' compliance history is not considered
The present inspection regime treats all importers equally, with no recognition of measures taken by importers to ensure the food imported by them is safe. Importers felt they were not being rewarded for taking measures off-shore which would improve food safety.
Delays in getting inspections done
Stakeholders have commented that since IFIP was integrated with Quarantine there have been increased delays in getting inspections done. Prior to amalgamation, IFIP inspections were almost always able to be arranged for the next day, but now delays can be as long as five days, particularly so in the busier ports of Sydney and Melbourne. Stakeholders complained of a lack of personnel within AQIS to deal with both IFIP inspections and enquiries relating to IFIP matters.
Officers lack of expertise and knowledge of food issues
Many importers commented that officers expertise and knowledge of food issues had deteriorated subsequent to the integration of IFIP with Quarantine. More experienced inspectors were seen as being more knowledgeable and more helpful to industry in providing information and assistance.
Inconsistency in treatment of products by officers
Stakeholders commented that different officers are inconsistent in the way they treat products. Consistency is important to allow importers to forward plan and cost their consignments with some measure of surety.
Poor information provided by IFIP on program and decisions
The need for transparency in the program was highlighted by many stakeholders. Some stakeholders commented that communication with IFIP in general and officers in particular was at an all time low, and was affecting their ability to operate cost effectively.
Holding Orders
Stakeholder comments included:
- no flexibility exists in the application of Holding Orders;
- all importers are penalised, not just the importer of the failing food;
- labelling failures should not have Holding Orders applied to them;
- Holding Orders are not working properly as there are other importers importing the same products that have failed and these do not get inspected or held; and
- many foods in the marketplace do not comply and should have been failed by IFIP.
Inflexibility of the Food Standards Code (not part of this Review)
While this was not part of this Review, there was an overwhelming number of comments by stakeholders on the inflexibility and prescriptiveness of the Food Standards Code. The Food Standards Code is being reviewed and ANZFA has indicated that the new Code will be less prescriptive and will answer many stakeholders concerns about the present format of the Code.
Labelling and description
Importers commented that the prescriptive nature of some labelling requirements contained in the Food Standards Code made it both costly and difficult for them. In particular the need to have a full importers name and street address meant that importers were unable to fully utilise ink jet printing used by manufacturers overseas. This technology has character limits and so was often unable to accommodate a full name and address. Importers suggested that requirements be changed to only requiring the name, telephone number and the registered ACN number on labels. Another area of concern was the need to comply with labelling requirements for additives, particularly colours. Many overseas manufacturers primarily produce for the United States market which has a different format for labelling which results in Australian importers needing to "oversticker" ingredient labels with the Australian ingredient descriptions. This extra expense is difficult to justify in their opinion.
Desire for government involvement
During the course of this Review it became apparent that almost all stakeholders were of the opinion that there was a need for government involvement in regulating the import of food. This was particularly emphasised by consumer groups. Industry sees this involvement as providing both a measure of food safety surety but also as a means of providing a "level playing field" in which they can operate their business. Several importers expressed concerns that without IFIP there would be a plethora of non-compliant and potentially dangerous foods entering Australia and that State and local government agencies would be unable to deal with these. They were concerned that these agencies already treated foods differently in each State or Territory and did not want this exacerbated.