In this edition, there are significant changes proposed in the transitional facility (TF) area that may affect some of you. Over the past three years, MPI has taken a more robust management approach to provide confidence across how TFs are managed. This is because the 720,000 sea containers entering New Zealand every year represent a significant pathway for the potential entry of contaminants and hitchhiker organisms. The dispersal of biosecurity risk material is inadvertently increased by these containers being moved to thousands of widely separated TFs across New Zealand. This is compared with the limited number of air and sea ports in New Zealand that provide biosecurity clearance for millions of passengers and other risk goods. There is also significant variation with the scale of TF operations, ranging from processing a single container per year to many thousands.
The proposed approaches are to:
Increase our enforcement options by introducing infringements for non-compliant TFs.
Introduce increased security requirements.
Applying a minimum number of containers that must be imported per year for approval and
Introducing online internal audit reporting.
This edition also includes updates on caravan inspections, what TF Operators need to do if they voluntarily cancel their TF approval, new import rules to stop brown marmorated stink bug, proposal on 100% AP reporting through the Container Check Portal, and other relevant information. Given these are important changes, we will also be sending an email to all TF Operators.
At present, MPI only infringes air passengers who fail to properly declare risk goods they bring into New Zealand. From 2019, MPI plans to introduce new biosecurity infringement offences in other pathways, including TFs. The introduction of infringements in other pathways will send a strong message about the critical nature of compliance and will deter people and organisations from breaking the rules. The infringements will be applied for offending that is not significant enough to warrant prosecution.
The fines are proposed to be $400 for individuals and $800 for companies. There are two new infringement offences that will allow us to infringe companies operating TFs or TF Operators. This would be for those TFs who do not have an approved TF Operator or those Operators who do not comply with applicable operating standards (details on what will be infringed to be finalised). Note that when Operators identify non-compliances and immediately take preventative actions, they would not be issued an infringement.
Last year, we announced a security crackdown to help prevent uncleared risk goods (including containers) from being wrongly released or stolen and to prevent undetected contaminants or pests from escaping. TFGEN currently states that risk goods must be kept in a secure manner at all times. Currently, a number of TFs do not have systems to prevent members of the public from gaining access to uncleared containers (e.g. TFs in business parks that have no fences or gates). This is in comparison to some larger TFs where the boundary is security fenced and patrolled, and access is tightly controlled at gated entry points operated on a 24/7 basis. Security requirements will be further strengthened to give MPI increased confidence that uncleared risk goods at a TF are fully secure at all times from unauthorised entry by unapproved persons.
To meet the new security requirements TFs must:
Devan the container inside a secure building
Hold a container in a secure fully fenced (at least 1.8m high) area
Have a lockable gate
Lock the container, for example, secure with a substantial padlock
In addition to the above, we encourage the use of alarm systems, security cameras, etc. We realise there are costs to meet these requirements so MPI will allow until1 September 2019 for existing TFs to comply. After this date, MPI will cancel TFs if they do not meet these new requirements. Any new TF application will need to meet these requirements. MPI may consider equivalent options to ensure security requirements can be meet.
MPI is considering deregistering existing TFs that don’t receive a sufficient amount of containers each year. The simple fact is TFs that do not deal with cargo regularly are more likely to be non-compliant as, for smaller TFs, biosecurity may be a minor consideration and biosecurity training may be forgotten. By comparison, for a large TF, biosecurity is a major function and the Operator/AP roles may be the sole responsibility for some staff.
MPI is proposing to revoke the approval of TFs thatreceive five or fewer containers per year. Nationwide, this decision would affect a quarter of TFs. However, these TFs only dealt with a tiny proportion of all containers 0.7% (3700) of those imported into New Zealand in the 2017/2018 financial year. To put this into perspective, one TF in Auckland unloaded more than 8000 containers in the same period. Note that special requirements will be taken into consideration (e.g., if specialised handling is required or in a region where no other TFs are available). Affected importers will still be able to receive low risk containers to their business using the Multi-Site TF (MTF) scheme - this is an alternative option where a third party takes all responsibility for biosecurity requirements.
In 2019 and going forward, all TF Operators will have to complete and submit their annual internal audit within the time period specified by MPI. This is to improve our data collection and enable us to identify areas for improvement. To make the internal audit process more efficient, we have created an online portal where you can fill out and submit your internal audits.
This means we are eliminating paperwork and double handling in the process of submitting your audit results. Filling out the online audit form only takes about 10 to 15 minutes. The internal audit for 2019 runs between 1 November 2018 and 1 February 2019 and if we do not receive your internal audit by 1 February 2019, your TF may be suspended. All operators are encouraged to submit their internal audit results during this period - you will receive an acknowledgement email of your audit submission.
Even if you have completed your 2018 internal audit, you will still need to complete this online form for the 2019 calendar year within the time period specified above. If you have just started operating (from 1 January 2018), you would have completed and met the standard as part of the initial operating requirements and your first online internal audit would be due in 2020.
In April, the TF number was removed from the public website and we had several responses from people asking why? The number was removed due to an internal recommendation that TF numbers are not made publically available. This is to prevent unauthorised use.
It is possible that a TF number of another business could be used without their knowledge to facilitate the delivery of containers. This is a potential biosecurity risk as TFs are approved to receive different commodity types and are required to meet specific requirements in TFGEN.
This operational change is in line with the removal of TF line types from the public website a few years ago due to concerns from Operators. MPI staff will not be giving out the TF number. So if anyone requires a TF number, they will need to contact the TF and ask them for this. This is part of our ongoing work programme to improve the security around the direction of containers.
MPI is updating our requirements to ensure the health and safety of our staff during inspections of caravans and campervans. The changes will also allow closer scrutiny for biosecurity risk. From1 September 2019, MPI staff need to be able to stand beneath the caravan or campervan to inspect the underside (e.g. not using a dolly).
This date has been selected to provide a suitable timeframe to become compliant. The recommendations for hoisting vehicles is in 6.14.2 (2) of the TFGEN Guidance Document where the considerations stated are for health and safety coverage of our MPI Inspectors when conducting inspections on vehicles (which includes caravans).
MPI will not provide ongoing approval of TFs after 1 September 2019 where inspections cannot be conducted safely (and comfortably) by MPI Inspectors.
TF Operators that have caravans or campervans arriving at their TF for inspection will need to come up with a safe way to provide suitable safe and compliant inspection conditions. There are several ways to achieve this requirement (e.g. use of a hoist, ramp, pit). Let MPI know how you plan to meet this requirement and an MPI Inspector will assess your proposal and approve the methodology. Note that some options will require official certification such as a hoist certificate limited to set caravan weights.
Due to a variety of circumstances, many TFs and Operators no longer wish to continue. In this situation, you need to email MPI in advance of ceasing operations to let us know, otherwise you will still be charged the annual TF fee and for any MPI inspections. You can do this by emailing the cancellation form email@example.com.
The TF Operator will also need to ensure that any waste in their quarantine bin has been collected by an approved waste disposal provider and they send MPI the destruction certificate or invoice for the relevant waste disposal. The absence of these documents could see TFs still incur charges from MPI. Once received, TF approval is cancelled and this stops any further charges.
Now when your TF Operator training certificate expires your TF will be automatically suspended by MPI’s IT system (Trade Single Window). Operators should receive automatic warnings from TSW repeatedly from three months out on a monthly basis from the expiry date as long as the correct email address has been provided. Note that once you have completed training, you need to send your TF Operator certificate toFacilityApprovals@mpi.govt.nz (and list your TF number so we know who you are).
Below are useful resources for staff training sessions we have been asked about.
TF Operators: Ensure your APs that find contamination or pests are following the ‘See, Contain, Report’ actions as on the Contamination Charts below.
Contamination Charts Posters:Available from your Quarantine Officer or the printer files on the MPI website>Importing>Border Clearance>Containers and cargo>Resources.
> Contamination charts poster – know the actions to take and when to notify MPI
> Contamination charts – 11 single posters
Online Reporting Instructions: Check your AP is accurately reporting contamination on the Container Checks Portal website.
> How to Report Contamination on the Container Checks website.
When sending your staff to AP training, make sure:
The right person is attending the course.
They know why they are attending and what will be expected of them in the workplace.
They are fit and ready to learn, e.g. not attending AP training directly following a night shift.
Learning is reinforced in ongoing internal staff training.
For feedback or complaints about training, please contact Anne firstname.lastname@example.org with ‘AP Training’ or ‘TF Operator Training’ in the subject line.
As with previous years, MPI will not be processing any new facility or TF Operator applications received from Monday 26 November until Friday 18 January. This is due to MPI staff members being deployed elsewhere over that period. However, MTF applications will still be processed (except between 24 December and 4 January).?
Importers will have to do more to ensure vehicles and machinery from overseas are free of brown marmorated stink bug (BMSB). The new Import Health Standard for Vehicles, Machinery and equipment came into force on 1 September with a focus on Japan given the issues last season with contaminated car carriers. There are also new restrictions on imports from many European countries (in alignment with the USA) given the spread of BMSB through Europe.
In addition to its natural occurrence in Japan (and other places is Asia), there are now16 actionable countries in Europe and North America with established BMSB populations that have been added to the list requiring management and treatment of vehicles, machinery and certain equipment during the BMSB season. These are Austria, Bulgaria, France, Georgia, Germany, Greece, Hungary, Italy, Liechtenstein, Romania, Russia, Serbia, Slovenia, Spain, Switzerland and the USA. Additional countries could also be added if BMSB spreads to other placers and becomes problematic.
All imported used vehicles from Japan must undergo cleaning and some form of approved treatment through an MPI-approved system during the risk season (1 September until 30 April). Used machinery from Japan must also be cleaned by an MPI-approved cleaning company, must get certified as being cleaned and must be treated before arrival in New Zealand during the risk season.
All new vehicles/machinery from Japan must be managed through an MPI-approved system or treated offshore during the risk season. Manufacturers in Japan or Europe/USA will have the option of applying to MPI for an MPI-approved system, therefore avoiding the need to fumigate or heat treat each new unit.
Used machinery from any other country must have a cleaning certificate (from 1 December 2018) stating that it has undergone thorough cleaning and treatment before arrival in New Zealand. There must be evidence the machinery was appropriately disassembled for cleaning.
In addition, MPI has also released an updated import health standard for sea containers where all containerised consignments from Italy must be fumigated or heat treated. Importers intending to import consignments that might be negatively affected by treatment should contact the MPI Target Evaluation Team and a rigorous inspection process can be arranged. MPI reserves the right to conduct further actions, including treatment, if contaminants or pests are found
Join Biosecurity New Zealand and its forum partners, the Government Industry Agreement and the Department of Conservation, at biosecurity’s premier event – theBiosecurity New Zealand Forum. This year’s forum theme is‘Biosecurity: Partnering to Protect’, exploring the many different approaches to, and motivations for biosecurity.
We need to ensure we are confident that sea containers are delivered to the TF they are directed to. Currently APs only need to report when biosecurity contaminants are found but we plan to introduce 100% AP reporting through the Container Check Portal.
This will allow MPI to reconcile container movements and see any anomalies and when identified, MPI will refer the agent/broker, transport company or TF Operator to our enforcement team for investigation. When this 100% reporting is introduced, APs will no longer need to complete paper log-sheets as the relevant information will be available on-line. This work is underway and we will let you know once the Container Check Portal has been updated.
The purpose of this newsletter is to provide regular updates on planned operational changes and other relevant information for the management of containment or transitional facilities (TFs) by approved TF Operators, Accredited Persons (APs) and staff.
Keeping You Informed!
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