Plant Export Operations Branch - Department of … Library/Images/DAFF/__data...Title: Volume 8A: Commodity Inspections - Hay and straw Date Published Current Version Number Program

Title: Volume 8A: Commodity Inspections - Hay and straw

Date Published Current Version Number Program Page Number 29 September 2014 FINAL V4.0 Plant Export Operations Branch Page 1 of 14

Plant Export Operations Branch

PLANT EXPORT OPERATIONS MANUAL

VOLUME 8A: COMMODITY INSPECTIONS – HAY AND STRAW

Contents

Introduction ...................................................................................................................................................... 2

Conduct Pre-Inspection Tasks ................................................................................................................... 4

Packaging and Empty Container approval ........................................................................................... 5

Conduct Flowpath Inspection Tasks ....................................................................................................... 6

Conduct Goods Inspection Tasks .............................................................................................................. 7

Tolerances ......................................................................................................................................................... 9

Rejection Principles .................................................................................................................................... 10

Inspection of Resubmitted Goods after Treatment ........................................................................ 10

Oaten Hay Exports – China ...................................................................................................................... 13



Introduction

This volume outlines the principles relating to the preparation, sampling, inspection and export certification of hay, straw, compound feed, mixed fermented feed and chaff. Under the Export Control Act 1982, there are ‘prescribed’ and ‘non-prescribed’ goods. Depending on what commodity is to be exported, the requirements that must be complied with may vary. Hay and straw, as listed in Section 3 of the Export Control (Plant and Plant Products) Order 2011, are always prescribed goods and will therefore be inspected and sampled irrespective of whether the importing country requires a Phytosanitary Certificate.

The sampling and inspection of prescribed goods must be carried out at a registered export establishment by an Authorised Officer (AO). Individuals undertaking these activities must be suitably qualified and have relevant authorisation and delegations necessary to inspect prescribed goods presented for export.

Hay and Straw

Hay and straw means a pasture or cereal plant (either whole or after harvesting seed) that is cut and dried. Oat, barley and wheaten hay and straw are subject to annual ryegrass toxicity (ARGT) testing.

Compound feed

Compound feed is a composite product made of a minimum of 80% hay and/or straw

with an additive to increase protein levels. Additives can include, but are not limited to,

pulse and oilseed (whole, cracked and meal) and mineral supplements. Compound feeds

are subject to ARGT testing and must be sampled and inspected as per hay and straw in

accordance with work instruction HAS3001 ‘Inspection and certification of hay and

straw’.

Mixed Fermented Feed

Mixed fermented feed is a mix of hay/straw and other additives that is fermented, packed

in sealed bales and exported in containers. Mixed fermented feed is not subject to ARGT

testing.

Chaff

Chaff is made by chopping straw or coarse hay into very short lengths using a machine

called a chaff cutter. It is used as animal feed and is a way of turning coarse fodder into a

form more palatable to livestock. Chaff is not subject to ARGT testing.



Annual Ryegrass Toxicity

Testing Requirements

ARGT is caused by toxins produced by the bacterium Rathayibacter toxicus that infect the

seed heads of ryegrass. The bacterium is transferred to ryegrass seed heads by

nematodes (Aguina spp.). The nematode, which only has one lifecycle each year, invades

the ryegrass during winter and produces a gall in spring that replaces a developing seed

in the immature seed head. If the bacterium is present, it quickly multiples during early

spring, swamping the nematode and taking over the gall. After the ryegrass flowers, the

bacterium begins to produce a powerful tunicamycin-like poison toxin called corynetoxin.

Toxin production increases rapidly just before the grass hays-off and persists in dry

pasture or hay and if ingested by livestock it causes annual rye grass toxicity, resulting in

death.

Export oat, barley and wheaten hay and straw must undergo laboratory analysis to test

for ARGT contamination. Australia has well established procedures to ensure examination

of field product for the presence of corynetoxin contamination of all export cereal hay and

straw.

The Department of Agriculture has produced a set of standards for minimising the risk of

corynetoxin contamination in export hay and straw. For detailed information on sampling

for ARGT refer to the Standard for minimising the risk of corynetoxin contamination of

hay and straw for export on the department’s website. The Standard allows producers or

exporters to test for corynetoxin directly using a test for corynetoxin or indirectly using a

test for R. toxicus. A test for R. toxicus is useful because samples of hay and straw tested

for R. toxicus and found to be negative cannot contain corynetoxin. The test must show

negative results for corynetoxin or R. toxicus before the hay is allowed for export.

Test results

ARGT test results will be audited by the department at the registered establishment audit.

At the audit the processor must demonstrate that all hay entering their facility has been

tested in the field and returned a negative result for ARGT or that any hay received on-site

where ARGT status is not known to be negative has a process in place to ensure that hay

is not processed for export until a negative ARGT test has been received.

During auditing for ARGT compliance that is undertaken at the registered establishment

audit, the processor must provide the following to the auditor:

documented procedure for intake of hay into the export site with reference to separation of hay with unknown ARGT status

http://www.daff.gov.au/biosecurity/export/plants-plant-products/corynetoxin

http://www.daff.gov.au/biosecurity/export/plants-plant-products/corynetoxin

http://www.daff.gov.au/aqis/export/plants-grains-hort/corynetoxin



documented ARGT program detailing testing procedures and the method of recording results

a summary report of all lots exported since the last audit with reference to the negative ARGT test result

copies of every ARGT test result

The auditor will trace a number of consignments from farm to export to confirm the bales

used and to ensure they tested negative for ARGT.

ARGT test results must be provided on a signed letter head from the laboratory

undertaking the testing using an approved method.

Reference and Instructional Material

Work Instructions: The AOs must use the work instructions as a quick guide to complete a specific job function. These can be accessed via the downloadable resources link.

Plant Exports Operation Manual: o Volume 2: Export legislation o Volume 5: Product Identification o Volume 11: Empty Container Inspections o Volume 16: Work Health and Safety (WH&S) o The “Standard for Minimising the Risk of Corynetoxin Contamination of Hay

and Straw for Export” (Accessed via Volume 8A resources section).

Legislation

Consideration must be given to the following legislation before goods are exported and

AOs must ensure that the legislation is abided by throughout the exporting process:

Export Control Act 1982

Export Control (Prescribed Goods – General) Order 2005

Export Control (Plant and Plant Products) Order 2011

Export Control (Fees) Order 2001

The legislations listed above are all accessible via the ComLaw website (comlaw.gov.au)

Conduct Pre-Inspection Tasks

Recording Inspection Results

Inspection details are recorded on the Export Compliance Record (ECR). AOs must use

one ECR for each inspection conducted. It is mandatory for AOs to use the ECR.

http://www.daff.gov.au/biosecurity/export/plants-plant-products/plantexportsmanual/resources

http://www.comlaw.gov.au/

http://www.daff.gov.au/__data/assets/pdf_file/0011/2142785/PE100_Export_Compliance_Record.pdf



Inspection Equipment Checklist

Waste bin and lid supplied by establishment for disposing of unwanted material

found during inspection

Torch capable of being focused to a spot

Scales

Sieves for separating insects and contaminants from the samples

Collection containers for holding samples

Knife and scraper suitable for cutting straps and removing residue from places

difficult to access

A pair of tweezers suitable for collecting larger species

Hand lens x10 magnification or more for pest, weed seeds and contamination

identification

Small painters brush for separating objects of quarantine concern and collecting

small insects from the grain samples being inspected

Vials/tubes filled with methylated spirits or 80% ethyl alcohol (ethanol) for

collecting arthropod specimens

Sealable plastic bags for larger specimens collection during inspection

Labels for specimens

Export Compliance Record

Pencils for labelling tubes (pens aren't suitable as alcohol dissolves most ink) and

pen for completing various forms

Personal protective equipment such as hand gloves, apron, face mask, goggles, etc.

Calculator or mobile phone with a scientific calculator

Packaging and Empty Container approval

Inspection of empty containers and packaging ensures requirements have been complied

with in the transportation of prescribed goods and no cross contamination issues exist

with loading prescribed goods into inspected empty containers. An AO must ensure that a

valid container approval has been issued.

Packaging material inspections

Materials to be used as packaging for prescribed goods and other materials applied to

prescribed goods at the time of packaging must be:

New or if previously used and intended for repeated use, must have been cleaned

and reconditioned to the satisfaction of an AO i.e. unlikely to impart odour, infest

or contaminate goods and be free of holes/rips/tears

Used in a manner that is unlikely to place the acceptability of the prescribed goods



at risk

Sufficiently strong to withstand the handling incurred by the materials during

transit

Otherwise appropriate to the goods

Free from any contaminants that could cross-contaminate the goods

Conduct Flowpath Inspection Tasks

Inspection Area

The AO must ensure the area to be used for the phytosanitary inspection is clean, well lit,

free from excessive dust and sources of cross-contamination and clear of fumigant gases.

The inspection equipment must be clean, adequate and fit for purpose.

The AO must ensure there is adequate access to all goods to allow sampling in a safe

manner from the entire consignment.

Commodity Flowpath

The commodity flowpath is deemed to be from the point of sampling to the point of

loading. The flowpath must be inspected prior to loading to ensure it is fit-for-purpose

and free of sources of cross contamination such as infested material and material capable

of infecting the commodity. In circumstances where the flowpath fails inspection, the AO

must be advised when the issue has been rectified and the flowpath is ready for

reinspection.

Assess the consignment

A consignment consists of each container listed on the NOI (EX28 or RFP). The content of

the entire consignment to be inspected should match the details on the NOI. Do not

proceed with the inspection if the consignment presented does not match the NOI.

Trade Description

When a trade description is applied to prescribed goods, the export of those goods is

prohibited unless that trade description is adequate and accurate.

A trade description applied to goods is taken to be adequate if it:

contains sufficient information to enable the goods to be readily identified is not ambiguous or unclear



satisfies any particular requirements under the Orders relating to the application of trade descriptions

satisfies any requirements of the importing country.

Where an AO is concerned that a false trade description has been applied to prescribed

goods, the AO needs to contact the Regional Plant Export Manager. In the interim, AOs

must withhold export documentation and require exporters to produce documentary

evidence to support the description given. These may include declarations by the

exporters/processors of the goods or certificates of analysis from accredited laboratories

for various parameters required by the importing country.

Conduct Goods Inspection Tasks

Categories for sampling and inspection

Goods must be sampled and inspected using one of the four categories listed in Table 1.

The sampling category used must be recorded on the ECR.

Table 1: Categories for sampling and inspection

Category Requirements Sampling/Inspection When a rejection occurs

A In line sampling 2 bales from every

container or 0.5kg loose

material from every

container

Reject each

container

B Voluntary fumigation at a

registered establishment

AND

Last audit score of processing

facility: Acceptable or

Excellent

(End point)

Random sampling plan

(Table 1 HAS3001 work

instruction)

Inspection of doors,

seals, floor, walls and

surface of all visible

bales of sampled

containers

Reject sampled

container

Sample each

remaining

container

C Voluntary fumigation at a

registered establishment

AND

Last audit score of processing

Random sampling plan

(Table 1 HAS3001 work

instruction)


Reject sampled

container

Sample each

remaining



Category Requirements Sampling/Inspection When a rejection occurs

facility: Marginal

(End point)



bales of every

container

container

D No voluntary fumigation

(End point)

Sample every container




bales of every

container

Reject each

container

Voluntary fumigation

Fumigation that is conducted before the inspection must be carried out in accordance

with label rates. The fumigant must be registered to treat stored product insect pests of

hay. Fumigation and gas free certificates identifying each container presented must be

provided to the AO before inspection can commence.

Commodity Sampling Methods

There are four sampling options for hay and straw products:

1. In-line sampling of bales: bales are removed at random from the production line

before packing into containers.

2. In-line sampling using loose hay and straw: Hay and straw can be sampled after

the process of teasing and/or slicing of hay and straw in-line. For this option the

establishment must have a conveyance system which catches the excess hay and

straw which has been generated after the process of teasing and slicing of hay and

straw. The sample must directly link to the bales being loaded into a specific

container. The sample must be taken in-line at the time of processing for the

specific container.

3. End point sampling of bales: Sampling is conducted on bales and containers after

containers have been packed.

4. Endpoint sampling of packages: Sampling is conducted on packages after they

have been filled.



Commodity Inspection Methods

There are three inspection methods for in-line and end-point inspections:

1. Biscuit technique: A compressed bale is comprised of 10-15 biscuits of hay. All

surfaces of the compressed bale are inspected. The straps of the bale are cut and a

minimum of three biscuits are shaken out over the inspection bench/sieve.

2. Coring technique: Coring must be undertaken using a hollow coring tube to

ensure the corer maintains sample integrity to allow identification of any insects

collected. For non-compressed hay, the tube must have a minimum diameter of

30mm and length of 450-500mm to collect samples. For compressed hay, the tube

must have a minimum diameter of 50mm and length of 200mm to collect samples.

The average straw length of the samples is to be at least 10-15 mm. Sample weight

collected from the container is 0.5kg.

Note: The use of a solid drill bit is not permitted and a coring tube must be used.

This is required to prevent live insects or contaminants being shredded.

3. Loose material technique: Loose material is shaken out over the inspection

bench/sieve.

Alternative sampling regimes to that outlined in this document for inspection of hay and straw for export may be considered at the discretion of the Assistant Secretary Plant Export Operations branch. For any alternative sampling methodology to be considered suitable, the methodology must be based on sound scientific evidence, and must be proven to be equivalent to that already provided by existing sampling and inspection methods.

Inspection of prescribed goods must be carried out in accordance with work instruction

HAS3001 Inspection and certification of hay and straw for export.

Tolerances

Tolerance levels imposed by the importing country takes precedence over any

tolerances listed in this manual.

There is a nil tolerance for live pest infestations and vermin (including rodents) for

prescribed goods unless a tolerance is specified in Table 2 or Table 3. Nil tolerance will be

applied, irrespective of whether the pests are found on the outside of the bales, on the

inside of the container, or from the samples inspected.

Table 2: Tolerances for hay and straw to countries other than China

Contaminant Tolerance level

Animal Carcases or part thereof Nil




Rodent and vermin droppings In any single 0.5kg sample not more than seven droppings

Soil and sand 0.2% by weight of sample

Table 3: Tolerances for hay and straw to China


Animal parts including limbs and carcasses Nil

Animal droppings Nil

Weed seeds Nil

Soil Nil

Metal Nil

Toxic plants Nil

Roots Nil

Rejection Principles

If any pests or contaminants are found in excess of tolerances the consignment must be

rejected.

Upon rejection an AO must notify a responsible person on an ECR that treatment of the

rejected container(s) is required, and that person must give details of treatment carried

out before the container(s) is re-presented for inspection.

Please refer to HAS3001 Inspection and certification of hay and straw for export for

specific rejection procedures.

Inspection of Resubmitted Goods after Treatment

Treatment of rejected goods

The choice of treatment is the responsibility of the owner/packer of the goods and not the AO.



Resubmitted goods must be inspected as per the work instruction and rejected if any live pests and contaminants above the tolerance levels are detected.

Live Insect Infestations

Live insect infestations must be treated if resubmitting the rejected consignment for

export. The exporter or their agent must provide a treatment declaration or fumigation

certificate before the reinspection can commence. The AO must verify that the goods were

treated to control all insect life stages but is not responsible for the choice of this

treatment.

Insecticides and fumigants

If an insecticide or fumigant is used, it must be:

registered for the particular use used in accordance with its registered label acceptable to the importing country.

Rejected goods treated with an insecticide or fumigant must not be resubmitted for inspection until after the exposure, airing periods and safety precautions specified on the registered label have been observed.

If a fumigant is applied, then the person responsible for the goods must also provide a fumigation certificate or declaration and a gas free certificate, issued by a suitably accredited/licensed fumigator, before the reinspection can commence to ensure that it is safe for the AO to conduct the inspection.

Live Rodents

Live rodent detections must be treated if resubmitting the rejected goods for export. The

exporter or their agent must provide a treatment declaration or fumigation certificate

before the reinspection can commence. The AO must verify that the goods were treated

but is not responsible for the choice of this treatment.

Fumigants

If a fumigant is used, it must be:

registered for the particular use

used in accordance with its registered label

acceptable to the importing country.

If a fumigant is applied, then the person responsible for the goods must also provide a

fumigation certificate or declaration and a gas free certificate, issued by a suitably

accredited/licensed fumigator, before the reinspection can commence to ensure that it is

safe for the AO to conduct the inspection.



Rejected goods treated with fumigants must not be resubmitted for inspection until after

exposure, airing periods and safety precautions specified on the registered label have

been observed.

Rodent Carcasses

Depending on where the carcass was found will determine if a treatment is required.

Please refer to HAS3001 Inspection and certification of hay and straw for export for a

more detailed procedure.

Contaminants

The tolerance levels for contaminants may vary from contaminant to contaminant and

importing country requirements. For example, some contaminants have a nil tolerance

and others may have some level of tolerance. The following principles should be used for

contaminants found in hay and straw samples during inspection:

1. For contaminants for which a nil tolerance applies, cleaning of the relevant goods must be carried out to remove the contaminating material if the goods are to be resubmitted for export.

2. For contaminants for which a numerical tolerance applies, cleaning to below the permitted tolerance may be carried out.

3. If contamination has occurred on the outside of packages it may be removed by brushing or other mechanical means.

Advise the exporter of any miscellaneous contaminants such as but not limited to

wood/timber greater than 50mm square, ergot infestation of ryegrass seed, moisture,

rags, hessian bags, tools, rocks. The container is not rejected however the exporter has the

option to withdraw.

Export compliance period

Prescribed goods that are inspected and passed as export compliant remain compliant for

28 days. In exceptional circumstances, the period of export compliance can be extended

beyond the 28 days.

To extend the period of compliance the exporter will need to provide details supporting

the request to the Department of Agriculture, Grain and Seed Exports Program before the

end of the initial 28 day period. The exporter must supply details of the exceptional

circumstances for which an extension is required, a justifiable period of extension, and

information that gives assurance that the condition of the goods has not changed since

inspection and that there has been no compromise of the phytosanitary status of the

goods, including the security. Once a decision is made the Grain and Seed Exports



Program will inform the exporter of the decision and the National or Regional

Documentation Hub Manager or Supervisor will be informed to make a record of the

additional approved period.

Reinspection of consignments where export of consignment is delayed

Reinspection of prescribed goods (as per HAS3001 Inspection and certification of hay and

straw for export) is necessary if:

1. The time between inspection and export exceeds the period during which the prescribed goods are passed as export compliant

2. The maximum time between inspection and export permitted by the importing country is exceeded.

When an importing country’s requirement is different from 28 days, or any time

extension that could be approved, the importing country’s requirement takes precedence.

Exporters must request reinspection if any of the above conditions have occurred.

Oaten Hay Exports – China

Registered Establishments

Establishments exporting oaten hay to China are required to meet specific conditions in addition to what is required for hay establishments exporting to other countries. In particular, establishments exporting oaten hay to China must be approved by the Department of Agriculture and listed as suitable by the Chinese authorities. A list of approved premises is available on the MICoR database.

Quality Management System

The establishment must implement a quality management system based on the Hazard Analysis Critical Control Point (HACCP) concept. The HACCP concept is internationally recognised as a method for defining and managing requirements for effective control of product safety and hygiene. HACCP facilitates the identification and maintenance of "critical control points" which limit risks to the consumer. Occupiers of establishments should consult with the department to determine if they have adequately identified all critical control points, and have addressed them adequately. Once they have drafted their quality management plan they will need to submit a copy to the department for approval.

Related eLearning Module

Defensible Decision Making

Export Communications: Governance

Export Communications: Techniques



Export Documentation – Electronic

Export Documentation – Manual

Export Inspections: Commodity Inspection – Hay and straw

Export Inspections: Export Registered Establishments

Export Inspections: Importing Country Requirements

Export Inspections: Product Identification, Pest & Diseases

Export Inspections: Ship Inspection

Export Inspections: Treatments

Export Inspections: Using MICoR

Export WH&S

Introduction to Empty Container Inspections

Plant Export Legislation

Questions

You can contact the AO National Helpline on 1800 851 305 to clarify any aspects of

this volume in the first instance.

You can also direct a specific question or provide feedback to

[email protected]

mailto:[email protected]

Documents

Plant Export Operations Branch - Department of … Library/Images/DAFF/__data...Title: Volume 8A: Commodity Inspections - Hay and straw Date Published Current Version Number Program