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For many years, New Zealand allowed imports of uncooked salmon for human consumption, but in 1983 this trade was stopped because of a belief that there could be a risk of introducing diseases into New Zealand fish stocks through such imports. This decision was made despite no formal risk analysis having been carried out.
Since importation was stopped, a number of our trading partners have sought to regain access to our markets for uncooked products derived from salmon. They argued that Australia and New Zealand were the only countries which did not accept this trade, and there was no logical reason to restrict it. On the other hand, such access has been opposed by local salmon farmers and recreational fishers who have concerns about what they fear are possible disease risks posed by such importations.
In 1995, following a risk analysis, MAF decided to remove this restriction for headless, gutted, wild, ocean-caught Pacific salmon from Canada. Since June 1995 approximately 40 tonnes of this product has been imported into New Zealand for further processing under strict conditions before being made available for retail sale.
Following a further comprehensive risk analysis, MAF has now decided to allow importation of uncooked, headless, gutted salmon, trout and char from certain countries.
The Biosecurity Act 1993 requires that when considering importations of goods that might cause unwanted harm to animal health MAF should consider the likelihood of organisms being introduced, and the possible effects such organisms might have on people, the environment and the economy of New Zealand.
Our trading partners, including the United States, wanted to gain access to our market and requested that New Zealand provide a scientific justification for the requirement that imported salmonid products must be cooked. The risk analysis examined what level of risk would be associated with importations of uncooked salmonid products.
Continuing a prohibition on imports was inappropriate, considering the low probability of introducing an aquatic animal disease through importation of headed, gilled and gutted salmonids for human consumption.
Continuing a prohibition on wild Pacific salmon for human consumption from the United States was inappropriate, considering that the probability of introducing an aquatic animal disease through imports from the USA was not likely to significantly differ to that for the importation of wild Pacific salmon from Canada which is currently allowed.
Risk management measures over and above those recommended by the OIE (the international animal health organisation) were appropriate considering the potentially severe consequences to New Zealand salmonid fisheries of an aquatic animal disease being introduced. (The OIE believes gutting alone is a sufficient risk management measure).
Additional risk management measures New Zealand could apply include restricting exporting countries to those assessed as meeting food safety and aquatic animal health surveillance requirements, and requiring bulk product to be processed in New Zealand under MAF regulatory control. In this case, regulatory systems in Australia, Canada, the United States, European Union and Norway would provide New Zealand with adequate food safety and aquatic animal health surveillance assurances if importations of salmonid products were permitted.
MAF should regulate processing of imported bulk product using a similar system set up to regulate imports of wild Pacific salmon from Canada. Any importations of product not packaged for direct retail sale must be consigned to registered processing premises, which are under MAF supervision. The processing standards ensure that accumulation of scraps, waste water or packaging as a result of processing imported product will not lead to concentrations of pathogens which place aquatic animals in New Zealand at risk of infection.
Critical assessment of the risk analysis was sought from seven international experts and two independent New Zealand experts. They all agreed with the conclusions of the risk analysis, and their technical comments were incorporated into the version of the analysis released for public consultation.
Furthermore, the 18 public submissions received during the consultation process were reviewed independently by a prominent and well-qualified fish health expert in the UK. MAF also reviewed the submissions to determine if new issues were raised which might change the conclusions of the risk analysis.
Neither the independent review of submissions, nor MAF’s own analysis, suggested that the conclusions of the draft risk analysis should be changed. MAF has therefore decided that there is no scientifically or technically justified reason not to allow the importation of the specified product.
For imported table fish to serve as a vehicle for the introduction of fish disease, all of the following conditions would have to occur:
the disease must be present in the waters of origin;
the disease must be present in the particular fish harvested (or the flesh must have become contaminated during processing);
the diseased flesh must pass inspection and grading procedures;
the disease-causing agent (pathogen) must be present in the imported tissues;
the pathogen in the flesh must survive storage and processing and be present at an infectious dose;
the pathogen must be able to establish infection either by being swallowed or by being absorbed through the skin of the host fish;
scraps of the flesh product must find their way into a susceptible host fish in New Zealand, or an infectious dose of pathogen must find its way into contact with a susceptible fish host by some other means.
When considering the likelihood of disease introduction by this route New Zealand must also consider the likelihood of introduction by other routes such as importation of marine fish for human consumption and for bait, movement of ballast water, migration of fish and sea animals, and oceanic currents. Measures imposed to reduce risk associated with importations of salmon, trout and char for human consumption should retain a level of balance with risks we are already accepting from these other sources.
New Zealand is committed to using sound science and an open decision-making process to establish any trade restrictions aimed at protecting animal health-protection measures. This is in line with this country’s commitments as a member of the World Trade Organisation (WTO).
The WTO rules for protecting animal health (as well as plant health and human health in relation to food safety) are set out in the SPS agreement, the ‘agreement on the application of sanitary and phytosanitary measures’. This agreement does not require us to lower our health-protection standards, but does oblige us to demonstrate that our measures have a sound scientific basis and are appropriate to our circumstances.