Protecting the Biosecurity of Agricultural Plant Species

Why we did this audit

Plant pests or diseases can impact Victoria's agriculture industry and environment. Plant biosecurity activities are crucial to stop pests and diseases entering Victoria and spreading.

 Agriculture Victoria, within DEECA, manages plant biosecurity in Victoria.

 Agriculture Victoria uses a wide range of activities to reduce plant pest and disease risk. These include plant research, quarantine, control orders and training.

 In this audit, we focused on:

•  surveillance
• industry compliance
• community and industry engagement.

We also examined Agriculture Victoria's role in the eradication and containment of selected plant pests since 2018. We looked at:

• the national khapra beetle eradication response
• containment of phylloxera.

Khapra beetle has been the only emergency plant pest eradicated in Victoria since 2018. Khapra beetle is a serious pest that infests stored produce like grain, cereals and dry foodstuffs. It could have a severe impact on Victoria’s grain, dried fruit and nut industries through lost trade.

 Phylloxera is one of 5 plant pests and diseases Agriculture Victoria is currently containing. Phylloxera is a small yellow insect that destroys grapevines by eating and damaging the roots. There are 83 strains established in parts of Victoria. There are no effective ways to eradicate grapevine phylloxera. 

Our key findings

Our findings fall into 3 areas:

Surveillance activities

Agriculture Victoria takes part in 3 national surveillance programs that focus on early detection of plant pests and diseases of national significance. These are:

• the National Bee Pest Surveillance Program (NBPSP), which targets bee pests and diseases
• the National Plant Health Surveillance Program (NPHSP), which targets national priority pests and diseases
• the ForestWatch program, which targets forestry and timber pests and diseases. 

Agriculture Victoria also does surveillance to certify that specific pests are not in certain areas, or present in Victoria. This is known as area freedom claims.

An area freedom certificate uses scientific evidence to show an area is free from a specific pest. It has significant economic benefits and trade advantages. It assures trade partners the specific pest will not be introduced to new areas through traded produce.

Agriculture Victoria engages with relevant stakeholders on plant biosecurity risks and responsibilities. It investigates community and industry reports of suspect plant pests and diseases as general surveillance. From January 2018 to December 2023, Agriculture Victoria received 2,789 reports through the MyPestGuide Reporter mobile application and DEECA's customer contact centre and website. 

Targets under national surveillance programs

Under the 3 national surveillance programs, Agriculture Victoria commits to annually survey:

• specific pests or diseases ('target pests')
• a specified number of locations
• a target number of trap or visual inspections
• each location at a certain frequency, such as every 14 days.

We examined 3 years of program surveillance records:

• 2020–21 to 2022–23 financial years for the NPHSP
• 2022–23 financial year for ForestWatch
• 2021 to 2023 calendar years for the NBPSP.

Agriculture Victoria surveyed:

• all NBPSP target pests
• almost all NPHSP and ForestWatch pests (94 per cent across both programs)
• all target locations for the NBPSP
• more locations than it committed to under the NPHSP and ForestWatch programs overall.

But Agriculture Victoria did not always meet targets agreed under national surveillance programs. Agriculture Victoria did not:

• meet trapping targets for some pests
• conduct any visual surveillance in 2021–22
• meet most NPHSP and ForestWatch trap or visual inspections targets
• always carry out surveillance activities as frequently as required.

Agriculture Victoria exceeded some NBPSP bee surveillance activity targets, but not others.

Risk-based rationale for national surveillance activities

When national surveillance programs specify surveillance requirements, these requirements become Agriculture Victoria's risk basis for its activities. 

For example, the NBPSP requires Agriculture Victoria to set up 6 sentinel bee hives at Port Melbourne.

When national surveillance programs do not specify requirements, Agriculture Victoria can decide when and how it meets program objectives. 

For example, Agriculture Victoria decides the exact locations and number of traps to set for NPHSP pests. Agriculture Victoria has a rationale on how it prioritises its activities according to the highest risks. But it does not always clearly document the rationale. 

Auditing agreements 

To protect market access, Agriculture Victoria uses a range of regulatory tools that help prevent plant pests and diseases entering and spreading in Victoria.

Agriculture Victoria accredits businesses to self-certify that their produce, area, or property is pest and disease free. 

Agriculture Victoria also accredits businesses to verify produce and plant products imported from interstate without having to present them to an Agriculture Victoria inspector. 

Agriculture Victoria schedules a set number of audits per year for each accredited business. This group of scheduled audits are known as ‘arrangement audits’.

The national Interstate Certificate Assurance (ICA) Scheme requires Agriculture Victoria to audit ICA-accredited businesses. 

Agriculture Victoria has also established audit schedules for businesses under compliance agreements and Plant Standards arrangements. These are state-based or bilateral protocols in place with other states and territories. 

Completing arrangement audits

Agriculture Victoria is not completing all arrangement audits according to these requirements. 

We analysed Agriculture Victoria’s data on half-yearly and annual arrangement audits for 2019–20 to 2022–23:

• Agriculture Victoria did not complete 25 per cent of scheduled audits across this period. 
• Uncompleted audits increased from 17 per cent of audits in 2019–20 to 31 per cent in 2022–23, as shown in Figure 1.

Figure 1: Proportion of uncompleted arrangement audits between 2019–20 and 2022–23

Source: VAGO based on Agriculture Victoria data.

In 2023, Agriculture Victoria's internal auditor found that staff were not consistently scheduling all required audits in its compliance management system, Vector. 

This means Agriculture Victoria cannot tell the arrangement audits' actual completion rate, including high risk arrangements.

Industry compliance

Agriculture Victoria prioritises compliance activities that address noncompliance and mitigate risks to market access. These risks include materials that could host pests or diseases moving into, around or out of Victoria. This broadly aligns with high-priority harms Agriculture Victoria identified in its 2023–26 Plant Biosecurity Compliance Strategy.

Compliance targets for phylloxera

Agriculture Victoria conducted over 90 per cent of regular compliance audits for phylloxera specific arrangements over the last 3 years. These are regular audits conducted on relevant businesses to verify they are operating according to required procedures. 

But because Agriculture Victoria is not consistently scheduling all required audits in its compliance management system, we do not know whether Agriculture Victoria is carrying out all compliance audits set out in arrangements.

Agriculture Victoria did not meet its internally set targets to do compliance inspections on phylloxera permits in 2021–22 and 2022–23. Agriculture Victoria issues these permits to businesses as needed to make sure they comply with movement conditions. Agriculture Victoria carried out:

• 136 per cent of required inspections in 2020–2
• 52 per cent of required inspections in 2021–22 
• 81 per cent of required inspections in 2022–23.

Approach to plant biosecurity preparedness

Agriculture Victoria takes a generic approach to plant biosecurity preparedness. It has targeted pest-specific preparedness plans for 2 pest threats, brown marmorated stink bug (BMSB) and Mediterranean fruit fly (medfly). Agriculture Victoria told us that because there is a vast number of plant pests and diseases that could enter Victoria, it is impractical and not an effective use of resources to undertake pest-specific preparedness for all priority pests. 

To support its generic approach, Agriculture Victoria has emergency management and response strategies consistent with national guidelines in place to respond to a plant biosecurity incursion.

Emergency response documents 

Agriculture Victoria’s Response to Biosecurity Emergencies – Concept of Operations (ConOps) is a guide to manage an emergency biosecurity response and Agriculture Victoria staff roles and responsibilities. The ConOps also specifies how Agriculture Victoria's emergency arrangements link with national and state emergency management plans.

When Agriculture Victoria suspects an emergency plant pest (EPP) incursion, its priority exotic plant pest investigation (PEPPI) process guides initial investigations. 

Agriculture Victoria has both general guidance and more specific resourcing models that guide resourcing in an EPP response.

Agriculture Victoria's EPP Model of Cover for Level 2 Biosecurity Emergencies sets out the roles, required capabilities and minimum staff numbers needed to effectively lead and manage a level 2 (major) EPP and apiary biosecurity incident.

Staff resources 

In 2020, khapra beetle was detected in goods distributed to retail stores and warehouses across Australia. Agriculture Victoria successfully led Victorian activities in the national response and helped develop the national response plan.

Agriculture Victoria internally evaluated its role in the successful national khapra beetle eradication. It concluded that it did not have enough skilled and knowledgeable staff to effectively respond to a level 2 plant pest emergency. 

Although Agriculture Victoria provides its staff with a broad range of emergency response training, it is not always clear how it prioritises and maps training to role needs and shortages identified through its Model of Cover. 

Agriculture Victoria is finalising a plan that will help it identify gaps and develop staff capabilities to effectively respond to an EPP event. 

DEECA is developing a resourcing system for emergency responses, which is due in 2026.

National frameworks for collaboration

Victoria works within a national biosecurity system. The Intergovernmental Agreement on Biosecurity sets out each government party's commitment to the objectives, roles, responsibilities, and governance arrangements of the system. This supports collaboration and coordination between the Commonwealth and state governments.

Victoria is a signatory to the national Emergency Plant Pest Response Deed (EPPRD). The EPPRD:

• requires immediate reporting 
• facilitates an early, comprehensive response to an EPP for all state and territory agencies 
• specifies cost-sharing and decision-making requirements and processes for collaborative EPP responses between parties.

The Australian Emergency Plant Pest Response Plan (PLANTPLAN) puts plant biosecurity emergencies management into practice for all EPPRD signatories. Signatories include governments, peak industry groups and Plant Health Australia.  

Relevant legislation

Agriculture Victoria regulates Victoria’s plant biosecurity system using the Plant Biosecurity Act 2010 (the Act) under the Victoria's Chief Plant Health Officer's guidance.

The Act's main purposes include to:

• provide for plant pests and diseases prevention, monitoring, control and eradication
• facilitate the movement of plants and associated products, equipment and earth material into, around and out of Victoria.

The Act allows the Minister for Agriculture to declare any pest or disease as exotic and subject to regulatory controls.

Agriculture Victoria also has emergency management obligations under the Emergency Management Act 2013 (Vic) and the State Emergency Management Plan. Under this plan, DEECA is the control agency for biosecurity incidents. 

The State Emergency Management Plan: Animal, Plant, Marine and Environmental Biosecurity Sub Plan outlines that DEECA will provide the strategic policy and direction for a biosecurity incident response where national arrangements do not need to be involved.

Surveillance and compliance

Agriculture Victoria manages Victoria’s plant biosecurity system through a range of activities, including plant research, quarantine, control orders and training. These activities work together to reduce the risk of plant pests and diseases entering and becoming established in Victoria. 

Biosecurity systems are made up of activities, which fall into broad phases:

Agriculture Victoria carries out a wide range of integrated activities across these phases. In this audit we looked at a selection of these activities.

Key surveillance activities

Agriculture Victoria participates in 3 national surveillance programs that focus on early detection of specific pests or diseases considered the highest biosecurity risk nationally. These programs are:

• the National Bee Pest Surveillance Program (NBPSP)
• the National Plant Health Surveillance Program (NPHSP)
• ForestWatch.

The ForestWatch program began in 2022–23. Before 2022, some pests surveyed under the program were part of the NPHSP. We discuss findings on these 2 programs together for ease of reporting across years.

Apart from the national programs, Agriculture Victoria does surveillance to certify that specific pests, such as cucumber green mottle mosaic virus and medfly, are not in certain areas or present in the state. These certifications are called area freedom claims. 

Agriculture Victoria also receives and investigates community or industry reports of suspect plant pests and diseases, which is a form of general surveillance. 

National surveillance program commitments

Under the 3 national surveillance programs, Agriculture Victoria commits to annually survey:

• specific pests or diseases ('target pests')
• a specified number of locations 
• a target number of trap or visual inspections
• each location at a certain frequency, such as every 14 days. 

Commitments to survey target pests

National governing committees that Agriculture Victoria is a member of decide which pests Agriculture Victoria must target for each national surveillance program.

Based on surveillance records in AusPestCheck, Agriculture Victoria carried out surveillance on all target bee pests and viruses in calendar years 2021, 2022 and 2023. 

For the NPHSP and ForestWatch, Agriculture Victoria surveyed for most target pests, as shown in Figure 2. 

Figure 2: Percentage of NPHSP and ForestWatch target pests that Agriculture Victoria surveyed for between 2020–21 and 2022–23, by financial year

Source: VAGO based on AusPestCheck data.

Agriculture Victoria told us it carried out surveillance for all target pests across the 3 years as shown in its program reports to the Department of Agriculture, Fisheries and Forestry (DAFF).

While these reports show that Agriculture Victoria surveyed more target pests, these records are not in AusPestCheck. And in some cases, Agriculture Victoria does not have the surveillance records. For example:

For 2022–23, Agriculture Victoria told us it did not carry out visual surveillance for sudden oak death and eucalyptus leaf blight because it focused on other target softwood pests instead.

Surveillance locations 

Under the NBPSP, Agriculture Victoria carries out surveillance at 4 specific locations – Port Melbourne, Geelong, Portland and Western Port. 

According to NBPSP surveillance records, Agriculture Victoria surveyed all 4 sites between 2021 and 2023.

As part of annual NPHSP and ForestWatch operational plans, Agriculture Victoria commits to survey a minimum or set number of locations. It either inspects traps, visually inspects host plants or both at each location depending on the target pest or disease.

Based on AusPestCheck data, Agriculture Victoria went above most targets for traps and visual surveillance between the 2020–21 and 2022–23 financial years, with some exceptions (see Figure 3).

Figure 3: Percentage Agriculture Victoria was above or under its NPHSP and ForestWatch survey location targets between the 2020–21 and 2022–23 financial years

Source: VAGO based on AusPestCheck data.

But our analysis of AusPestCheck records showed gaps in surveillance evidence for certain pests.

Agriculture Victoria told us its program reports to DAFF are more accurate about its surveillance activities. But these reports do not always show that Agriculture Victoria met its targets, and where they do, the records are not in AusPestCheck. 

Agriculture Victoria told us that some surveillance records may not have uploaded because data fields between its internal records system and AusPestCheck do not fully match.

Surveillance activities

For NPHSP and ForestWatch, Agriculture Victoria commits to regularly inspect traps or do visual surveillance at each survey site. 

To calculate the annual target for each pest, we multiplied the number of survey sites by the number of required inspection rounds.

We also analysed Agriculture Victoria’s surveillance records from AusPestCheck between 2020–21 and 2022–23 to calculate Agriculture Victoria’s total trap and visual inspections for each pest.

Agriculture Victoria did not carry out all the required trap and visual inspections for NPHSP and ForestWatch for all years (see Figure 4). 

Figure 4: Percentage of NPHSP and ForestWatch trap and visual inspections Agriculture Victoria carried out between 2020–21 and 2022–2023

Note: AusPestCheck did not have any visual inspection records for 2021–22, so the percentage completed is 0 per cent. 
Source: VAGO analysis of NPHSP and ForestWatch surveillance records.

Reflecting the overall shortfall, Agriculture Victoria did not meet inspection targets for most pest categories across 2020–21, 2021–22 and 2022–23 (see Figure 5). 

Figure 5: Number of pest categories that Agriculture Victoria exceeded or did not meet trap and visual inspection targets for NPHSP and ForestWatch, by year

Note: Agriculture Victoria either exceeded or did not meet targets. There were no instances where Agriculture Victoria met the target exactly.

Source: VAGO analysis of NPHSP and ForestWatch surveillance records.

The NBPSP has a target number for some, but not all, bee surveillance activities. We focused on these key activities:

• inspect hives and catch boxes
• floral sweep netting
• sampling for tracheal mites
• an 'additional activity' – either drone uncapping, sugar shake or alcohol wash.

Agriculture Victoria met or exceeded some, but not all, targets for these activities (see Figure 6). 

We could not assess if Agriculture Victoria met its catch box inspection target for 2021 as it could not provide this data. But it did provide evidence it completed these inspections. 

Figure 6: VAGO assessment of Agriculture Victoria’s key NBPSP activities against program targets between calendar years 2021 to 2023

Source: VAGO analysis of NBPSP surveillance records.

Surveillance rounds 

For some NPHSP and ForestWatch pests, Agriculture Victoria must carry out surveillance:

• a minimum or set number of times at each trap or site (surveillance rounds)
• every 14 days, for either a fixed period or throughout the year. 

As Figure 7 shows, Agriculture Victoria did not meet the surveillance rounds targets for most pest categories in 2020–21, 2021–22 or 2022–23.

Figure 7: Number of pest categories that Agriculture Victoria met, exceeded or did not meet surveillance rounds targets by financial year

Note: *This includes pests that did not have records in AusPestCheck.
Source: VAGO analyses of Agriculture Victoria's surveillance records in AusPestCheck.

We found that Agriculture Victoria's median time between trap or visual inspections across all pests is 14 days. Overall, Agriculture Victoria met its surveillance target.

But the time between trap inspections or visual surveillances was above the 14-day target 31 per cent of the time. The longest median time between trap or visual inspections was 18 days for BMSB visual inspections in 2022–23.

For the NBPSP, Agriculture Victoria must carry out bee surveillance activities every 6 weeks, or 42 days. Overall, Agriculture Victoria met this target. 

The median time between completing these activities was 42 days. But the elapsed time between bee surveillance activities went above the 42-day target 41 per cent of the time.

Monitoring progress 

Agriculture Victoria recently took steps to improve how it monitors its progress against NPHSP and ForestWatch surveillance targets. 

Agriculture Victoria started using PowerBI in 2023 to track its progress in meeting NPHSP and ForestWatch targets, such as clearing traps, undertaking visual inspections and changing lures. It also identifies quality issues with NPHSP and ForestWatch surveillance activities and records. 

Agriculture Victoria advised us that it is still refining this tool, but it should help Agriculture Victoria act early when reporting shows it is not on track to meet its national surveillance targets. 

General surveillance

Agriculture Victoria collects and investigates community reports of suspect detections, which is a form of general surveillance. If Agriculture Victoria suspects an EPP or a national priority plant pest, it may take further action, such as obtaining samples to diagnose or conduct targeted surveillance. 

Agriculture Victoria told us it expects staff to acknowledge or respond to a community report within one business day. But it has not documented this target to monitor its service standard and make sure staff expectations are clear. It has also not documented its process for triaging community reports to make sure staff respond consistently. 

From January 2018 to December 2023, Agriculture Victoria received 2,789 reports. Our analysis of Agriculture Victoria data shows it responded to 47 per cent of community reports within its response target of one business day. We excluded 10 per cent of reports because they did not have a response date or their response date was before report date. 

Targeting surveillance activities

Agriculture Victoria needs to consider many factors when planning its surveillance activities, including when and where to set traps.

To detect incursions early, Agriculture Victoria needs to target areas where plant pests or diseases are more likely to enter, spread and establish, and optimise those activities. National surveillance programs set out some, but not all, surveillance requirements. Agriculture Victoria has discretion when these requirements are not clear.

Risk-based rationale 

For the NPHSP and ForestWatch, Agriculture Victoria has not always clearly documented the rationale for locations it surveys and how many traps and visual surveillance activities it carries out.

The rationale for NBPSP activities is clear in some, but not all, areas. 

Agriculture Victoria surveys 4 locations under the NBPSP – Port Melbourne, Geelong, Portland and Western Port.

NBPSP decided Port Melbourne is high risk for Victoria based on a September 2020 national risk assessment of ports for bee biosecurity (2020 national bee biosecurity risk assessment). It also sets clear requirements on the level of surveillance activity Agriculture Victoria must carry out at this location. For example, Agriculture Victoria must set up 6 sentinel hives and inspect them every 6 weeks.

Agriculture Victoria has not clearly documented its rationale for surveying Geelong, Portland and Western Port. These locations were part of NBPSP until 2021, when the previous program contract ended. NBPSP stopped funding them from 2022 because the 2020 national bee biosecurity risk assessment did not identify them as high risk.

Agriculture Victoria told us they decided to continue surveillance because of biosecurity risk factors they identified, as well as state and national risk assessments, and apiary industry concerns. While these considerations are important, there is no documentation to show how Agriculture Victoria assessed them as a higher priority than other bee biosecurity program activities.

Stakeholder engagement activities

Agriculture Victoria conducts a broad range of communication and engagement activities. It creates and distributes information across a range of formats and platforms. 

These activities inform stakeholders of plant biosecurity risks and how to minimise potential impacts, prepare for and respond to an EPP event. 

Agriculture Victoria also raise community awareness. It helps the public to identify and report suspect plant pests and diseases. Agriculture Victoria triage community reports of suspect plant pests and diseases and investigate further where relevant. This can lead to surveillance activities to confirm whether an exotic plant pest or disease is present and a risk to Victoria.

Stakeholder understanding of biosecurity

Agencies can engage with stakeholders more effectively if they understand stakeholders’ level of knowledge, how they want to receive information and what influences their decision-making. 

We found that Agriculture Victoria has researched stakeholders’ understanding of biosecurity. But this has been more heavily focused on animal or livestock biosecurity matters. 

Due to the research participants' composition and sample size, Agriculture Victoria has not been able to clearly extract biosecurity data specifically related to plant agriculture (crop farming and industry, instead of livestock or animals). 

This level of detail could help further Agriculture Victoria's understanding of stakeholder knowledge and biosecurity behaviours in plant-specific industries and across the sector.

Types of regulatory tools

Agriculture Victoria has a program of regulatory activities to manage compliance with the Plant Biosecurity Act 2010 and associated regulations. The plant biosecurity program has a 3-year Plant Biosecurity Compliance Strategy that identifies compliance risks or harms and prioritises them based on risk. 

The 2023–26 strategy identifies high-priority harms: 

• host material moving uncontrolled into Victoria from interstate or other countries
• host material moving uncontrolled from a restricted or a control area in Victoria
• host material moving uncontrolled from Victoria to other states.

These harms could result in pests or diseases entering and spreading in Victoria, or to other states and territories. This could lead to Victorian producers losing access to these markets.

To mitigate harm, Agriculture Victoria has various regulatory tools at its disposal. For example:

• The Minister for Agriculture can declare importation orders that prohibit or restrict certain materials from entering Victoria, unless importers meet the conditions that Agriculture Victoria specifies.
• Agriculture Victoria can declare certain parts of Victoria ‘control areas’ or ‘restricted areas’ and uses permits to regulate movement or contain some plant pests and diseases to these areas.

Businesses can apply to Agriculture Victoria to issue a Plant Health Certificate, which certifies that their plant goods meet the relevant quarantine conditions. 

Agriculture Victoria can also accredit businesses to self-certify that their produce, area or property meets the relevant quarantine or movement conditions. 

There are 2 types of these accreditation arrangements:

• the Interstate Certificate Assurance (ICA) Scheme, which is a national scheme to accredit businesses to issue Plant Health Assurance Certificates for various ICA procedures.
• Plant Standards arrangements, which are biosecurity protocols that apply to Victoria only, or protocols bilaterally agreed between Victoria and other states and territories or DAFF.

Agriculture Victoria also conducts other compliance and enforcement-related activities, including:

• audits of arrangements and permits, to move plant pest and disease host material around Victoria
• verifying imports are free from specific exotic pests, such as red imported fire ants. 

Agriculture Victoria can also enter compliance agreements with businesses. It can accredit businesses to verify imports without having to present them to an Agriculture Victoria inspector. 

Compliance activities to support market access

Since 2022–23, the Plant Biosecurity Program has prioritised compliance activities in its annual project tracker using priority and consequence rankings. Priority rankings are either mandatory, ‘should do’ or ‘may do or defer’. Consequence rankings are from '1' to '6'.

Our review of ranking outcomes for 2023–24 shows that Agriculture Victoria's priority is to react to potential noncompliance and facilitate and maintain market access. Mandatory activities with higher consequence rankings ('1' to '3') focus on: 

• meeting national and interstate obligations, especially auditing higher risk arrangements and investigating noncompliance reports
• processing new arrangements and movement permits (for phylloxera and potato cyst nematode) and issuing Plant Health Certificates to maximise market access
• responding to new detections or suspect reports of pests that need containing, specifically phylloxera and potato cyst nematode.

This ranking broadly aligns with high-priority harms identified in the 2023–26 Plant Biosecurity Compliance Strategy.

Arrangement audit requirements

Agriculture Victoria schedules compliance audits of its arrangements with businesses under the ICA Scheme, Plant Standards and compliance agreements.

The national ICA Scheme requires Agriculture Victoria to audit accredited businesses. This is a mix of regular (annual or biannual), initial, random, and investigatory audits. Each ICA procedure sets out the schedule for annual and biannual audits. 

Agriculture Victoria has established its own audit schedules for businesses under compliance agreements and Plant Standards arrangements, which includes regular annual or biannual audits.

Completing regular arrangement audits 

We analysed Agriculture Victoria’s data on annual and biannual arrangement audits for 2019–20 to 2022–23 and found that:

• on average, Agriculture Victoria did not complete 25 per cent of regular audits
• the proportion of regular audits not completed has increased in the last 4 years from 17 per cent in 2019–20 to 31 per cent in 2022–23 (see Figure 8).

Figure 8: Completed and uncompleted regular arrangement audits between 2019–20 and 2022–23

Source: VAGO based on Agriculture Victoria data.

Agriculture Victoria did not complete audits for some arrangements it identified as higher-risk based on factors such as economic, historical non-conformance and risk of damaging the state's reputation.

For example, Agriculture Victoria rated ICA 29 Treatment of Nursery Stock for Export to the Interstate Markets as its second riskiest arrangement. Agriculture Victoria’s 2023 internal audit found that Agriculture Victoria did not audit 2 accredited businesses under this arrangement for 2 years in a row.

An internal audit Agriculture Victoria conducted in 2023 found that staff were not consistently creating audit events in its compliance management system for each arrangement to prompt compliance officers when the audit was due.

Agriculture Victoria is not meeting its targets to audit all businesses under the ICA Scheme, Plant Standards and compliance agreements. 

Since 2022, Agriculture Victoria has prioritised audits it identified as higher risk, such as initial compliance audits and investigatory audits, along with annual and biannual audits of other arrangements considered high risk to minimise this impact. 

Regulatory approach to contain phylloxera

Agriculture Victoria uses a range of regulatory controls to support early detection and limit the spread of phylloxera in Victoria. In line with the National Phylloxera Management Protocol, all grape-growing regions within Victoria are classified into 3 types of phylloxera management zones: 

• Phylloxera Infested Zones (PIZs) – where phylloxera is known to occur. Includes a 5 km buffer from the closest infested vineyard. There are 6 PIZs in Victoria
• Phylloxera Exclusion Zones (PEZs) – an area demonstrated to be free of phylloxera. The movement of risk vectors into the area is controlled. There are 2 PEZs in Victoria
• Phylloxera Risk Zones (PRZs) – areas that have not been surveyed for phylloxera, so its presence is unknown.

Agriculture Victoria produces an annual Phylloxera Operational Plan to guide the implementation of pest-specific deliverables. These activities include:

• inspecting suspected reports of phylloxera
• responding to new detections
• issuing movement permits for control areas
• conducting surveillance for exclusion of phylloxera in PRZs 
• carrying out compliance inspections for permits.

Agriculture Victoria issue permits for phylloxera host materials movement. A permit condition can be that Agriculture Victoria issues a Plant Health Certificate, which confirms host materials meet relevant quarantine conditions. Or, the permit holder may need to issue a Plant Health Declaration or meet permit conditions (such as maintaining treatment records).  

Phylloxera compliance inspections

The Phylloxera Operational Plan requires that Agriculture Victoria undertake compliance inspections on phylloxera permits issued to ensure compliance with movement conditions.

The target is 10 per cent of the movement permits issued in the year. Figure 9 shows Agriculture Victoria has not met this target in 2 of the last 3 years. Agriculture Victoria carried out more than the required number of inspections in 2020–21, but just 52 and 81 per cent in 2021–22 and 2022–23.

Figure 9: Phylloxera compliance inspections 2020–21 to 2022–23

Source: Agriculture Victoria based on data extracted from Agriculture Victoria’s Vector Max database and BioWeb system.

Agriculture Victoria also carries out compliance audits of phylloxera-specific procedures and protocols as a condition of accreditation arrangements. Agriculture Victoria must:

• undertake an initial compliance audit within 4 weeks of the business receiving accreditation or issuing an assurance certificate
• carry out regular scheduled compliance audits twice a year for businesses that operate for more than 6 months each year.

ICA arrangements also require random audits on a minimum of 5 per cent of accredited businesses annually.

Agriculture Victoria's records show that in 2020–21, 2021–22, and 2022–23, it conducted over 90 per cent of regular compliance audits for phylloxera-specific arrangements.

But Agriculture Victoria staff have not consistently created audit events for each arrangement in its internal records system, Vector.

If staff do not create audit events in Vector, they will not be completed. This means there may be regular compliance audits stipulated in arrangements that Agriculture Victoria never carried out.

Agriculture Victoria told us that they recently centralised the processing of arrangement renewal applications to its Biosecurity Services Centre. This will standardise Vector processing, including the creation of annual audit events for all active arrangements.

The National ICA Audit Program found Victoria failed to conduct random audits on 5 per cent of ICA accredited businesses each year. Agriculture Victoria told us that random audits are a high priority but have a low consequence rating if not completed because Agriculture Victoria already carry out initial audits prior to issuing a Certificate of Accreditation for all new arrangements.

Despite random audits being a requirement under the national ICA Scheme, Agriculture Victoria advised us it has cancelled this deliverable for 2023–24. 

New phylloxera detections 

Statewide, new phylloxera detections remain low (refer to Figure 10). But the Maroondah PIZ is expanding. Some properties recorded multiple detections.

Figure 10: Number of properties with confirmed new detections of phylloxera by year

Source: VAGO based on Agriculture Victoria reporting.

Figure 11 details these new phylloxera detections. When a new detection occurs either just within or just outside a PIZ boundary, the response is to extend the PIZ boundary.

Between 2018–19 and 2022–23, Agriculture Victoria carried out 6 extensions to the Maroondah PIZ. Agriculture Victoria has advised these extensions may be due to a natural pest spread, especially with the potential for uncontrolled movement within the PIZ. But the exact cause of this movement is unknown.

Agriculture Victoria did not need to extend the remaining 5 PIZs between 2018–19 and 2022–23.

Figure 11: Phylloxera detections and containment actions 2018–19 to 2022–23

Note: There were no detections in 2020–21.
Source: Agriculture Victoria.

Emergency response documents 

Agriculture Victoria has plant pest biosecurity emergency response strategies and management plans that are consistent with national guidelines.

Agriculture Victoria’s ConOps sets out:

• how to initiate and manage an emergency biosecurity response 
• the roles and responsibilities of Agriculture Victoria staff. 

The ConOps specifies how Agriculture Victoria emergency arrangements link with the State Emergency Management Plan and the State Emergency Management Plan: Animal, Plant, Marine and Environmental Biosecurity Sub Plan.

The ConOps also aligns with the EPPRD and PLANTPLAN in how it outlines:

• biosecurity response phases and activities
• levels and categories of EPPs
• reporting obligations. 

Agriculture Victoria has also developed the priority exotic plant pest investigation (PEPPI) process. The PEPPI process guides the initial investigation following a suspect EPP report. This happens before the biosecurity risk is known and the response strategy has been developed.

The PEPPI process supports emergency responses by providing checklists of actions to take after a suspect report. It also provides templates to guide and document action plans, progress reports and management decisions. 

Approach to plant biosecurity preparedness

Agriculture Victoria takes a generic approach to plant biosecurity preparedness. Agriculture Victoria told us that this is because of the vast numbers of plant pests and diseases that could enter Victoria, which makes it impossible to have a pest-specific plan in place for even a fraction of them. Agriculture Victoria advised that generic preparedness allows them to respond to any pest or disease detection. 

To guide a generic response, Agriculture Victoria relies on the framework in its emergency response documents to ensure decision-making and response activities are implemented.

Agriculture Victoria has developed specific preparedness plans for only 2 pest threats to date: BMSB and medfly. These provide operational detail and guidance on initial actions to take in the event of a detection in Victoria. Agriculture Victoria told us these pests met its criteria for developing a specific preparedness plan and had been prioritised. These criteria are:

• there is a high risk of detection
• the response requires specific operational requirements. 

But Agriculture Victoria has not documented these criteria or how BMSB or medfly were assessed. Agriculture Victoria told us that it developed:

• the BMSB Preparedness Plan because there are regular BMSB detections in Victoria
• the Medfly Preparedness Plan because there are inconsistencies in national plans and, although medfly is currently only present in Western Australia, Agriculture Victoria considers there is a significant risk it could spread to Victoria.

National response to khapra beetle

Khapra beetle is one of Australia’s plant pests of concern. In 2020, khapra beetle was detected in goods distributed to retail stores and warehouses throughout New South Wales, Western Australia, Queensland, South Australia, Tasmania and the Australian Capital Territory.

The Commonwealth Department of Agriculture, Water and the Environment, now DAFF, initiated and led a national eradication response.

Agriculture Victoria was Victoria’s lead agency in the national response and implemented the state’s activities in line with the EPPRD, PLANTPLAN and the national Khapra Beetle Response Plan.

Agriculture Victoria helped develop the national response plan. During the response, it:

• completed trace forward analysis to work out the likely movement path of khapra beetle from its original source and detections
• completed surveillance and trapping activities to check whether khapra beetle had spread
• reapplied chemical treatments where necessary
• coordinated public information, communication and engagement activities in Victoria. 

In December 2021, the National Management Group decided that surveillance and emergency response activities in affected states and territories provided enough evidence to conclude that the khapra beetle had not established in Australia.

Resourcing challenges

Agriculture Victoria’s evaluation of its role in the khapra beetle response found it had not sufficiently planned to ensure it had the resources needed to carry out an EPP response while maintaining business as usual. The evaluation found that:

• there were challenges resourcing staff with the right skills and knowledge, due to a limited pool of people 
• the resourcing model was reliant on staff goodwill rather than effective resource planning, which is not a sustainable long-term approach.

Agriculture Victoria told us that these staffing challenges require significant resourcing and time to address but that progress has been made to address them. 

Internal guidance on resourcing needs

Agriculture Victoria has both general guidance and more specific resourcing models that provide an overview of resourcing needs in an EPP response.

Agriculture Victoria's ConOps details the critical roles and staff responsibilities during an emergency response. The guidance is general in nature, noting that resourcing models will differ based on operational need, type of plant pest, and necessary response activities. 

The EPP Model of Cover for Level 2 Biosecurity Emergencies sets out the roles, capabilities and minimum number of staff required to effectively lead and manage a level 2 (major) EPP and apiary biosecurity incident. Agriculture Victoria advised it is currently updating the Model of Cover to review the current number of available trained and technical staff, such as entomologists, pathologists and risk analysts, and capability gaps. It is due for completion by September 2024.

Agriculture Victoria has also developed a model of cover for a scenario where there are 3 concurrent emergency events – an EPP response, an emergency animal disease response, and an agricultural recovery event, such as a fire. The model calculates the number of resources Agriculture Victoria has, using a range of assumptions, to fill these roles if needed.

Response preparedness training for Agriculture Victoria staff

Agriculture Victoria provides staff a broad range of emergency response training. It has conducted simulation exercises to prepare for a plant pest biosecurity incursion. 

Agriculture Victoria's plant pest emergency response training includes: 

• online foundational and emergency responder courses on the Agriculture Victoria corporate learning portal 
• specialised training, such as Emergency Governance and Emergency Response Manager
• simulation exercises, including:
  • ‘Exercise Coombes’ in 2018, which tested the response to a tarnished plant bug incursion (a high-priority plant pest)
  • an industry liaison exercise in 2023, which scenario-tested BMSB detection, along with a virtual response training exercise to prepare for an EPP incident.

Agriculture Victoria also advised us that staff:

• receive training opportunities through external programs
• may join emergency responses in other jurisdictions as professional development
• may support response efforts within other parts of DEECA, such as animal health responses (for example, avian influenza) and the agricultural recovery from fires and floods.

As of 2024, Agriculture Victoria has 8 staff who participate in the National Biosecurity Response Team program. The program provides training and professional development activities around biosecurity emergency responses.

Response to an EPP

When determining what resources it needs to respond to an EPP event, Agriculture Victoria considers the complexity of the response and the available response options. 

However, Agriculture Victoria's evaluation of their role in the national response to khapra beetle found that it had challenges resourcing staff with the right skills and knowledge. 

Internal modelling by Agriculture Victoria also shows it does not have enough staff with the right capabilities to effectively respond to a plant pest emergency while maintaining business-as-usual functions.

Although Agriculture Victoria offers emergency response training to staff, it is not clear how Agriculture Victoria maps this training to address role needs and shortages, as identified through Model of Cover documents. 

Business units across Agriculture Victoria add training needs for nominated staff into a specific spreadsheet. Agriculture Victoria told us it uses this to identify priority courses to address Model of Cover gaps. But we could not deduce from the spreadsheet:

• which courses are prioritised
• how courses and emergency roles align with EPP Model of Cover requirements
• how many staff attend each training course to meet Model of Cover requirements.

Agriculture Victoria is still finalising a plan that will provide guidance on how to identify gaps and develop staff capabilities to effectively respond to an EPP event. The draft Emergency Management Workforce and Capability Plan sets out the following:

• models of cover will be updated annually for high-risk pest and disease scenarios
• a comparison will be conducted to identify gaps in the capacity to respond to an emergency
• a training needs analysis will then highlight gaps, which will become the focus of capability development. 

Agriculture Victoria advised that it addresses emergency response capacity and capability gaps via workforce 'pools' identified in its Emergency Animal Disease Surge Workforce Strategy. It achieves this through:

• deploying staff from other areas within Agriculture Victoria, DEECA and across the Victorian Public Service
• casual and contract employment arrangements, and labour hire
• a national agreement for the interstate deployment of response personnel, under the National Biosecurity Committee-endorsed Interstate Deployment Arrangements.

DEECA is also developing an internal resourcing system for emergency responses, which is due to be completed in 2026.