ROBERTS, Dr William, Adviser, Australasian Plant Pathology Society

CHAIR: Welcome. Would you like to comment on the capacity in which you appear today?

Dr Roberts : I work for the Plant Biosecurity Cooperative Research Centre but I am here today representing the Australasian Plant Pathology Society.

CHAIR: You have lodged a submission, which we have numbered 4. Would you like to make any amendments or additions to that submission?

Dr Roberts : No.

CHAIR: I now invite you to make a brief opening statement before we go to questions.

Dr Roberts : Thank you for providing an opportunity for the Australasian Plant Pathology Society to talk to the committee on the Biosecurity Bill. The APPS is a professional society dedicated to the advancement and dissemination of knowledge on plant pathology and its practice in Australasia. Plant pathology is concerned with understanding and managing plant diseases in the natural environment and in agricultural systems, a major focus of biosecurity. I would like to take this opportunity to emphasise two issues raised in the APPS submission. Firstly, incorporating a statement on appropriate level of protection, or ALOP, into the legislation is not a good idea. The concept of ALOP is based on the trade agreement, the sanitary and phytosanitary agreement of the World Trade Organisation. It seems deceptively simple: each country develops a policy on the level of both security protection and applies this in managing the risks associated with imports. However, despite many attempts, international guidance on the definition and application of this term has not been forthcoming.

Australia's difficulties in applying the concept of ALOP have been well illustrated by losses in the WTO dispute settlement process on salmon and apples and the concerns of this committee about the matrix used by the Department of Agriculture, Fisheries and Forestry to apply the concept of ALOP to import risk analyses. Apart from this it is not appropriate to use a specific term from an international trade agreement in Australia biosecurity legislation. The biosecurity legislation is about the protection of plant, animal and human health and the environment in Australia, not simply about trade. The inclusion of a specific trade term in the legislation will tend to reinforce industry and community views that the focus is on facilitating trade rather than providing biosecurity protection.

There are also problems with the proposed statement on ALOP. Although this statement, which is low but not zero, has been used for some time, many stakeholders both industry and the broader community consider it is nontransparent, confusing and subject to arbitrary application by administrative practice. This issue has been extensively canvassed in major reviews of quarantine and recommendations made to provide much greater clarity on Australia's policy on biosecurity protection. It is difficult to see how embedding the term in legislation along with its current unclarified definition will provide importers and trading partners with additional certainty of the standard that is being applied and increase transparency in its application when assessing biosecurity risk as stated in the explanatory memorandum associated with legislation.

My second point relates to the capacity to deliver scientific and technical services needed for biosecurity. A risk based approach is being proposed where the actions taken to manage risks are closely related to the specific circumstances rather than based on a set of standard procedures as has been done in the past. This is consistent with Australia's international obligations and has the potential to result in better biosecurity outcomes but it will be much more complex and challenging to develop and deliver than the current rules based approach.

In particular, the move to a risk based approach will require very significant investment in training of officers involved in biosecurity activities to ensure they have adequate technical knowledge. There will also be a need to recruit a significant number of additional staff with appropriate technical and scientific skills to develop appropriate risk management measures based on the assessed risks, to monitor outcomes and provide backup for frontline biosecurity staff. However, it is not clear that is sufficient skilled staff will be available to undertake this work unless there is a significant increase in the recruiting, training and development of technical staff.

To illustrate this, the APBS in conjunction with the Australian Entomological Society commissioned a study in 2012 that shows that Australia's capability in plant pathology and entomology has continued to decline since an earlier study in 2006. The latest study has indicated that the age profile in these disciplines has shifted to an older profile, with fewer in the under 35 age bracket. In the next 15 years over 50 per cent of the capacity will need to be replaced just to maintain Australia's current low capacity. In this situation continues, it will not only threaten the ability to deliver high quality biosecurity and a high quality biosecurity system but it will also make it very difficult for state government agencies to provide adequate pest and disease protection for agriculture and the environment. I will table the summary of this report that is commissioned by the APBS and the Australian Entomological Society for this committee. The full version of the report is available via the APBS website. Thank you once again for the opportunity to present. I am happy to answer your questions.

Senator BACK: Dr Roberts, I can only agree with you in terms of the appropriate level of protection be enshrined in legislation. What would happen if it was placed there and over some period of time international trade agreements et cetera went away from an ALOP to some other form of scrutiny? What would be the outcome then? Would we have to change legislation?

Dr Roberts : I believe so. I see that as one of the issues. The legislation we are talking about changing now has been in place since around 1908. We are now in 2013, so if this new legislation is likely to have that same sort of longevity and the thinking about ALOP changes or the international agreements change, where does that leave the legislation? Presumably there will have to be modifications to those terms.

Senator BACK: You would have followed the debate that had its origins with this committee in Senate estimates where we challenged the risk matrix being applied at that time for the importation of apples from New Zealand. That led to dissatisfaction with the mathematical methodology, which then led to the committee receiving authorisation to seek input from others, and that led to Dr or Mr Peace from New Zealand. Does your organisation or scientists with whom you are associated have the capacity to test that same data against Peace's alternatives and inform this committee whether the same appropriate level of protection would emanate from those changed methodologies? There are a couple in the Peace documentation if you have studied it. We at this moment do not seem to be able to get the department to use its own figures, data and risk assessments for each of the five areas, so we wonder if you, through industry, might.

Dr Roberts : It is an interesting idea. The short answer is that the CRC could arrange and be involved in such a process, but I am not the CEO of the CRC so I use caution in putting the CRC forward. It is an idea that we would certainly be prepared to consider. I do believe that amongst the participants of the CRC we would have or find the capacity to do that. Whether you would get a satisfactory result, in terms of a black-and-white conclusion, I do not know, so I would caution that one of the problems is it is not a black-and-white area. The problem is the uncertainty starts way back in ALOP. Low but not zero: what on earth does that mean? It means something different to you, to me, to everyone else probably. Then you translate that through to the matrix, and the risk assessors really need something like that to do their work—they cannot work with a definition saying 'low but not zero'—they need the matrix or something similar to do their work. Coming back to your point, I think the CRC would be happy to consider that proposition from the committee, but I cannot tell you whether we would or would not do it if asked.

Senator BACK: When I read your comment—and you have just spelled it out—that 'stakeholders in industry and the broader community consider it non-transparent, confusing and subject to arbitrary application by administrative practice', I could not but help consider that that applied exactly to our dissatisfaction with the risk matrix process. That leads me to your second point because in setting the parameters for the risks associated with each step along the journey there are qualitative and quantitative assessments. But a lot of that comes down to the expertise of the person or people engaged in that process, doesn't it?

Dr Roberts : That is correct, and it is one of the difficulties with declining expertise available. The reality is that you cannot take a good plant pathologist, entomologist or animal health person off the street or from another institution and say, 'Do some risk analysis and tell us what the answer is,' because they need to develop what is the target, the degree of protection you are trying to achieve. Either that or you give them something that really is black and white: 64 or something like that, if you could. That is the deceptive aspect of ALOP—it is a very simple concept, you just set a level of protection and arrange everything so it meets that. If it does not, you put risk management in place. It is a very simple concept, but no-one around the world, including in the international organisations, has been able to pin it down in a satisfactory way so anyone—

Senator BACK: Exactly. This came home to us starkly yesterday when a witness in Hobart told us that in his background—he is now in a scientific role—he managed packing sheds. And he said, 'Unless you have worked in and managed a packing shed, you could be taken into it, even as an administrative person, and if you did not have the skills and expertise, I could tell you anything about the day-to-day management of the packing shed and therefore the risks associated with something escaping from that packing shed.' It really came home to me that, again, each step of this process requires not just the scientific training but the practical industry training to enable a person to make an accurate judgement. Any of us could be taken into a packing shed—Senator Edwards may have some experience of this, but I certainly have none at all—and it would not really matter what my theoretical knowledge was; if I did not have the practical knowledge to know what to look for and see where the risks were, I could come up with a conclusion that could be totally and utterly wrong, couldn't I?

Dr Roberts : Yes. It requires judgement. That is the point. It is not just scientific and technical knowledge; it is using that to make a judgement against the specific circumstances. You have to have the background to make that judgement as well as specific knowledge relating to the particular events that you are looking at.

Senator BACK: You have got a possible multiplication of errors, haven't you? You have got to apply some sort of level of risk to each step along the journey, which may or may not be accurate and may or may not have some allowance for error. But, how you treat each of those—and that is where we got into our arguments with Dr Grant in the apple situation—whether you add them, whether you multiply them, whatever you do with them—this is where I think we got value from Mr or Dr Peace—you could well end up with a very different outcome than the one that has been established. Of course, it goes to my last question to you, which is to do with industry. It possibly has a profound effect on industry itself, does it not? Do you believe that, in the legislation we are being asked to consider, there is adequate scope and opportunity for industry to be able to voice its concerns at the highest and last level before a final decision is made?

Dr Roberts : It really all depends on how the legislation is administered. I worked in DAFF for 20-plus years. DAFF does try its hardest to involve relevant stakeholders. I know some people do not particularly think they do, or think they do not do it very well, but they certainly try. I do not see anything in the legislation that constrains DAFF, or whatever body is going to do this work in future, involving stakeholders, industry or the community at all levels. There is nothing that constrains that. I will come back to my starting point, that it is really just how the legislation is run in terms of how it is administered and what involvement—

Senator BACK: Therefore, do you think there would be a greater level of community confidence if the director of biosecurity was at arms-length from, different to, independent from the secretary of the department, which is the current intention?

Dr Roberts : I must say—this is a personal opinion and not necessarily APPs'—the statutory authority or separate body model is certainly appealing to me. I think that needs to be set aside from a department that has got a very strong interest in trade and import and is also strongly influenced by other Commonwealth departments that work in the same sort of arena. The thought that is very appealing to me is that you take it out and put it separate and tell it, 'You have got very narrow guidelines which relate to biosecurity protection. Do not worry about the national policy aspects that flow from that; someone else will look after those. You tell us what the answer is on the technical and scientific basis.'

Senator BACK: So the importation or the export of some other product and commodity does not get tied into it. Thank you, Dr Roberts.

Senator SIEWERT: I know you had the ALOP process but, if I understand your comments both here and in your submission correctly, you would amend the legislation to not use that concept in the legislation?

Dr Roberts : I think so. The sort of mantra in international fora about ALOP is that it is an issue of national country policy, if you like. It comes down to the point which opens the possibility that your ALOP—if you could measure it accurately this year—might be quite different in 20 years' time because it is subject to community and national policy development.

So, it does not seem wise to me to embed it, complete with a definition which I do not think that is very helpful to anyone, in the legislation itself. I would much rather see that there may be a reference to into it along the lines of, 'the government will set the level of protection periodically, in consultation with the industry and the community,' or something like that. That is a bit wishy-washy in a sense—but it does not leave a lot of process embedded in the legislation—but it does allow for the fact that over time the ALOP may change, the international agreements may change and the risk appetite in general of the Australian community may change as the rest of the world changes. I just think it is not smart to embed something that could be stuck there for a long time and is simply a specific term out of an international trade agreement, not a biosecurity agreement.

Senator SIEWERT: Thank you. You made a comment about a lot of this being left up to the department to assess and implement. A lot of it goes back to the regulations. We have had a lot of comment about people not having seen—

Dr Roberts : Yes. In the submission I did—and the devil is in the detail, of course—we have not seen the devil yet.

Senator SIEWERT: Yes, exactly.

Senator COLBECK: Or the half-cooked chook!

Senator SIEWERT: Yes! In terms of what we do with this legislation: there have been a lot of calls to see the regulation, and some calls that we should not deal with the legislation until we have seen the draft regulation. Do you think there is enough in the legislation to give—I call them 'hooks'—enough guidance? Or should we be hard line and say, 'We don't want to deal with this until we see the regulation'?

Dr Roberts : Other than the ALOP aspect, I am reasonably comfortable with the legislation. I think it allows plenty of scope to do what needs to be done; again, with the caveat that it depends on how it is administered of course. And, of course, the regulation is a large part of how it is administered.

Senator HEFFERNAN: And how it is resourced.

Dr Roberts : And how it is resourced, yes. I do have concerns about the capacity to deliver it, but that is a separate issue.

From a personal point of view, and probably from the APBS point of view as well, I think we would be happy for the legislation to go through. But there has to be a real and meaningful consultation on the regulation and the lower level supporting material before that is finalised as well.

Senator HEFFERNAN: The ALOP: isn't that a pathway that would be continuously lowering the bar to enable trade? There is huge pressure on countries through free trade agreements and the WTO to facilitate trade. It has been the experience of this committee, and you have witnessed some of it over the years, that rather than to lift the standards of countries you tend to lower them so you are all on the same playing field. With the ALOP and the proposition that somehow you would have judgements made on the risk for a particular importation and the amount of scrutiny you would apply to that, and the more that you emphasise the processing in the country of origin: isn't that sure to fail? You would be aware, Dr Roberts, that in Asia to get the paperwork right if you pay the person enough bribe money—'facilitation' they call it, to make it sound nice—you can get the signature. We are talking about relying on signatures on bits of paper—and we saw this with the bananas. The biggest producer of bananas in that country was the minister for agriculture. If we do not have some sort of mandatory, obligatory intervention, won't the smarties who can pay their way through the system just put the appropriate paperwork up to say 'we are outside the risk area,' therefore it will be an easier path—bearing in mind that, once the stuff gets here, it is someone else's responsibility if it gets out into the plant community or wherever it goes. Shouldn't we be more precise than what is proposed? You say you agree with the legislation—

Dr Roberts : If the risk assessment is done correctly, it should take account of how much confidence you can put on, say, the offshore activities of the source country versus what you need to do on arrival or at distribution or whatever within Australia. In principle there is no problem taking those difficulties or problems into account in the risk. In the end your risk analysis might say we have a very low degree of confidence in this particular requirement being delivered to the full standard in the source country, so you could get a very low score or a very high probability of failure, depending on how you run the risk assessment process. It is not a fundamental problem of principle; it is a fundamental problem of having enough resources to apply and the determination that it will be done properly, otherwise Australia will not take the imports.

Senator HEFFERNAN: But under this arrangement, because of that exact thing, the resources and funding to supervise it, isn't the pendulum swinging more to the tick and flick, do not ask do not tell and look the other way?

Dr Roberts : Certainly there is a move in a lot these areas for co-regulation or industry, both in Australia and overseas, delivering aspects of it and at some stage you would hope that the authority concerned has done the right assessment of what are the risks if it fails, and a bit of self-interest might get in the way and they might decide to do it et cetera. That is an issue. Interestingly enough, one of the projects that CRC is planning to do, and we are in the middle of developing it, is what can you expect from a co-regulation type of activity. What we are trying to do is explore the limits. If you are going to manage a process with these sorts of characteristics, is it reasonable to expect co-regulation to deliver the same standard that a government authority might or a third-party auditor might or someone else might? That is in the early stage of being developed as a project. It will probably be a few years before it starts producing results.

Senator HEFFERNAN: In that project would you give serious consideration to the capacity of facilitation, which is normal in certain parts of the world—paying for the signatures on paper—versus the culture we have, which is that you have to get it right; you cannot pay to get a signature?

Dr Roberts : We would be a bit careful about how we characterised it in our study, but we would certainly talk about what are the consequences of failure—do you have to get the industry side or the source country side working 100 per cent of the time to deliver the requirements; is it all right if they only do it 95 per cent of the time, or if they do it only 95 per cent of the time is there a measure you can put further down the chain that is going to compensate for those failures? It is to do some of that thinking. It will be a fairly theoretical study, I think, in its initial stage, but it is trying to get to that sort of point.

Senator HEFFERNAN: We do not have the resources to go over there and check, wherever it is. We have some resources, but it is impossible. Whether you like it or not, there is endemic corruption in doing business in Asia. Do you recognise that? You are not the department; you can have an opinion now! What went wrong with some of that sheep stuff in the Middle East was a mix-up in the bribes. And people do not like to talk about it, but—

Dr Roberts : There is some belief that the bump problem on wheat exports to another country in that region was related to that same issue.

Senator HEFFERNAN: Yes, it was. So, in terms of protecting our farmers, who have no recourse on the people who set the system in place if it fails and we get a huge problem—the citrus canker will destroy 800,000 or 900,000 mandarin trees—how do we come to terms with the difficulty of relying too much on signatures on paper from the importing country?

Dr Roberts : There are different approaches. You can put offices in the source country, if that is what you feel you need to do, to manage that process. We do use pre-clearance arrangements on occasion. In some cases it is convenient for importers as well, because they know that when the material arrives at our border they will get fairly quick and easy release because all the measures are done offshore but under Australian supervision. So, those mechanisms are there. It is a difficult area, and I think if there is a push on the basis of legislation to rely much more on source-country activities then there really does need to be a very significant increase in the resources available.

Senator HEFFERNAN: So, if we go to a system that does not have random intervention—random checking—and we go to a risk based approach whereby if the profile says that this particular product has a lower profile and more or less gets a green-light corridor through the system, won't that just become a lurk? The reason that fertiliser got through the ports here—I do not know whether they paid someone to not open the doors—was, according to the department, that it was in a certain sized bag. Well, if you know that you can put it in a certain sized bag or whatever, won't that just become the way through the system, like a mandatory speed camera that you know is not going to be in the system?

Dr Roberts : Yes, but a responsive and well-resourced biosecurity system should pick that up very quickly.

Senator HEFFERNAN: But we do not have that.

Dr Roberts : And it should modify the conditions. For example, we would change the bag requirements or increase inspection on that size of bag, or something. That is sort of the issue I am a bit concerned about—the resources and technical capacity to do this.

Senator HEFFERNAN: So, can we extend the legal and administrative responsibility beyond the receival point in Australia? The decision makers will say it is okay to bring whatever it is in. They are administratively responsible at the exit and at the wharf, at the present time. Can't we extend their responsibility a little bit further so we can crack someone's head if what they have brought in turns out to be, like that fertiliser, a complete farce? Shouldn't we have a continuous train of responsibility right through the system, rather than have a Chinese wall halfway along it?

Dr Roberts : It sounds like a good idea, but I suspect there are significant legal problems in reaching too far offshore. But the ultimate sanction is to say that that product or that country or that importer or that chain that is being used to do the imports should be crossed off the list—that we are no longer going to accept that, until perhaps significant and good remedial action is taken. I am aware of cases, some years ago now, in which every single fumigation operator in one particular country—every single one of them—was crossed off. AQIS would not accept any fumigation certificates from that country for a while. So, there are those sorts of sanctions, but they are pretty blunt and often a long time after the event.

Senator HEFFERNAN: If I was the cocky at Condoblin who received the fertiliser, knowing it had come through a supervised Customs and AQIS process, which it did, and it turned out to be dirt—full of weeds and crap, as it turned out to be—I would like to think I could sue someone or get some sort of compensation. But, at the present time, the people who supervise that are untouchable. Do you think that is fair?

Dr Roberts : I do not know their specific circumstances. It they were public servants supervising and acting in good faith, I suspect you would have trouble legally. You would have to prove, I assume—

Senator HEFFERNAN: We won't go into all that legal stuff.

Dr Roberts : All of that. But if the ultimate buyer believes the product is not up to scratch—separate, perhaps, to the biosecurity issues—they always have the redress of going back and arguing the toss. That stops at the border, obviously; they cannot go much further than that. I am not aware that you would have much chance, in most circumstances.

Senator HEFFERNAN: In that instance, the person just disappeared into the ether in China.

Senator COLBECK: You were talking to Senator Back about the development of the BIRAs. You also mentioned in your submission, under point 3, the requirement for greater contact with commercial processing packing facilities in this country if importers are seeking to rely on action taken in exporting countries as a component of risk management. Do you see the current structure of the legislation as allowing for that collaboration? We did hear yesterday in Hobart, from a number of the industry participants, that they would like to be more closely engaged in the process of the development of the import risk assessment rather than coming in towards the end and having to respond and react. They would like, using their knowledge base, to be able to provide—and this reflects some of what Senator Back was saying as well—some practical input into the development of systems and processes to assist in import risk assessment. Do you see the current legislation, as it stands—bearing in mind that we have not seen the regulations yet—as facilitating that? Or is that much more a procedure and process thing?

Dr Roberts : Yes, I think it is down at that level. I do not remember anything in the legislation which would inhibit or prevent that process, but equally I do not think it is directly promoted in the legislation itself. Again, I think that is a question of how the relevant department delivers.

Senator COLBECK: So that is a behavioural thing, but it could be facilitated under the development of the processes of the BIRA and the new procedures which come out under that process.

Dr Roberts : Yes. The industry and community involvement in those procedures has substantially increased over the 20-plus years I have been involved. I understand that a lot of people do not think it is adequate. But it has certainly increased a lot over that period. I do not see any constraint on that process increasing—

Senator COLBECK: Are there any issues with that level of engagement through the commencement of the process? Are there any issues which cannot be properly managed by declarations or things of that nature?

Dr Roberts : I suppose there are some sensitivities associated with conflict of interest. If you are an importer of a product and you see a whole lot of local producers in the room, you might begin to wonder whether there is a conflict of interest—just commercial interests in terms of competition. That is always a difficult issue to manage. I have a fair bit of sympathy for people in government departments who have to manage that issue. What they are trying to do is get good, meaningful input from local industry about what they see as the risks, how their industry is structured and what the introduction of different organisms would do for their industry. But they are trying, to some extent, to keep out direct competition issues. So it is a very difficult task.

Senator COLBECK: I think we probably saw a certain element of that in the discussions we had on the import risk assessment for apples from New Zealand. There was a lot of conversation about the visibility of the standard orchard practice which was to be utilised as a basis for that import risk assessment. But the industry were then told that that was a proprietary product, and it was commercial-in-confidence, so they could not see it. It became a topic of debate and a bit of bitterness over 12 months or so. But, when it was finally released, the revelation was that anything that was relevant was actually written into the import risk assessment—basically just lifted out of that and put in there. But that simple disclosure at the beginning of the process would have saved everyone a whole heap of grief. But, again, that was a condition the importing country put on the information. It still became a point of huge contention during the debate around that issue. Do you think there is the capacity to actually deal with some of those things as part of the process?

Dr Roberts : I don't think you can legislate for them in any satisfactory way. That is part of the problem, because they vary quite a lot.

Senator COLBECK: No, it is a regulatory and a behavioural process.

Dr Roberts : What you really need is all parties doing the best possible job they can in the circumstances. I know that, in the New Zealand case, a lot of that stuff was claimed to be commercial-in-confidence and they did not want to release it. I was involved in a number of the earlier apple IRAs. With the ones I was involved in we specifically had to get clearance from New Zealand before we put it in there, but we could not reveal the whole manual and procedures in detail. So I think there will always be a problem. I hope we don't have too many New Zealand apples! I must say, one of my first tasks when I joined DAFF in 1989 was starting to work on New Zealand apples. When I retired I was still working on New Zealand apples.

Senator COLBECK: We have a few colleagues who went through the same thing, throughout their careers in this place. You mentioned the flexibility with increasing complexity—so, the approved arrangements, if you like, from a number of different sources given you a number of different procedures you have to deal with. Therefore there are issues around auditing and the understanding of all those different systems. Do you think part of the process could be that there are some underlying principles that fit within that?

Dr Roberts : The problem with this area is that the complexity is enormous. There are thousands of plant diseases that we do not want; there are thousands of insects that we do not want—and that is just on the plant side: then you have food safety issues and all the health issues on top of that. The complexity is such that it is made extremely difficult—any overarching principles would be at such a high level that they are not going to make a big difference to what you do. So really every case is different.

The approach that has been used—and is still being used until this new legislation goes through—is to make sets of rules that are believed to capture everything from the best case to the worst case in a particular area. So you make a set of rules and you train people to audit those rules. So they do not have to think too much about the biology; they do have to think about the auditing and whether they are being properly delivered—but they are largely auditors of delivering the rules and the process.

What will potentially happen under the new legislation is that, rather than a standard set of rules—'this is product Y: here is the rules for product Y; are they delivering them et cetera'—they might have 20 different rule sets for product Y because there are 20 different importers, all from a different source and all under different conditions. So there is certainly a strong audit function, but you do need people who have enough background to say, 'That is slightly off the rule, but is it enough to make a big difference or not' et cetera. That is what I mean by increasing the complexity and the training that is going to be needed.

Senator COLBECK: Does that also have the potential to increase alertness a little bit? If you are exposed to a number of different methodologies, it might actually, with experience, give the capability to alert you to wrinkles that might be appearing in the different systems. Rather than being on the one path the whole time—and we talked earlier about familiarity breeding complacency—if you have got a number of different systems that you are looking at it could potentially give you the capacity to be a bit sharper across the different systems.

Dr Roberts : I do not disagree. If all they are doing is auditing the same thing over and over again there is a risk of the attention wandering, I suppose. Whether it is really a good idea to fix it by making it much more complex, I am not too certain. Don't get me wrong: I think that approach can still deliver very high-quality biosecurity protection. But I come back to my point: it will require resources and training to get the right people to do it.

Senator COLBECK: Looking at it from a slightly different perspective, is it likely that you could end up with having to have a number of different levels of speciality in that system? That could embed additional cost if you have got so many different mechanisms, the specialist in one or two there and another two or three here and you need different resources to do that, and they are sourced from within your system and you need to have additional capacities rather than someone who can go in and do one thing across a whole range of different sites.

Dr Roberts : I think that is an issue that will have to be addressed. I think you will need some specialisation in the front line offices and also for back office, to provide all that backup.

Senator COLBECK: You do mention the risks with a risk based process. We had a conversation earlier about some of the issues that they had in New Zealand with having to move backwards and forwards to different approaches. Is it that we are going to have to have a mix of systems to deal with this and, depending on circumstances, occurrences? Senator Heffernan was discussing someone who is gaming the system; potentially you change the system or the mechanism to manage that or to manage the risks that that might toss up.

Dr Roberts : Yes, you will. Almost inevitably if you are going to allow for different circumstances or different risk management based on different sources you are going to have to take account of that and you are going to have to face perhaps the possibility that one country gets pretty upset when you apply much more stringent conditions on them which might be based on some consideration of this facilitation issue, while another country gets away with much less stringent conditions because we know their performance and trust that they will deliver up to the standard. But that is one of the sensitivities that will have to be managed. If what you are about is just tailoring quite closely the risk management measures to the source then you have to accept managing those sorts of sensitivities.

CHAIR: Dr Roberts, as there are no further questions, thank you.