FAQs related to Request for development of an Import Health Standard (Processed Plant and Forestry Products)

In the US, genetically modified lucerne could cross-pollinate with non-GM lucerne, and the modified traits may be inherited by the next generation.  Lucerne is a perennial species and feral plants grow along field edges and roadsides in the main seed production areas in the US. Consequently, wild plants containing GM genes may persist in these environments.

Little is known about the potential for persistence of these GMOs in the New Zealand environment. However, GM lucerne is not approved by the Environmental Risk Management Authority (ERMA New Zealand) for release into the New Zealand environment.

The GM lucerne varieties have been modified to be tolerant to glyphosate herbicides (the principle ingredient of Roundup^TM  and several other herbicides) , to assist with weed management for the production of hay and forage in the field. The varieties contain the glyphosate tolerant gene (CP4 EPSPS) and a promoter from the Figwort Mosaic Virus (FMV).

If this testing protocol were not established, the likelihood of inadvertent import and planting of GM lucerne/alfalfa into New Zealand may increase. Little is known about the potential for persistence of these GMOs in the New Zealand environment, therefore existing lucerne hay and alfalfa/lucerne seed markets may be affected.  Additionally, growers of these seeds may find themselves in breach of the HSNO Act, as GM lucerne/alfalfa has not been approved for planting in New Zealand.

The key cost is that of the test itself.  Testing costs between $340 and $560 NZD depending on which laboratory conducts the test. Importers are likely to pass any increased costs from testing on to their consumers, so lucerne hay and alfalfa sprouts may cost slightly more as a result.

MAF and ERMA New Zealand have the ability to prosecute under the both the HSNO and Biosecurity Acts.  This is considered on a case-by-case basis.

Working closely with ERMA New Zealand, MAF would work to ensure that the GM lucerne, and commodities likely to harbour it, were isolated and devitalised so that no seeds could germinate.

ERMA New Zealand supports the Environmental Risk Management Authority in its decision making role for applications to import, develop, or field test new organisms; or to import or manufacture hazardous substances. These applications are made under Part V of the Hazardous Substances and New Organisms Act 1996.

Testing typically takes two to seven days, depending on laboratory workloads. Most importers arrange for testing to be conducted offshore prior to shipment of seeds, so delays at the border are not anticipated.

The importer is required to meet the costs of testing. The testing costs between $340 and $560, depending on which of the three MAF approved laboratories conduct the testing (USA, France or Australia).

The MAF-approved test, which requires a sample size of 3200 seeds, will detect GM if it is present in the sample 99.9% of the time. A sample size of 3200 seeds (required by all of the MAF testing protocols) provides a 95% confidence that GM seed will be sampled from a seed lot if it is present in concentrations of 0.1% or more (greater than or equal to 1 in 1000 seeds).

GM lucerne/alfalfa was approved by the USDA (US Department of Agriculture) in July 2005 for wide-scale cultivation. In the same year it was assessed and approved for human food in Canada and Mexico in 2005, and in 2006, Japan.

Although GM lucerne/alfalfa is intended primarily as an animal feed, its safety for human consumption has also been assessed in case some inadvertently enters the human food supply.

Food produced from Roundup-ready corn, soybean, canola and sugar beet, which all contain the same modified gene as GM lucerne, have already been approved as safe for consumption by Food Standards Australia New Zealand (FSANZ). FSANZ are currently conducting an initial assessment of GM lucerne as food, and if it is approved for human consumption, all products containing GM must be labelled as genetically modified in accordance with the Australia New Zealand Food Safety Code, Food Standard 1.5.2. This provides consumers with choice as to whether or not they purchase foods containing GM ingredients.

For any questions about food safety, please contact the New Zealand Food Safety Authority :

New Zealand Food Safety Authority
68-86 Jervois Quay
PO Box 2835
Wellington

Most imported seed is grown into pasture or lucerne hay for feeding livestock. A smaller proportion is sprouted as alfalfa sprouts for human consumption.

In 2005, New Zealand imported approximately 37,000 kg of lucerne seed for sowing and approximately 9, 000 kg seed for sprouting.

Production of lucerne for livestock and alfalfa sprouts in New Zealand relies on seed imported from large breeding programmes in the US, Australia and Europe. New Zealand’s own lucerne and alfalfa seed production industry is small, and is localised in areas of Canterbury and Otago where climatic and soil conditions are favourable. Overseas specialised breeding programmes offer growers a wider range of seed selections not otherwise available to the New Zealand industry.

Medicago sativa is the Latin name for lucerne, also called alfalfa. The seeds may be grown as a forage crop or lucerne hay for feeding livestock, or sprouted to produce alfalfa sprouts for human consumption.

The protocol will require importers to have consignments of viable lucerne/alfalfa seed tested for the presence of GM seed at one of the three MAF approved testing laboratories located in Australia, France or the US.

Importers of viable lucerne seed for producing animal feed and alfalfa seed for human consumption will be affected.

MAF would like to hear feedback from people who have an interest in, or would be affected by, the seed testing protocol. The protocol would be put in place by amending the existing Import Health Standards for Medicago sativa ( Seed for Sowing and Importation of Grains/Seeds for Consumption, Feed or Processing – Plant Health Requirements).

The purpose of a seed testing protocol is to minimise the likelihood that GM seed will inadvertently be imported into New Zealand within consignments of conventional seed. MAF already has seed testing protocols in place for maize and sweet corn, oilseed Brassica, and soybeans, which were implemented in 2001 and 2002. MAF intends to extend these requirements to lucerne/alfalfa because two varieties of genetically modified (GM) lucerne are entering commercial production in the US for the first time this year.

MAF is responsible for enforcing the ‘new organism’ provisions of the Hazardous Substances and New Organisms Act 1996 (the HSNO Act). GM lucerne is considered a ‘new organism’ under the HSNO Act and cannot legally be imported or grown in New Zealand. The HSNO Act prohibits the importation, field-testing or release of any ‘new organism’ without approval from the Environmental Risk Management Authority (ERMA). To date, no GM organisms have been approved for release in New Zealand.

Under the Biosecurity Act 1993, decisions on issuing import health standards are the responsibility of the Director-General of MPI, on the recommendation of a Chief Technical Officer from Biosecurity New Zealand. Biosecurity New Zealand is the part of MPI that administers the Biosecurity Act.

In March 2002, the FAO Interim Commission on Phytosanitary Measures adopted new guidelines for wood packaging for international trade. These were called the International Standards for Phytosanitary Measures (ISPM) No 15: Guidelines for Regulating Wood Packaging Material in International Trade (ISPM 15).

ISPM 15 describes phytosanitary measures to reduce the risk of introduction and/or spread of quarantine pests associated with wood packaging material (including dunnage), made of coniferous and non-coniferous raw wood, for international trade.

New Zealand, as a signatory to the International Plant Protection Convention, has revised its own wood packaging import standard to more closely align it with this international standard.

Internationally wood packaging is recognized as an important pathway in the transmission of pests. A significant proportion of wood packaging is manufactured from relatively low quality raw wood which is likely to contain pests.

Many invasive pests have been intercepted on wood dunnage, pallets, crating or other wood packaging imported into New Zealand.

Most international exporters will be aware of, if not already complying with, the ISPM 15 standard so explaination of the New Zealand standard should not be too difficult.

We recommend e-mailing the link to the full standard to all your suppliers for them to review.

There are a number of different pest that could be found on untreated wood packaging. Some examples are:

• Powder post beetle
• Asian longhorn beetle
• Citrus longhorn beetle
• Subterranean termite

Even if wood packaging is treated accredited persons should still watch out for other pests and diseases that might be in their consignment. Re-infestation of treated wood packaging is also possible.

Wood packaging material includes items such as dunnage, crates, fillets, spacers, pallets, drums, and reels. Peeler cores are exempt from the international standard ISPM 15, but are included in the New Zealand standard when used for packaging.

Packaging that is made from manufactured wood, such as plywood, oriented strand board, fibre-board, paper and cardboard packaging or those made from non-wood articles and thin wood (considered to be 6mm thickness or less) are exempt.

Wood packaging material such as sawdust, wood wool, and shavings, are regulated according to the Import Health Standard for Sawdust, Wood Chips, Wood Shavings, and Wood Wool from All Countries.

Wine barrels and animal crates used for the transportation of live animals are regulated by the Import Health Standard for Woodware from All Countries

Acceptable methods of treatment are available in Appendix 1 and Appendix 3 of the import health standard for wood packaging material.

Methyl bromide is an ozone depleting substance and its use is not encouraged when alternatives are available. Methyl bromide use as a quarantine treatment is exempt from the consumption controls under the Montreal Protocol. It is not known how long this exemption will remain in place.

Yes. These items are not regulated under the wood packaging standard, but regulated under the Import Health Standard for Woodware

The International Standard for Phytosanitary Measures No. 15: Guidelines for Regulating Wood Packaging in International Trade encourages countries to adopt similar import measures to reduce the incidence of unwanted exotic pests moving to new areas. Several countries have decided to adopt this International Standard as import measures and many other countries have given notice that they, too, intend to adopt the recommendations of ISPM 15

As an exporter, you will need to meet the importing country's requirements. Requirements for the export of certified wood packaging are provided in the export phytosanitary requirements for other countries.

Wood packaging returning to New Zealand must meet the requirements of the New Zealand import health standard as it could have been infested whilst offshore with exotic pests.

Yes it does change their role. Accredited persons should still be inspecting all wood packaging for pest such as insects and fungi but they must also record the ISPM 15 compliance status of the wood packaging on their container log sheets.

We recommend that non-compliant wood packaging be treated or destroyed.