From Strategy To Reality: Implementing The New Biosecurity Strategy

A speech to the Biosecurity Summit Wellington 4 October, 2003

Murray Sherwin Director-General, Ministry of Agriculture and Forestry

Introduction

On 25 August this year, Biosecurity Minister Jim Sutton released the Biosecurity Council’s new Biosecurity Strategy document. That Strategy had been three years in the making, a process that involved numerous public submissions, nationwide public meetings, the engagement of officials from many government agencies, as well as representatives of local government, universities, Crown Research Institutes, non-government organisations and other special interest groups, including industry representatives. In short, this was a huge piece of work. If nothing else, it has proved that there is both a high degree of interest in issues of our biosecurity system, and the answers are not that easily discovered. This process has been hard yakka.

The release of the Council’s new Biosecurity Strategy was not the end of the process. But nor was it the beginning. Over the past five or so years, biosecurity or aspects of it have been subject to near constant review and enquiry. Amongst the more recent reports are those that study our surveillance systems, the processes by which import health standards are developed, container risks and strategies to better manage those risks. And the lessons we can draw from that succession of reviews are either positive ones (i.e. this is a system running rapidly to keep pace with new demands, and constantly looking for new and better ways to meet its objectives), or the negative ones (i.e. this is a system failing to meet expectations and therefore subjected to constant review as improvements are sought).

Whichever interpretation you prefer to apply, the Biosecurity Strategy provides a robust platform from which to make a quantum leap in our biosecurity capability and risk management, and to deliver the sort of biosecurity protection that New Zealanders are saying they wish to see.

Scope of the review

But before we can start to improve our biosecurity systems, we need to have a common understanding of what it is we are talking about. To quote from the Strategy:

“In its broadest sense, biosecurity covers all activities aimed at managing the introduction of new species to New Zealand and managing their impacts once here”.

However, the focus of the Strategy, the work of our biosecurity agencies, and the focus of this conference relates to a subset of what is described above. Again, to quote from the Strategy document:

“The focus of this strategy is on pre-border, border and post-border activities designed to keep out new pests. These are central to the Crown’s biosecurity responsibility. Beyond this, the strategy addresses the Crown’s role in maintaining and monitoring the framework for pest management under which agencies, industry and individuals take collective actions against pests.”

Strategic vision

The vision outlined in the Biosecurity Strategy document is:

“New Zealanders, our unique natural resources, our plants and animals are all kept safe from damaging pests and diseases.”

This vision is elaborated with a series of statements about what we should be seeing from our biosecurity system in the future:

“By 2010 …New Zealand has a high performing, integrated system for managing biosecurity risks to the economy, environment and human health. New Zealanders understand and have confidence in the biosecurity system; committed and playing their role, from pre-border through to pest management.

Decisions are founded on good information, based on quality science, taking into account the full range of values at stake and with transparent trade-offs. There is efficient use of the biosecurity budget and biosecurity risk management (from pre-border to pest management) provides an appropriate and sustainable level of protection for New Zealand.”

Context and evolution

What we now call biosecurity was one of the earliest regulatory interventions in the young New Zealand colony. From around 1840, it was recognised that introduced pests and diseases were having a devastating effect on farming, and controls on imports and eradication of diseased animals was introduced. From that point, the various predecessors of MAF found themselves engaged in associated regulatory activities and needing to build the necessary skills. The focus was clearly on animal and plant health. Environmental protection or sustaining indigenous biodiversity was not the role of the agriculture ministry. Indeed, since the general theme of development centred on creating a South Pacific version of Mother England, rapidly displacing indigenous biodiversity was perfectly natural and acceptable.

In some senses, we’re still hearing the graunching of gears as New Zealand shifts its attitudes towards indigenous biodiversity. We’ve moved, relatively briefly, from a strategy which more or less deliberately set out to alter the landscape, introduce new species even at the expense of displacing indigenous flora and fauna, to strategies centred on actively protecting and enhancing indigenous biodiversity, alongside the maintenance and development of a modern, vibrant society and an economy based substantially on increasingly sophisticated forms of primary production. Biosecurity is at the front end of that transition.

“Biosecurity” too has made some substantial transitions, especially over the past decade or so. The last major shift in the biosecurity regulatory landscape took place in 1993 with the passage of the Biosecurity Act. This Act fundamentally rewrote the biosecurity task. Amongst other things, it established a broad biosecurity tool for government, regional government and sectors, with a scope that encompassed economic, social and environmental values, setting us on the path to today’s biosecurity system and capability. This change is significant – the original thinking that underlies the Act was that it was a tool capable of being used by any portfolio Minister and department that had “biosecurity” interests to protect. This started the fragmentation process.

An update to the system in 1997 established the current four-way Vote structure, with biosecurity funding voted for the Department of Conservation, Ministry of Fisheries, MAF and the Ministry of Health. In that year also, the Biosecurity Council was established by the Biosecurity Minister to co-ordinate and to provide strategic leadership to the biosecurity system.

In 1998, the Ministry of Forestry was merged with MAF. That consolidated the primary production interests in biosecurity and extended MAF’s role into matters of indigenous forestry, giving MAF a stronger link with environmental matters.

That development was further strengthened in 1999, when internal restructuring in MAF led to the creation of the Biosecurity Authority. With that came the decision to establish an Indigenous Flora and Fauna unit within MAF’s new Biosecurity Authority and border measures intended to address the full range of biosecurity risks, not just those associated with primary industries. At that time, MAF was also assigned the lead role in responding to environmental pests, such as ants, frogs and moths. The new Biosecurity Authority began developing memorandums of understanding with other biosecurity agencies in an attempt to clarify roles and responsibilities and to avoid duplication of effort.

Why the need for further change now?

The biosecurity system is under pressure. Public and political expectations have risen sharply. Biosecurity is now a very high profile activity and is engaged daily in high impact and controversial activities. The nature of the biosecurity risks faced has grown as trade and international passenger flows have increased, as our international trading relationships have expanded to include a whole new set of countries and products, each with new pests and risks. Moreover, aircraft and ships deliver people and goods to our shores quicker than ever, increasing the risk of hitchhiker pests surviving the journey.

The task set for the Biosecurity Council was to develop a Strategy to respond to those increased expectations, the widening scope of biosecurity, the changing pattern of risk, and the sense of a system under growing and unsustainable stress.

THE BIOSECURITY STRATEGY

I won’t attempt to summarise the three years of work encapsulated in the Council’s Biosecurity Strategy. But key thrusts related to simplifying and clarifying accountability and governance structures, bringing a wider, more strategic “whole-of-system” focus to our biosecurity work and bringing greater inclusiveness, transparency and consistency to risk assessment, prioritisation and decision-making across the whole biosecurity system.

A key proposal, now accepted by the Government, is that there should be a single point of accountability and leadership for the biosecurity system, and that should reside with the Director-General of MAF.

The recommendation that we establish a single point of leadership for biosecurity reflected a sense that the current arrangements of multiple agencies, multiple biosecurity votes with the Biosecurity Council sitting over the top of the structure was failing to provide the overarching leadership and drive needed by the system. In part, that is a product of inconsistencies between the intended overarching and co-ordinating role of the Biosecurity Council, and the obligations faced by biosecurity chief executives in terms of their accountabilities to Ministers. In part, it reflects the wide membership of the Council which makes it unsuited to a strong strategic role. In part, it simply reflected the inadequacy of the departmental resources in areas of high level strategy – as stress came on the system to deal with day-to-day pressures, the capacity to undertake strategic analysis and support the Council in its role also fell away. For all of those reasons, I believe that the focus in the Biosecurity Strategy document on the need for a single point of leadership was well founded.

A quick review of submissions received on the earlier draft Strategy reveals a reasonable consensus around the need to consolidate leadership. But, equally, it is clear that numerous submitters, especially those with strong environmental interests, were looking for either a stand-alone biosecurity agency, or for a transfer of that role to an agency other than MAF. Underlying that preference was a concern that primary industry and trade dominate MAF’s interests. The other biosecurity agencies have similar concerns – that biosecurity funding, risk assessment and decision-making under MAF leadership risking being skewed towards primary industry interests and against environmental, marine, or human health outcomes. Overcoming these concerns is a challenge that MAF accepts as part of its new biosecurity responsibilities.

Why MAF?

The Strategy team reviewed a range of alternative options. It concluded, rightly I believe, that biosecurity should rest in a core Government agency. The range of issues involved, the high level of quite intrusive regulatory powers associated with biosecurity, and the inevitably high levels of government funding involved all pointed to the need for close Ministerial oversight. This is not a function suited to a Crown-owned entity, or other non-departmental structure.

While we could envisage alternative departments to which the biosecurity function may have been assigned, there are particular reasons why it should be with MAF, even as the scope of the function broadens well beyond its original primary industry focus:

MAF currently houses the vast bulk of our biosecurity capability – in total around 800 of MAF’s staff are engaged more or less directly in biosecurity. This is a substantial operation and a major relocation would not be undertaken lightly. MAF’s biosecurity role has extended considerably in recent years as expertise has been built with environmental and other pests beyond the traditional risk to animal, plant and forest health. There are strong links between the biosecurity system and our ability to provide food safety assurances to domestic customers and foreign governments – a reason why the New Zealand Food Safety Authority is attached to MAF. Our ability to make biosecurity interventions at the border and pre-border are subject to the application of the World Trade Organization’s (WTO) sanitary and phyto-sanitary (SPS) Agreement. MAF has considerable expertise and experience in SPS matters, and provides invaluable support to the Ministry of Foreign Affairs and Trade’s role in international trade negotiations. As a small nation dependent on its ability to trade in biological products for its economic strength, there is a crucial need for close consistency between how we treat imports into New Zealand, and how we expect trading partners to treat New Zealand’s exports at their point of entry into foreign markets

WHAT MUST CHANGE TO FACILITATE MAF LEADERSHIP?

Choosing to vest responsibility for leadership of system-wide biosecurity in MAF is certainly not a “do nothing” option. This will require a significant overhaul of structure, processes, systems and culture in order to deliver on the outcomes sought in the biosecurity strategy.

The starting point for this overhaul is the MAF Statement of Intent (SOI) – our key statement of the organisation’s strategic direction. With our initial SOI, published in July this year, we have quite consciously adopted strategic priorities that fit within a sustainable development framework. In short, MAF recognises that to flourish, New Zealand’s primary industries must be successful in meeting both cost/productivity efficiency and environmental, social and cultural sustainability objectives. For MAF to be relevant and effective, it too must understand and fully incorporate concerns for environmental, social and cultural outcomes into its policy, regulatory and service delivery functions.

Behind that lies a cultural and organisational change process that encompasses staff selection, job descriptions, performance appraisal, training and prioritisation. That process is underway. It is, of course, directly relevant to our biosecurity function in the context of the broader leadership mandate envisaged in the Biosecurity Strategy. But the sustainable development theme extends across the full range of MAF activities.

Other expectations within the Biosecurity Strategy equally will require changes in MAF’s systems, processes and behaviours. These include the way in which MAF engages with other agencies and stakeholders, the development of “whole of system” approaches to risk assessment and decision-making and how we capture, analyse and distribute information.

WHAT WILL NOT CHANGE

While there are many things that will change as a result of the Government’s adoption of this Biosecurity Strategy, there are also things that will not.

High on that list is the degree of protection provided for our primary industries. While there are clear messages in the Strategy about the need to lift the game with respect to environmental, human health and marine biosecurity risks, there is no sense in which that is presented to us as something that should be achieved by diverting resources away from the protection accorded to the primary industries. Those sectors are simply too significant to be contemplating a lesser degree of biosecurity protection. Indeed, the study on the economic impacts of a foot and mouth disease outbreak, as published last year by the Reserve Bank and Treasury, demonstrates starkly why we must maintain and enhance our efforts on that front. While the study focused on economic impacts, we shouldn’t forget that an economic shock of the scale projected is equally a shock to our capacity to meet environmental, social and cultural goals.

Expect also to see our biosecurity system retaining science-based risk analysis at the core of its processes. In a world of often high uncertainty and contention, it is important that we seek objective and evidence-based judgements as far as possible. We need to do that to enhance the capacity to sustain decisions in the face of challenge, at times very vigorous challenge from both domestic and international sources; in order to ensure consistency with the international agreements which are at the core of our international trading arrangements; and to lower risks that others attempt to apply unjustified measures against New Zealand products attempting to enter their markets.

Expect to see our biosecurity work maintain strong links to international agreements and the international rules of trade, especially the SPS Agreement. The New Zealand Government is strongly committed to these key international agreements and conventions because they:

Enshrine countries’ sovereign rights to set their own levels of biosecurity protection, while Imposing disciplines within which those protections are implemented.

New Zealand is a significant beneficiary of a well functioning multilateral trading regime, and we will continue to invest heavily in the maintenance and enhancement of that regime. It is as important to our biosecurity arrangements and our capacity to effectively implement biosecurity risk management as it is to our capacity to export to other countries.

The United Nations’ Convention on Biological Diversity (CBD) also impacts on our biosecurity planning. The CBD has three objectives:

Conservation of biodiversity Sustainable use of biodiversity Equitable sharing of the benefits from the use of genetic resources.

Like the SPS Agreement, the CBD enshrines a country’s sovereign right to determine how to manage its own biodiversity and how to benefit from its biodiversity. But it also comes with some obligations. The main obligation is to have a national strategy (which New Zealand does) and to report on it (which we do). There is also an implied obligation to implement the national strategy, keep it up to date, and to reasonably reflect the articles of the convention and the decisions of the conference of parties. For example, coming out of the CBD work there is a global plants strategy (for conserving biodiversity), an international agreement on ballast water, an agreement on plant genetic resources, and there are some principles about invasive alien species in the pipeline.

The national biodiversity strategy “Our chance to turn the tide” was launched in 2000. The action plan has 10 themes:

1. Biodiversity on land 2. Freshwater biodiversity 3. Coastal and marine biodiversity 4. Conservation and use of genetic resources 5. Biosecurity and biodiversity 6. Governance 7. Mâori and biodiversity 8. Community participation and awareness 9. Information, knowledge and capacity 10. New Zealand's international responsibilities

There are a number of specific actions under each theme, including several that involve MAF or are led by MAF.

Finally, under the theme of “what will not change”, it is important to stress that MAF “leadership” does not mean MAF does everything. The leadership role is about a single point of accountability, a single point at which biosecurity strategy and priorities are articulated and given drive. MAF becomes that central point of focus and co-ordination. An aim is to improve co-ordination, not remove the need for it.

Other agencies will continue to deliver significant biosecurity activities. MAF will continue to need their active engagement, and their specific and specialised knowledge. There will be formal delegation of some roles and responsibilities to other chief executives, especially in the marine and health areas.

Other roles are likely to continue unchanged (e.g. the Department of Conservation’s pest management roles) but with clearer knowledge and shared understandings of respective priorities and strategies.

The vote funding structure review will need to support the governance structure.

What happens next?

The short answer is that there is a great deal to come.

The Cabinet has now formally adopted the Biosecurity Council’s Strategy document and we are now hard at work on the implementation phase. This will not be easy or quick. I expect that we are looking at a three to five-year process of building capability on the way to satisfying the expectations identified in the Strategy.

For the first phase of this development work, Larry Fergusson, MAF’s Deputy Director-General is heading up a project team. Over the rest of this year, Larry’s project will:

Establish the high level strategic team Establish the key stakeholder forums Design and begin implementation of the organisational change process, including both cultural and structural elements Establish a process for capability development, in line with the priorities identified in the Biosecurity Strategy.

By early 2004, we should have a revised structure for the biosecurity group in place within MAF, and key positions filled.

Already underway is the formation of the high-level biosecurity strategic capability. This will include secondees from each of the biosecurity agencies and will concentrate on:

Maintaining and developing the Biosecurity Strategy Development of whole-of-system risk assessment and decision-making prioritisation frameworks and processes Maintaining and enhancing capability Advising on outcomes and monitoring and evaluating performance.

The early priorities for our capability development process are clear enough. They flow from both the Biosecurity Strategy, and from the numerous recent reviews of aspects of the biosecurity function. Included in the agenda are such matters as:

Implement changes flowing from the review of import health standard processes Implement changes from the surveillance review Finalise and implement the funding review recommendations Establish the capability for the whole-of-system leadership role Enhance data/information/knowledge management capability Enhance contracting/project management capability Establish an effective Mâori responsiveness strategy Enhance science linkages Improve use of modelling techniques Review the vote funding structure.

MAF’s acknowledgement of the task ahead

We have a daunting agenda. We will need to deal with it in a quite formal and structured fashion to avoid being overwhelmed by the magnitude of the task. Through all of this, of course, the team is also conducting business as usual in the sense of incursion responses and the multitude of tasks that can impact on priorities day-to-day. There are likely to be tensions encountered between the capability building role and the immediate operational needs. For that reason, the early establishment of the strategic group is essential.

Likewise, while there has been Ministerial sign-off on the Strategy proposed by the Council, we should expect to encounter real resistance from Ministers as we go back to Cabinet with funding requests for those components of the Strategy requiring Crown funding. To be successful, we will need to establish sound business cases, to be able to demonstrate real efficiency and effectiveness, and to ensure that each new initiative is well presented within the context of the overall programme.

To repeat: This is a daunting agenda. I hear the reservations that have been expressed by some during the development of the Strategy about MAF’s suitability for the role. We intend to perform in a way that earns the confidence and respect of our various stakeholders. To earn that confidence and respect, we need to be able to engage effectively with stakeholders, to understand that transparency and consistency are essential ingredients in our in risk assessment and decision-making, and that we need to be able to reflect a genuinely “whole-of-system” approach to our work.

There are other points that all of us with an interest in biosecurity must also understand. One is that good and timely decision-making will not always result in popular decisions. Much of the work we do is inherently contentious. Another is that expectations are high, and resources are finite. While we expect to add some additional resource to our biosecurity effort through this capability development process, hard-edged prioritisation is inevitable. And again, it won’t be popular.

This process of capability development will not happen overnight. And while MAF is now responsible for leadership of the process, we are not the only player on the field. Biosecurity has multiple stakeholders. We need to be flying in formation if we are to be successful.

MAF wants to do this job and to do it well. I look forward to working with you as we strive to meet the many expectations of this Strategy.

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