Freight & Trade Alliance (FTA) met Thursday 4 and Monday 8 November 2021 with executives of the Department of Agriculture, Water and the Environment (the department) as a part of a series of bi-lateral meetings to discuss a number of serious and escalating operational concerns raised by members.
It is evident that a myriad of factors are causing significant costs and inefficiencies for both the department and industry. These relate to both document assessment and inspections.
While FTA is committed to a continuation of collaboration with the department to implement remedial actions, there is clearly a need for a broader over-haul of outdated practices with labour-intensive processing of documents to be replaced with more efficient data transfers, facilitation via industry self-assessment (including increased utilisation and expansion of Automatic Entry Processing) and modernised electronic profiling.
The time is right for such reform via:
- utilisation of flexibility offered within the new Biosecurity Act (including Approved Arrangement capabilities);
- an enormous injection of funding received by the department in the last Federal Budget; and
- a Federal Government mandate for efficiencies (reduction of red-tape) as a part of the emerging Simplified Trade System (STS) reform and Regulatory Sandpit initiative.
FTA will lead advocacy for such reform through direct engagement with the department and panel involvement in forums such as the ministerial-led Biosecurity Futures
In the interim, the following summary outlines the current status and opportunity for incremental improvements in departmental service delivery.
Document assessment delays- Over recent months, members have increasingly reported that import document processing times have been growing, now exceeding a week in extreme circumstances.
- At the time of last weeks meeting, the department stated that biosecurity processing is four (4) days outside service levels and one (1) day for imported food.
The above brought into question the consistency in practice and appropriateness of the department's service standards - FTA emphasised the need to review standards (established in excess of 10 years ago) to meet contemporary commercial expectations in parallel to ensuring effective biosecurity risk management is maintained.
COVID Fatigue- The department explained the impacts on their human resources affected by COVID-19 and the extreme workload faced by officers in managing record high numbers of Lodgement Reference Numbers (LRNs).
- While a heavy use of overtime has helped manage workloads to date, it is becoming increasingly evident that this is not a sustainable long term solution.
- As Melbourne and Sydney emerge from lengthy lockdowns, officers are now understandably seeking to take a proportion of their leave entitlements – the department is looking to best manage this entitlement and ensure availability to deliver critical functions.
The department is confident that much of this impact on human resources will be addressed by the recruitment underway, officer training program and phased introduction of automation to assist in documentation assessments - it is also envisaged that a new solution used to automate processing of Self Assessment Clearances (SACs) will allow for further redeployment of officers' time to address document processing.
Incorrect lodgement- The department has identified significant increases in the number of LRNs being lodged 12 hours or less of arrival, as well as incomplete and inaccurate documentation.
FTA is working with the department to assist address these issues where they exist. Details of these common errors are being shared in our customs broker Continuing Professional Development (CPD) training. FTA is encouraging the department to work direct with those businesses (as required, with the support of FTA) to implement remedial action of those slowing down of the system and affecting all parties.
FTA sees merit in incentivising "early" lodgement and reiterated reasons why this cannot always be achieved, particularly in circumstances when customs brokers receive late documentation from importer clients - FTA acknowledged that the latter is a matter that must be addressed between commercial parties.
FTA Preliminary Concept - A primary cause of problems is the "late" declarations submitted by importers / customs brokers - feedback from members was that one the reasons for late reporting was the need to wait for the cargo report to be lodged by the shipping line / freight forwarder noting that the import declaration must match with the cargo report on critical data fields (including vessel / voyage).
- While an importer or customs broker may have consignment details (in some cases weeks) in advance of arrival, they may not know the import vessel details until much later - particularly in the common circumstances where the cargo is being transhipped between vessels before arriving into Australia.
- While a "pre-load reporting model" would largely address this by ensuring earlier cargo reporting (this being a proposal raised by FTA as a part of the STS and current Regulatory Sandbox review), we acknowledge that this would be a complex Integrated Cargo System (ICS) change necessitating it to be a long-term reform.
- As an alternate solution, FTA has proposed a concept of importers and customs brokers lodging early - where they are unsure of import vessel details, they simply lodge with some form of "check to arrive" or "dummy" details. Once import vessel details are known, an amendment is made to the import declaration.
Both the department and the Australian Border Force are checking to see what impacts this would have on their profiling / risk assessment. We assume that this concept would also have benefits for the ABF in receiving earlier declarations but understand that this may have other adverse border protection consequences.
Further member updates on operational changes and our ongoing advocacy activity will be provided as progress is made.
Sal Milici - Head of Border & Biosecurity - FTA / APSA