Chapter 7: Improving the UK’s biosecurity
Problems with current biosecurity arrangements
169.Existing biosecurity arrangements are far from perfect, as the number of threats in recent years to animal and plant health testifies.213 In the past, as Dr Robert Black from the Natural Resources Institute noted, what is sometimes referred to as the ‘weakest link’ issue may have been a contributory factor:
“Some countries or particular points of entry used to be regarded as a soft touch for importing some plant material such as cut flowers and so on that would ultimately end up in the UK from third countries because they did not have adequate inspections. They could come by lorry all the way through into the UK. That has been tightened up considerably.”214
170.As described in Chapter 1, as an EU Member State the UK has a limited ability to take its own biosecurity measures. Nonetheless, Professor Clive Brasier saw Brexit as “an opportunity to significantly tighten biosecurity and eliminate the ‘weakest link’ issue prevalent in the EU”, claiming that “our island status favours such an approach”.215 He argued that “timely notification by countries with a ‘new’ pest or disease … often fails due to lack of political will”, on the grounds that reporting such a disease would affect a country’s trade interests.216 He also reported “tardiness in identifying the true scientific status of the organism … [because labs are] often overloaded or poorly funded”.217
171.The white paper on The Future Relationship Between the United Kingdom and the European Union has clarified that the Government’s preferred relationship with the EU would be one in which a “common rulebook” would maintain harmonised rules on goods which would otherwise need to be checked at the border, including those which “safeguard human, animal and plant health”.218 This would allow near-frictionless trade with the EU to continue, but would limit the opportunities for new and stronger approaches to biosecurity that some of our witnesses identified.
172.Membership of the Single Market required the UK to share a biosecurity regime with the EU. The Government will need to choose between maintaining that alignment for the sake of trade, and taking alternative approaches to strengthen its biosecurity once it is no longer constrained by EU policy. The need to facilitate trade post-Brexit must not be allowed to compromise the UK’s biosecurity.
Possible improvements
Taking action faster
173.Dr Christine Middlemiss, Defra’s Chief Veterinary Officer identified “a number of areas where we might want to take increased action quicker than the EU has done”.219 The City of London Corporation concurred, positing that a UK alternative to the Rapid Alert System for Food and Feed “could enable risks to be controlled earlier, as currently it takes too long for potentially hazardous food and feed to be placed on the high-risk list, or banned”.220 Professor Nicola Spence, Defra’s Chief Plant Health Officer, underlined that it had taken “months” for the EU to consider placing restrictions on Spanish potatoes to prevent the spread of the potato flea beetle, warning “months can be critical”.221
174.Lord Gardiner agreed:
“I would suggest that one of the ways in which we have an ability to become ever more biosecure is the ability for the Chief Veterinary Officer, or the Chief Plant Health Officer, or the head of the non-native species secretariat, immediately to come to a Minister and say, ‘this has come up on the horizon; this is a problem. Should we be doing something about it?’ If their advice is that we should, we have the ability to act more speedily.”222
175.After Brexit it may be possible for the UK to respond more quickly to newly-identified biosecurity threats, rather than waiting for EU institutions and 28 Member States to agree on an appropriate course of action.
Taking UK-specific action
176.According to the Royal Horticultural Society: “The most obvious positive step for legislative change is to prioritise UK biosecurity activities to UK, rather than EU needs.”223
177.This could include creating a UK list of Invasive Alien Species, and adding species which are present in the EU but have yet to reach the UK. Defra pointed out that “maintaining freedom from plant pests such as the oak processionary moth and tobacco whitefly are important UK priorities, but not for those countries which already have the pests”.224 Similarly, Anglian Water Services told us that post-Brexit the UK could place “a greater focus on species native to the EU that are or could be invasive in the UK”.225
178.Conversely, many witnesses highlighted the opportunity to remove species from the list that are a biosecurity risk in other Member States but not the UK. In the words of Dr Niall Moore, Defra’s Chief Non-Native Species Officer: “Some of the species listed at the moment are not threats to the UK. We are taking action on those even though they do not pose a threat to the UK.”226 Fera gave an example: “The UK focuses significant inspection effort on citrus fruit imports to protect the wider citrus industry in the south of Europe (especially Spain), but where there is little or no threat to the UK.” Relaxing such controls “should free up biosecurity resources to focus on areas perceived as a higher risk to the UK”.227 Mr Alan Bell pointed out that apple snails are prohibited in the EU as an invasive species,228 but argued that the UK was outside the risk area because of its colder climate, so could safely allow their import: “The UK has no reason whatsoever to fear the shell suited migrant molluscs with an EU ASBO.”229
179.Depending on the nature of the UK’s post-Brexit relationship with the EU and its agencies, the UK may be able to establish its own lists of restricted species, both removing items on the EU lists that pose no threat to the UK, and adding items where doing so would improve the UK’s biosecurity. This would, however, have implications for the UK’s ability to trade freely with the EU.
180.Regardless of the nature of the UK’s future relationship with the EU, it is vital that alterations to the list of restricted species remain evidence-based.
Additional restrictions
181.Many witnesses argued for additional constraints on goods coming into the UK and for enhanced inspections at the border. The Woodland Trust argued that “the UK should take the opportunity to take a stronger stance on protection of our unique habitats through improved UK legislation on border biosecurity”,230 while the British Ecological Society advocated “stricter border checks, tighter permit requirements, and restrictions or bans on certain high-risk imports to the UK”.231
182.In our Brexit: agriculture report we highlighted the potential for non-tariff barriers to disrupt trade, creating an increased need for customs checks and the certification of products and production facilities.232 In other words, additional controls on imports will come at a cost. Nonetheless, Defra appeared to agree with the views expressed by witnesses: “Depending on the exact nature of our future relationship, leaving the EU will provide an opportunity to examine how we can introduce stricter biosecurity measures on imports from remaining Member States.”233
183.The RSPB highlighted the opportunity to extend the Invasive Alien Species (IAS) List:
“The IAS List currently includes only 49 species. A recent peer-reviewed study found it would be advantageous to immediately begin the process of risk assessment for over 200 species potentially suitable for inclusion on The IAS List. However, gaining majority agreement among the Member States during the risk management process can be politically challenging … Consequently, a UK withdrawal from the EU potentially presents an opportunity to improve UK biosecurity, by rapidly increasing the number of species included on The IAS List.”234
184.Witnesses also had many suggestions for specific areas where additional safeguards could be introduced. These included:
- Pot plants, whose soil is “a key pathway for terrestrial invertebrate INNS [invasive non-native species]”;235
- Products which risk importing Xylella fastidiosa, a plant bacterium;236
- Firewood, which can carry fungi and insect eggs;237
- Tick and tapeworm treatments and/or the reintroduction of rabies testing for cats and dogs being brought into the UK;238
- Imports from Member States affected by African Swine Fever;239
- The personal luggage allowance which currently allows travellers arriving from the EU to bring in plants, seeds and potentially contaminated meat.240
185.The Government told us that it would “explore options to enhance our biosecurity where it is possible to do so”, and specifically acknowledged the opportunity “to provide better protection against serious threats, such as Xylella fastidiosa”.241
186.The UK could consider the merits of implementing far stricter biosecurity controls than are currently in place, although this would have implications for trade agreements and appears to be at odds with the Government’s proposal to share a ‘common rulebook’ with the EU. Once the scope of the UK’s ability to adjust its arrangements in the context of its future relationship with the EU has been clarified, we urge the Government to consult on and conduct a scientific assessment of areas where it might be appropriate to impose additional biosecurity restrictions, particularly in relation to the threat posed by invasive species.
Alternative approaches
187.The RSPB highlighted the opportunity to simplify the UK’s legislative framework for biosecurity: “For historical reasons, different biosecurity threats have their own legislative frameworks and resulting inspection and enforcement regimes. This is despite them undertaking broadly similar practical functions.”242 They noted that this led to a “complicated network of responsible bodies”:
“Across the UK 20 Government Departments and Agencies have responsibility for biosecurity … Communication and coordination between them is inevitably challenging and such an arrangement runs the risk of diluting responsibility for action and causing the inefficient use of resources.”243
188.The Wildlife and Countryside Link agreed: “Outside of the EU, the UK has the opportunity to rationalise its biosecurity legislation by reducing duplication of mechanisms and resources across disparate departments and agencies.”244 The British Ecological Society also sought greater legislative coherence: “Moving forward it would be beneficial to investigate the pros and cons of having a Biosecurity Act or similar piece of legislation which brings all the different pieces of legislation together to provide coherence and prevent any duplication of work.”245
189.The Woodland Trust went further, pointing out that “many novel organisms which have had an impact in the UK were previously unknown to science and therefore would not have appeared on any international risk-based lists before their introduction”.246 This led Dr Emily Lydgate, Lecturer in Environmental Law at the University of Sussex, to argue for a more radical change of approach:
“We would no longer be bound to provide freedom of movement to EU goods, so we could move towards Australia’s approach of regulating species introduction through a whitelist, which designates only the species that are allowed, rather than the EU’s blacklist approach, which designates the species that are not allowed.”247
190.Brexit provides an opportunity for the Government to consider fundamentally altering its approach to managing biosecurity, moving away from a system based on a list of restricted items, which does not provide optimum protection against unknown risks, and towards a unified biosecurity policy across all sectors.
Australia and New Zealand
191.Dr Kezia Barker, Lecturer in Geography at Birkbeck, University of London, described Australia and New Zealand as “world leading” in terms of biosecurity,248 while Dr Paul Walton from the RSPB told us that the rate of establishment of new species in New Zealand has “fallen off a cliff” since new biosecurity legislation was passed.249 According to the Woodland Trust, “New Zealand has been able to take advantage of its island status to protect indigenous species that are at risk from population decline or extinction through the introduction of invasive species.”250 The Agriculture and Horticulture Development Board agreed:
“The UK could look to Australia and New Zealand as examples of high standards in external biosecurity for island nations. Many will be familiar with sniffer dogs checking passengers and luggage for food at airports in New Zealand. It has previously been argued that the size and volume of flow renders this impractical at UK ports and airports. However, random risk targeted action by border patrols funded by heavy enforcement fines combined with more effective communication to travellers … could be considered.”251
192.Professor James Brown told us: “On the specific point of dirty clothing, the practice in Australia is to make sure that travellers know that clothes or footwear which has been worn on farms outside Australia must be cleaned before they are worn again at home. This is done at points of entry. This could easily be done in the UK.”252
193.The British Ecological Society pointed out that “New Zealand is investing in and empowering its citizens to play a critical role in managing and preventing biosecurity threats. The UK should continue to look into and invest in ways it can raise awareness among its citizens.”253
194.The examples of Australia and New Zealand show that more restrictive regimes can be highly effective at maintaining biosecurity on remote island nations, particularly when legislation is combined with public awareness campaigns. While the UK is not so geographically isolated, and implementing a similar regime would require a substantial increase in biosecurity resourcing, the Government may wish to review the costs and potential benefits of such measures after the UK has left the EU.
216 Ibid.
217 Ibid.
218 The Future Relationship Between the United Kingdom and The European Union, Cm 9593, July 2018, p 23 [accessed 18 August]
219 Q 39; also written evidence from Horticultural Trades Association (PAB0022) and Woodland Trust (PAB0030)
227 Written evidence from Fera Science Ltd (PAB0009); also Q 4 (Dr Barker), Q 39 (Prof Spence), and written evidence from Prospect Union (PAB0008) and Agriculture, Horticulture Development Board (PAB0017)
228 Apple snails were first recorded in the wild in the EU in 2010, when they were reported in rice fields in the Ebro Delta in Spain, and are deemed to be a “threat to the freshwater wetlands of southern Europe”. See European Food Safety Authority, ‘Apple snail poses a serious threat to south European wetlands’: https://www.efsa.europa.eu/en/press/news/140430a [accessed 17 September 2018]
229 Written evidence from Mr Alan Bell (PAB0001); also written evidence from the Ornamental Aquatic Trade Association (PAB0002).
232 European Union Committee, Brexit: agriculture. (20th Report, Session 2016–17, HL Paper 169)
234 Written evidence from RSPB (PAB0024); also Q 19 (Dr Walton), written evidence from Anglian Water Services (PAB0006)
235 Written evidence from Wildlife and countryside Line (PAB0025); also written evidence from Buglife (PAB0007), British Ecological Society (PAB0023), Prof Clive Brasier (PAB0028)
238 Written evidence from British Veterinary Association (PAB0013), Dogs Trust (PAB0016) and Welsh Government (PAB0033)
240 Q 39 (Prof Nicola Spence) Written evidence from Royal Horticultural Society (PAB0020), Written evidence from Prof Clive Brasier (PAB0028), Written evidence from National Pig Association (PAB0032)
243 Ibid.
245 Written evidence from British Ecological Society (PAB0023); also written evidence from Woodland Trust (PAB0030)
246 Written evidence from Woodland Trust (PAB0030); also written evidence from Prof Clive Brasier (PAB0028)
248 Ibid.