Submissions

Federated Farmers Submission on Phase 3 Mushroom Growing Medium Guidance Document and Import Health Standard

Federated Farmers views any new proposal to import material that may pose a biosecurity risk to New Zealand with caution. Federated Farmers would only be satisfied with the importation of mushroom growing medium if these products are subject to strict science-based biosecurity protocols that are rigorously implemented and enforced.

Federated Farmers is not convinced that the measures outlined in this proposed Import Health Standard are sufficiently robust to adequately address the risks associated with the importation of these products.

Federated Farmers opposes this Import Health Standard unless all our recommendations are met and the measures outlined adequately address the associated risks. 

Summary of Recommendations

  • Federated Farmers submits that a list of regulatory requirements that sit outside the Import Health Standard should be included in the preamble section of the Import Health Standard.
  • Recommends that MPI reconsider the temperature thresholds and time to ensure that all biosecurity threats posed by this material are eliminated.
  • Recommends that any validation of the new temperature and time thresholds should be achieved using a simulated pathogen study to show that all the risk pathogens are neutralised by the composting process.
  • Recommends that a scientifically based temperature map study of the load should be undertaken at least three times, to show the required temperature is reached.
  • Recommends that samples of the composted material be drawn and checked for the presence of viable seeds. A germination test should be undertaken on seeds or parts of seeds that are detected.
  • Recommends that if the germination test is positive, no further consignments should be cleared for entry into New Zealand.
  • Federated Farmers supports an independent review of the proposed Import Health Standard by an independent New Zealand based scientist.
  • Recommends that MPI stringently monitors and audits the import pathway to ensure that all imported growing medium is free of viable weed seeds and any other material that poses a biosecurity risk.
  • Recommends that MPI actively and rigorously monitor the performance of any external accredited organisation and National Plant Protection Organisation (NPPO).
  • Federated Farmers submits that an annual audit and inspection is undertaken, and is a thorough and whole system audit.
  • Recommends that spent growing medium is not discharged onto land.
  • Federated Farmers submits that on arrival all consignments should be inspected by MPI.

For more information, see the full submission​