FINDINGS AND TEN RECOMMENDED ACTIONS FOR IMPLEMENTATION
Findings
Recommended actions for implementation
Action #
Theme 1: Transparency and consultation during the IRA process
 The IRA Handbook and the department’s website do not meet
the needs of several stakeholder groups, do not always
provide enough information and do not adequately
communicate all the aspects of the IRA process including;
technical methodologies, consultation processes and other
policies used by the department when undertaking IRAs.
Revise IRA related web pages of the Department of Agriculture
website and IRA Handbook to increase transparency and provide
more information for stakeholders about how IRAs are conducted
and when consultation occurs. The IRA Handbook and website will
be written in a way that can be easily understood. Revisions will
include, but won’t be limited to, explaining and providing:
 That the comment period is based on calendar days, not
working days.
 The consultation process and how and when the department
will engage with stakeholders during the IRA process.
 The terms of reference for completing IRAs. This would include
information about the department’s conflicts of interest policy,
timeframes for completing the IRA, a statement explaining how
and why officers are selected to conduct IRAs.
 The overarching technical methodology used for IRAs and
ensuring it is presented in a clear, concise and unambiguous
manner (including by consulting with stakeholders and CEBRA
about the communication methods) (a detailed methodology
will be included in individual IRA reports as necessary).
 Policies for the use of external expertise during the IRA process
which includes mechanisms for identifying and addressing
conflicts of interest.
 The location of the ESG information and reports on the website
so that it is easily located from the respective IRA webpage.
 The department’s approach to workload prioritisation.
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Findings
 There are a broad range of views and suggestions about the
content and purpose of the IRA Handbook and there should be
consultation with stakeholders when developing a new
IRA Handbook for use under the Biosecurity Bill 2014.
 There is little information publically available which specifically
identifies how, when and why the department undertakes
consultation with stakeholders before an IRA begins.
 There is a need for more early and regular consultation with
affected stakeholders throughout the IRA process. This
consultation could include issues such as the scope of the IRA
and why a risk assessment was undertaken as an IRA.
 Earlier involvement of stakeholders in the IRA process and
provision of more information on the decision making
processes used in IRAs may help address stakeholder concerns
about IRA outcomes being predetermined before an IRA is
conducted.
 The existence of the department’s stakeholder register is not
well known by many stakeholder groups. This results in the
department being overly reliant on interested individuals or
smaller groups making first contact to declare their interest in
an IRA process.
Recommended actions for implementation
 A clear articulation of Australia’s approach to ALOP.
 A clear articulation of when an IRA is conducted.
 A clear explanation of the process, purpose and outcomes of the
IRA appeal process.
 An explicit explanation of how regional differences and regional
impacts are taken into consideration when conducting an IRA.
Provide the draft revised IRA Handbook to stakeholders for
consultation in 2015.
Undertake consultation with affected stakeholders early in the
process when developing the scope of the IRA to help minimise
misunderstandings and encourage greater sharing of scientific
information.
Action #
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Including, for example, a clear articulation of why a risk
assessment was undertaken as an IRA.
Review and consider the arrangements supporting the Biosecurity
Advice notice stakeholder register to establish whether it is
meeting the current needs of both the department and
stakeholders.
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Findings
Recommended actions for implementation
 A dedicated contact point for stakeholder groups would
facilitate two-way communication and information provision
between stakeholder groups and the department.
Trial a stakeholder liaison officer or client account manager for
each IRA.
 The department will work with stakeholders to determine
whether this is a practical, feasible and useful resource for both
the department and stakeholders.
Theme 2: The use of internal and external scientific expertise during the IRA process
Consider ways it can provide more assurance of the technical
 To improve aspects of transparency and the provision of
aspects of IRAs through provision of the following information in
information regarding technical information used and
IRA reports:
considered during an IRA, the department could provide an
overarching explanation around the methodology used to
 Ensuring that themes and areas of significant comment or
conduct IRAs, how uncertainty is dealt with and the underlying
scientific conflict which are raised in submissions are addressed
assumptions that are used to reach key decisions such as how
for every IRA report.
risk levels are determined in an IRA.
 How areas of significant uncertainty have been addressed
during the IRA.
 From time to time the department provides formal responses
 Inclusion of clear rationale and technical justification for why
to stakeholders following their submissions to draft IRA
reports. However, there are no publicly available policies for
particular risk ratings were assigned in individual IRAs.
when or why the department does this, and it is not done
 Continuing to work with CEBRA to ensure the risk assessment
consistently due to the very resource intensive nature of the
methodology is robust and fit for purpose.
process.
 Better communication of the way that decisions were made
during an IRA could aid in reducing stakeholder concerns
about the issue of impartiality.
Action #
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 More information on the decision making process could be
provided in final IRA reports which may help to address
concerns about how scientific input was considered and the
rationale behind the decisions in IRA reports were made.
 Many stakeholders were not aware that the department
utilises external expertise when conducting risk assessments
and some do not feel engaged in the process for determining
Consult further with stakeholders about the processes and policies
for using external expertise during an IRA. This will include the:
 Consideration of ways to consult with stakeholders on the use
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Findings
external experts to be used during an IRA.
 The department does not provide early information to
affected stakeholder groups about what external experts are
being used in each IRA and this information is not usually
outlined on the website or in the final IRA reports.
 The ESG is highly valued by the department and stakeholders
alike, but there are improvements that could be made to
increase its value to both groups.
Recommended actions for implementation
of external expertise during an IRA.
 Inclusion of a detailed explanation in each IRA report of how
external expertise was used during the IRA.
Trial and develop a proposed alternative model for the use of
external expertise and seek feedback from stakeholders, including:
 The function and role of the external experts.
 Ways in which feedback on the deliberations of external experts
is provided to stakeholders.
 Stakeholder’s role in the process.
Theme 3: The consideration of regional differences in animal or plant health status during the IRA process
Include an explicit section in all IRAs about how and when regional
 The amount, type and presentation of information in IRAs
differences and regional impacts were considered and the reasons
about regional differences and regional impacts, does not
for why they were or weren’t considered further.
always satisfy stakeholders that these issues have been
adequately considered.

There is a need for better communication about what
Australia can and cannot consider with respect to regional
differences and regional impacts.
Action #
Explore ways to better explain regional differences and regional
impacts (consequences) and the process used to assess regional
differences and regional impacts (consequences) during an IRA.
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