Introduction

1. The Australian border is a challenging environment with people, cargo and mail items entering and leaving in significant numbers each week. The majority of these people, goods and mail pose no threat, but there are some that do present risks to Australia’s safety and security. The Department of Agriculture (Agriculture) has identified a range of commodities that pose a biosecurity risk, including particular seeds and grains, animal products and veterinary therapeutics. For the Australian Customs and Border Protection Service (Customs), the predominant risks to border security are the importation of illicit drugs and firearms.

2. In this context, Agriculture seeks to support access to overseas markets and to protect the economy and the environment from the impacts of unwanted pests and diseases.¹ Similarly, Customs seeks to protect the safety, security and commercial interests of Australians through border protection activities.² Both agencies appreciate, however, that there is a balance to be struck between managing these risks and facilitating legitimate trade and travel.

3. Different import streams also present different risks. Agriculture and Customs (collectively referred to in this report as the border agencies) consider that international mail items pose a lower risk when compared with air and sea cargo because mail items are generally smaller consignments and intended for domestic use or consumption. The management of risks in any one stream is necessarily influenced by the availability of resources and the overall risks that each agency seeks to manage at the border.

Assessing risk in international mail

4. In 2012–13, around 180 million international mail items arrived in Australia in the form of letters, express mail service, parcels and articles ordinaire (AO).³ While all incoming international mail is subject to border controls, Agriculture and Customs cannot and do not screen all mail received. Rather, the border agencies seek to take a targeted approach that identifies the mail considered to be at higher risk of containing quarantine risks or prohibited imports. Adopting a risk‑based, targeted approach is consistent with the agencies’ views that the vast majority of mail is compliant with legislative requirements⁴, and that screening all international mail would be costly and resource intensive.

5. Implementing this approach for international mail is challenging because, unlike incoming air and sea cargo, the border agencies do not receive pre‑arrival details of the sender, receiver or declared contents of individual items. The border agencies advised that this lack of pre‑arrival data constrains their ability to conduct risk‑based targeting. Agriculture and Customs generally focus their targeting analysis on historical seizure data—that is, quarantine material or prohibited imports that have previously been seized and factors such as the country of origin, the mail type and the significance of each seizure. Implicit in this approach is the understanding that not all mail containing quarantine risk items or prohibited imports will be targeted, and that screening effort is weighted towards the cohorts considered most likely to contain the highest risk items.

Australia Post‘s role and the screening of international mail

6. Australia Post receives international mail at one of four offices of exchange (referred to as gateway facilities) located in Brisbane, Melbourne, Perth and Sydney.⁵ The border agencies inform Australia Post of their targeting priorities, and Australia Post is required to present requested mail for screening. Screening is a non‑intrusive assessment of individual mail items to determine whether they may contain quarantine risk material or prohibited imports. The screening process involves one or more of the following: a visual assessment of individual mail articles; viewing x‑ray images; and/or detector dogs that are trained to target and identify specific odours that may indicate that mail items are non‑compliant. Depending on their targeting priorities, mail cohorts may be screened by one border agency or by both.

7. In 2012–13, Agriculture reported that it screened around 35 million mail articles (around 19 per cent of all mail), which resulted in the seizure of 27 608 items carrying quarantine risks. By comparison, Customs reported that it screened around 46 million items (around 25 per cent of all mail) and seized 67 123 prohibited imports. The number of seizures by Agriculture has declined by around 75 per cent since 2006–07, while Customs seizures have increased by around 190 per cent over the same period.

8. Mail that is screened and assessed as compliant is cleared for delivery by Australia Post, and mail assessed as potentially containing prohibited imports or quarantine risk material undergoes further ‘examination’. The examination process involves the opening of mail by Australia Post so that its contents can be checked by the relevant border agency. Mail articles identified with prohibited imports or quarantine risk material are seized and their details entered into the seizure database of the relevant agency.⁶ The seizure data then forms the basis of future targeting analysis. As seizures generally come from mail that has been screened, processes to monitor risks in unscreened mail are important to provide a comparable assessment of risk between screened and unscreened mail. For these purposes, Agriculture has implemented a leakage survey and Customs has a sampling program.

9. Agriculture and Customs work closely with Australia Post to facilitate the movement of international mail into Australia’s postal network. However, each agency has a different role and sometimes competing objectives. This relationship has been formalised through a Memorandum of Understanding, and regular meetings of a National Tripartite Forum.

Staffing and funding at the border agencies

10. At the end of 2012–13, Agriculture employed 97 full time equivalent staff working at the gateway facilities, and Customs had 152 full time equivalent staff. Agriculture has been reducing staffing levels at the gateway facilities, and is continuing to assess the nature of its workforce deployed across its border compliance operations. In contrast, the Government announced on 23 January 2014 that it will allocate an additional $88 million in funding over four years to increase the rate of Customs’ cargo screening at the border. This funding will include $30.1 million to increase air cargo and international mail screening, with the number of mail items required to be screened to increase by 10 million to a total of 50 million.⁷ Customs advised that the increased funding for international mail operations was based on the calculation of an additional 22 operational staff employed at the gateway facilities.

Audit objective and criteria

11. The objective of the audit was to assess the effectiveness of Agriculture’s and Customs’ arrangements for the targeting and screening of incoming international mail to identify prohibited and restricted goods. In order to form a conclusion against the audit objective, the ANAO adopted the following high level criteria:

• appropriate administrative arrangements support each agency’s international mail program;
• methodologies for targeting international mail are effective;
• screening and examination arrangements for incoming international mail items are effective; and
• processes are in place to measure and report the performance of the international mail programs.

Overall conclusion

12. Achieving and maintaining a balance between border control and facilitating the flow of international mail into Australia is a challenge for Agriculture and Customs, who work in close cooperation with Australia Post. The volume of international mail, particularly parcels and other larger items, continues to increase. Australia received around 180 million international mail items in 2012–13 at its four gateway facilities, with the vast majority of mail considered to be compliant with border regulations. To screen and examine all consignments would be costly, resource intensive, and impede the flow of mail. Nevertheless, some international mail will contain quarantine risk material or prohibited imports, and a small proportion of these items may pose a serious risk to the wellbeing of people in Australia. It is therefore necessary for Agriculture and Customs to have adequate processes in place to identify those mail items that are more likely to carry higher risk non‑compliant goods and deal with them appropriately.

13. Prior to 2008–09, the border agencies screened all incoming international mail. Since that time, each agency has sought to encourage voluntary compliance by educating the public about quarantine and customs requirements, and has developed risk‑based strategies for targeting and screening higher risk cohorts of mail on arrival. However, neither agency is able to demonstrate the effectiveness of these strategies. They also gain limited assurance from their leakage survey (Agriculture) and sampling program (Customs) in relation to the number of detections missed in unscreened mail.

14. Agriculture’s targeting model is statistically based, nationally consistent and reflects the work undertaken by the department since 2011 to improve its understanding of risk in the mail environment. Initial targeting analysis (undertaken in 2011) estimated that the department could expect to seize around 72 per cent of targeted high risk quarantine material. Agriculture advised that this work was an early move into what was considered an innovative risk profiling methodology and that its seizure rate estimate was ambitious, and required optimal operational conditions. The ANAO’s analysis of the department’s leakage survey data indicated that it has substantially under achieved against this estimate as only around 19 per cent of high risk quarantine material was seized between August 2012 and May 2013. The department was unable to fully explain the wide variance between its estimated and actual seizures, but subsequently advised that it reviewed its targeting priorities in late 2013, although these are yet to be implemented.

15. Customs’ targeting approach, which it describes as ‘intelligence‑led risk‑based’, is more devolved and is based on an assessment of risk by each gateway manager, taking into account a range of inputs including seizure data and national intelligence reports. However, in practice, targeting decisions were often not documented, did not align with risk analysis, were inconsistent between gateways and incompatible with analysis provided in the national intelligence reports, providing little assurance that Customs is adequately and consistently targeting high risk mail cohorts. Further, Customs does not assess the effectiveness of its targeting strategy. Rather, it considers that an increase in seizures from 23 009 in 2006‑07 to 67 123 in 2012–13 reflects improved targeting processes. The ANAO’s analysis of data from the agency’s sampling program indicated that around only 13 per cent of prohibited imports arriving in international mail were seized in 2012–13. Customs advised that it now considers the implementation of its sampling program was flawed, raising questions about the integrity of its sampling data.⁸

16. Agriculture aims to screen only the mail that is targeted as a result of its risk analysis and the processes employed by each gateway facility are generally consistent. In 2012–13, Agriculture reported screening around 35 million articles, and seizing more than 27 000 items. In contrast, Customs adopts a more flexible approach, with gateways sometimes screening untargeted mail, and at other times not screening targeted cohorts. There is no guidance to support, or visibility by Customs’ management of, these different screening practices. Customs reported screening around 46 million mail articles, and seizing more than 67 000 items for 2012–13.

17. It is important to note that the number of seizures is not, in itself, an indicator of effectiveness. Activities to promote voluntary compliance may reduce the flow of risk items in international mail, and the nature of goods that are considered to warrant seizure can, and do, change over time. It is for this reason that Agriculture’s leakage survey and Customs’ sampling program have been implemented to assess the risks of missed detections in unscreened mail. The absence of a ‘leakage’ target however, means that the agencies have not determined whether the estimated outcome of their respective targeting and screening methodologies represents an acceptable level of missed detections. Both agencies have advised that they are reviewing their survey and sampling methodologies.

18. Agriculture and Customs devote considerable resources to their international mail programs and their respective Portfolio Budget Statements outline outcomes relating to the implementation of risk‑based intervention strategies for these programs. However, as neither agency has developed appropriate deliverables, key performance indicators and targets, the agencies do not adequately report their performance against their stated outcomes and objectives. External reporting by both agencies provides little insight for key stakeholders into the success (or otherwise) of the operations of international mail. In addition, the collection of performance data relating to screening activities, particularly for Customs, requires review⁹, if the actual number of mail items screened is to be reported accurately against its target volumes. Greater management oversight is also required by Customs to gain assurance that gateway facilities are employing consistent targeting and screening practices.

19. The ANAO has made three recommendations directed towards improving Customs’ targeting and screening practices, and Agriculture’s and Customs’ reporting frameworks.

Key findings by chapter

Administrative Arrangements for International Mail (Chapter 2)

20. The border agencies have appropriately incorporated the key risks associated with international mail into their corporate risk management arrangements. They have also identified in agency‑wide and division‑level planning documents a range of staffing‑related risks such as the theft of seized goods by staff, or that staff may engage in abuse of office or make an unauthorised disclosure of information. Agriculture advised that there have been no instances of any such risks being realised in international mail, while Customs had investigated two suspected thefts. Although the thefts were not attributed to any individuals, the agency was installing additional closed‑circuit television cameras at the time of the audit.

21. The Australian Federal Police also advised that it had not identified any instances of corruption in international mail, but that organised crime employs sophisticated methods to circumvent screening and law enforcement efforts. Therefore, it considers that the risk of corruption or criminal penetration may have similarities to other import streams where investigations have shown that officers working at the border have been involved in illegal activities.

22. The relationship between Agriculture, Customs and Australia Post is supported by a Memorandum of Understanding (signed in August 2009) and Intervention Strategy Agreements that outline the targeting priorities of each agency.¹⁰ A National Tripartite Forum provides strategic guidance, and senior managers of each agency advised that the relationships are cooperative. Nevertheless, the ANAO identified instances where agencies had not adequately consulted or taken account of the overall impact of their individual decisions on broader gateway operations. Early and ongoing consultation between the tripartite partners on key prospective strategic developments could have enhanced the overall tripartite relationship.

Promoting Importer Compliance (Chapter 3)

23. Agriculture and Customs have organisation‑wide strategies to promote voluntary compliance. These strategies include providing information to the public through agency websites¹¹, as well as the use of social media for targeted communication campaigns.¹² To assess the effectiveness of its compliance activities, Agriculture uses its leakage survey to estimate the proportion of non‑compliant mail items approaching the border. Customs does not use its sampling program in this manner.

24. A specific risk for Customs is the importation of firearms in the mail, particularly given the lack of pre‑arrival information. If such items are not detected they will be released into the community without verifying that a legitimate import permit was issued. Customs advised that it cannot mandate that importers use sea or air cargo, rather than international mail, to legitimately import firearms. However, Australia is a signatory to a treaty, known as the Universal Postal Union, which includes a restriction on the carriage of firearms in air mail. Australia Post advised that it seeks to enforce this restriction when such imports are reported to it by Customs.¹³ Customs’ seizure data indicates that it seized and subsequently released¹⁴ 2687 firearms or firearms parts sent in air mail items in 2012–13, but the agency provides the relevant sender details to Australia Post on an ad hoc basis only. The management of firearms risks would be more effective if, in the shorter term, Customs implemented procedures to routinely share firearms seizure data with Australia Post. In the longer term, there would be benefits in the two agencies working to harmonise their approaches in support of Australia’s international commitments.¹⁵

Targeting for Quarantine Risks (Chapter 4)

25. In November 2011, Agriculture introduced a National Profile Register, which outlines the mail cohorts that it will screen and those that will be assessed and released.¹⁶ Agriculture’s targeting model underpinning the national profiles is statistically based, and considers the likelihood that each mail cohort will contain higher risk quarantine material, as well as a predicted screening effectiveness. This model estimated that the national profiles, current at the time of the audit, would result in 20.6 per cent of non‑letter class mail being targeted, and that 72 per cent of all higher risk quarantine material would be seized. However, the ANAO’s analysis of Agriculture’s leakage survey results indicate that around 19 per cent of higher risk quarantine material was seized between August 2012 and May 2013.¹⁷ Agriculture subsequently advised that its 2011 work was the first iteration of what it considered to be an innovative risk profiling methodology. The department now considers that the 72 per cent seizure rate estimate was overly ambitious.

26. To continue to improve its targeted approach and risk analysis, Agriculture has also undertaken three product prioritisation projects since 2010, with the aim of identifying low risk commodities that can be removed from the Quarantine Proclamation 1998. In completing the second product prioritisation project, Agriculture estimated that 55 000 items that would normally have been seized each year in the past, would no longer need to be seized as they are now considered low risk. The removal of these low risk commodities from the Quarantine Proclamation 1998 is a practical approach to reducing the department’s operational workload, and provides some context to the 75 per cent reduction in the number of seizures by Agriculture in 2012–13, when compared with its 2006–07 seizures.¹⁸

27. Agriculture advised that the significant work undertaken to refine its concepts of risks will have impacted the performance of its targeting model. The department advised that it reviewed its national profiles in 2013, some two years after implementing its first version of these profiles. To date, the new profiles have not been operationalised and Agriculture is continuing to use the national profiles developed in 2011.¹⁹

Targeting for Prohibited Imports (Chapter 5)

28. Customs’ targeting framework is outlined in Instructions and Guidelines: International Mail Risk Assessment (Risk Assessment Guidelines). However, the key risk factors identified in the guidelines, including the mail type, country of origin and materiality (or significance) of past seizures, are not clearly articulated. For example, the guidance on materiality does not clearly outline the types of prohibited imports that are considered higher risk, and are to be given priority when conducting targeting analysis. In addition, there is no guidance on how the three risk concepts interact to form a comprehensive targeting model.

29. In April 2013, Customs’ Intelligence Division released its first quarterly Analysis and Risk Assessment of the Postal Environment (Advanced Analytics Report). The report improves on former analysis by providing a risk ranking for each cohort, based on the number of seizures of narcotics achieved compared with incoming mail volumes. While this report was a significant step forward, there were limitations to the analysis, including that it focused only on narcotics seizures (nine per cent of total seizures) and did not include other commodities such as firearms.²⁰

30. Customs’ targeting decisions are devolved and are made by gateway managers at each facility taking into account their own risk analysis and available intelligence. As a consequence, there were variations between gateways as to the treatment of some mail cohorts. Inconsistencies between cohorts ranked in the Advanced Analytics Reports and the targeting priorities of the Sydney Gateway Facility were also identified. Gateway managers must balance a range of factors when making targeting decisions, but variable targeting decisions, and decisions that were not documented or supported by targeting analysis reduce the overall confidence of Customs’ targeting strategies.

31. Customs implements a sampling program, which aims to sample 280 891 letter class and 6082 non‑letter class items each year to assess the risk of missed detections in unscreened mail. The ANAO’s analysis found that Customs had adopted a narrow focus for the sampling program, with 88 per cent of the non‑letter class mail items being AOs, and that 80 per cent of the AO items sampled were from a single cohort. Using Customs’ sampling data, the ANAO estimates that around 467 893 prohibited imports (87 per cent) were not detected by Customs’ screening of international mail in 2012–13. While Customs designed the program to provide a 95 per cent confidence rating, the agency has subsequently advised that it is not confident in the design or implementation of its sampling program and the reliability that can be placed on the sampling data. Customs advised in March 2014 that it has suspended the sampling program pending a review of the program.

Screening and Examination of International Mail (Chapter 6)

32. Agriculture aims to screen mail cohorts based on its National Profile Register, and with the screening capability (detector dogs or x‑rays) that it has assessed as likely to be most effective. This approach seeks to maximise the effectiveness of its screening resources, but limitations with Australia Post‘s sorting capabilities means that the department screens more mail than is required by its profiles. In particular, at the Sydney Gateway Facility it screens around 57 per cent of mail instead of its targeted 20 per cent. While Agriculture considers that the over‑presentation of untargeted mail has a significant impact on its overall effectiveness, Australia Post advised that it would take more resources for it to separate some untargeted mail cohorts than it would for Agriculture to screen them.²¹

33. Customs also uses detector dogs and x‑ray machines to screen mail, with individual gateways adopting different screening approaches. These may include screening AO mail that is not targeted, and at other times not screening mail that is targeted. In addition, two gateway facilities undertake mail bag screening, which involves screening an entire bag of mail rather than one or a few items at a time. Customs has not developed guidance to support these screening practices, and there were differing views in relation to the methods used to screen AOs. The lack of effective oversight arrangements for AO screening reduces the assurance that these practices are appropriate to the circumstances and commensurate with the increased risks of leakage.

34. The border agencies conducted two trials in 2011 to explore the potential for one agency to screen a cohort of mail on behalf of the other. A joint communiqué released by the border agencies following these trials indicated that collaborative screening had resulted in efficiency gains, that border risks were managed appropriately, and that these trials would be expanded to other mail cohorts. At the time of the audit, both agencies advised that collaboration now refers only to one agency referring items of interest to the other if identified during their own independent screening activities. Nevertheless, there is no strategy in place to enhance cross‑agency training to assist staff to understand and recognise the border risks of the other agency. Reassessing opportunities to enhance collaboration may assist Agriculture and Customs to maximise their limited screening resources to enhance operational effectiveness.

35. The ANAO observed vulnerabilities in processes for managing seizures. Agriculture recorded in its MAPS database that it returned to sender 43 of the 68 cannabis seizures it made in 2012–13. Agriculture subsequently provided information to indicate that the seizures had in fact been transferred to Customs as is required.²² However, there was no clear alignment between these seizures and the records in Customs’ DGMS database to enable verification that the agency had received the seizures from Agriculture. This gap may have been caused by issues such as time lags in entering seizure data into the system. The ANAO’s analysis of Customs’ seizure data found that its gateways take, on average, between four days (Melbourne Gateway Facility) and 9.8 days (Perth Gateway Facility) after the day of seizure to enter data in the DGMS. Such delays pose risks for Customs, as data entry into DGMS is the principal means by which evidence of seized goods is maintained.

Measuring and Reporting Performance (Chapter 7)

36. Agriculture’s Portfolio Budget Statement (PBS) outcome was to support access to overseas markets and protect the economy and the environment from the impacts of unwanted pests and diseases, and the safe movement to and from Australia of animals, plants, people and cargo. Underpinning this outcome was an objective and deliverable related to the implementation of risk‑based intervention strategies and a key performance indicator to implement change projects. Similarly, Customs’ PBS outcome was the protection of the safety, security and commercial interests of Australians through border protection designed to support legitimate trade and travel, which is also underpinned by an objective of undertaking risk‑based interventions. Customs did not have a key performance indicator, but it did have three deliverables for 2012–13.²³ Neither agency is able to adequately assess its performance against the stated outcomes and objectives.

37. The border agencies rely on Australia Post’s volumes data to assess the number of mail items screened. Australia Post provides two types of mail volumes data: individual gateway data and national level data. The border agencies expressed concerns about the variability of the different data sets, noting their reliance on this data for their own reporting and targeting analysis. While Australia Post advised that the national data is more accurate, at the time of the audit both agencies used the gateway level volume data for reporting purposes due to a six‑week time lag in receiving the national data.²⁴

38. Neither border agency has documented its processes for using Australia Post’s volumes data to estimate screening numbers at each gateway. There were also differences in the way that the gateway facilities were reporting their screening numbers for each agency, but the differences were most notable for Customs.²⁵ Advice provided by each gateway, and internal documents regarding Customs’ reporting processes, indicates that Customs has been under‑reporting non‑letter class mail screening volumes, so that it is not seen to be significantly over achieving against its target volumes. However, the true extent of the discrepancy between reported and actual screening numbers is unknown.

39. Agriculture has developed five internally reported performance indicators, which adequately cover the key aspects of its management of mail processing. The indicators cover risk in the mail environment, as well as the effectiveness of the targeting, screening and examination processes to locate higher risk quarantine material. Nevertheless, monthly and quarterly reporting was considered by Agriculture staff, at the time of the audit, to be overly statistical and difficult to interpret. Agriculture advised in March 2014 that it has since revised its quarterly reporting process to more clearly present this information. Customs also prepares monthly management reports that contain a significant amount of useful performance data. Nevertheless, comparing performance between gateway facilities is difficult, noting that there is limited confidence in the screening numbers reported by each gateway.

Summary of agency responses

40. The report was provided to Agriculture and Customs, along with extracts to the Australian Federal Police and Australia Post. Agriculture, Customs and the Australian Federal Police have provided formal responses which are included at Appendix 1, and Agriculture has also provided a summary response as below.

The Department of Agriculture (the department) considers the report and findings provide a basis for further improvements to the risk based management of biosecurity in international mail. As noted in the report, international mail is currently estimated to have an overall compliance rate with quarantine regulations of 99.9 per cent.

In an environment with over 186 million approaching mail items per year, the department’s challenge is to identify biosecurity risk material in less than 0.1 per cent of arriving mail. The department’s risk management approach has been implemented over recent years to concentrate resources in the areas of highest risk. The department’s deployment of risk mitigation and targeting measures will continue to be refined with increased knowledge, understanding and experience of risk in this pathway.

The department is working closely with the University of Melbourne through the Centre of Excellence for Biosecurity Risk Analysis (CEBRA) on two key projects to further improve the targeting of biosecurity risk in the international mail pathway. These involve the spatial analysis of delivery addresses for intercepted mail items, with the objective of improving interception rates for certain classes of mail and, the examination of end‑point surveys in international mail.

Recommendations

Footnotes

[1] Department of Agriculture, Budget: Portfolio Budget Statements 2013–14, 2013, p.69.

[2] Australian Customs and Border Protection Service, Budget: Portfolio Budget Statements 2013–14, 2013, p.97.

[3] Collectively this report refers to express mail service, parcels and articles ordinaire (AO) as ‘non‑letter class mail‘. The characteristics of each mail type are provided in Table 1.1.

[4] Using Agriculture’s seizure and leakage survey data, Agriculture and the ANAO estimated that 99.9 per cent of incoming mail items in 2012–13 were compliant with quarantine regulations. Using Customs’ seizure and sampling program data, the ANAO estimated that 99.7 per cent of incoming mail items in 2012–13 were compliant with customs regulations.

[5] The facilities are the Brisbane Airport Transit Centre, Melbourne Gateway Facility, Perth Gateway Facility and Sydney Gateway Facility.

[6] Agriculture’s seizure database is the Mail and Passengers System (MAPS) and Customs’ is the Detained Goods Management System (DGMS).

[7] Scott Morrison MP, Minister for Immigration and Border Protection (Press Release), $88 million to better target border crime, 23 January 2014 <http://www.minister.immi.gov.au/search/cache.cgi?collection= immirss&doc=2014/sm 211078.xml> [Accessed 29 January 2014].

[8] The sampling program is discussed in Chapter 5.

[9] Currently, each gateway facility calculates and reports screening numbers differently, reducing the confidence that can be placed in the accuracy of screening figures.

[10] Australia Post advised that the Memorandum of Understanding has been used as a template by other foreign postal services, which it considers highlights the sound framework in place.

[11] For example, Agriculture has an Import Conditions Database located on its website, which allows the public to search for the import conditions of around 20 000 different commodities.

[12] Agriculture sent a specially designed brochure to 5165 individuals who had been identified as purchasing plant and seed material via the internet in 2011 and 2012 and Customs uploaded a presentation on YouTube to highlight the risks of importing laser pointers.

[13] Australia Post advised that it contacts the relevant foreign postal service to manage this non‑compliance, which may involve a relevant law enforcement agency where appropriate.

[14] Customs seizes all firearms and firearms parts that it finds as part of its screening activities and will release the goods if the importer has been granted a valid permit.

[15] Australia Post advised that it raised this issue with Customs at the October 2013 meeting of the National Tripartite Forum. Customs advised that legal advice was sought, and that this advice confirmed that the sharing of this seizure data with Australia Post was allowed under s.16 of the Customs Act 1901. Australia Post also advised that it publishes a list of prohibitions for international postal operators, which reflect Agriculture’s and Customs’ restrictions on the import of goods.

[16] ‘Assess and release’ refers to a process where unscreened mail is set aside for visual assessment.

[17] Overall, the ANAO estimates 133 568 mail items containing quarantine risk material were not detected, including 41 646 mail items carrying higher risk quarantine material.

[18] Analysis of some commodities subject to product prioritisation shows that removing these products from the Quarantine Proclamation 1998 had resulted in significant reductions in overall seizures.

[19] Under its revised national profiles, the department advised that its target screening volumes will be commensurate with estimated levels of approaching higher risk material.

[20] Customs advised that the risk rankings are based on its strategic priorities and that other intelligence reports identify the source countries of some other types of prohibited imports without producing risk rankings. Customs also considered that it cannot ignore all lower risk prohibited imports, and that when making targeting decisions gateway managers must take account of the specific mail cohorts that arrive at their facility.

[21] Australia Post also advised that it is extending the Sydney Gateway Facility to support the improved presentation of international mail for border screening.

[22] Agriculture advised that its MAPS system does not allow for staff to record that seizures were referred to Customs. As a result, staff were recording these seizures as ‘Return to Sender’, and then recording in a free text field that the cannabis seeds were transferred to Customs.

[23] The deliverables were: the screening of 15 million letter class mail items; the screening of 25 million non‑letter class mail items; and the number of examinations that are conducted.

[24] The six week delay occurs because Australia Post uses its own data and the data of foreign postal services to negotiate and agree on an incoming mail volume number from each country.

[25] For example, the Perth Gateway Facility reports that it screens the full volume of targeted mail. By contrast, the Melbourne Gateway Facility reported that, to account for variances in Australia Post’s volumes data, it subtracts 45 per cent from the volume of targeted mail for its reporting. The Melbourne Gateway Facility could not provide the basis for this subtraction, and ANAO analysis found that there was only a four per cent variance between gateway and national data between January and May 2013.