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    THE EXPORT GRAIN CHAIN

    Discussion Paper

    Prepared forThe South Australian Freight

    Council Inc.

    Source: D Bourne Jones: Mal_de_Mer

    Source: Flinders Ports website

    By

    Ian Lovell

    10

    th

    December 2008

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    Introduction

    A Grain Industry Forum hosted jointly by Shipping Australia Limited and theSouth Australian Freight Council was held on Monday the 24th of November2008. Background papers prepared for the Forum can be found at:

    http://www.safreightcouncil.com.au/ba.asp.

    This paper is based on participant input at the Forum aimed at mapping theexport grain chain and associated issues.

    The objective of the Forum is to identify grain export supply chainimpediments in order to formulate an improvement strategy. This discussionpaper forms an integral part of the process.

    This report has been prepared based on information sourced from or supplied by third parties.Accordingly, Ian Lovell accepts no liability resulting from the accuracy, interpretation, analysis

    or use of information provided in this report. It is important to understand that much of theinformation gathered is anecdotal or based on information provided by third parties and assuch has not been corroborated.

    The Export Grain Chain

    The export Grain Chain is complex and incorporates a large number ofplayers [over 30] involved in commercial, operational and regulatory functions.

    Before bulk wheat and in SA/Victoria barley export market de-regulation theexport of grain was controlled by the single desk marketers: AWB for wheat

    and ABB for Barley. A limited number of specialised grain types such asDurum wheat were exported by other companies but in terms of total exportsthis was small. Both AWB and ABB operated vertically integrated operationsspanning the supply chain from buying, storing, contracting transport andloading.

    Since grain market de-regulation in 2007-2008 abolishing the single desk thenumber of participants, particularly buyers and sellers have increased.

    Concurrently there is an increase in smaller volume shipments particularly ofcontainerised grain.

    In the last year containerised wheat exports have doubled and volumesthrough the Port of Adelaide are estimated at 1,500 twenty foot equivalentunits (teu) per month.

    For transport operators and service providers the number of firms they dealwith has increased as has the complexity of coordinating service provision.

    In addition drought conditions in Australia are forcing stronger competition forgrain between the domestic and export feed and food market.

    High employment levels are also affecting the availability of adequately skilledlabour in the grain supply chain.

    http://www.safreightcouncil.com.au/ba.asphttp://www.safreightcouncil.com.au/ba.asphttp://www.safreightcouncil.com.au/ba.asp
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    The Export Grain Chain Generalised

    Grain export ports in South Australia include: Port Adelaide, Port Lincoln, PortPirie, Port Giles, Thevenard, Wallaroo and Ardrossan. Due to draught

    restrictions some bulk grain vessels load in one port and top-off in a secondport. Port Adelaide has key bulk loading facilities at the Inner and OuterHarbor. Containers are loaded at the Outer Harbor DP World containerterminal. Loading rates differ from Port to Port.

    Key parties involved in the grain chain include:Grain Forecasters [e.g. PIRSA]Growers/ProducersBuyers [e.g. Overseas or Australian companies]Grain Exporters [e.g. Overseas or Australian companies]BanksInsurance companies [including EFIC]Ship OwnerChartererShipping AgentBulk Handlers/Loaders [e.g. ABB Ltd]Port Operators [e.g. Flinders Ports, ABB Ltd]Pilots [e.g. Flinders Ports, ABB Ltd]Stevedores [e.g. Patricks]Towage Operators [e.g. Svitzer, Port Lincoln Tug Co]Road Operators

    Rail Operators [e.g. GWA ]Rail Track Operators [e.g. ARTC]Depot operatorProvidoresBunker ServicesWaste Disposal OperatorsFumigatorsShip CleanersMarine SurveyorsLabour ProvidersRegulators

    Internationally: IMO, AMSA, SOLAS, ISO 14001, MARPOL, UNCITRALand import country regulators

    In Australia: Australian Customs Service [ACS], Australian QuarantineInspection Service, Environmental Protection Agency(s) [EPA],Department of Immigration and Citizenship [DIaC], Department ofInfrastructure, Transport Regional Development & Local Government [DI],Department for Transport, Energy and Infrastructure [DTEI], Department ofHealth & Ageing

    Generic regulators at a Federal & State level for functions such asOccupational Health Welfare & Safety etc

    A number of firms fulfil more than one of these functions.

    Set out in the following diagram is a generalised map of the grain supply chain.

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    Grain

    Grower

    Unload & store on farm or

    at Bulk Handler Silo

    Harvest &

    Transport Load for transport to

    export bulk handler Sea, rail or road to

    export port siloUnload at

    export silo

    AQIS

    registered &

    approved

    establishment

    Make up export

    consignment:

    Segregation &

    Blending

    Transport to port

    bulk loader

    Load to

    ship &

    Vessel

    Departure

    Ocean Voyage with or

    without 2nd

    port loading

    Berth Vessel at

    destination port

    Unload grain

    to store Load grain

    to transport

    Sea, rail or road linehaul

    to destination Unload grain delivery to customer (s)

    GrainForecast

    Grain

    Buyers

    Grain

    Sellers

    Bulk

    Handler

    Port

    Operations

    Regulatory

    Authorities

    DI: Transport SecurityIMO, AMSA, SOLAS, ACS, AQIS,EPA, DIAC, DoHA, DTEI, ISO14001, MARPOL, UNCITRAL

    Ships

    AgentSecurity, Berth Allocation

    Pilotage, Towage,

    Mooring, Marine Survey,

    StevedoringLabour,Providores,Bunkers,Waste, Survey, Cleaning,

    Approvals

    Vessel

    Arrival &

    Berthing

    Marine Survey,

    ACS / AQIS

    Inspection

    Approvals

    Customs, Health

    Security, Inspections,

    approvals

    Port

    O erations

    Ships Agent

    Vessel

    Schedule &

    Stowage

    Finance,

    banking,

    insurance

    Import

    Permit

    Purchase by

    consumer(s)

    Charter, Vessel &LogisticsArran ements

    Grain Chain Map

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    Commercial Export Arrangements - Buyer with Seller

    Financial arrangements / Letter of Credit / Insurance

    Shipment specifications / Ship Charter / Delivery Date

    Import Permit

    Sellerbuys grain from growerCashForward ContractFirm Grain OfferPool

    Grower / Seller organises transport to accumulation site /

    export port

    Charter Party

    Arrangements

    Ships Agent at

    export port

    Vessel

    Instructions

    Arrangements

    Notifies: Seller, Port Operator/ Port services tugs, pilotage, mooring labour,berth allocations, harbour services, stevedore, bulk handler, Transport Security,Marine Surveyor, AMSA, AQIS, ACS,

    Exporter

    Arrival at Berth

    Ready to Load Declaration

    Marine Survey

    AQIS Pratique Inspection

    AQIS Ship Inspection

    Incinerator Inspection

    ACS/DIAC/Security

    AQISImportPermitSurvey

    ACS: Export Clearance No.

    Authority to Deal

    Certificate of Clearance

    AQIS

    Export Permit [WEA bulk wheat]

    Phytosanitary Certificate

    AQIS

    inspection

    of grain &

    loadingequipment

    Load

    Vessel /

    Lodge

    manifest

    Key Documents/Approvals

    Vessel

    Clearance

    Vessel

    Departure

    Bulk Handler

    ApprovedEstablishment

    Shipprior to port entry

    Load Port, Survey, AQIS Quarantine Pre-Arrival Report (QPAR)96 to 12 hours prior to arrival, Stow Plan& AMSA Stability Calculations, Ballast Water Plan, ACS arrival forms, De-Rat & Sanitation Certificates,Gypsy Moth Certificate if reqd, ISSC, ships security level, last 10 ports of call, power, water, waste,bunkers, stores, SOLAS, ETA, Vessel Entry Form

    Fumigation

    Certificate

    ACS: ExportDeclarationRequest to Load ShipStores, DepartureReport

    http://www.abb.com.au/Portals/0/GMPDF/GMDFSheetCashPrices1860_5.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetForwardContracts%201864_5.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetForwardContracts%201864_5.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetFirmGrainOffer%202474_2.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetFirmGrainOffer%202474_2.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetABBPool2606_1%20web%20version.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetABBPool2606_1%20web%20version.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetABBPool2606_1%20web%20version.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetABBPool2606_1%20web%20version.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetFirmGrainOffer%202474_2.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetForwardContracts%201864_5.pdfhttp://www.abb.com.au/Portals/0/GMPDF/GMDFSheetCashPrices1860_5.pdf
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    Containerised Grain Exports

    Containerised grain exports differ from bulk grain exports in a number of ways.Essentially the grain export process involves grain being packed into acontainer in bulk or in bags. This takes place at a registered and AQIS

    approved facility. Once the container and grain is inspected by AQIS or underan AQIS approved arrangement the container is sealed and enters theregular container export supply chain. The empty container can be inspectedat the container depot and sealed for transport to the packing facility.

    In contrast with bulk ship vessel grain exports the containership does not needto be grain inspected. An additional point of difference is that mostcontainerships run to a fixed day sailing schedule and generally face fewervessel delays compared to bulk charter vessels.

    Containerised grain exports can be packed off-port in regional areas with the

    containers being delivered from the container depot to the packing location byroad and/or rail. The physical inspection may occur in the regional packingfacility or if remote on arrival at a metropolitan location.

    AQIS requires different grade containers to be used for export bulk andbagged grain. Shipping Australia Ltd has produced the following guide.

    CONTAINER CLEANLINESS STANDARDSGrade Criteria Commodities

    FOOD CONTAINER

    (FC)

    (Including DPI Grade)

    No Taint

    No Flaking Paint

    No Interior Transferable StainsClean & Dry Floor

    No Cargo Residue

    No Infestation

    Dried Fruit

    Flour

    Grain/Peas/CerealsRice

    CLEAN CONTAINER

    (CC)

    No Obnoxious Odours

    No Flaking Paint

    No Transferable Internal Rust

    No Transferable Floor Stains

    Clean & Dry Floor

    No Cargo Residue

    No Infestation

    Milk Powder

    Canned Fruit

    Personnel Effects

    Pet Food

    Bulk Food

    Commodities

    (with fitted liner)

    GENERAL CARGO(GC) No Cargo ResidueDry Floor

    Normal Wear & Tear

    Acceptable

    General CargoCotton

    Steel

    Machinery

    Tyres

    MULTI PURPOSE

    CONTAINER

    (MC)

    No Cargo Residue

    Cargo Worthy

    Suitable for carriage of

    nonsensitive Cargo. Includes

    containers prepared with

    linings & absorbent material.

    Hides

    Bone Meal

    Bagged Chemicals

    Scrap

    Source:http://www.shippingaustralia.com.au/Portals/57ad7180-c5e7-49f5-b282-c6475cdb7ee7/061998FactSheet.pdf

    http://www.shippingaustralia.com.au/Portals/57ad7180-c5e7-49f5-b282-c6475cdb7ee7/061998FactSheet.pdfhttp://www.shippingaustralia.com.au/Portals/57ad7180-c5e7-49f5-b282-c6475cdb7ee7/061998FactSheet.pdfhttp://www.shippingaustralia.com.au/Portals/57ad7180-c5e7-49f5-b282-c6475cdb7ee7/061998FactSheet.pdfhttp://www.shippingaustralia.com.au/Portals/57ad7180-c5e7-49f5-b282-c6475cdb7ee7/061998FactSheet.pdf
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    In the case of grain AQIS rejects the container if it finds live pests in residuesor on the structure of the container; live rodents or evidence of rodentsharbouring behind linings; residue infestible by pests; structural damage thatpests could enter after loading; non-infestible materials, odour, water, rodentcarcasses or droppings.

    Documentation

    The following Australian Customs Service picture depicts export ofcontainerised grain from a registered approved depot to the ContainerTerminal Operator. A guide is on the ACS website.

    Source: ACS website

    In addition to ACS AQIS documentation through EX-Doc is shownbelow.

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    AQIS EX-Doc

    EXPORTER LODGES AN RFP WITH REQUEST FOR AN EDN

    AND REQUESTS THE RFP TO BE FORWARDED TO THE AA

    ESTABLISHMENT AT FINL STATUS

    EXDOC VALIDATES THE MESSAGE, OBTAINS EDN AND RETURNS THE RFP

    NUMBER, STATUS AND EDN TO THE EXPORTER OR AA ESTABLISHMENT

    EDI USER AMENDS RFP WITH FURTHER DETAILS

    EXDOC VALIDATES RFP AND ASSIGNS A STATUS OF EITHER INIT OR

    FINL

    AA ESTABLISHMENT AMENDS & AUTHORISES RFP AND FORWARDS

    THE RFP TO THE EXPORTER AT HCRD STATUS. EXDOC ASSIGNS A

    STATUS OF EITHER INSP OR HCRD OR COMP

    AA ESTABLISHMENT MUST AMEND RFP IF STATUS IS INSP

    EXDOC WILL ASSIGN A STATUS OF EITHER HCRDOR COMP

    AQIS OFFICER PERFORMS FINAL SECURITY CHECK ON RFP WITHHCRD STATUS. EXDOC ASSIGNS A STATUS OF COMP

    EXDOC GENERATES A CERTIFICATE WHEN RFP HAS A STATUS OFCOMP

    AA ESTABLISHMENT

    EXPORTER

    IF A STATUS OF INIT IF A STATUS OFFINL

    Source: AQIShttp://www.daffa.gov.au/aqis/export/plants-grains-hort/exdoc/manual

    http://www.daffa.gov.au/aqis/export/plants-grains-hort/exdoc/manualhttp://www.daffa.gov.au/aqis/export/plants-grains-hort/exdoc/manualhttp://www.daffa.gov.au/aqis/export/plants-grains-hort/exdoc/manualhttp://www.daffa.gov.au/aqis/export/plants-grains-hort/exdoc/manualhttp://www.daffa.gov.au/aqis/export/plants-grains-hort/exdoc/manual
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    Exporters through Ex-Doc notify AQIS of a potential export of productusing the request for permit (RFP) suite of messages. An ExportPermit Number (EPN) is required for all prescribed grain & horticulture.

    Grains: whole seeds of -

    wheat

    oats

    barley

    canola

    dried field peas

    sorghum

    soybeans

    mung beans

    Grains: whole and split seeds of vetch

    lentils

    chickpeas

    lupins

    faba beans

    Grains: plant products

    hay and straw of cereal origin

    The receipt of an RFP [request for permit] initiates a regime ofvalidation activities to ensure that the product complies with Australianand NPPO country standards. The final step in the approval processfor RFPs is the allocation of an Export Permit Number (EPN) whereapplicable and production of the appropriate certificate by AQIS.

    RFP includes:

    Grain & Horticulture export registered/listed establishment, wherethe product is to be inspected

    quantity, description and identification marks of product

    description of how the product is packed, and container number(s) ifapplicable

    exporter details

    name of vessel, voyage number (or alternatively flight details), dateof departure

    consignee, country of destination, port of discharge and place offinal destination

    the type of Certificates and endorsements required, if applicable.

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    Phytosanitary Certificate

    Where a Phytosanitary Certificate is required AQIS procedures areclearly spelt out in Phytosanitary Certificate Completion (Exports)Work Instruction, at www.aqis.gov.au

    Below are examples of Phytosanitary Certificates for

    Grain for Consumption Methyl Bromide Fumigated

    Grain for Consumption Phosphine Fumigated

    Bulk Grain

    Phytosanitary Certificate Grain for Consumption Methyl Bromide Fumigated

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    Phytosanitary Certificate Grain for Consumption Phosphine Fumigated

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    Phytosanitary Certificate Bulk Grain

    The Phytosanitary Certificate is the official means by which the AustralianGovernment certifies to the National Plant Protection Organisation [NPPO] ofthe importing country that the product meets that countrys import standards

    and regulations.The following diagram represents a simplified export grain container chain.

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    Finance,Banking,

    Insurance

    Containerised Bulk Grain Chain -Simplified

    Grain

    Seller

    Grain

    Buyer

    Grain

    Producer Transport topacking

    lace

    Booking request to

    Shipping Line / Agent

    Shipping line quote &

    booking confirmed

    Forwarding Instruction to

    Line / Agent from exporter

    Bill ofLading Cut

    Instruction toContainer depot

    Container

    Inspection

    Depot Inspection

    Declaration

    Exporter

    Pick up of empty

    container from depot

    Container

    ReleasePack

    Container

    Grain

    Inspection

    Seal

    Container

    Transport to

    Container Terminal

    PRA & Book

    Time Slot to Depot& Container

    TerminalCTO

    Container

    receival /

    load to stack

    ACS /

    AQIS /

    Line /

    Agent

    Approvals

    & docs

    Vessel

    Arrival &

    loading

    Vessel &

    Cargo

    Clearance

    Vessel

    Departure

    Port

    Operations

    & Services

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    ISSUES RAISED AT THE FORUM

    ABB Grain Storage & Bulk Handling Facilities at Outer Harbor. Source: ABB Grain Ltd

    A range of issues were raised at the Grain Forum and some solutions

    suggested at and after the Forum. This section summarises them.

    Market InformationInformation on the production of grain and market demand for it is dispersedacross various sources / organisationsSolution: Consider a linked web portal to make such information moreaccessible

    Grain Market DeregulationThe deregulation of export grain has a number of impacts apart fromincreased competition. There is an increase in containerised exports as

    smaller volume/specialised traders and sellers enter the market. This isexacerbating a shortage of Food Quality export containers.Solution: AQIS approval to use liners in lower grade containers as a functionalbarrier between the cargo and the container

    As the market becomes increasingly dispersed in terms of grain exporters thetransport task is becoming harder to manage, particularly in terms of avoidingberth clashes, schedule slippage, provision of tugs and use of rail.Solution: Make better use of information technology and shared information portals Produce a Grain Export Information & Procedures Pack for all parties in

    the supply chain accessible on the web

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    DroughtDrought conditions are increasing competition between the domestic andexport markets for feed and food grainSolution: Greater efforts needed to drought proof farms / businessdiversification

    Shorter Lead Times/Delays/Inspections/In-Transit FumigationOrder lead times are getting shorter and can be between 5-21 days. This putspressure on the whole supply chain. This is exacerbated by grain beingshipped year round not just in peak season. The impact is that shipmentscan be delayed increasing costs.

    The new grain loading facility at the Outer Harbor has some 60,000 tonnesstorage capacity and grain sourced from the Inner Harbor silos relies on acontinuous/reliable transport chain. This increases the risk of ship delays inthe event that: Grain is found to be unfit for export Loading equipment is not cleared as suitable for export grain The ship is not cleared as ready to load

    With the advent of Panamax ships the ready to load failure rate is significantlyhigher than smaller vessels

    Solutions: Use ships that have demonstrated procedures in place and appropriate

    levels of equipment to pass inspection Develop International Standards Tighten supply chain coordination and use sound practice to ensure

    rejections are minimised Have grain inspections carried out earlier in the chain e.g. at Inner

    Harbor Inspect ships at anchorage by the use of remote inspection technology Allow in-transit fumigation for minor infestation of grain where permitted by

    importing country examine Export Control Act

    24/7 OperationsGrain Ports, associated facilities and transport corridors need to be able tooperate 24/7.

    Solution: 24/7 capability needs to be safeguarded by all three tiers ofGovernment

    Availability of ServicesThe availability of Tugs and AQIS inspectors to meet the grain task is an issue.The issue of availability of trained labour was also raised

    Solutions: Better coordinate vessel arrivals by early advice of berth and tug

    availability

    Increase AQIS staff levels and/or productivity Increase pool of trained inspectors, particularly in regional areas

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    e.g. Use same staff to conduct pratique as ship hold inspections e.g. Use Marine Surveyor or third party to conduct inspection using remote

    technology uplinked back to AQIS office Increase training effort to meet labour shortages

    EPA RequirementsIn the case of Ballast Water Australia has a dual system, one from Victoriaand one for other jurisdictions. Emission controls being developed areonerous.

    Solution: Raise need for national consistency with Government

    Consistency in Regulation and Regulatory CriteriaMany of the regulations applied to grain exports are to an extent subjectiveand this can lead to inconsistency in their application. AQIS inspections are a

    case in point that AQIS has sought to address.

    Solution: Greater transparency in criteria used by regulators shared withindustry may assist as may chain participant training courses including webbased training.

    Safety on the WaterfrontSafety on the waterfront and at sea remains an ongoing issue that requirescontinual improvement without imposing a cost burden.

    Solution: Better national & international safety information sharing.

    Summary

    Issues raised at the Forum include:Market Forecast Information Better Use of the WebConsistent Grain Export Procedures Grain Information PackManaging the Transport Task Sharing Of InformationShortage of Food Quality Grain Export Containers Use of LinersDrought - DiversificationShorter Lead Times:Supply Chain Coordination

    Ship Inspection Failures International Ship StandardsGrain Inspections at Outer Harbor Risk of failureShip Delays Berth AvailabilityInspection Of Ships At Anchorage Remote Inspection TechnologyIn Transit Fumigation for minor infestation where permitted by import country24/7 OperationsAvailability of ServicesEPA Requirements - ConsistencyConsistency in Regulation and Regulatory CriteriaSafety on the Waterfront

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    The grain chain is not only complex but is becoming time compressed as aresult of larger ships, relatively smaller holding load capacity at ports andmarket demand.

    In looking at the regulatory arrangements there appears to be significant

    opportunity to streamline both functions and processes.

    In terms of industry there also appears to be scope for improvement throughbetter sharing of information, albeit consistent with ACCC requirements.

    It is suggested that this paper and the minutes from the forum be widelycirculated to grain chain participants, forum attendees and key Governmentagencies including:

    Australian Transport Council of Ministers [ATC] National Transport Commission AQIS & Grain Industry Consultative Committee DAFF ACS Department of Infrastructure, Transport, Regional Development and Local

    Government DFAT Austrade DTEI BTE / ABARE

    In addition to circulating this information a follow on Grain Chain SolutionsForum is suggested to crystallise key issues and recommend tangiblesolutions at both a policy and operational level.

    Comments on this discussion paper should be sent to:

    Neil MurphyGeneral ManagerSouth Australian Freight Council Inc296 St Vincent St, Port Adelaide SA 5015Tel: (08) 8447 0688, Mob: 0427 089 240

    Fax: (08) 8447 0606Email:[email protected]

    Ian Lovell

    Ian LovellConsultant

    Tel 0400 708 182 [email protected]

    mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]
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    AQIS Special Terms / Glossary

    Term Meaning

    AA Approved Agreement (with AQIS)

    ABS Australian Bureau of Statistics

    ACS Australian Customs Service

    AQIS Australian Quarantine and Inspection Service

    AHECC The Australian Harmonised Export Commodity Classificationassigned by the Australian Customs Service

    AFFA Department of Agriculture, Forestry and Fisheries - Australia,was previously known as the Department of PrimaryIndustries and Energy (DPIE).

    EDI Electronic Data Interchange

    EDIFACT UN Standard EDI for Administration, Commerce andTransport

    EDI User An exporter or agent who has Third Party Interface Softwareand is registered for a particular commodity

    EDN Export Declaration Number obtained from ACS

    EDS Electronic Documentation Section of AQIS Central Office

    EPN AQIS Export Permit Number ( PIG / PIH number)

    ER AQIS Establishment Register System

    EXDOC Export documentation softwareICS Customs Exports integration system software. EXDOC

    interfaces with it to obtain an EDN

    LAN AQIS Local Area Network running EXDOC programs

    NPPO National Plant Protection Organisation

    Prescribed Goods Fresh fruit, Fresh vegetables, Dried fruit, Prescribed grain,Plants or Plant products for which a Phytosanitary certificateor any other official certificate is required by an importingcountry authority

    RAS AQIS Remote Area Site running EXDOC programs

    RFP Request for Permit to Export Prescribed Goods (EXDOC

    EDI message) (old EX28/EX222 document)

    RO AQIS Regional Office

    SANCRT The United Nations EDIFACT registered global electroniccertificate covering animal, plant and fish products

    Third PartyInterface Software

    Software developed by 3rd party software developers as theinterface between the exporter and EXDOC

    UN United Nations

    VAN Value Added Network (an alternative name for Carrier)

    WAN AQIS Wide Area Network running EXDOC programs