Biosecurity Manual For The Nursery Production Industry

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Biosecurity Manualfor the Nursery Production IndustryReducing the risk of pests entering and becomingestablished in your production nurseryVersion 1.0

Plant Health Australia (PHA) is thelead national coordinating body forplant health in Australia. PHA works inpartnership with industry, governments,researchers and others, providing nationalcoordination to improve biosecuritypolicy and practice across Australia’splant industries and to build capacity torespond to plant pest emergencies.www.planthealthaustralia.com.au Plant Health Australia 2010This work is copyright except whereattachments are provided by othercontributors and referenced, in which casecopyright belongs to the relevant contributoras indicated throughout this document.Apart from any use as permitted underthe Copyright Act 1968, no part may bereproduced by any process without priorpermission from Plant Health Australia.Requests and enquiries concerningreproduction and rights should be addressedto the Communications Manager at PHA.The Nursery and Garden IndustryAustralia (NGIA) is the peak industry bodyfor the Australian nursery and gardenindustry and is responsible for overseeingthe national development of this diverseindustry. This includes liaising withgovernment departments on industryissues, providing strategic direction andleadership and ensuring communicationof relevant information. The industry is farbroader than the perceived “ornamental”market, and supplies greenlife to a widearray of end users including the forestrysector, revegetation/landcare sector,landscapers, fruit orchardists, cut flowerand vegetable growers.NGIA’s vision is for a unified Australiannursery and garden industry that isproductive, profitable and e:02 6215 770002 6260 a.com.auAn electronic copy of this manual is availablefrom the website listed above.Disclaimer: The material contained in this publication isproduced for general information only. It is not intended asprofessional advice on any particular matter. No personshould act or fail to act on the basis of any materialcontained in this publication without first obtaining specific,independent professional advice. Plant Health Australia andall persons acting for Plant Health Australia in preparing thispublication, expressly disclaim all and any liability to anypersons in respect of anything done by any such personin reliance, whether in whole or in part, on this publication.The views expressed in this publication are not necessarilythose of Plant Health Australia.

Table of contentsSix easy ways to protect your production nurseryBiosecurity overviewWhat is biosecurity?What is production nursery biosecurity?Regional biosecurityIndustry Best Practice and biosecurityPestsHigh priority exotic pest threats of the nursery production industryPest surveillanceReport suspect pestsProduct managementGrowing media, propagating material and other production inputsPotting and propagating facilitiesWater managementProduction nursery waste2444568810101212121313People and biosecurity14Biosecurity signsManaging people movementContractors and utility providersOverseas travellers14141515Equipment and vehicles17Movement of vehicles and machineryWash-down facilitiesDesignated parking areasBiosecurity summaryFurther informationExample recordsVisitor recordMaterials import inspection recordVehicle inspection recordCrop monitoring recordFact sheetsGuava (Eucalyptus) rustGlassy-winged sharpshooterSerpentine leafminerAsian gypsy mothSudden oak deathCitrus longicorn beetlePoinsettia thrips171818212224242526272828303234363840

Six easy ways to protectyour production nursery2You have an important roleto play in protecting yourproduction nursery and theentire industry frombiosecurity threats.Here are six simple, routine practicesyou can do to reduce the threat of newpests (invertebrates, pathogens andweeds) entering and establishing onyour property. Each practice should beembedded in your nursery’s everydaymanagement as they make goodbusiness sense by reducing the risk ofspreading pests. These also supporton-farm programs (Nursery IndustryAccreditation Scheme Australia(NIASA), EcoHort and BioSecureHACCP) developed by Nursery andGarden Industry Australia (NGIA) toensure good farm hygiene at all times.Don’t put your livelihood at risk byneglecting nursery biosecurity.1. Be aware of biosecurity threatsMake sure you and your productionnursery workers are familiar with themost important exotic productionnursery pest threats. Conduct abiosecurity induction session toexplain required hygiene practices forpeople, equipment and vehicles onyour property.2. Use only clean, pest-freeand preferably certified,production nursery inputsEnsure pests and other contaminantsdo not enter your property withproduction nursery inputs, suchas growing media, fertiliser andpropagation material. Purchasethese only from reputable suppliers,preferably with NIASA accreditationor BioSecure HACCP certification.Keep records of all nursery inputs.3. Keep it cleanPracticing good sanitation andhygiene will help prevent the entryand movement of pests onto yourproperty. Workers, visitors, vehicles,raw material and equipment canspread pests, so make sure theyare decontaminated, or havecome from a clean source, beforeentering and leaving your property.Have a designated visitor’s areaand provide vehicle and personneldisinfecting facilities.

4. Check your productionnurseryMonitor your crops and rawmaterials frequently. Knowing theusual appearance of the plants inyour production nursery will helpyou recognise new or unusualevents and pests. Keep written andphotographic records of all unusualobservations. Constant vigilance isvital for early detection of any exoticplant pest threat.5. Abide by the law espect and be aware of laws andRregulations established to protectthe nursery production industry,Australian agriculture and your region.6. Report anything unusualIf you suspect a new pest – reportit immediately.If you see anything unusual,call the Exotic Plant Pest HotlineINET PEST HOTLEXOTIC PLAN118 0 0 0 8 4 8 83

Biosecurityoverview4This manual is designed to assist you inprotecting your property and the nurseryproduction industry from new and invasivepests. By implementing the recommendedmeasures in your day-to-day operations,you will improve your own biosecurity andthat of your region, while minimising croplosses and unnecessary costs.The definition of a pest used in thismanual covers all insects, mites,snails, nematodes, pathogens(diseases) and weeds that may harmplants or plant products. Exoticpests are those not currently presentin Australia. Established pests arethose present within Australia.What is biosecurity?Biosecurity is a set of measures that canbe put in place at the national, regional orproduction nursery level to protect againstthe introduction and spread of new pests,and to effectively deal with them shouldthey arrive.Australia’s geographic isolation has meantthat we have relatively few of the pests thataffect plant industries overseas. Freedomfrom these exotic pests is a vital part ofthe future profitability, productivity andsustainability of Australia’s plant industries.Biosecurity allows us to preserve existingtrade opportunities and provide evidenceto support new market negotiations.What is production nurserybiosecurity?Production nursery biosecurity is a set ofmeasures designed to protect a propertyfrom the entry and spread of pests.Production nursery biosecurity is yourresponsibility and that of every personvisiting or working on your property.Through the implementation of productionnursery biosecurity measures, growersplay a key role in protecting the Australiannursery production industry from exoticpests. If a new pest becomes establishedin your production nursery, it will affectyour business through increased costs(for monitoring, cultural practices,additional chemical use and labour toapply them), reduced productivity(yield and/or quality reductions) and/orloss of markets.The industry has developed BioSecureHACCP guidelines to assist productionnurseries implement sound on-farmbiosecurity measures. More informationon BioSecure HACCP can be found atwww.ngia.com.auEarly detection and immediatereporting of pests increase thechance of effective and efficienteradication.

Regional biosecurityBiosecurity implementation at theregional level supports the measuresimplemented on your property. Considerestablishing or contributing to biosecuritymeetings to coordinate and promoteregional biosecurity, which will reducethe biosecurity threats to all properties inyour region.At a regional level, potential biosecuritythreats may originate from neighbouringnurseries or farms (operating orabandoned), other commercial plantings,native vegetation or amenity plantings.Movement of plants or plant productswithin the region also increasesbiosecurity risks.Reduction and management ofbiosecurity risks at the regional levelcan be achieved through activities suchas raising awareness of key threats tothe area, identifying and documentingthe locations of production, providingguidance on the appropriate protocols tofollow when moving produce within theregion and engaging the local council.Within a region, every agriculturalbusiness will be financially affected inthe event of an exotic pest incursion.The impact might be in lost production,restrictions on market access,compliance costs, quarantined produceor even crop destruction.Implementation of production nurserybiosecurity underpins regionalbiosecurity, which in turn underpinsnational biosecurity. Promotion ofbiosecurity at the regional level isenhanced through broad engagementof the community, understanding theregion, the source and nature of threats,and having knowledge of the expertiseand resources available to the region.This is supported by a commitmentfrom everyone to implement biosecuritymeasures, carry out surveillance andreport suspect pests.If production nursery biosecuritymeasures are supported by communitybased measures, a regional frameworkfor biosecurity can be coordinated andis achievable.5

Industry Best Practiceand biosecurity6The Nursery Production Farm ManagementSystem (FMS) includes the NurseryIndustry Accreditation Scheme Australia(NIASA), EcoHort and BioSecure HACCPBest Management Practice programs.Membership and involvement in theNursery Production FMS is open toproduction nurseries and growing mediasuppliers and provides participatingbusiness with a good grounding inbiosecurity measures and practices.Implementing the Nursery Production FMSin your business encourages good hygiene,pest monitoring and traceability in youroperations. Biosecurity traceability allowsfor the trace-back of plant material andproduction nursery inputs on your propertyto its source, the trace-forward of plantmaterial that has left your property, andthe provision of records of surveillanceand pest management practicesundertaken on your property.In addition, information included in theNursery Production FMS provides furtherdetails and recommendations for theimplementation of many of the measuresoutlined in this manual.For more information about theNursery Production FMS, visit NGIAat www.ngia.com.auBioSecure HACCP – anon-farm biosecurityprogramBioSecure HACCP is theon-farm biosecurity program forproduction nurseries and growingmedia businesses in Australia,which validates many of the BestManagement Practice strategiesemployed under NIASA. Thisprogram provides growers withdecision making tools to supporton-farm biosecurity, and guidesthe identification and mitigation ofrelevant risks.The BioSecure HACCP riskmanagement system encouragesa businesses to maintain thestrictest internal quarantineprocedures possible and recordthe actions taken at criticalcontrol points. Through theseactions a business is betterprotected in the event of abiosecurity threat. Importantly,BioSecure HACCP will supportfuture market access bothdomestically and internationally.

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PestsHigh priority exotic pest threats of the nursery production industryThe following are some key high priority exotic pest threats for the Australian nurseryproduction industry as identified through the development of the Nursery and Garden IndustryBiosecurity Plan (IBP). Any of these pests would have serious consequences shouldthey enter and become established in Australia. For a complete list of exotic pest threatsfor the nursery production industry, refer to Nursery and Garden IBP, available . Additional information on each ofthese pest threats is included in the fact sheets at the back of this manual.POTENTIAL ECONOMIC IMPACT – HIGH-EXTREME Over 100 known host plant species, mainly from theMyrtaceae family Brown to grey lesions usually surrounded by yellow spores Lesions develop on actively growing leaves, shoots andfruits Severe infections may kill shoot tips or cause leaf distortion Spread with infected plant material or through wind dispersalPaDIL (J.A. Rocabado)Guava (Eucalyptus) rust (Puccinia psidii)POTENTIAL ECONOMIC IMPACT – HIGH Wide host range of over 200 species Adults (12-14 mm long) are dark brown with stippled spots onhead and back, and transparent wings with reddish veins Produces watery excrement, appearing as white spots, whichoften collects during feeding Known vector of Xylella fastidiosa pathogen (Pierce’s disease),which causes leaf scorch symptoms Can spread by flight or as a hitchhiker on plant materialReyes Garcia III, USDA Agricultural ResearchService, Bugwood.orgGlassy-winged sharpshooter (Homalodisca vitripennis)Serpentine leafminer (Liriomyza huidobrensis)POTENTIAL ECONOMIC IMPACT – HIGH Wide host range of over 40 species Small (1-2.5 mm) black fly with yellow head and yellow spotson thorax Larvae mine under the surface of stem or leaf tissue Mines are white with dampened black and dried brown areas Mines are typically serpentine, of irregular shape and increasein width as the larvae mature Spread occurs with infested plant materialMerle Shepard, Gerald R.Carner andP.A.C Ooi, Bugwood.org8

9POTENTIAL ECONOMIC IMPACT – HIGH Very wide host range, with over 650 known hosts Egg masses laid on solid surfaces and covered in light tan fuzz Mature caterpillars are large (50-65 mm long) and hairy withtwo rows of spots (red and blue) along their back Moths have greyish-brown wings (30-40 mm wingspan) inmales or white with grey markings (40-70 mm) in females Causes heavy defoliation and larvae may produce webbing Can spread large distances naturally or with infested plantmaterialJohn H. Ghent, USDA Forest Service,Bugwood.orgAsian gypsy moth (Lymantria dispar)POTENTIAL ECONOMIC IMPACT – HIGH Infects over 130 tree and shrub species Symptoms in shrubs: blackened shoots, diffuse dark brownspots or blotches with fuzzy margins, starting at the leaf tip Symptoms in trees: stem canker with red to black thick sapoozing on the bark surface. Stem necrosis leads to the deathof whole crown Spread with infected plant material, or water, growing mediaand compost that has been in contact with infected plantsJoseph O’Brien, USDA Forest Service,Bugwood.orgSudden oak death (Phytophthora ramorum)POTENTIAL ECONOMIC IMPACT – MEDIUM Wide host range of over 100 species of woody trees Large black beetle (20-40 mm) with white spots on outer wingcovers and antennae that are longer than the body Larvae (50-60 mm long) are creamy white with a black head Larvae and adults remain under bark or within woody tissue Frass (sawdust) accumulates at the base of infested trees Can spread in infested plant material. Adults can fly up to 1 kmArt Wagner, USDA APHIS PPQ,Bugwood.orgCitrus longicorn beetle (Anoplophora chinensis)POTENTIAL ECONOMIC IMPACT – MEDIUM Attacks over 100 species, particularly greenhouse crops Adults are brown (1.6 mm in length) with red between segments Feeding damage results in shallow puncture wounds on theleaves, reduced leaf size and lightening of colour Black spots (faecal droppings) left on leaf surfaces Potential to act as a vector of plant pathogens Can spread with infested plant materialLance Osborne, University of FloridaPoinsettia thrips (Echinothrips americanus)

10Pest surveillanceMonitoring and surveillance across aproduction nursery involves looking forand recording the presence, absence andpopulation levels of pests. Conductingregular monitoring is a fundamental part ofnursery management practices and givesthe best chance of spotting a new pestsoon after it arrives. Pest surveillance isalso a key component of NGIA’s BioSecureHACCP on-farm biosecurity program.Pest surveillance is necessary for: Exotic pest eradication: Early detectionof exotic pests improves the chanceof eradication or containment withina region. However, if eradicationor containment are not feasible,early detection in conjunction withcontingency planning and preparednessby government and industry bodies(e.g. preparing emergency chemicalregistrations, permits for importation ofbiocontrol agents, awareness materialand training in pest diagnostics),assists with a more rapid and effectiveresponse. Market access: Export and interstatemarkets can require ‘evidence ofabsence’ data for exotic and someestablished pests that are of concern.The Australian nursery productionindustry, in collaboration withgovernments, must prove throughsurveillance that pests of concern havebeen looked for and found to be absent. Improved pest management:Management of established pestsrequires regular inspections todetermine population levels to improvemanagement decisions and provideclients with healthy nursery material. Pest status information: Surveillanceat the nursery level contributes essentialinformation to regional biosecurity effortsand ultimately to the national status(presence/absence) of a pest.All pest (exotic and established)surveillance activities carried out on yourproperty should be recorded. Theserecords can be used in the response toa pest outbreak and provide support toindustry surveillance activities.The addition of exotic pests to currentdatasheets is an effective recordingmechanism. Guidelines for effectivenursery monitoring are included in theBioSecure HACCP manual and an examplecrop monitoring record sheet is included inthis manual (see page 27).Report suspect pestsEarly detection and reporting may preventor minimise long-term damage to, orquarantine period of, your productionnursery, region or the entire industry.Report any unusual or suspect plantpest immediately via the Exotic PlantPest Hotline on 1800 084 881.Calls to the Exotic Plant Pest Hotline will beforwarded to an experienced person in yourstate or territory government, who will asksome questions about what you have seenand may arrange to collect a sample.

Do not send samples without firstspeaking to someone from the statedepartment, who can discuss the correcttype of sample, its packaging, handlingand transport to the laboratory assignedfor diagnosis.In some states, the Exotic Plant PestHotline operates only during businesshours. Outside these hours, leave yourfull contact information and a briefdescription of the issue and your callwill be followed up as soon as possible.Every report will be taken seriously,checked out and treated confidentially.If you have found a suspected exoticplant pest, the following generalprecautions should be taken immediatelyto contain the pest and protect otherparts of your production nursery: Mark the location of the pest detectionand limit access to the area for bothpeople and equipment. Wash hands, clothes and boots thathave been in contact with affectedplant material or growing media. Restrict operations in the area whilewaiting for the identification of thesuspected exotic pest.If you see anything unusual,call the Exotic Plant Pest HotlineT PESTEXOTIC PLANHOTLINE118 0 0 0 8 4 8 8The Emergency Plant PestResponse Deed (EPPRD)and the Nursery IndustryThe EPPRD is a formal, legallybinding document between PlantHealth Australia (PHA), Australianand state/territory governments,and plant industry signatories.As a signatory to the EPPRD,Nursery and Garden IndustryAustralia (NGIA) has a seat atthe decision making table andalso contributes to funding ifan approved Response Plan isimplemented to eradicate anEmergency Plant Pest (EPP).Under the EPPRD, NGIA and itsmembers have a responsibilityto report suspect pests. Theearlier a new pest is detected, thegreater the chance an eradicationresponse will be mounted and themore likely it will be successful.Within an approved ResponsePlan, grower reimbursementpayments (Owner ReimbursementCosts) are included for directcosts incurred as a result oferadication of a pest incursion.For more information onOwner ReimbursementCosts refer to the PHA websitewww.phau.com.au/epprd11

Product management12Growing media, propagatingmaterial and other productioninputsPests and contamination can beeasily brought onto your property withproduction nursery inputs (includinggrowing media, plant containers andfertiliser) and plant material.Be aware that you cannot visuallyassess the true health of yourpropagation material, as viruses, viroids,phytoplasmas and other pests may notdisplay symptoms. Ensure propagationmaterial is ‘clean’ (i.e. tested with no pestdetections) and where possible, use onlycertified production nursery inputs.To minimise the risk: Purchase plant material only fromtrusted sources (i.e. NIASA accreditedor BioSecure HACCP certifiedbusinesses) that will provide you withreliable records of the material’s source,and the treatment and testing history. Check your propagation material andproduction nursery inputs thoroughly. Maintain a register of all productionnursery inputs entering your property,including its source (with contactdetails), specific planting or storagelocations, numbers of plants or otherproducts, and the date of use (seepage 25 for an example). Request information on the source ofmaterial and testing timetable. Maintain and monitor any motherstockplants to the same standards asproduction areas. Follow the procedures outlined in theBioSecure HACCP manual.Potting and propagating facilitiesGood hygiene practices undertakenduring potting and propagation willminimise the chance of pest spread.The facilities and areas where thesepractices are undertaken should beseparated from production areas.Benches and tools used for propagationshould be regularly washed anddisinfected, preferably between eachbatch of media or plant material.Potting containers should be clean anddisinfected before use.All spilt material and plant waste shouldbe collected and discarded regularly.

Water managementProduction nursery wasteThe management of water quality,including pest infestation levels, isimportant for the maintenance ofhealthy plants. If water sources becomecontaminated they can spread peststhroughout production areas.Maintaining good productionnursery hygiene can minimisecross-contamination and breedingenvironments for pests. This shouldbe achieved in combination with aneffective pest monitoring/managementprogram. A ‘spray diary’ record shouldaccompany each consignment ofplant material.To minimise the risk: Regularly test water storages andmonitor surrounding vegetation for thepresence of pests. Keep areas around water storagesfree of plant waste and other potentialsources of infestation. Production nursery area run-off shouldnot enter irrigation sources withoutprior catchment and treatment.NGIA has developed a Best PracticeManual CD for Pesticide Applicationin the Nursery and Garden Industry.This CD outlines measures foreffective and safe application ofpesticides as part of an IntegratedPest Management program forproduction nurseries and contains apesticide management diary to recordpesticide application events. For moreinformation visit www.ngia.com.auAll plant waste and spilled growingmedia should be collected andremoved from production areas.Waste should be disposed of awayfrom production facilities/areas andwater sources.Appropriate disposal mechanisms forplant waste include hot compostingor delivery to a dedicated wastemanagement facility.13

People and biosecurity14Biosecurity signsManaging people movementWell designed signage informs visitorsthat biosecurity on your propertyis important and that they shareresponsibility for maintaining it. The signsserve to alert people to the potentialimpact of their visit.People moving between differentproduction nurseries and horticulturalregions can spread pests on vehicles,equipment, boots and clothing. Themost obvious risks are pests carried ingrowing media and plant material.Signs also demonstrate yourcommitment to production nurseryhygiene, safety and auditable systems.Biosecurity signage should be placed atthe main gate, external entrances, visitorparking areas and wash-down facilities.Implementing the following measureswill reduce the threat of human activityintroducing new pests into yourproduction nursery:Biosecurity signs at entrances or nearstorages should direct visitors to contactthe owner or nursery manager andformally register their presence beforeentering any production areas. The signshould include important contact details,such as the office telephone number,mobile number and/or UHF channel.Contact PHA for further information onobtaining biosecurity signs for your property. Maintain a visitor register (see page 24),which will record visitor movementsand help manage safety issues. Brief all workers, contractors andvisitors on your biosecurity measures. Employee and visitor footwear andclothing should be free of soil and plantmaterial before entering or leaving theproduction nursery. Provide scrubbing brushes, footbaths,boot covers, rubber boots andprotective clothing, such as disposableoveralls, for people entering or leavingyour production nursery, or movingfrom contaminated to clean areas ofthe property. Sealed or compacted pathways withgood drainage should be installedthroughout propagation and productionareas. Display biosecurity awareness materialwith simple and effective messages instaff rooms, storage sheds and otherplaces where staff congregate.

Contractors and utilityprovidersThe term ‘contractors’ includes utilityproviders, earthmoving companies,transport providers and researchpersonnel, who enter a productionnursery in their day-to-day operations.Contractors pose a significant riskbecause of the movements betweenproperties.Placing biosecurity signs onexternal property gates can play animportant part in raising biosecurityawareness with contractors, especiallyproviders of power, water, gas andcommunications.Limit the risk of contractors introducingnew pests onto your property, byrequesting all contractors’ vehiclesand equipment be cleaned beforestarting work on your property. Providea suitable wash-down bay to completethis task (see page 18).To ensure your property does notbecome the source of pest infectionsfor others, you have a responsibility toinform contractors of any declared ornotifiable pests already present on yourproperty.Overseas travellersPeople returning from overseas are athreat to our biosecurity, especially ifthey have visited production nurseries,farms or markets where plant materialand produce was sold.Several plant pests have beenintercepted at the Australian borderand overseas travellers haveunknowingly brought in pests in thepast. Air travel means exotic plantpests are only a few hours away.To protect your production nursery,ensure that all people who haverecently returned from overseas havecleaned their boots and clothes beforeentering. Great care should be takento prevent the introduction of plantpests into Australia.15

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Equipment andvehiclesMovement of vehicles andmachineryVehicles and production nurseryequipment, such as sprayers, tractorsand hand tools can carry pests inadhering growing media and plantmaterial. Pests can then be introducedto a previously clean property or crop.It is impractical to stop all vehicle andequipment movement on and off theproperty, but using dedicated nurseryvehicles, washing down machinery onconcrete pads and denying access ofdirty machinery can reduce the spreadof pests.Contractors, re-sellers, service providers,and drivers of delivery trucks (for growingmedia, compost, mulch, fertiliser, etc.)and earth moving equipment enteringthe property should be requested toclean their vehicles and equipmentbefore entering production or storageareas. Alternatively, place these storageareas at a point on the property thatallows access without traversing theproduction areas.Businesses open to the public and thoseopen to growers (e.g. for field days,equipment demonstrations, etc.) have aheightened risk and therefore designatedparking areas away from production sitesare important.Measures to reduce the risk of pest entryon equipment and vehicles include: Inspect all vehicles entering theproduction nursery for the presence ofpests and plant material and record theoutcome in a register (see page 26). Hose off and disinfect machinery in adesignated wash-down area (see page18) before moving between properties. Cleaning vehicle floors and tyres ofgrowing media, plant material andpests, especially after visiting otherproperties. Where possible, use your own vehicleto carry visitors around your property. In production areas, keep vehiclemovement to a minimum, especially onwet soil, and stick to regular pathways. Always make sure that borrowedand second-hand equipment andmachinery is cleaned before movingthem into your production nursery. Regularly clean all tools and equipmentused in the production nursery,preferably with a disinfectant orbleach solution (see Appendix 1of BioSecure HACCP).Inspecting and cleaning machineryis more time and cost effective thanmanaging a new pest introduced toyour property.17 pag

HACCP) developed by Nursery and Garden Industry Australia (NGIA) to ensure good farm hygiene at all times. Don't put your livelihood at risk by neglecting nursery biosecurity. 1. Be aware of biosecurity threats Make sure you and your production nursery workers are familiar with the most important exotic production nursery pest threats. Conduct a

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