Risk Management in Aquaculture

Risk management is the process of identifying, selecting and implementing measures that can be applied to reduce the level of risk. In the risk evaluation step of pathogen risk management, the unmitigated risk estimate for the hazard is compared with the level of risk acceptable to the importing country (based on the national appropriate level of protection (ALOP)). If the ALOP is met, the importation can be approved without further action. However, if the risk posed by the commodity exceeds that specified by the ALOP, then risk mitigation measures should be considered.       During option evaluation possible measures to reduce the risk posed by the hazard are identified and evaluated for efficacy and feasibility, and the least restrictive measure(s) found to reduce the risk to an acceptable level are selected. The process is essentially the same at that used during risk assessment, with new scenarios and pathways being constructed that incorporate steps for possible risk mitigation measures to determine their ability to reduce the overall risk (now the mitigated risk estimate) to an acceptable level.

   Once effective risk mitigation measures have been identified, the next phase is implementation, monitoring and review. In this phase, the requirements for importation, including any mitigation measures, are presented to the Competent Authority of the exporting country (and the proponent) and the importation process is monitored and reviewed by the importing country’s Competent Authority to assure that all conditions for importation are met. 

   Several important principles of the SPS Agreement related to the risk management process should be kept in mind:

• Least restrictiveness – Risk management measures must be applied in the least trade restrictive manner possible. Thus if there are several risk management options that will allow the proponent to meet the importing country’s ALOP, the proponent should be able to choose the least burdensome (least trade restrictive) method.
• Equivalence of mitigation measures –The concept of equivalence allows the exporting country the opportunity to prove that its own risk mitigation measures lower the risk to within the importing country’s ALOP.
• Consistency in application – The importing country must apply the same ALOP (i.e. accept the same level of risk) at both external (international) and internal (national) borders; and the ALOP must be applied consistently across the range of commodities in which the country trades, without prejudice as to the country of origin.

   Typically, there are a wide variety of risk mitigation measures that are potentially available to be use singly or in combination. For import risk analysis, for example, these include health certification, quarantine (at various levels of stringency), inspection, diagnostics testing, vaccination, prophylactic treatments, use of alternate sources (e.g. specific pathogen free stocks, hatchery stocks of known health status), use of different life cycle stages (e.g. eggs rather than juveniles or adults), contingency planning, etc. (some of these are discussed in more detail in Trade and Governance Sections). It is important to note that the specific risk mitigation measures will vary on a case by case  basis depending on wide variety commodity-related factors. In some cases, the proponents may be able to suggest less onerous or costly measures that achieve the same results; in other cases, risk mitigation measures may be available but too burdensome to be practical; while in others, a detailed analysis may reveal that no effective risk mitigation is possible.    

   Pathways analysis and scenario diagrams can be used to gauge the effectiveness of a risk mitigation measure or combinations of measures, in lowering risk. Each measure can be incorporated into the pathway analysis, and the overall risk recalculated to see if the risk has been reduced to an acceptable level. Pathway analysis also allows for sensitivity analysis; that is, it allows for identifying those pathway steps that most influence the final risk estimation for a particular pathogen. This can help in targeting risk mitigation measures, as well as in identifying those areas where information needs are most critical, if highly sensitive pathway steps are associated with a degree of uncertainty or subjectivity.

   In some risk analysis sectors (e.g. human health and food safety), it is considered important or essential that the agencies responsible for risk assessment and implementation of risk management be autonomous.