Risk Management Proposal  
 
Zoo Crocodilia and Zoo Crocodilia  
Hatching Eggs  
ZOOCROCS .SPE  
 
 
 
 
[Document Date]   
 
 
Disclaimer  
This risk management proposal does not constitute, and should not be regarded as, legal advice. While every 
effort has been made to ensure the information in this document is accurate, the Ministry for Primary Industries 
does not accept any responsibility or liability whatsoever for an y error of fact, omission, interpretation or opinion 
that may be present, however it may have occurred.  
© Crown Copyright - Ministry for Primary Industries  
 
 
 
 
 
 
 
 
 
 
 
 
 
Contact for further information : 
Ministry for Primary Industries (MPI )  
Regulation & Assurance Branch  
Animal Imports  
PO Box 2526  
Wellington 6140  
Email: animal.imports@mpi.govt.nz  
Telephone:  04 890 0134  
 Risk Management Proposal:  Zoo Crocodilia and Zoo Crocodilia Hatching Eggs  [Document Date ] 
Ministry for Primary Industries   Page 1 Contents  
1 Purpose  3 
2 Background  3 
3 Objective  3 
4 Options assessment  3 
5 Recommendations for identified risk organisms  4 
5.1 Edwardsiella tarda  4 
5.2 Amblyomma.spp  5 
5.3 Placobdelloides stellapapillosa  6 
 
 Risk Management Proposal:  Zoo Crocodilia and Zoo Crocodilia Hatching Eggs  [Document Date ] 
Ministry for Primary Industries   Page 3 1 Purpose   
The purpose of this document is to:  
 Show how options for the management of risk o rganisms have been assessed.  
 Provide recomme ndations for the import requirements.  
2 Background  
Crocodilians  and their hatching eggs a re considered risk commodities, with the potential to harbour exotic 
viral, bacterial and parasitic disease which could become established in New Zealand.  
In November 2007 , the Import Risk Analysis: Crocodilia and eggs of Crocodilia from Australia  was 
completed by the Ministry for Primary Industries (MP I).  
Subsequently the Import Health Standard s (IHSs)  for Zoo Crocodilia from Australia  and Zoo Crocodilia 
Hatching Eggs from Australia  were issued in 2008.  
The zoo industry has since requested  expansion of  eligibility to all freshwater and saltwater animal s in the 
order crocodilia from the European Union, Malaysia, Singapore, Indonesia, Thailand, Papua New Guinea 
and Australia as part of the zoo’s planned Southeast Asian development due to open in 2020.  
In response to the request, MPI developed the Import Risk Analysis : Crocodilia from Malaysia, Singapore, 
Indonesi a, Thailand, Papua New Guinea, northern Australia and the European Union  dated March 2019.   
This risk analysis considers the biosecurity risks associated with the importation of captive hatched and 
reared, saltwater and freshwater Crocodilia from the Europ ean Union (for the purposes of this document 
referred to as the European Zone), and Malaysia, Singapore, Indonesia, Thailand, Papua New Guinea 
and northern Australia (collectively referred to as the ‘Malaysian Zone’).  
This Risk Management Proposal (RMP)  has been written to accompany the upda ted Import Health 
Standard for Z oo Crocodiles  and Zoo Crocodile Hatching E ggs. 
3 Objective  
The objective is to manage, to an acceptable level, the biosecurity risks posed by the import of zoo 
crocodilia ns and their hatchin g eggs in to New Zealand .  
4 Options assessment  
Under Article 3.3 of the World Organisation for Animal Health (OIE) Agreement on the Application of 
Sanitary and Phytosanitary Measures (the SPS Agreement), risk management measures which provide a 
level of prot ection greater than provided by international standards may be imposed only when they can 
be scientifically justified on the basis of a risk assessment.  
For a detailed analysis of hazards and their risks please refer to the  following  supporting document s: 
IRA: Crocodilia from Malaysia, Singapore, Indonesia, Thailand, Pa pua New Guinea, northern Australia 
and the European Union  dated March 2019.  
IRA: Crocodilia and eggs of Crocodil ia from Australia  dated November 2007.  Risk Management Proposal:  Zoo Crocodilia and Zoo Crocodilia Hatching Eggs  [Document Date ] 
Ministry for Primary Industries   Page 4 From the  IRA (2019) , the following organisms were classified as hazards in the commodity and identified 
for risk management.   
 
 Edwar dsiella tarda  
 Amblyomma  spp. 
 Placob delloides stellapapillosa    
 
5 Recommendations for identified risk organisms  
The organisms that were considered as hazards are those that c ould be transmitted by crocodilia and that may 
infect domestic or feral /wild ani mals, or humans in New Z ealand or establish in the environment.  
The following organisms  were considered hazards in the commodity will be considered in this RMP.  
5.1 Edwardsiella tarda  
Edwardsiella tarda  is not included on the OIE -listed diseases, infections and infestations in force in 2018.  
Edwardsiella tarda  is not on the unwanted organism list.  
5.1.1 Risk management  presented in the 2008 IHS for Z oo Crocodilia from Australia  
(1) The Crocodilia to be imported are:  
a) born and reared in an environment with good quality water from a supply not inhabited by fish (either 
potable water or water from a bore) and have never been fed on fish or been exposed to live fish; 
OR  
b) during the pre -export isolation period samples from both gular and paracloacal glands were collected 
from each animal and these samples have been cultured fo r Edwardsiella tarda with negative 
results;   
AND 
c) during the pre -export isolation period faecal samples were collected from each animal on two 
separate occasions, at least 14 days apart, and these samples have been cultured for Edwardsiella 
tarda  with negative results.  
5.1.2 Risk manageme nt options presented in the 2019  IRA 
(1) There is a moderate risk from Edwardsiella  tarda in the commodity and potential risk mitigation measures 
are described for crocodilians imported from the Malaysian Zone.  
(2) The risk co uld be reduced by:  
a) Maintaining crocodilia within the temperature range of 24 -28 degrees Celsius ; 
 AND/OR  
b) Crocodilia should have been reared in an environment with good quality water from a supply not 
inhabited by fish (either potable water or water from a bore) and have not been fed on fish or been 
exposed to live fish;  
AND/OR  
c) Samples from both gular and paracloacal glands should be cultured for Edwardsiella  tarda  with 
negative results ; AND 
d) Faecal samples collected on two separate occasions and cultured f or Edwardsiella  tarda  with 
negative result.  
  Risk Management Proposal:  Zoo Crocodilia and Zoo Crocodilia Hatching Eggs  [Document Date ] 
Ministry for Primary Industries   Page 5 5.1.3 Discussion 2019  
(1) Edwardsiella  tarda  are ubiquitous bacteria which have been  reported to be present in the normal intestinal 
flora of wild and captive aquatic animals including crocodiles . Edwardsiella  tarda  is distributed globally, but 
is not recognised as present in New Zealand.  
(2) It is likely that conditions of stress, which lead to immuno suppression , lead to clinical disease . 
(3) The IRA suggests  that Edwardsiella  tarda  may be present in the environment and may  lead to high 
bacterial numbers and subsequent disease if condition s such as water temperature , water flow rate , and 
water pollution  provide optimal conditions for the bacteria.  Outbreaks of disease can be controlled by 
improving hygiene, water quality and  reducing stocking densities.  
(4) There is no evidence that Edwardsiella  tarda  is able to be transmitted through crocodile eggs.  
(5) The IRA determined there is no risk to human health from Edwardsiella  tarda  carried by c rocodilia ns due 
to the remote risk of human exposure and the simple measures that can be implemented to mitigate risks  
for carers and handlers.  
(6) The below  recommendations  acknowledge  that the risk posed by the importation of a small number of 
crocodiles  into con tainment  is very low . MPI’s Impor t Risk Analysis: Ornamental Fish  concluded that it 
would be time consuming, expensive and unjustified to put in place measures  for Edwardsiella  tarda  in 
animals showing no clinical signs of disease during a quarantine period , and recommend ed testing  be 
conducted  only for those fish that show signs of disease during the quarantine  period .  
(7) Given the above, t he below recommendations are considered appropriate risk mitigation measures for 
Edwardsiella  tarda . 
5.1.4 Recommendations  2019  
(1) The recommendation is t hat the animals are healthy,  and originate from p remises that are under regular  
veterinary supervision; and follow a health monitoring programme including necropsies, and 
microbiological and parasitology testing . 
(2) Each crocodilian  to be imported must be certified as originating from a captive  population in which no 
isolation of Edwardsiella  tarda have  occurred.  
(3) Each crocodilian  to be imported must be  certified free from clinical evidence of infectious disease, external 
parasites, plant and seed contam ination, and appear  to be fit for travel . 
(4) On arrival , crocodilians must remain in post arrival quarantine for a period of at least 30 days. During this 
time the crocodilians must be inspected weekly and subjected to MPI approved testing for Edwardsiella  
tarda if displaying clinical signs .  
(5) The draft has been amended to reflect this.  
5.2 Amblyomma.spp  
Amblyomma spp . are blood su cking i xodid ticks with some species acting  as vectors of diseases such as Rocky 
Mountain spotted fever and ehrlichiosis.       
Amblyomma  spp. are not included in the OIE -listed diseases, infections and infestations in 2018.  
Amblyomma  spp. are listed on the unwanted organisms register.  
The only tick of this species found in New Zealand is the endemic Amblyomma sphenodonti  on tuatara.  
5.2.1 Risk management from the 2008 Import Health Standard for Zoo Crocodilia from Australia  
(1) None apart from the requirement that d uring transport to the port of departure and during transit to New 
Zealand, all feed provided is free from evidence of contamination with ticks and weeds/weed seeds.  Risk Management Proposal:  Zoo Crocodilia and Zoo Crocodilia Hatching Eggs  [Document Date ] 
Ministry for Primary Industries   Page 6 5.2.2 Risk management options presented in the 2019 IRA  
(1) Risk mitigation measures could include a combination of pre -export quarantine in a tick -free environment 
and the application of topical permethrin -based ectoparasiticide tre atment.  
(2) The above risk mitigation measures relate only to crocodilia imported from the Malaysian Zone . 
5.2.3 Discussion 2019  
(1) Amblyomma spp ticks vary in their host specificity and tick parasitism on crocodiles is  extremely  rare. 
There is only one published recor d of Amblyomma on a crocodilian and the author of the study suggests 
that the local monitor lizard population served as the preferred host and transfer was accidental.  
(2) Hard ticks do not occur on wholly aquatic vertebrates and thus any infestation must occur during terrestrial 
emergence of the crocodile.  
(3) The i mportation of a few c rocodilia into a containment facility is not considered to be relevant from a 
biosecurity point of view.   
(4) However , in line with other zoo standards , each crocodilia n should be i nspected for ectoparasites 
including ticks prior to export . 
5.2.4 Recommendation  
(1) The recommendation is that all crocodilia must undergo an inspection for ectoparasites prior to export.  
(2) Additionally  and in line with other zoo standards , during transport to the p ort of departure and during 
transit to New Zealand, all feed and  bedding provided must be certified  free from evid ence of 
contamination with ectoparasites.  
5.3 Placob delloides stellapapillosa  
Placob delloides stellapapillosa  is a predacious and facultative sanguivorous leech that parasitises on a variety of 
vertebrates and invertebrate hosts . 
Leeches have been identified as vectors of some haemoparasites in crocodilians including haemogregarines and 
trypanosomes, however in reptiles these haemoparasites have  been found to be non -pathogenic and therefore 
the risk analysis concluded that the vector potential of Placob delloides stellapapillosa  is considered negligible . 
Placob delloides stellapapillosa  has been reported attached to crocodilians in the Malaysian Zo ne. 
The host range of the leech is unknown and the risk assessment concluded that there is a moderate 
consequence assessment for its potential to establish and parasitize other organisms living in and around New 
Zealand waters.  
These organisms are not incl uded in the OIE -listed diseases, infections and infestations in force in 2018.  
5.3.1 Risk management from the 2 008 Import Health Standard for Z oo Crocodilia from Australia  
(1) None  
5.3.2 Risk management options presented in the 2019 IRA  
(1) Risk mitigation measures could include a combination of pre -export quarantine in a leech -free 
environment and the topical app lication of vinegar and alcohol.  
(2) The above risk mitigation measures relate  only to crocodilia imported fro m the Malaysian Zone  Risk Management Proposal:  Zoo Crocodilia and Zoo Crocodilia Hatching Eggs  [Document Date ] 
Ministry for Primary Industries   Page 7 5.3.3 Discussion 2019  
(1) The importation of a few crocodilia into a containment facility is not considered a releva nt pathway fro m a 
biosecurity point of view.  
(2) However , in line with other zoo standards,  each crocodilia n should be inspected for ectoparasites 
including leeches prior to export . 
5.3.4 Recommendation  
(1) The recommendation is that all crocodilia must undergo a thorough  inspection for ectoparasites , including 
leeches  prior to export.  
(2) Additionally  and in line with other zoo standards, during transport to the port of departure and during 
trans it to New Zealand, all feed and  bedding provided must be certified  free from evidence of 
contamination with ectoparasites.