Biosecurity Amendment Bill

Hon GERRY BROWNLEE (Acting Minister for Biosecurity) Link to this

I move, That the Biosecurity Amendment Bill be now read a second time. The bill was referred to the Primary Production Committee in early September, and although no public submissions were received by the closing date of 22 September, the committee has done a thorough job in examining whether the bill will achieve its purpose, and has recommended it should be passed with some amendments.

Before I outline those amendments to the House, the Hon David Carter, the Minister for Biosecurity, wished to thank the committee for its work. The committee’s meetings have been notable for the sense of common purpose with which members from both sides of the House have come together to review this bill. The Minister appreciates their involvement, including that of the Green Party, which attended the committee meetings in a non-voting capacity. Every member of the committee shared the main aim of ensuring that our biosecurity systems are soundly based and deliver a high level of protection to this country. That protection goes beyond recognising the importance of agriculture to our economy. Improving biosecurity protection also safeguards our health—the health of human beings and the unique plants and animals that feature in New Zealand’s environment.

In fact, the committee’s concern about ensuring high levels of biosecurity protection extended beyond the measures outlined in this bill. In its commentary as reported to the House, the committee has noted that more needs to be done to manage biosecurity at international airports. I agree. The scope of this bill affects only a small and very specific part of biosecurity law. Let me make it clear that this short bill is about increasing the penalties for international passengers who offend against the law, either by mistake or by carelessness, when they are asked to declare whether they are carrying any risky items such as food. As the Minister for Biosecurity stated to the House during the first reading of this bill, it is only one part of a package of measures to improve biosecurity at the border. Many of the changes under way are operational issues, so they do not need any law change to make them happen.

It might be helpful for the House if I briefly go over that ground again. The Government has consistently stressed a need for the Public Service to constantly re-evaluate the way it does things, and to be innovative in improving the quality of its services. In biosecurity, as in so many other areas, it makes sense to focus effort in the areas where risk is higher. This bill will support moves to improve our handling of the risks posed by international travellers coming to this country.

In the future, arriving passengers will be profiled, and our efforts will be directed primarily at those who are considered to be high risk. Low-risk passengers will be allowed to pass through with less scrutiny, but they will still receive attention and will be subject to the higher penalties that this bill enables. The better targeting of biosecurity risk at the borders is not just about risk-profiling work; it includes a whole package of measures, including better targeting of, and translated, publicity material, and closer cooperation between border agencies both in New Zealand and Australia, including information sharing between our two countries.

There is no doubt that the great majority of international travellers are happy to comply with the law once they are properly informed. Targeting communications to specific groups of people will help that message get through in the most effective way. We will make travel much less restrictive for low-risk trans-Tasman passengers who comply, but those people who fail to comply with the requirements will be hit with the stick of higher penalties.

The committee has been rigorous in examining this bill and the range of improvements to biosecurity risk targeting that lie behind it. I am pleased to note that there was no objection to increasing the penalties for travellers who carelessly make an incorrect declaration about some of the goods that they are carrying. In fact, the committee felt that the bill did not go far enough. In its original form, the bill would have increased the maximum penalty on court conviction for this offence from $400 to $800, but the committee felt that a higher penalty was called for, and recommended that the upper limit be raised to $1,000 to more accurately reflect the serious harm that could be done to our economy, environment, or human health as a result of biosecurity breaches. I am sure that figure will ratchet up over the years, as there is a need to ensure that court fines keep pace with rising costs, and, therefore, the pernicious aspect of the penalty on those who choose to offend will also rise.

The committee also carefully examined a number of other points in the bill. As originally drafted, the bill was to take effect through a separate Order in Council. It was drafted in that way because the bill moves the existing infringement offence out of the Biosecurity Act into regulations. That means supporting regulations must come into force at the same time as the amendments are made to the Act, otherwise there would be a gap after the infringement scheme had been removed and before it was re-enacted by the new regulations.

When the bill was passed by the Regulations Review Committee, the committee recommended fixed commencement dates. As a result, the bill has been reported back to the House with amendments so that it will come into force no later than 12 months after the Royal assent. It can still be brought into force earlier, through an Order in Council, if all operational details such as printing and distributing the new infringement forms and pre-printed publicity material are ready to go before the 12 months are up.

The committee has also recommended a change to the wording of one clause in the bill for the sake of clarity. Clause 8 is about setting the regulations I have already referred to. At present, two offences under the Act may be dealt with by issuing an infringement fee or instant fine. When passed, the bill will make it possible to extend the scope of the infringement scheme to apply to other offences. The committee has recommended a change to the wording to clarify that the infringement scheme can be applied only to offences already set out in the Act, just in case someone was under the impression that entirely new offences could be created arbitrarily, without the scrutiny of Parliament. I think that is a sensible move, although I would say that, quite without the scrutiny of Parliament, there are any number of people who wish ill in this regard who are quite capable of devising new offences themselves.

In any event, I thank the Primary Production Committee on behalf of the Minister for Biosecurity, and I thank the Regulations Review Committee for its work. I am confident that the bill being reported back to the House is stronger for the committees’ considerations.

Hon DAMIEN O’CONNOR (Labour) Link to this

The Labour Opposition will be supporting the Biosecurity Amendment Bill. It is, as the Minister Gerry Brownlee says, one more step in trying to uphold the highest standards of biosecurity for people and goods coming into this country. It is, in fact, a bigger stick to wave around at the people who come across our borders. The Primary Production Committee, in its wisdom, has endorsed that. In fact, it made a move in the direction of increasing the size of the stick by saying that the maximum penalty could be up to $1,000, whereas the bill originally recommended $800. That acknowledges the importance of the issue.

However, I put on the record that the Government’s making this change at the same time as it is cutting the biosecurity budget raises concerns for the Opposition. It is important that we uphold the highest standards. It is important that we indicate to people who knowingly or unknowingly bring into this country unwanted goods or organisms that they will be penalised, and that that penalty is appropriate. It is important that we make sure we give the appropriate warnings to those people; the bill has been amended to make sure that we can print the correct material in order to align it with the incoming regulations and the enforcement of the Act. That is great; again, that was due to the wisdom of the select committee. But we have to make sure that we warn people in a way that is clear and that can be understood. I put on record the fact that many of the forms are confusing for people coming into New Zealand, particularly those for whom English is a second language. So in supporting the passage through the House of this bill, which is a larger stick, I say there is an obligation on the Government to make sure that the information supplied to people before they hop on the plane, while they are on the plane, and before they pass through our borders is clearly understood, and that they understand they will be caught, prosecuted, and fined for bringing into this country illegal or unwanted goods and organisms.

Many of those organisms threaten our biological economy. I read a statement from Federated Farmers that pointed out that, should foot-and-mouth disease ever come into this country, it would cost our economy $6 billion in the first year. Those potential harms to our economy are significant. That is why we have to have legislation like this.

I refer the House again to the collective wisdom of the select committee, Government members included. It said in the report back in this bill that there is some concern, as the committee remains unconvinced that sufficient work is being done in regard to biosecurity risk profiling at airports. The Prime Minister’s enthusiasm as Minister of Tourism has to be welcomed for encouraging as many Australians into New Zealand as possible, but in lowering the barriers we cannot risk compromising our biosecurity status. The select committee pointed to problems that still have to be resolved prior to implementing the changes allowing easier passage for Australians into this country.

Labour supports the bill. We urge all Government members to read the report back from the select committee. We expect the Government to get on and address the points raised by the committee.

SHANE ARDERN (National—Taranaki - King Country) Link to this

The Government enthusiastically supports the passage of the Biosecurity Amendment Bill. There was a lot of discussion about it in the Primary Production Committee, as the previous two speakers have alluded to. The issue that was of concern to the select committee was that in the interests of streamlining our borders with Australia, in particular, but also of streamlining our borders full stop, there is an element of risk. It is always a debating point about how much risk is too much and how much is not enough. The debate on that point took place with some enthusiasm, and the issues that concerned the committee that are still unresolved are those regarding the digital transfer of images from Australia to New Zealand.

The proposal under this bill is that in streamlining the processing of a business person who flies from Australia, say from Sydney, to Auckland in the morning and then flies back in the afternoon, carrying nothing more than a briefcase, that traveller should be exposed to exactly the same X-ray scrutiny as someone who is travelling from further afield or who had been away from home for longer. The rationale is that that person could have an apple in his or her briefcase that carries fruit fly or the like, which could have a devastating effect on New Zealand. The proposal is, of course, that his or her briefcase will be X-rayed in Australia, and the image will be transferred to New Zealand for investigation, for inspection, prior to the traveller arriving in New Zealand. That sounds as though it is perfectly rational, with modern technology. But there are some property rights issues about who owns that image, and whether our biosecurity personnel and customs personnel will have access to it. Those issues have to be resolved.

The moving of the regulatory powers with regard to penalties from the legislation to regulations seems very sensible, in the sense that we do not know until we have tried using a penalty whether it has the desired effect. Our instant fine until now has been $200. Most people will acknowledge the comments made by the previous speaker, Damien O’Connor, that the potential risk to our biodiversity and our economy through something like fruit fly or foot-and-mouth disease are not worth contemplating, in the sense that it would bring New Zealand’s economy back to Third World status in a very short time. So at one level we have to be very vigilant about how we handle these things, and at another level we have to be practical about ensuring the free flow of people in and out of our country. Clearly a $200 fine has not been a strong-enough deterrent. When we look at the extent of biosecurity incursions over the last few years, we see that, in fact, in a year 8 tonnes of meat—a big truckload—was intercepted at our borders, either in people’s personal hand luggage or on their person. That was 8 tonnes of meat!

We have to ask these questions: how would foot-and-mouth get into New Zealand, and how much risk should we take? We know that people tried to import that meat into New Zealand illegally, because we intercepted it. That means that our biosecurity staff are doing a superb job, and they deserve a bouquet for that. But we also know, because of their own research, that as much as 10 percent of illegal imports get through. Allowing that level of risk can only be described as creating the potential for there to be a devastating effect on our economy. We are looking very closely at what can be done to enhance our surveillance—at the amount that gets through and the amount that does not get through—and at the penalties that we should put in place to prevent illegal imports from happening or to deter people from trying to make them.

The issues around the $200 instant fine have been well debated. There was some argument—and probably with some credibility; it is very hard to say, but we will know over time—about whether, if the fine is increased to $400 or to a higher amount, people would then make the call to pay the instant fine on the spot or would decide to take it to the next level. People are allowed 14 days in which to pay the instant fine, and if they do not, they go though a court process. The argument put up against imposing too high an instant fine is that too many people will take matters to the next level, and at that point it would become a huge cost not only to the State but also to the court system—that it would become a fairly complicated process. It was argued that despite the fact that people could potentially end up with a criminal record, they would still argue the toss, particularly over what could be described as a minor offence, like having an apple in a briefcase, which could bring in fruit fly, and take it to the next level. So the committee looked at whether the earliest penalty, or the minimum penalty, that could be imposed at the border was high enough. At $800 it decided no, and that the amount should be lifted to $1,000 in order to act as a greater deterrent.

I am pleased to say that the Government has accepted those recommendations. There was a unanimous vote in the select committee, and that was almost the case in the House, I hasten to add, which is an unusual set of circumstances in the parliamentary process. Clearly, the bill has the will of the majority, and I look forward to its passage.

SU’A WILLIAM SIO (Labour—Māngere) Link to this

Thank you, Mr Chairman, for the opportunity to speak and make a contribution on the Biosecurity Amendment Bill. When I listened to the speech of the chairman of the Primary Production Committee, Shane Ardern, I got a sense that this bill does not convey what he was trying to convey in his speech. He was trying to convey the sense that the Government was doing something, but the reality is that I do not get that sense at all. There was a lack of ambition in the rhetoric that we just heard. When we look at the bill, we see that it only talks about increasing the penalty from $400 to $1,000 for the poor soul who comes through our borders, who perhaps may speak a different language and not be able to fully understand English. That is what this bill is about. It is a shame that although he talked about what we could have done as a country, that is not what the bill does.

As the member for Māngere, where Auckland Airport is located—we call that place the gateway to New Zealand, the gateway where New Zealand touches the rest of the world—I know that biosecurity is important to the constituents there. It is about protecting our borders and being able to ensure that our economy, our environment, and human health get the best resources in order to ensure that they are protected. I follow my colleague the Hon Damien O’Conner in saying that Labour supports this bill. It is not the kind of work we ought to be doing in order to secure our borders. The sad thing is—

KEVIN HAGUE (Green) Link to this

The Green Party supported the Biosecurity Amendment Bill in its first reading and will continue to support it in its second reading.

Biosecurity seems to have four different phases. One is prevention of biosecurity risks occurring in the first place; the second is detection of those risks, typically at or around the border; the third is stamping out incursions where they have got through our detection process; and the fourth is mitigation, where the incursion cannot be stamped out and we are, instead, looking to ameliorate the worst effects. It is obvious that, just as in my field of health, where we look at exactly those same phases in trying to intervene in a person’s disease progression, our emphasis must be on the first phase—on prevention. So we do everything that we can to prevent the biosecurity risk in the first place; if that fails, we then throw as much resource as we possibly can into the detection process.

This bill deals largely with the detection process, but the Government believes that the increased fines that the bill provides are an important element in the prevention process. It is really those first two phases of the biosecurity process that I want to focus on tonight.

In relation to prevention of biosecurity risks, I begin by giving praise to MAF Biosecurity. I had the privilege of being able to join the Primary Production Committee—and I thank Shane Ardern and the members of the committee for the opportunity to do so—during the consideration of this bill. During that time we heard from MAF Biosecurity about the processes it uses to educate travellers about biosecurity risks. I was impressed by the lengths to which MAF Biosecurity is going in that regard.

Travellers coming into the country are just one aspect of the biosecurity risk that we face. There is a very much larger risk that we face around goods and freight coming into the country through shipping containers and shipping holds. It is much more difficult to prevent biosecurity risks in that regard, because many of the operators have commercial incentives to skimp on the processes that might be used to reduce or eliminate biosecurity risks to this country.

I point out the unnecessary risk we often pose to ourselves by our needless importation of goods into this country. I have spoken in the House several times about our importation of palm kernel. It is a classic example of a product that we have absolutely no need to import into New Zealand. The biosecurity risks that we import with that product are substantial. I have spoken in the House, as has Damien O’Connor, about the risks in relation to insect infestations of palm kernel shipments that arrive here. I have also spoken about the risk of foot-and-mouth disease from palm kernel. We are importing this stuff from a region of the world where foot-and-mouth disease is endemic. The stuff is coming into the country and being fed out, and farmers are reporting soil contamination. That soil contamination can occur only after the point in the process where the palm kernel is exposed to heat. In other words, the contamination is occurring after the only process that might have done something about foot-and-mouth disease. We know that foot-and-mouth disease is viable in soil and water for extended periods of time. This is a massive risk that we are taking, and we are taking it entirely needlessly.

This is the kind of madness that can result in particular from free-trade agreements. I raise the topic because it is timely. We have just signed another free-trade agreement, with Malaysia, which is, incidentally, a country in which foot-and-mouth disease is endemic. Free-trade agreements encourage the import of goods to contribute to a consumption-led economy, the very kind of economy we do not need; the kneecapping of local industries—in the case of palm kernel, the grain farmers of New Zealand, who are suffering very badly as a result of this trade—and the taking of entirely unnecessary biosecurity risks. In the prevention phase there is a whole bunch of risks that we are taking that we do not need to take.

In relation to detection, these increased fines are effectively a trade-off that the Minister for Biosecurity proposes. They are proposed as a disincentive for travellers to bring in with them biosecurity risks, on the basis that travellers will pay closer attention to their luggage and weed out those risks. We are making this trade-off because the Prime Minister wants the travelling time from Australia to New Zealand to be 8 minutes shorter. The goal is the saving of 8 minutes on a trip of multiple hours. For that, we are sacrificing our approach of universal screening to one that is based on risk profiling.

I want to raise in the House some figures that the Primary Production Committee heard from MAF Biosecurity about that issue. I hesitate before doing so to point out that the select committee itself, as Shane Ardern has noted, and I thank him for that, has indicated to this House that it is not convinced by the risk-profiling approach. More work needs to be done on that and the select committee is absolutely right. MAF Biosecurity found in its trial of the risk-profiling approach that those passengers who were deemed to be low risk and went through the low-risk trial lane nonetheless yielded some 51 items of biosecurity risk. So out of the 1,186 seizures of biosecurity risks, most of them were from passengers deemed high risk, but 51 came from passengers deemed low risk. If we screened only those passengers deemed to be high risk, those 51 risk items would have entered New Zealand. Of those 51 items—I will not run through the whole analysis—some 17 of them, for example, were fruit fly host material. Well, I have spoken in the House before, in my first reading speech, about the catastrophic impact of a fruit fly infestation in the Bay of Plenty in just the first year.

Another 18 of those 51 risks were around footwear that had not been properly cleaned. What is the risk around improperly cleaned footwear? Well, it is the importation of soil, which can contain pathogens. I have spoken about the risk of foot-and-mouth disease from soil, but also in the news in this last week or so I have talked about the risk to our iconic kauri species from another soil-based pathogen.

These are risks that the Government proposes to take in return for saving 8 minutes. I have spoken in the public domain in the last week about the Government being asleep at the wheel on biosecurity. The Minister for Biosecurity has accused me of being alarmist. Well, I am alarmed. I am alarmed at the risk, and so should this House be and all New Zealanders. This is a massive risk; we do not need to take it. The Green Party will support the bill.

COLIN KING (National—Kaikōura) Link to this

It is a pleasure to be speaking in the second reading debate on the Biosecurity Amendment Bill. I would like to start by saying that it is a bit rich when the Opposition talks about the Government sitting on its hands and cutting the budget, when over the 9 years that members opposite were in Government there were 333 incursions. We had the painted apple moth, didymo, the varroa bee mite, and Didendum, to name a few. To be honest, if we were going to get foot-and-mouth disease, we would have got it under that Labour Government. If we were going to get bovine spongiform encephalopathy, we would have got it under that Government. It is a bit rich, and probably an indication that Labour members are out of touch with the farming community, when the backbenchers parrot away about things they do not know much about. They just read off a sheet of paper, with no real passion or anything like that.

I tell the shadow spokesperson for agriculture and biosecurity that it was very interesting to research the reduction in the biosecurity budget. It actually related to two particular programmes of eradication. One programme, which related to the red fire ant from the Whirinaki area, has come to an end. It has been declared successful as of 4 p.m. on Wednesday, 22 April 2009. The second programme is close to eradicating the southern salt marsh mosquito, which was found in a number of salt marshes around New Zealand, but is holding on in one area, down in Marlborough at the mouth of the Wairau. The outcome is looking very good, but the programme will carry on for another 12 months when traps will be checked to make sure that that mosquito is eradicated.

I congratulate Biosecurity New Zealand. Those two eradication programmes and costs within the budget are no longer required. I put that on the record so that the erroneous comments on the other side of the House are put into context. They were two individual programmes that have been successful, unlike a lot of the failures made by members opposite when in Government.

We stop and think about the varroa bee mite when we look at the second reading of the Biosecurity Amendment Bill. Procrastination by the previous Labour Government allowed the varroa bee mite to get down in the South Island, and there was no coordination whatever under that Government. We can see why those members are in Opposition, which is where they should be.

But back to the bill. It is always good to see the Primary Production Committee working collegially. There are a couple of things that the two main parties in this country do agree on; one is trade and the other is biosecurity. It is on record now that we want to see a lot more rigour in resolving the tension that exists between tourism and our primary sector export industries.

When we look at the issue in context we see that New Zealanders and Australians do very well. They are the lowest offenders. But 4,700 infringement notices were handed out, which makes this bill very, very relevant. Of those notices, 1,361 were given to New Zealanders. It is important that we toughen up the procedures. Giving people 14 days’ leeway to pay their $400 instant fine is very reasonable. The select committee was informed that setting a fine at $200 led to a compliance percent rate in the high 90s. However, if memory serves me correctly, a person who featured on Border Patrol the other night held out for the maximum number of days before paying the fine. That is why the select committee was of the view that a $1,000 fine was quite reasonable and appropriate. That is not the whole cost—there are court and conviction costs—so the $1,000 figure needs to be seen in that light.

Let us look at the cost of some of the incursions that have happened. Didymo is projected to cost this country $285 million, and the varroa bee mite, which has decimated clover legumes in the South Island, is projected to cost $300 million. In the long term, those costs affect our pastoral industries.

This bill is particularly tight and is targeted at ports and points of first arrival—ports being both airports and seaports such as those in Auckland where international cruise liners come in. We can never understate the importance of this issue. Although I become agitated at some of the piousness and self-righteousness that emanates from the other side of the House, we cannot let our guard down. Thousands upon thousands of farmers risk incredible amounts of investment. To ensure that the Government does its bit, we must reinforce our biosecurity laws. I have great pleasure in recommending this bill to the House.

DAVID SHEARER (Labour—Mt Albert) Link to this

As other speakers have said, Labour supports the second reading of the Biosecurity Amendment Bill. First of all, I will comment on the reference by the previous speaker, Colin King, to, I assume, Su’a William Sio. Mr King criticised him for being a backbencher and not a farmer, and therefore for supposedly knowing nothing about biosecurity. That is a bit like saying one needs to be a tree in order to understand forests. Su’a William Sio’s point was that he was passionate about biosecurity, and that he lived in an electorate that was the gateway to Auckland. As a result of that, he said this bill did not go far enough and he wanted it to go further. I totally agree with him on those points.

This bill, as has been mentioned by a number of speakers, increases the maximum fine. I think that will serve as a deterrent against people bringing in goods that could risk New Zealand’s biosecurity. But I think there is a point at which a deterrent could actually become a liability in terms of its transaction costs, as Shane Ardern mentioned. I agree with him on that. I think, to the credit of the Primary Production Committee, that it has got the balance pretty much right in this bill. All the changes to the bill make good sense.

I will reinforce another of the points that Su’a William Sio mentioned, as well: the point about language. We have people from about 180 ethnic groups coming into the Auckland region, and obviously speaking many, many different languages. We need to get across to those people the biosecurity protection rules and deterrents, and in order to communicate with them it is very important to write as clearly and as simply as possible, and in a language that they can understand. It is all very well fining them and deterring them afterwards, but if they did not understand the rules when they first came in, then it is somewhat too late to fine them for breaching the rules.

Labour believes that having an effective biosecurity regime is vital in order to protect New Zealand’s interests. But obviously, that is not just about increasing the fines and penalties. As my colleague Damien O’Connor mentioned, the Government, at the same time as it is trying to increase biosecurity by increasing the penalties for biosecurity breaches, is also cutting $2 million from the biosecurity budget and cutting 56 front-line jobs. That seems to me to be a backwards step. I think that the whole point of the discussion about the front line, which comes through in our discussions on the police, the public health system, or on whatever else it may be, is an important one. But although the Government says it is supports front-line jobs and is cutting administrative staff, the cutting of administrative staff means that front-line staff will have to do administrative work. That defeats the purpose of the goals of biosecurity, law and order, etc.

I remember living out in west Auckland, so I remind the House of the plague of the painted apple moth when it came into New Zealand, probably by means of a container imported from Australia, and of the millions of dollars that we had to spend on aerial spraying in order to get rid of that pest. It is much better to have a policy of deterrence, as the Green Party was mentioning, than to try to pick up the pieces and repair the damage later on.

I do not want to talk any further on this bill. We have broad agreement on it in the House. I think the bill is incredibly important for the New Zealand economy. The Reserve Bank mentioned, for example, that an outbreak of foot-and-mouth disease in New Zealand—and Kevin Hague also mentioned this—would be devastating. The bank put the cost of an outbreak at about $10 billion. That would be a devastating loss for New Zealand. Mr Hague also mentioned the palm kernel imports, which this Government continues to allow into the country even though at least 50 known pests are associated with that product. It would be a smart idea not to bring palm kernel in as a food for livestock, and instead to use the alternative foods that we have here in New Zealand. That would be good for the economy and good for biosecurity, as well. I will stop there, but once again I commend the select committee for coming to an agreement on this bill, and I also commend our front-line biosecurity staff—those who are left—for their efforts to defend New Zealand’s best interests. Thank you.

SANDRA GOUDIE (National—Coromandel) Link to this

I am delighted to speak to the Biosecurity Amendment Bill. It is fantastic that we are actually moving pretty quickly to raise the fines for people who bring in any foreign goods or food goods into New Zealand, and who cross our borders with items they should not have on their person or in their baggage. I think the bill is fantastic. In actual fact I am probably more of the tendency to put up those fines even further. I think it is fantastic that we are now getting through this process.

This legislation cannot come soon enough. The sooner we enact this bill and start imposing realistic fines on people for bringing unwanted goods into our country and threatening our biosecurity, the better. I think that the select committee has done a great job across the House to progress this bill, and I say “Well done!” to everybody. The legislation cannot come soon enough. Let us hit offenders in the pockets so that they know they cannot keep contravening our biosecurity rules.