2454 final report.pdf - Agra CEAS Consulting

Evaluation of the Community Plant Health Regime: Final Report
DG SANCO Evaluation Framework Contract Lot 3 (Food Chain)
Indeed, this calls for a pest risk approach in some cases, while a pathway risk approach may
work better in others (as discussed above for plants for planting). Moreover, no specifically
defined measures are foreseen for HO listed in Annex I, as a consequence of which the security
level offered by listing high-risk pests in Annex I is relatively low.
HOs listed in Annex I are prohibited from entry into the EU and may also not move around the
EU in any form or on any host. However, for most of these pests there are no specific import or
movement requirements, whereas for HOs in Annex II there are specific import requirements.
For example, in the case of Rhynchophorus palmarum, this is listed under Annex I and therefore
subject to a blanket import ban, so there are actually no specific import requirements for this pest
and no testing on imports even from high risk origins; however, visual inspection on this HO is
not effective, as the weevil lives inside the trunk (and cutting into the palm is not considered to
be a viable option due to its destructive nature), raising the risk of a latent outbreak (latent
infections are in fact a general problem jeopardising the effectiveness of the CPHR). If the
general requirement is properly implemented, Annex I should provide a higher degree of
protection, but in case of incomplete implementation, this could potentially lead to greater risk.
In those cases where the HO is included in the list under Annex II (with specific hosts), more
specific requirements apply and therefore MS have the obligation to take measures. It is
therefore suggested that this may result in more effective protection 89 .
Some stakeholders perceive the Annexes to be too complex and advocate a simpler and more
readable list (i.e. a simple list supported by a searchable database with the requirements) in order
to improve ease of reference. Furthermore, they commented that it is preferable to specify the
host plant for the HO (i.e. the approach of Annex II); along the same lines it is suggested that for
TCs it would be simpler to list commodities and the HOs relevant for the commodities. It is also
suggested by stakeholders that classification for the purposes of protected zones (PZs) needs to
be reassessed (the argument being that PZs seem to be ineffective, and that different levels of
requirements within EU are questionable and should be assessed and removed, because they
increase the burden for operators; the effectiveness of PZs is discussed in section 3.6).
At the operational level (i.e. import controls, surveillance), although the general perception
amongst CAs is that the number of listed HOs is not an issue per se for inspections, at least for
import controls, it is noted that the declining staff resources available to CAs are a major
constraint and the expertise may be variable for the different HOs; also, the number of listed
HOs could pose problems for the diagnostics sector for individual MS and increases the need for
a collaborative approach. To address these issues a greater degree of prioritisation appears
therefore to be needed, and indeed has been advocated in some cases (by both CAs and
stakeholders).
In practice, some degree of focus of the plant health services on specific HOs is already taking
place. An analysis of the lists of HOs provided by MS CAs in response to Q2.2 of the general
survey indicated that NPPOs in the 27 MS currently focus ‗as a matter of priority‘ on a more
89 It is also suggested that the measures carry a cost (which potentially could be of benefit to other MS/the whole of
the EU) but only specific MS carry the costs. This suggests there may be disincentives or perverse incentives in the
current system.
Food Chain Evaluation Consortium 66