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)
chinensis. Another example in the potato sector is the Potato Leafroll Virus (PLRV). A 2007
paper by IUFRO 92 (2009) asks for a pathway approach to plants for planting (rather than the
current pest by pest control approach), similar to what is currently followed on wood packaging
material (WPM), on the basis that plants for planting have provided just as many introductions of
previously unknown forest pests as WPM 93 . In May 2006, the IPPC established an Expert
Working Group in this area (Specification No. 34: Pest risk management for plants for planting
in international trade). The risks of plants for planting and the need for a pathway approach have
also been addressed in the work of EPPO, as highlighted in a recent EPPO colloquium on the
subject in October 2009 94 . By analysing interception reports and recent pest introductions, the
EPPO showed that imports of ornamentals and woody plants in particular were risky pathways.
The question on the appropriate positioning of RNQPs is raised because in the EU, two sets of
legislation currently cover the range of regulated pests and some overlap may exist between
these: the Plant Health Directive 2000/29/EC and the Marketing Directives for Seeds and Plant
Propagating Material (S&PM) 95 . According to the above definition, Directive 2000/29/EC can be
seen as exclusively dealing with regulated quarantine pests (RQPs), on the basis of the current
principle that tolerance = zero; however, when the other above mentioned criteria are considered,
the Directive may also be dealing with some pests that could be defined as RNQPs. On the other
hand, on the basis that the current S&PM Directives regulate pests with tolerance ≥ zero 96 , also if
the other criteria are taken into account, the S&PM Directives could be seen as potentially
covering both RQPs and RNQPs. Indeed, as will be discussed below, there is considerable
confusion amongst MS and stakeholders over the scope of each set of legislation but also over
the definitions of an RQP versus an RNQP; furthermore, some, although relatively minor,
overlap in coverage of pests between the two sets of legislation currently exists.
It is also noted that the IPPC definition of RNQPs potentially raises a question on the difference
between RNQPs and ‗quality‘ pests and what could be the criteria for the classification or nonclassification
of a given organism in either of the two categories. Quality pests are not regulated
pests and are not covered by the RNQP concept but may also be responsible for unacceptable
economic impacts of ―a non-phytosanitary nature‖. They are however managed by farmers
themselves by application of crop rotation, use of plant protection products, etc.
92 ‖Recommendation of a Pathway Approach for Regulation of Plants for Planting‖: a Concept Paper from the
IUFRO Unit on Alien Invasive Species and International Trade.
93 References quoted are: Relevant ISPMs, regional certification schemes such as: NAPPO's Regional Standard for
Phytosanitary Measures (RSPM) No. 24 Integrated Pest Risk Management Measures for the Importation of Plants
for Planting into NAPPO Member Countries, EPPO Standards: PM4 certification schemes. Canadian Food
Inspection Agency‘s Policy Directive No. D-04-01, Canadian Nursery Certification Program (CNCP).
94 EPPO Council Colloquium (Angers, FR, 2009-09-24), ‗Increasing trade, changing climate, emerging pests: Is the
plant health sector prepared?‘ (http://archives.eppo.org/MEETINGS/2009_conferences/council_colloquium.htm)
95 http://ec.europa.eu/food/plant/propagation/index_en.htm
96 Under the S&PM Directives pests which are widely established (which therefore do not qualify as quarantine pests),
may be prohibited or only permitted within a certain tolerance on planting material such as certified seed potatoes,
seeds and certain ornamental, vegetable and fruit plants. For seeds it is specified that all pests, must be at the lowest
possible level. It is also possible under the requirements of the S&PM Marketing Directives that the marketing of a
plant variety can be prohibited on the grounds that cultivation could be harmful in relation to plant health, to the
cultivation of other varieties or species and there is an imminent danger of the spread of pests.
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