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)
The general concept of the PP system is considered useful and well defined, but its
implementation is questioned by most MS CAs. The main criticisms have been that the system
has not prevented the spread of some HOs e.g. Phytophthora ramorum, Dryocosmus kuriphilus
or Rhynchophorus ferrugineus, to which PPs apply, and this is confirmed by the fact that there
are regularly notifications of interceptions during intra-Community trade. Also, due to latent
infections and the limited number of inspections of registered establishments (required only at
least once a year), the non-presence of HOs cannot be guaranteed with sufficient reliability.
The main reason explaining the above dysfunctions relates to the lack of capacities of NPPOs to
carry out plant health checks due to shortages of staff and other resources. In MS where
resources are available and enough attention has been given to the PP system, implementation
was found to be more effective and in compliance with the relevant legislation. In some MS, the
delegation to growers has created a very uneven situation depending on the level of knowledge
of business operators, leading to the conclusion that the system has lost some credibility and is
today perceived as a purely administrative task with insufficient plant health focus.
In terms of the coverage of plants and plant products to which the PP should apply, it has been
proposed that, as is done for the listing of HOs, a discussion and decision platform should be
established to regularly update the list of species to be covered by the PP. The Annex WG could
be a very well suited platform for this mission. Currently there are considerable differences in
view among MS whether or not all host species which are a potential host for a given HO should
have a PP.
Several interviewees have indicated that risk analysis is usually insufficiently detailed and does
not include up-to-date surveillance details, documentation of trade pathways within the EU or
considerations of the potential economic impacts of a given threat. Therefore the intensity and
frequency of PP checks are usually based on the cultivation pattern of specific crops and not on
the potential phytosanitary risk per se. Resources should be devoted to areas and species that
pose a high potential plant health risk or where there is uncertainty of the risk. It has also been
indicated that the PP system does not use PRA proportionately. Requirements are the same
throughout the EU and are not flexible enough to consider local/regional conditions and
specificities at MS levels.
General survey results
Q4.2 Extent to which the PP system sufficiently takes into account risk analysis
6 out of 26 MS CAs and 8 out of 25 stakeholders consider that the PP system takes into account risk analysis. (5 MS
CA and 10 stakeholders do not know).
Additionally a large number of interviewees have indicated that the PP does not always take into
account the risk posed by plants for planting that are exempted from any inspections and from
the PP system. Exemptions of the PP obligations for ―small producers‖ and for ―final
consumption use‖ are analysed in the last chapter of this section.
Another exemption related to farm-saved seed (FSS) has been reported by the interviewees as
creating potential gaps in the system. Farm-saved seed is seed that is multiplied by the farmer on
his/her own holding for further planting on their own farm (seed cannot be sold to third parties).
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