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 survey results indicate that MS CAs are sufficiently confident in the implementation of the
producer registration system in terms of ensuring both phytosanitary risk prevention and free
trade. However, stakeholders are more sceptical in terms of the benefits of the current
registration system, although overall they appear to be satisfied with its implementation (Q
4.4.a). These findings were confirmed during the interviews and field visits.
General survey results
Q4.1.a Extent to which the plant health rules for intra-Community trade have been effective for preventing
the spread of HOs:
Provisions MS CA Stakeholders
Registration of producers, collective 21 out of 25 11 out of 23 (10 do not know)
warehouses and dispatching centres
Inspection of above. 21 out of 25 12 out of 24 (8 do not know)
Official checks (occasional and
regular checks by official services)
19 out of 25 13 out of 23 (9 do not know)
General survey results
Q4.1.b Extent to which the plant health rules for intra-Community trade have been effective for ensuring the
free circulation in plants/plants products:
Provisions MS CA Stakeholders
Registration of producers, collective 21 out of 24 (2 do not know) 11 out of 23 (10 do not know)
warehouses and dispatching centres
Inspection of above. 22 out of 25 (3 do not know) 11 out of 22 (10 do not know)
Official checks (occasional and
regular checks by official services)
22 out of 26 (3 do not know) 12 out of 23 (10 do not know)
A key criticism of those that are more critical of the current registration and inspections system is
the adequacy of the frequency (at least one a year) and the level (at least visual observation) of
the inspections performed by the NPPO services in registered establishments. In particular,
several interviewees have indicated that this is viewed more as a formality rather than as a real
guarantee of the compliance of business operators with plant health rules.
To perform the task of official inspections, MS inspection services should have access to the
relevant products at all stages in the production and marketing chain, and to the records kept by
registered business operators. The 2005 FVO report highlights that all MS considered in that
review (17 in total) had a national or regional database of registered establishments, which, in
most cases, was electronically available and accessible to plant health inspectors.
The registered producers are subject to certain other obligations (laid down in Article 2(2) of
Commission Directive 92/20/EC): in particular, they should immediately notify the responsible
official body of any unusual occurrence of HOs, symptoms or any other plant abnormality; and
they should keep records of all product movements through their premises. The 2005 FVO report
indicates that these obligations were not fully respected by registered establishments, mainly due
to a lack of awareness among producers or a lack of inspections but also for reasons of
impracticality (e.g. keeping a detailed plan for glasshouses with a high turnover of plants).
Food Chain Evaluation Consortium 119