2454 final report.pdf - Agra CEAS Consulting

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Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) Despite these positive findings overall on the current implementation of the registration and inspections system, with the reduction generally observed in the MS in NPPO resources, future reliability may be at risk. For example, most MS have been unable to provide detailed guidelines to registered producers on the implementation of the system, due to shortage of staff and resources. 3.5.4 Functioning of system for registered nurseries to issue plant passports The PP is prepared by the responsible official body in the MS and may be issued either by the responsible official body directly or – under their control – by the registered producers/private operators authorised to do so under NPPO supervision. Nearly all MS have delegated the issuing of PPs to private operators under NPPO supervision. Only BG, RO and PL have reported that they have not implemented this option, as it is considered that the registered producers are not sufficiently prepared to issue PPs. Registered producers have to apply for an authorisation to issue PPs and the responsible official bodies retain the obligation to ensure that certain conditions are fulfilled and certain functions (e.g. issuing of replacement passports). In some MS a visit before registration or before authorization for issuing PPs is also carried out, even if not required by the legislation. The possibility of sanctions exists in the system: in case inspections made on the premises of registered operators find the presence of HOs, the passport is not issued 134 , the activities of the producers are partially or totally suspended (until the risk is eliminated) and official measures are taken (including: product treatment; movement under official control to zones where the plant materials and HOs do not present additional risk; movement to places of industrial processing or destruction). However, it is not clear (there is no evidence) as to whether these are actually applied. The evaluation has found that stakeholders are by and large satisfied with the current implementation of the system for delegation of PP issuing under NPP supervision; however the majority of MS CAs do not consider that the system provides sufficient guarantees at present. General survey results Q4.5. (CAs): Is the authorisation system for registered nurseries to issue PPs under NPPO supervisions functioning properly and reliably? 14 out of 26 MS CAs (2 do not know) consider that the system functions properly and reliably. Q4.4.b (stakeholders): Extent to which the stakeholders are satisfied with the current implementation of the provisions authorizing registered producers to issue plant passport under NPPO supervision All stakeholders (16 in total) are satisfied with the current provisions authorising registered producers to issue plant passports under NPPO supervision. During the interviews, stakeholders highlighted the significant advantages of the current system of delegation of issuing of PPs under official supervision as follows: 134 Art. 11 (2) of Directive 2000/29/EC provides however that it can be issued for parts of the products, if there is no risk of spread of HOs for the part concerned. Food Chain Evaluation Consortium 120
Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) Flexibility as regards planning and logistics for producers and traders, as they do not have to rely on official services to get the paper documents and to organise their day-to-day activity; Cost-effectiveness, as the issuing of PPs can be optimally integrated in the daily activities rather than being delayed awaiting official documents; Reduction of overlapping activities in cases where the PP is associated with the S&PM certificate (e.g. seed potatoes). For CAs the major issues are linked to the understanding of the system. Larger companies that are used to issuing a large number of PPs know the system quite well, but this is not the case for all smaller companies, even if they are sufficiently informed on the requirements. In these cases, the real purpose of the PP is unclear to operators mainly because the origin of the plant material so easily disappears in the marketing chain between MS. Additionally, registered nurseries are not always aware which plant species need a PP and therefore they provide PPs to plants which are not covered by such requirements. At the same time, the NPPO is not always informed about the species that are present at the premises of registered operators. These elements conjointly lead to a degree of dysfunctionality within the current system. CAs interviewed have also reported that some obligations related to record keeping are not performed satisfactorily, as the private operators consider that they will do their ―paperwork‖ later and finally this is not properly done until they are inspected. In the case of issuing of replacements PPs, only the CA should be competent to do this according to the legislation; this is not currently the case as this task is mostly delegated i.e. in cases where replacement PPs are used, these are prepared by the registered holdings and not by the NPPOs as required by the legislation. This point is also highlighted in the 2005 FVO report. Producers generally use the normal PP instead of the replacement PP mainly because they are not fully aware of the obligations and for practical reasons. Finally, there is concern that, with the reduction of field inspections at registered nurseries, the phytosanitary status may be at risk because private operators currently have incentives to sell plant products not free of HOs rather than destroying them. 3.5.5 Traceability issues The plant passport is an official label which provides evidence that the provisions of Directive 2000/29/EC related to plant health standards and special requirements are satisfied. The PP was never intended to be used just as a traceability tool, although there is reference to the possibility of setting up a system to trace back to origin in the base Directive (Art. 6(6) 135 ). On the other hand, the list of required information and the movement of the PP document with the consignment are elements that contribute to a certain level of traceability (e.g. registration number, individual serial or week or batch number, botanical name, and country of origin or consignor country for third country products). 135 “[…] a system may be set so that certain plants, plant products and other objects may, if necessary and in so far as possible, be traced back to their origins, bearing in mind the nature of the production or trading conditions”. Food Chain Evaluation Consortium 121
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