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) PZs have mainly lost their status because they became contaminated, due to the difficulty of preventing entry of contaminated plants and plant products. Additionally, in a few cases, efficient long term control measures have been developed e.g. plant varieties resistant to Erwinia amylovora and rhizomania, which removes the need for a PZ approach. Over the reference period, the number of PZs which have lost their status is much higher than the number of ―new‖ established PZs, e.g. for Erwinia amylovora (fire blight). The number of HOs for which PZs exist per type of HO has not been significantly modified over the reference period with the majority still pertaining to insects, mites and nematodes. Analysis of the Annexes of the PZ legislation further demonstrates that the list of HOs for which PZs exist has remained stable over the last 20 years. Furthermore, the perimeter covered by each PZ can decrease within a MS over time. This phenomenon has occurred mainly in the case of PZs for Erwinia amylovora (fire blight) and the Grapevine flavescence dorée phytoplasma. Table 3-14: Number of HOs for which PZs exist in the EU 1992 2001 2008 Insects, mites and nematodes, at all stages of development 17 16 16 Bacteria 3 2 2 Fungi 5 3 4 Viruses and virus-like organisms 3 3 4 Source: Compiled by FCEC based on Commission Regulation (EC) No 690/2008, Commission Directive 2001/32/EC and Commission Directive 1992/76/EC The establishment and use of a PZ has a double objective. Firstly, it is a tool to control and reduce the spread of HOs in the territory; secondly, it should provide guarantees that plants and plant products introduced into the PZs are free of the specific HO(s) for which the PZ status has been granted. Although not specifically stated in the legislation, by default, the latter guarantee should also apply to products coming from PZs. The effectiveness of the PZ system and its implementation in meeting these objectives is discussed below. General survey results Q 5.3*: What is the level of guarantees that the PZs in the EU are indeed free from the respective HO(s) Level of guarantees MS CA Stakeholders High 6 out of 23 (0 do not know) 0 out of 19 (9 do not know) Low 1 out of 23 (0 do not know) 1 out of 19 (9 do not know) Depends on MS 3 out of 23 (0 do not know) 6 out of 19 (9 do not know) Depends on HO 3 out of 23 (0 do not know) 1 out of 19 (9 do not know) Depends on MS and HO 10 out of 23 (0 do not know) 2 out of 19 (9 do not know) * Q 5.2 in the case of the stakeholder q/naire Food Chain Evaluation Consortium 130
Evaluation of the Community Plant Health Regime: Final Report DG SANCO Evaluation Framework Contract Lot 3 (Food Chain) The overall feedback from the general survey and the expert interviews and field visits is that, while the general concept of PZs was in the past considered useful and effective in slowing down the spread of certain HOs, e.g. Erwinia amylovora (fire blight) in the 1980s, continued variations in implementation of the concept at MS level have led to a loss of credibility. This can further undermine the utility of the system as a plant health control measure. The main reasons underlying the loss of credibility of the concept, as indicated by interviewees, can be listed as follows: Strictness of the PZ requirements and lack of effective enforcement at MS level; Complexity of using a PZ for trade purposes; Findings of HOs in a PZ in practice often do not lead to the loss of the PZ status. The level of guarantees that the PZs are free from the respective HO(s) depends largely on how the PZ principles have been implemented by MS. For example, if the methods and frequency of surveillance in PZs have not been harmonized for a given HO, then the level of guarantees is likely to differ between MS. Interviewees reported several examples where MS do not meet control and reporting obligations or do not establish reliable surveillance programmes. This is also confirmed from systematic report findings: although most MS carry out monitoring in PZs, some overview reports on this (FVO reports, reports to annual meeting of the SCPH), reveal different depths of monitoring by MS. The level of guarantees that PZs are free from specific HOs is also dependent on the biology of the pathogen. In cases in which the HO can spread naturally, maintenance of the PZ is more difficult than for HOs whose spread is strictly associated with the movement of plant and plant products. For example, transmission of Erwinia amylovora can occur by air, rain or by vectors (insects), and in open conditions there are more genera of host plants for this particular HO. Respondents also observed a lack of reporting to the EU, with several examples of MS not submitting the required reports to the European Commission and to other MS. For example, Regulation (EC) No 823/2009 mentions the lack of reporting from Greece that did not notify the Commission of any results of such surveys on the presence of the HOs concerned over a period of five years 139 . An analysis of data on reports submitted by MS 140 since 2001 has shown several cases where reports are not submitted, and cites a few examples of HOs for which reports are systematically not submitted by some MS. Several stakeholders have reported that PZs are maintained more on purely commercial/political grounds and are therefore no longer effectively serving plant health objectives, i.e. having a PZ offers an economic advantage for local growers when exporting within and outside the EU. 139 Reg. 823/2009 gives to Greece recognition as a protected zone (with respect to those HOs) until 31 March 2010, in order to carry out survey and to notify its results to the Commission. This decision was made on the basis of information provided by Greece in March 2009, showing that the necessary legal, financial and organisational steps had been taken to carry out regular and systematic official surveys for those HOs, 140 Notification of the results of surveys in PZs, submitted to the Commission pursuant to Article 2(h) fifth paragraph of Directive 2000/29/EC. Food Chain Evaluation Consortium 131
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