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)
Another concern is linked to the fact that producers/growers/farmers may not be able to identify
the plant health problem and recognise the disease. However the majority of the interviewees
consider that the level of education of farmers is generally increasing, even if highly variable
across MS and business sectors.
Delays in notification by MS CAs have also been reported as being an issue. The evaluation has
found that this is inextricably linked to the availability of sufficient capacities at MS level to deal
with the situation and the implementation of any potential measures that will need to be taken.
When a new HO outbreak occurs, the MS has to notify the Commission and then set up an
eradication/containment plan. However, this obligation does not take account of the technical
and economic capacity of the MS to support effective implementation of the plan. If core
capacities are lacking, the MS may prefer to delay notification, or not to notify the new HO in an
attempt to avoid creating new problems that may threaten trade. The lack of capacity at MS level
can therefore lead to non compliance with the notification obligation as described in Article 16
of the base Directive.
Stakeholders have also highlighted during the interviews the lack of resources at MS level to
effectively survey for the presence of HOs. The surveillance programs in each MS consist of the
mandatory programmes defined in the emergency and control measures, the surveys that have to
be established in the Protected Zones, and in some MS some additional surveillance plans
defined at MS level and based on regional or national plant health issues (implementation of
surveillance is discussed in section 3.3). Interviewees indicated that when resources are cut, the
first activity to be reduced is surveillance, and this is not really reflected in the number of
surveillance plans but in the level of intensity of the surveillance undertaken. For example, the
intensity of traps to capture Diabrotica beetles will be reduced in order to cut down on costs.
The key conclusion from the above analysis is that notifications on the identification of new HOs
in a given zone and presence of unknown and not (yet) listed organisms is delayed by the
absence of incentives to notify for: 1) the farmers/growers to the NPPOs; and, 2) the NPPOs to
the EC. Given the ineffectiveness of the implementation of these provisions, in many cases (as
also discussed in section 3.3.3), when the EU receives notification of outbreaks or new findings,
the pest is already quite well established and emergency measures are taken too late to achieve
optimal usefulness and effectiveness.
3.7.2 Emergency preparedness
The evaluation has also addressed the level of emergency preparedness of MS and the
Community, taking into consideration the effectiveness of the emergency interventions, the
instruments available to the Commission and MS for rapid intervention against outbreaks and
new diseases, and the availability of up to date contingency plans.
The previous section has clearly illustrated the inadequacy of the current approach in terms of
adoption and implementation of the emergency measures to deal in a timely and effective
manner with emergency situations. Clearly, some of the instruments available today for the
Commission and MS are targeted in the right direction, including the requirement to notify
outbreaks and to take measures at MS level first (before harmonised measure can be considered
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