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)
21 179 ) and the WTO-SPS Agreement (Article 5.3 and Annex A, point 1.4), as risk is in principle
characterised also by the economic impact of a pest. This cannot be addressed by EFSA as its
mandate is confined to assessing the biological risk.
The reason why EFSA is not involved in the analysis of the economic impact of PRAs is linked
to the principle of separation of risk assessment from risk management. EFSA risk assessments
do not lead to a conclusion on whether a pest should be regulated or not. EFSA evaluates a risk
but the final decision regarding the appropriate measures needs to be undertaken by the risk
manager, i.e. the Commission (and MS). Regarding the management options, EFSA may
possibly evaluate these in terms of their effect on the level(s) of risk, but does not evaluate them
in terms of cost-effectiveness and feasibility (unless the latter is defined as technical feasibility),
minimal impact or non-discrimination. In this context, the analysis of economic impact is
considered to be closely related to ‗acceptability of the level of risk‘, which is a management
decision and depends on other factors including socio-economic and political considerations.
The Commission has taken the position that this function should not be included in the EFSA
mandate. If an economic impact analysis is needed (e.g. because MS request it or the
Commission considers that is needed for the preparation of a policy proposal) this will be
performed separately (e.g. for Diabrotica which was conducted at the request of MS). Therefore
the only economic data foreseen for inclusion in the EFSA PRAs relate to the extent of the
problem and the impact on plants (volume of production, size of land potentially affected etc.)
and are not expressed in monetary value 180 .
During the evaluation MS have taken a balanced view regarding which organisation should be in
charge in performing such type of socio-economic studies in support to policy decisions and no
clear trend has emerged on how to structure this type of assessment, other than that cooperation
and synergies should be sought in order to maximise the knowledge and data provided by the
various organizations currently conducting PRAs (EPPO, MS CAs, research bodies).
The outputs of the EU-funded project PRATIQUE are expected to play a key role in the
development of PRA methodology, by providing generic economic and modelling techniques to
support the development of decision support tools for pest management. However, the
179 ISPM No. 11 (2004): Pest risk analysis for quarantine pests, including analysis of environmental
risks and living modified organisms; ISPM No. 21 (2004): Pest risk analysis for regulated non-quarantine pests.
Stage 2 of the PRA, risk assessment involves an evaluation of the probability of pest entry, establishment, and
spread, and of their potential economic consequences. Art. 5.3 WTO-SPS Agreement: “In assessing the risk to
animal or plant life or health and determining the measure to be applied for achieving the appropriate level of
sanitary or phytosanitary protection from such risk, Members shall take into account as relevant economic factors:
the potential damage in terms of loss of production or sales in the event of the entry, establishment or spread of a
pest or disease; the costs of control or eradication in the territory of the importing Member; and the relative costeffectiveness
of alternative approaches to limiting risks”. Annex A, point 1.4, Risk Assessment is defined as “the
evaluation of the likelihood of entry, establishment or spread of a pest or disease within the territory of an importing
Member according to the sanitary or phytosanitary measures which might be applied, and of the associated
potential biological and economic consequences”.
180 Only the biological impact on crop production/agriculture/size and land etc. is included, but this is not expressed
in monetary terms.
Food Chain Evaluation Consortium 162