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)
Only 4 MS considered there are opportunities for further delegation, but in 2 of these this was
due to the fact that the possibility of delegation is not used at all at present. One of these MS
indicated that delegation could be to a private body under official supervision (for
surveillance and rapid alert/early warning systems).
It is important to differentiate between the delegation of official tasks to another legal body
and delegation of certain tasks to the individual registered growers and suppliers.
As regards delegation of official tasks to another legal body, via tender or contract, a critical
factor is the capacity of such body to have the expertise required to carry out the very
specialized tasks associated with plant health inspection, surveillance and diagnostics. The
limited and declining availability of such capacity and expertise, whether at public or private
level, is discussed in section 3.9.
In terms of the delegation of tasks to individual registered growers and suppliers, the main
argument provided during the interviews in favour of this approach is that this would
contribute to cost reduction by avoiding double checks in the case for instance when growers
and suppliers do, in the context of their own quality system, the same checks as those carried
out by the inspection bodies. Several interviewees highlighted that the concept according to
which the NPPO supervises (by auditing) the companies own quality assurance and internal
inspection procedures (as foreseen under the framework food hygiene Regulation 178/2002
and the Regulation on official controls (882/2004)) is a concept that works well within other
areas of EU legislation (notably in the food safety field), and needs to be further examined for
the purpose of the inspections imposed under the CPHR. This issue is also discussed in
section 3.12.2 under coherence with the general principles of official controls.
As regards the availability of incentives for the effective implementation of the CPHR,
responses to the general survey indicate a general lack of incentives as regards the timely
reporting of outbreaks and the effective implementation of control measures.
Private operators in the production and supply chain have a strong commercial interest in
producing and selling healthy plants or plant products, and therefore in controlling the health
of the plants or plant products they produce, sell or receive. The question arises whether selfresponsibility
suffices in all contexts to ensure plant health for the system as a whole. The
availability of incentives aims to ensure this is the case.
It appears that currently few incentives exist for the timely reporting and implementation of
control measures in case of emergencies and outbreaks. The existing incentives are
compensation schemes developed in some MS for some sectors for private operators at
individual level; and the solidarity regime developed at EC level to compensate the costs of
implementing phytosanitary measures for public authorities. The suitability and sufficiency of
these incentives is discussed further in section 3.11.7 of the Report.
Conclusions
The NPPO is the Single Authority and the Responsible Official Body within the meaning of
Article 1.A of Directive 2000/29 in the majority of MS; the current legal framework is
considered to be adequate.
FCEC 182