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)
Table 5-5: Preliminary analysis of options: positioning of RNQPs
Positioning of RNQPs: preliminary analysis of each option
Option: Description Impact Advantages Disadvantages
i. Status quo
(quarantine
regime, with
some
improvements)
ii. Zero tolerance
regime
iii. Specified
tolerance
regime
Improvements:
potential transfer, as
appropriate, of certain
‗borderline‘ cases
Positioning within PH
regime all HOs for
which zero tolerance
is required
Introduce RNQP
concept within CPHR
with HOs with
threshold levels other
than zero, as a specific
Annex to the Directive
2000/29/EC
Low.
Expected to add a limited
number of HOs in the
Directive. Would result in
‗clarification‘ of application
rather than extension of
scope.
Low.
Only change is that HOs for
which a zero tolerance is
required may move to the
responsibility of another
governmental service.
High.
Expected to add a
significantly larger number
of HOs in the lists,
compared to option ii. It may
also ‗destabilise‘ current
management structures and
tools under CPHR.
Clarification of application of rules;
Remove partially overlaps between
CPHR and S&PM regimes;
Proportionate increase between the
risk and the requirements.
Possibility to apply plant health
measures to phytosanitary issues
(mandatory official controls);
Eliminates overlaps / improves
coherence between CPHR and S&PM
regime;
No need to introduce the RNQP
concept within the EU legislation
(CPHR and/or S&PM).
Clarity and simplicity for intra-EU
trade (simplified plant passport) and
external trade based on one unique
regulation for all PH requirements;
More effective control of reintroduction
across MS;
The plant health Directive can ensure
more protection;
Case-by-case rather than systemic
approach might entail risk of
sustained legal and practical
confusion on how best to position
new ‗borderline‘ cases;
May lead to confusion for
inspection services (increase of
activities, needs for training,
practical organisation of the
inspections);
Reduced control on phytosanitary
risks for HOs moving from CPHR
to S&PM (focus on seed only and
not on seed + crop production).
Mixture of HOs that are currently
managed differently at the level of
inspection (official inspection in
CPHR vs inspection under
delegation in S&PM) may raise
administrative and operational reorganisational
issues.
Fundamental review of the CPHR
approach and tools (RNQP concept
to be included in EU regime);
Creates dichotomy of objectives,
therefore high risk for confusion and
contradiction in implementation;
Current tools may not be
appropriate;
Food Chain Evaluation Consortium 327