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)
2009 86 . More specifically a targeted and stricter approach appears to be needed for plants for
planting and Propagating Material, in particular applying pathway analysis more systematically
in order to direct efforts to the most significant risks, or where risks are uncertain. This point is
discussed in more detail in section 3.4 on imports.
According to the results of the general survey (Q2.1.f), the current overall structure of the
Annexes is generally considered to be appropriate. Although the difference in approach for
Annex I versus Annex II is considered appropriate by the majority, several comments point out
that there are elements of inconsistency with objectives. In particular, it is pointed out by some
respondents that Annex II (the majority of comments relate to the approach in Annex II) is too
narrowly targeted in terms of host plants, and therefore may not provide adequate protection if an
HO appears on hosts other than those listed. Further comments put forward by some MS CAs are
that: this division does not include the spread of specific HOs in final production and the
possibility of their natural spread, through vectors, etc.; Annex II is useful for distinguishing
risks from plants and produce (e.g. many citrus pests which are only quarantine listed when on
plants, not on fruit), but raises problems when quarantine status is only on certain genera.
Another comment (from a trader) is that plants infested with an HO regulated in Annex II cannot
be traded, while at the same time the HO may occur on other hosts in the area of destination, and
therefore this raises questions of whether the protection is justified and effective.
The distinction between Annex I and Annex II raises problems at operational level, as in the
view of interviewees it is ambiguous as to whether action can be taken when an HO is found on
new hosts, which is a sign of increased risk (e.g. action is required against Erwinia chrysanthemi
to protect potatoes but it is listed only on Dianthus). However, one MS also pointed out that
currently provisions exist within Art. 3(7) of the Directive 87 , which allow the Commission and
MS (through comitology) to take actions against HOs which are listed in Annex II but occur in
plants or plant products other than those listed. It is suggested that this possibility should be
taken into account more and discussed, probably with a view to delegating responsibility to MS
for tackling these cases.
On the other hand, even though the listing in Annex I should in theory provide more protection
in that inspections can be targeted on any hosts, this may not always be the case as the broader
range of potentially susceptible hosts may constitute a problem for inspections to be fully
effective. In practice therefore, Annex I is perceived to be too broadly defined in terms of listing
pests rather than host materials therefore making it difficult for inspectors to target inspections 88 .
86 EPPO Council Colloquium (Angers, FR, 2009-09-24): ‗Increasing trade, changing climate, emerging pests: Is the
plant health sector prepared?‘http://archives.eppo.org/MEETINGS/2009_conferences/council_colloquium.htm.
87 In accordance with the procedure referred to in Article 18(2), implementing provisions may be adopted to lay
down conditions for the introduction into MS and the spread within MS of: (a) organisms which are suspected of
being harmful to plants or plant products but are not listed in Annexes I and II; (b) organisms, which are listed in
Annex II, but which occur on plants or plant products other than those listed in that Annex, and which are suspected
of being harmful to plants or plant products; (c) organisms, which are listed in Annexes I and II, which are in an
isolated state and which are considered to be harmful in that state to plants or plant products.
88 The difficulty for inspectors in targeting inspections arises because plant pests are polyphagous, therefore listing
them against selected hosts does not deal effectively with the risk. There is a need of risk management systems that
can cope with polyphagous pests which may be present on a wide range of traded commodities.
Food Chain Evaluation Consortium 65