BTSF. Better Training for Safer Food Initiative. Food and Veterinary Office (FVO)

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1 Better Training for Safer Food Initiative Food and Veterinary Office (FVO) Audits on Plant Health and Plant Protection Products in Third Countries BTSF Demetrios Fragoyiannis European Commission Food and Veterinary Office Rabat, Kingdom of Morocco 8-12Dec 2014

2 European Commission Is the European Union's (EU) executive body Represents the interests of the EU as a whole Key roles of 'initiative' proposes legislation - and 'Guardian of the Treaties' enforces EU Law

3 European Commission 33 Directorates-General, including DG Health & Consumers DG SANCO: as from 1/1/2015 DG Health & Food Safety, DG SANTE Acting director Mr Ladislav Miko 2 Directorates in DG SANCO directly responsible for plant health and plant protection products

4 EC - DG Health and Consumers - Directorate E Food Safety / Director Mr Eric Poudelet Responsible for policy relating to plant health and plant protection products (PPP): legal measures to minimise plant health risks (limits on TC interceptions) and risks emerging from increased PPP residues; Chairs the Standing Committee for Plants, Animals, Food and Feed (SCoPAFF) and its sections of Phytopharmaceuticals - Pesticide Residues, Plant Health, Animal Health and Welfare etc. Chairs task specific Working Groups (e.g. WG on Reduced frequency of inspection at import) Represents the EU in international organisations as EPPO.

5 EC - DG Health and Consumers - Directorate F Food and Veterinary Office (FVO) / Director Mr Michael Scannel: Inspection / audit office Mission Statement: the promotion of a better quality of life by ensuring a high level of protection of consumer s health, safety and economic interests as well as of public health; Audits in MS and in TC (incl. audits for EU enlargement): Production and follow-up of recommendations; Reporting back directly to the relevant sections of SCoPAFF and contributing to the legislative process of the EU: Publication of reports on the internet:

6 EC - DG Health and Consumers - Directorate F EUROPHYT (plant health database): Notifies interceptions and analyses reports of investigations and action plans to prevent further interceptions; Follows the Surveillance carried out in Member States for the detection of Harmful Organisms and the Notifications of outbreaks of harmful organisms; Chairs Expert Task Force on Response to Risks from Imports;

7 The FVO is Based in Ireland: Grange, County Meath has 170 staff, including ca. 100 inspectors: veterinarians, agronomists, and experts with relevant qualifications runs 7 Units carries out audits covering a wide range of issues

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9 FVO Audits To assure effective control systems and to evaluate compliance with EU legislation by Member States and EU import requirements by Third Countries Upon request by Third Country: for the recognition of equivalence, pest status, provision of derogation for import of prohibited commodities into the EU Follow a high-risk based approach Third countries and EU EUROPHYT or RASFF notifications Auditing Systems of Production of plants for planting, fruits, vegetables, cut flowers, wood and wood packaging material etc.

10 FVO Audits Annual FVO Work Programme 250+ audits annually; Approximately 60% EU MS, 30% Third Countries; No charges, mutually beneficial; Auditing national control systems not individuals; Facilitate trade with safe products; A need for BTSF and Sustained Training;

11 FVO Audits in Third Countries - F4: Plant Health / Phytosanitary Controls; Pesticide Residues Controls; Organic Farming; GMOs; Contaminants (chemical and microbiological);

12 FVO Audits Process in line with standard audit practice: an Audit Plan defines the scope and objectives / key control points to be visited and requests for an itinerary; A Pre-Audit Questionnaire requires information for the optimum planning and conduct of the audit Start with an opening meeting headquarters of competent authorities (CA) Continue with visit(s) and interviews of officials/producers in regional services, border inspection posts and other control sites within the export system (places of production, pack houses) Final (closing) meeting with main findings and preliminary conclusions of the audit, the major noncompliances and the CA comments/corrections/clarifications

13 FVO Audits Draft report 20 working days (10 if urgent) Recommendations to address shortcomings CA provide comments/corrections/clarifications and an action plan (AP) to address the recommendations -25 working days (10 if urgent) FVO finalise report, and assess action plan 20 working days (10 if urgent) If needed additional information/clarifications requested Final report, CA comments and AP published on FVO website:

14 FVO Plant Health: Response to emerging risks from imports Preparation of the 'Alert list' which should include Third Country / commodity / HO combinations if interceptions, reported to EUROPHYT in the reference period exceed a given threshold: It is now published on DG SANCO website: y/alert_list_trade_non_eu/index_en.htm; Standard (automatic) notification to the NPPOs of the TCs on the alert list. Informs the TCs that the EU is alerted due to the increase in the number of interceptions of high risk commodities : the Commission expects that the CAs of the TCs take steps to improve the situation.

15 FVO Plant Health: Response to emerging risks from imports Harmonised additional action(s): Recommendation for intensified import inspections at EU MS level and mandatory sampling for further laboratory analysis; Commission letter with suggestions [Request] for additional phytosanitary measures to be introduced by the exporting country; Commission letter with specific warning about the introduction of Commission safeguard measures, linked to thresholds, announcing introduction of "threshold five regime"; Formal Commission emergency measures including additional requirements or a temporary import ban.

16 FVO Plant Health Audits General Priorities Since its establishment FVO carried out audits in 29 TCs, many of them visited more than once! Almost all due to EUROPHYT interceptions Why is there a problem? Are EU import requirements being complied with? Additional measures required? EU legislation is not directly applicable for TCs: the performance of TC CAs is assessed against EU import requirements and relevant ISPMs: N os 7, 12, 23, Control system organisational issues Requirements of inspection for issuing phytosanitary certificates

17 FVO Plant Health Audits Typical Findings(1) -Main issues are organisational: Poor overall control of export procedure; Lack of awareness or understanding of EU requirements by operators / inspectors, combined with limited technical information; High pressure to handle / export of perishable goods within a limited time period or during rush hours; Insufficient or inadequately trained staff; -Problems on enforcement, where no sanctions are imposed in cases of fraud;

18 FVO Plant Health Audits Typical Findings(2) During inspections carried out immediately prior to export -Lack of appropriate documentation and traceability of consignments with goods destined for export: No inspection records or records not available / ignored at place where phytosanitary certificate is issued; Incorrect additional declarations in the PCs; -Poor inspection conditions and/or inspection facilities / equipment: "Traffic" problem of consignments and presence of agents or exporters in the inspection area; Common problem around the world the contrasts found during audits between different TCs;

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26 FVO Plant Health Audits Typical Findings(3) During inspections carried out immediately prior to export - Poor inspection performance due to: non "appropriate" sampling for visual inspection (size and representativeness of sample) non "appropriate" examination of the sample for detection of target pests (in line with biology requirements for the detection of the pest) incorrect frequency, timing, or intensity of the inspection (not immediate)

27 FVO Plant Health Audits Typical Findings(4) During inspections carried out at the place of production (PoP) - Specific requirements for PoP freedom not respected (i.e. plants for planting vs. Bemisia tabaci, Citrus fruits vs. Phyllosticta (=Guignardia) citricarpa etc.) Inspections of places of production not performed at all (pre-export inspection not enough); Incorrect frequency or timing of inspections during periods where the presence of certain HOs is not expressed or it is latent; Tracing back and forward system non reliable or absent.

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29 FVO Plant Health Audits Typical Findings(5) Action taken if a pest found during internal interceptions / rejections: Often only the infected product or box is excluded from export, instead of the whole lot; The remaining part of the lot is considered free: not in line with ISPMs and a gamble (to be detected or not in the EU BIPs); Findings not internally communicated within official services (i.e. from the authorities at PoE to the PoP); Risk commodities not identified leading to a seasonality of pest findings

30 FVO Plant Health Audits Typical Findings(6) Action taken in response to international non-compliances and interceptions: No systematic follow-up; Not all the services / stakeholders / operators communicated of the event; Lack of review of the export inspection system and its effectiveness; Absence of corrective actions.

31 Pesticide Audits to Third Countries General Priorities and Scope RASFF: Notifications for pesticide residues in EU Rapid Alert System for Food and Feed Trade: volume of imports into the EU Import control data: Regulation (EU) 669/2009 MS control data: compiled in report of EFSA (European Food Safety Authority) To evaluate the control systems for pesticide residues in foodstuffs of plant origin intended for export to the EU. To evaluate the control systems for marketing and use of plant protection products (PPPs) Legal Basis: Regulation (EC) No 178/2002; Regulation (EC) No 882/2004; Regulation (EC) No 852/2004; Regulation (EC) No 396/2005.

32 Pesticide Audits in Third Countries

33 Morocco 2006, 2011, 2013 Egypt 2007, 2010 Kenya 2007, 2013 South Africa 2006, 2014

34 Pesticide Audits to Third Countries For food of non-animal origin: Third Country approval or export certification for PPP residues purposes is not required under EU legislation; Imports of the food into the EU are allowed upon the guarantees offered by the importer; Importer has to ensure compliance with requirements of EU law or with equivalent conditions; EU legislation does not contain specific requirements in TCs for pesticide controls in fruit and vegetables; The competent authorities are, however, the natural contact points of the EU; The reports contain recommendations to the competent authorities.

35 Meetings and visits in Third Countries Competent authorities (central and in 2 regions); Pesticide residue laboratories.

36 Meetings and visits in Third Countries(2) Growers of produce involved in RASFF notifications; Retailers of plant protection products; Pack-houses for fruit and vegetables

37 Results authorisation of plant protection Systems are in place for the authorisation of plant products (PPPs) / Controls of PPP retailers protection products (PPPs); Many of the PPPs authorised in TCs can't be marketed and used in the EU; Their authorised use can cause residues in excess of EU MRLs and EU RASFF notifications; Systems in place for official controls of retailers of PPPs in accordance with national legal provisions; Formulation analyses regularly performed (however there is a variation: due to limited or no controls in some countries)

38 How can I apply pesticides and be in line with EU MRLs

39 and my products not being intercepted in the EU due to the presence of pests?

40 Results controls of growers, packhouses and RASFF follow up Official controls of growers only in some TCs; Private controls, especially on large producers: Certification to private GAP standards Advice on pesticide usage for EU market and private sampling through exporters and EU retail chains Producers keep records of pesticide uses. Pack-houses generally registered; Traceability is generally in place, often back to the plot/orchard; Generally good follow-up of EU RASFF notifications by authorities.

41 Results sampling for pesticide residues / Official Laboratories Sampling programmes not in all TCs and often focus on domestic market; Sampling generally in line with Dir 2002/63/EC = CAC/GL 33/1999; Export controls performed by some TCs; Labs often accredited to ISO 17025, but scope of accreditation is small; Rarely use of LC-MS/MS for pesticide residues; Analytical screen generally small (often < 50 substances), and does not include important pesticides used by growers and notified in RASFF system. Controls by official laboratories mostly not effective

42 We could do more if we used LC-MS/MS

43 Conclusions of pesticide audits in TCs 1.Official pesticide controls focus mostly on compliance with national rules, which differ from EU legislation, and official laboratory control is ineffective. 2.Authorisations of PPPs in TCs are not aligned with EU MRLs, and growers producing for export to the EU must be informed on Good Agricultural Practices in line with EU MRLs. 3. Such information is often provided by pack-houses and exporters, and their self-control systems can ensure compliance with EU MRLs. 4. Main Problems in areas without strong private sector. 5. Co-operation between authorities and private sector important.

44 Further EU Measures for non-compliance Increased levels of import controls (Regulation 669/2009) by DG SANCO: e.g. Kenya, Egypt and Morocco; Further safeguard measures (e.g. export certification) possible in exceptional cases (curry leaves and okra from India).

45 Any questions?