Lars Christoffersen
European Commission Food and Veterinary Office, Grange, Dunsany, Co. Meath, Ireland; e-mail: [email protected]
The introduction of the European Union internal market (in 1993) required an increased harmonization of the plant health controls carried out in the EU. The European Commission established an Office (now called the Food and Veterinary Office) with the main task of verifying that adequate levels of control are in place in the member states in the areas of food safety, animal health, plant health and animal welfare. This Office carries out 20 - 25 plant health inspection missions per year. Organizational and practical aspects of this work are described in the paper.
Since the creation of the European Union single market at the end of 1992, goods, once they have entered into or are marketed within the EU, can circulate freely between member states without any further border controls. All plant health controls are still the responsibility of individual member states. A European Commission plant health "inspectorate" was created in 1993 with the main task of verifying that the key elements of the EU plant health regime are implemented to an acceptable standard across the EU.
The mandate for the work of the commission inspectors is given in Article 21 of the principal piece of EU plant health legislation, Council Directive 2000/29/EC (Council of the European Union, 2000). In particular, the inspectorate is authorized to carry out on-the-spot inspections to verify that member states properly implement:
the EU plant passport regime
The EU plant passport is a label that travels with plants and plant products indicating that they have been produced under officially controlled conditions and that they are free from quarantine organisms. The full legal definition of a plant passport is given in Article 2 of directive 2000/29/EC.
the protected zone regime
A protected zone is an area recognized as free from a specific harmful organism and granted a higher degree of protection than the rest of the EU against that harmful organism. The full legal definition of a protected zone is given in Article 2 of directive 2000/29/EC.
imports controls
outbreak controls
Individual member states are obliged to eradicate or contain outbreaks of harmful organisms in areas of their national territory where the organisms are not already known to occur.
safeguard measures.
Member states can also apply additional protective (emergency) measures generally to certain commodities or imports. Such measures must subsequently be reviewed at EU level and adopted for general application in the EU or revoked.
Article 21 also stipulates some general rules for the conduct of these on-the-spot inspections:
Member states shall be given sufficient advance notice.
Member states shall cooperate to enable the inspectors to meet the objectives of the inspections.
Inspectors shall have the same rights and observe the same rules as the national inspectors in the respective member state.
The European Commission plant health inspectors are part of the Food and Veterinary Office (FVO), a directorate within the Health and Consumer Protection Directorate General (see figure 1). They make up the sector "Plant Health" in unit 4. The FVO’s main activity relates to on-the-spot inspections in relation to food safety, animal health, plant health and animal welfare. It is located in Ireland.
Fig. 1: Organization chart for the European Commission Directorate General for Health and Consumer Protection.
(as of 1 June 2004)
At present, there are about 90 inspector posts in the FVO. In unit 4 ("Food of plant origin, Plant health; Processing and distribution"), there are about 20 inspectors, of whom six, all agronomists, are in the sector "Plant Health".
As indicated above, the main tool for monitoring member states’ delivery of plant health controls in the EU is on-the-spot inspections. This is supplemented by other means, such as evaluation of reports and data requested from member states, either directly or required under legislation. However, in the following description, only the inspections are addressed.
One of the advantages of being placed in a larger Office dedicated to inspections is that the process and methods of inspection can be properly developed and guided. There is consequently a well-developed FVO manual of procedures, describing in detail all steps of the work, from planning of the annual inspection programme to implementation, reporting and following up of individual inspections. There is also a specific unit for "Quality, Planning and Development", which keeps the manual updated and provides quality assurance for the work of the Office. This ensures a uniform approach to the work and a consistent level of quality in the carrying out of inspections and preparation of inspection reports.
The programme of inspections is established as a rolling 12-month programme, reviewed every half year. The inspection programme is presented to the member states in advance and published on the Internet. The strategy for plant health inspections has moved towards fewer inspections, but inspections of a more comprehensive nature, where whole control systems are evaluated rather than, for example, the handling of a particular pest or pest outbreak. With this approach and the additional preparation that this entails, as well as the current quality level for inspections and reporting, the capacity with the staff complement mentioned above is 20 - 25 inspections per year.
The inspection mission process
An inspection mission takes typically four to five working days. However, measured in time, the inspection itself is the smallest part of the work. For a successful result, there is substantial work required both before and after the inspection. Figure 2 gives an overview of the various steps in the inspection mission process.
Fig. 2: Steps in the inspection mission process.
Preparation of the inspection
Good preparation is essential for a successful inspection. At least two months before the inspection, dates are agreed with the plant health service in the country to be inspected and an official notification is sent.
With the notification letter is also sent an inspection plan. This document helps the inspected party to understand what the inspection is all about and properly prepare for it. It thus speci.es in detail elements such as:
Usually the notification letter is also accompanied by a pre-inspection questionnaire. This should be filled in by the inspected party and returned to the inspection team before the mission. It helps the inspected party to focus on the information required by the inspection team and also gives time to prepare data (e.g. statistical data and documentation) that cannot always be provided immediately during an inspection. It also helps the inspection team to prepare the inspection, for example in judging whether the itinerary proposed by the inspected party is appropriate. Finally, it saves time during the inspection that basic information has already been shared and the inspection can then focus on verifying that this information accurately reflects the practice at all levels in the country visited. The questionnaire will typically address:
The inspection
An inspection team usually consists of two European Commission inspectors. Often, this is supplemented by a national expert from a member state (other than the one being inspected) when a particular technical expertise is required. As mentioned above, the itinerary is prepared in advance based on a proposal by the inspected party who knows the relevant sectors and the geography of the country the best. This itinerary can be changed in the course of the mission. Visits are often added with short notice to ensure non-biased results. The main elements of a typical inspection are:
At the closing meeting, the main findings and conclusions are presented orally to the inspected party. This ensures that there are no misunderstandings and prevents major surprises on the part of the inspected party when the inspection report arrives. It also gives the inspected party the opportunity to respond immediately with commitments for remedial action, where deficiencies have been identified.
Reporting
The reporting follows a standard format and procedure. Where deficiencies have been found, specific recommendations for remedial action are included in the report. The inspected party is consulted on a draft of the report. The inspection team corrects any factual errors in the report and introduces clarifying comments following this consultation. The report is then finalized, distributed to all member states and sent to the European Parliament and published on the Internet (at europa.eu.int).
Follow-up and close-out
Experience has shown that systematic follow-up to the inspections and their recommendations is necessary to achieve real improvements; and this element in the monitoring of delivery of proper plant health controls by member states has gradually been strengthened over recent years. Where there have been recommendations for remedial action in the report, the inspected party is now required to submit an action plan addressing each recommendation. The action plan is evaluated and if found satisfactory, the file is closed. If a plan is not submitted or if it is found inadequate, further inquiries are made or follow-up missions carried out. Outstanding issues are added to a country profile, which contains all such issues in the areas covered by the FVO (i.e. including food safety and veterinary issues), and which can be used for high-level meetings with the relevant member states. As a last resort, the European Commission can launch legal proceedings against a non-compliant member state.
The work to monitor the delivery of plant health controls in the EU has developed over the years and some lessons have been learned:
Fewer, more comprehensive inspections covering whole control systems and not just isolated outbreak situations have proved a way to use resources better.
It is important to have well-developed procedures and quality control to ensure a uniform approach to the work and a consistent, high level of quality of the inspections and the reports.
Systematic follow-up of the report recommendations is necessary to ensure that inspections result in improvements.
To carry out good-quality work, substantial resources are required.
Reference
Council of the European Union. 2000. Council Directive 2000/29/EC of 8 May 2000 on protective measures against the introduction into the Community of organisms harmful to plants or plant products and against their spread within the Community. Official Journal of the European Communities, L 169: 1 - 112 (available at ue.eu.int).
