Title: DirectorateGeneral Health
1Directorate-General Health Consumers
- Better Training for Safer Food 2008
2- Training Workshop
- on Veterinary Checks
- in port BIPs
- Rotterdam
- DG SANCO F5 - FVO
3- Purpose and implementation of FVO missions
- Problems identified at port BIPs
4- Currently there are
- 295 BIPs in 27 MS
- 27 BIPs in 2 EEA countries
- 1 BIP in Faroe Islands
- Amongst the MS 133 port BIPs
- Most of them in Spain 21
- UK 15
- Italy 16
- 10 of them with consignments
- 12.700 to 45.000 per year
- Ca. 85 BIPs with less than 1000 consignments per
year
5Missions carried out by the FVO
- Evaluation of the Import/Transit Control Systems
in Member States and evaluation of individual
BIPs - Regular inspections to all BIPs based upon risk
assessment - Responsibility to recommend approval of new BIPs
- Evaluation of measures to prevent illegal imports
- Focus more on the import/transit control system
within the audit approach - Including follow up of previous FVO inspections
- Assessment missions in Candidate Countries and
pre-approval visits - Missions in co-operation with ESA to NO and IS
6Evaluation of import controls
- Supervision of the BIPs by the CCA
- Co-operation and exchange of information between
different authorities - Identification and selection of relevant
consignments - Determination if import/transit conditions of
consignments are met at the BIP - Controls at all entry points (Pet animals and
passenger luggage, mail) - Supervision of non-EU-conforming consignments
-
- Destruction of relevant consignments and galley
waste
7FVO inspections
- 2006 18 Inspections
- 6 (old) Member States 18 BIPs and 5 new BIPs
- 5 (new) Member States 12 BIPs and 1 new BIP
- 3 Candidate Countries 16 new BIPs
- 1 EEA country 3 BIPs and 1 new BIP
- 1 Equivalency Country (FI) 1 BIP
- 2 (new) MS (warehouses and transit)
- 2007 19 Inspections
- 12 Member States BIP / Import controls 38 BIPs
1 new - 2 Candidate Countries 6 BIPs
- 1 EEA country 6 BIPs 1 new
- 1 Equivalency Country (CH) 2 BIPs
- 3 (new) MS (warehouses and transit)
8Inspection approach
- Risk based approach to select MS and BIPs to be
visited - Pre-mission questionnaire
- Preparation, also in view of the follow up of
last report - Opening meeting with CCA
- Visits on-the-spot in BIPs, customs warehouses,
ship suppliers, caterers, non-BIP-entry points
etc. - No evaluation of the work of individuals but of
the systems in place - Closing meeting with CCA
- Reporting procedure
9The ideal system ensures (1)
- Good supervision, including guidelines, manuals
etc. - Good co-operation between veterinarians, customs
and other CAs including proper exchange of
information - Proper identification of relevant consignments
- Correct veterinary checks and their follow up in
BIPs - Traceability for non-EU-conforming consignments
- Adequate follow up and customs supervision for
relevant consignments (in particular
non-EU-conforming POAO in transit, including
customs/free warehouses) - Exchange with customs and other intelligence to
ensure adequate risk assessment and targeting of
POAO and live animals
10The ideal system provides (2)
- Measures to prevent attempted illegal imports
- Measures to detect illegal imports
- Customs priority, targeting of controls,
information to travellers - Mass screening, e. g. sniffer dogs trained for
POAO or scanners - All entry points and baggage types and mail
- Ensure adequate destruction
- Sanctions provided for as a deterrent
- Risk analysis for freight
11Good co-operation at the BIP beneficial to all
involved parties and consumers
12Co-operation and exchange of information between
services (1)
- Art. 6 of Regulation (EC) No 136/2004 and Art. 5
of 282/2004 - Coordination with other enforcement services
- The CA and the official veterinarians of each
Member State shall coordinate with other
enforcement services to gather all pertinent
intelligence regarding introduction of animal
products. - (a) information available to customs services
- (b) information on ship or boat manifests
- (c) other sources of information available to
the port commercial operators.
13Co-operation and exchange of information between
services (2)
- Co-operation between customs, port/airport/rail/ro
ad authorities is necessary to ensure a proper
overview of consignments arriving, transiting or
transhipping in the relevant areas of the BIP. - Close co-operation is necessary between the
various services involved in consignments coming
from third countries and in particular with the
Customs services for gathering information and
for that also access to their databases or
relevant parts thereof is foreseen. - Information technology systems used by the
competent authority shall, in so far as it is
possible and where it is appropriate, be
integrated with those of the customs services,
and with those of commercial operators in order
to speed the transfer of information.
14Identification and selection (1)
- Art. 3 of Directive 97/78/EC
- Member States shall ensure that no consignment
from a third country is introduced, ,
without having been subjected to the veterinary
checks required by this Directive. - Art. 4 of Directive 91/496/EEC
- Each consignment checked at BIP
- Relevant consignments must be presented to the
BIPs what system has been put in place to
ensure this ?
15Identification and selection (2)
- Very clear requirement for pre-notification in
advance of arrival of consignments on the EU
territoryArt. 17 of Reg. 882/2004, Art. 2 of
Reg. 136/2004, Art. 1 of Reg. 282/2004 - Verification Cross checks of pre-notifications
with arrival information - Availability of arrival information?
- BIP staff assume that customs will find
consignments not pre-notified or presented to the
BIPs however, customs systems do not flag
veterinary consignments, in particular under
transit procedure - Problem Composite products are these flagged in
the Customs system yet - Action taken where consignments not pre-notified
to the BIP are detected ?
16Identification and selection (3)
- Temporary storage Art. 50 of the Customs Code
- Provides for storage up to 20 or 45 days before
the formalities necessary to be assigned a
customs-approved treatment are carried out - Have veterinary checks been carried out ?
- How do you know ?
- Quay side, warehouses at ports are you sure no
unchecked POAO are stored ? - What action is taken if unchecked consignments
are found ? - Free zones Art. 24(2) of Reg. 882/2004 customs
services shall not allow their entry or handling
in free zones or free warehouses without the
agreement of the competent authority. - How is this implemented in practice?
-
17Identification and selection (4)
- Customs Rely on customs procedures, on customs
electronic systems - CCA/CA does not carry out supervision, checks in
the storage facilities to verify if all
consignments are presented first to the BIP - Operator Possibility of errors or fraud
18Transhipments
- Identification and selection can arrive from EU
ports - Documentary checks on manifests/other information
availability of information from all ships ? - Pre-notification with unloading time
- Where are consignments stored before reloading
temporary storage ? - Veterinary checks minimum, maximum time
- Harmonised approach for issuing CVEDs
19Veterinary checks in BIPs (1)
- Are consignments directly presented to the BIP
and are mixed consignments screened for the
presence of POAO? - Are the quay sides where the unloading of the
consignments takes place within the same customs
designated area as the BIP? - Is customs supervision of the consignments
ensured when they have to be transported to the
BIP? - Equipment and premises present for all categories
for which BIP is approved (i.e. for housing live
animals pending results of laboratory test,
equipment for checking bulk consignments, pet
animals e.g. micro chip reader)
20Veterinary checks in BIPs (2)
- Documentary Correct model certificate? Forgery?
- Correctly completed?
- TC eligible? Residue plans approved ?
- Establishments eligible?
- Identity Container seals, carton labels
- Comparison of information in health
certificate - Animal identification and animal welfare
checks - Physical Sensory examinations
- Simple physical or chemical tests
- Laboratory tests microbiological, residues
- Re-inforced checks following Safeguard
Decisions/RASFF - Live animals clinical examination and welfare
checks - Decision on consignment Transits, rejections,
channelling, re-imports, exemptions from checks
(e.g. samples)
21Measures to detect illegal imports
- Passengers
- information to travellers posters/leaflets
- announcements on ferries/cruises
- checks (targeted) travellers, baggage, parcel
post - sanctions
- destructions
- Freight
- customs profiling, selection criteria and
priorities (often not POAO) - recent developments OLAF
- response to avian influenza outbreak increased
awareness
22Accompanied pet animals
- Checks usually done by customs
- List of entry points dogs, cats, ferrets, birds
- Instructions?
- Co-operation agreements?
- Requirements?
- Meaning of Annexes (titration test,)?
- Maximum numbers (gt 5 to BIP) accompanied by owner
- Equipment (readers for micro chips)
- Sanctions or which action if discrepancies were
detected?
23Summary FVO findings (1)
- Implementing Measures
- Instructions guidelines
- Progress, however, in some MS problems were
noted, not always centrally coordinated leading
to inconsistencies sometimes not detailed enough
or incomplete. - Monitoring plans (Annex II Regulation (EC) No
136/2004) - some variations with plans and its
implementation, the reporting requirement not
fulfilled in most MS - CITES list
- Not consistent with BIP list in a number of MS
- Old list 2 Countries for Fishery products
- Now in Regulation (EC) No 2076/2005 no list of
establishments and no measures to ensure stay on
National market
24Summary FVO findings (2)
- Organisation of import/transit control system
- Veterinary Organisation
- Staff some problems at individual BIPs (not all
tasks done) - Training many MS was in place, sometimes problems
with delivery to all staff or to staff in other
services. - Supervision and monitoring
- Most MS have progress in this regard
- Some cases follow up of identified problems was
problematic - Co-operation between involved services
- Generally improvement noted, ad hoc and
formalised co-operation but still problems with
sharing of electronic information on arriving
consignments in systems of other services
25Summary FVO findings (3)
- Operation of import/transit control system
- Documentation and Registration
- Documentation some individual omissions, basic
documentation usually available, problems with
channeled lists, warehouse lists and animal
health requirements for other MS - Records/Registers TRACES now used often problems
with information not recorded in system, lab
sampling, re-dispatched consignments. Follow up
registers and records regarding kitchen waste
also problematic. Individual logs for ICs not
always in place. - Communication
- TRACES used but some variations still being
observed and problems noted especially regarding
data input errors. Also problem in that
consignment may arrive before TRACES message.
26Summary FVO findings (4)
- Operation of import/transit control system (ctd)
- Facilities equipment and hygiene
- Generally improvement, more problems with live
animal facilities, generally improvement in
equipment and hygiene - Many problems with facilities due to reluctance
to take enforcement action by MS CA. - Identification and selection of consignments
- Variation in implementation of automatic flagging
in Customs systems for import and generally not
in place for transits - Problems with temporary storage before checks,
lack of pre-notification of consignments,
verification activities e.g. manifest checks etc - Veterinary Checks and follow up of consignments
- Documentary checks, channeling, re-imports and
re-dispatched consignments are problematic, as is
Article 24. Reduced checks improvement as most MS
have a system - Live animals, temporary imports of horses. route
plans and requirements for other MS for
non-harmonised animals
27Summary FVO findings (5)
- Operation of import/transit control system (ctd)
- Transit supervision
- Transit some problems with notifications to and
confirmation of exit by the BIP of exit and in
the follow up of these consignments by the entry
BIP - Problems with notification of warehouses.
- Problems with identification at exit BIPs
- Non-EU complying consignments
- Not all MS have approved warehouses or suppliers
according to Art 12 and 13 - Some problems in records registers by operator
and with segregation - Generally improvement noted but follow up of
exit not fully in place and notifications between
entry and exit BIPs and discovery in exit BIPs - Transhipments BIPs often not aware
- Supervision of disposal of kitchen waste
- BIPs often unable to demonstrate awareness of
destruction system - Some shortcomings in recordkeeping and
documentation by operators
28Summary FVO findings (6)
- Operation of import/transit control system (ctd)
- Supervision of passenger luggage
- Usually customs responsibility some problems with
destruction and provision of information to
travellers, at road BIPs problems with lack of
seizure (passenger not allowed entry) - Customs often unclear of allowances.
- Controls on accompanied pet animals
- Problems with lists of entry points and with
provision of information to public, travelers and
control staff - Some shortcomings with the provision of equipment
e.g. micro chip readers - Some issues to do with training and instructions
as in some MS control staff unclear about
requirements for rabies antibody titration
29New approach
- Regulation (EC) No 882/2004 Art. 45 (1) general
audits of MANCPs - Art. 45 (2) specific sectoral audits to
supplement general audits - Risk based selection of MS and BIPs to be
inspected - Process has started pilot in 2007 in 2 MS
- 2008 in 7 MS general audits ongoing throughout
the year - Focus will be on system and MS ability to
demonstrate they can and do implement it
30- Thank you for your attention !