DirectorateGeneral Health

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Directorate-General Health Consumers

• Better Training for Safer Food 2008

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• Training Workshop
• on Veterinary Checks
• in port BIPs
• Rotterdam
• DG SANCO F5 - FVO

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• Purpose and implementation of FVO missions
• Problems identified at port BIPs

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• 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

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Missions 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

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Evaluation 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

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FVO 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)

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Inspection 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

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The 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

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The 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

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Good co-operation at the BIP beneficial to all
involved parties and consumers
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Co-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.

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Co-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.

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Identification 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 ?

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Identification 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 ?

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Identification 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?

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Identification 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

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Transhipments

• 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

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Veterinary 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)

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Veterinary 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)

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Measures 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

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Accompanied 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?

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Summary 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

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Summary 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

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Summary 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.

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Summary 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

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Summary 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

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Summary 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

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New 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

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• Thank you for your attention !