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Training Workshop on Veterinary Checks

In road/rail BIPs

Poland 8/6/2010 DG SANCO F5 - FVO

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Purpose and implementation of FVO missions

Problems identified at BIPs

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Currently there are 286 BIPs in 27 MS 23 BIPs in 2 EEA countries1 BIP in Faroe Islands2 BIPs in CH

35 road BIPs:PL: 6BG/LT/RO/EL: 9

11 Rail BIPs:PL: 5

LT/HU/LV: 5

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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• Verification procedures related to 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

• Internal or external audits of the import/transit control system

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FVO inspections

2007: 19 Inspections 12 Member States BIP / Import controls 2 Candidate Countries 1 EEA country

1 Equivalency Country (CH) 3 (new) MS (warehouses and transit)

2008: 16 Inspections 14 Member States BIP / Import controls 1 Candidate Country 1 Equivalency Country (CH)

2009: 17 Inspections 15 Member States BIP / Import controls 2 EEA countries

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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

Operators

Agents

CCA BIP Staff

Port, airport,rail authorities

Customs

CONSUMERS

BIP

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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• Co-ordination 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 manifests, bills of loading;

(c) other sources of information available to the commercial operators.

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Co-operation and exchange of information between services (2)

• Co-operation between customs, rail/road authorities is necessary to ensure a proper overview of consignments arriving or transiting 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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System to ensure presentation of consignments for veterinary checks (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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System to ensure presentation of consignments for veterinary checks (2)

• Very clear requirement for notification in advance of arrival of consignments on the EU territory:Artt. 3 of Dir. 97/78/EC and 91/496/EEC, Art. 2 of Reg. 136/2004, Art. 1 of Reg. 282/2004

• Verification: Cross checks of notifications with arrival information

• Availability of arrival information?

• BIP staff assume that customs will find consignments not notified or presented to the BIPs; however, custom’s 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 notified to the BIP are detected? Enforcement measures as laid down in Art. 54 of Reg. (EC) No 882/2004

• Road/rail BIPs: What system is in place to ensure exit checks on transit are carried out

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System to ensure presentation of consignments for veterinary checks (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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Veterinary checks in BIPs (1)

• Are consignments directly presented to the BIP and are mixed consignments screened for the presence of POAO?

• 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). Separate lines between imports/exports of live animals.

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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 certificateAnimal identification and animal welfare checks

• Physical: Sensory examinationsSimple physical or chemical tests

Laboratory tests: microbiological, residues Re-inforced checks following Safeguard

Decisions/RASFFLive 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)

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 (> 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,

– CITES list

• Not consistent with BIP list in a number of MS

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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 in place in many MS, sometimes problems with delivery to all staff or to staff in other services.

– Supervision and monitoring:

• Most MS have progress in this regard

• Follow up of identified problems was sometimes problematic

• Audits as laid down in Reg. 882/2004 started in 2007 and are developing

– 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

• Co-operation and coordination is now also required under Art. 4 of Reg. 882/2004

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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.

• Warehouses use the BIP log in although should have their own

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Summary FVO findings (4)• Operation of import/transit control system

– 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. Improvement for reduced checks 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

– Transit supervision:

• For transits 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 and registers by operator and with segregation

• Generally improvement noted, but follow up of exit not fully in place and shortcomings for notifications between entry and exit BIPs and discovery in exit BIPs

– 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

– 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, travellers 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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General Audit

• Consists of a General and a Specific Part

• The General Part focuses on the system as required under Reg. 882/2004

• The Specific part focuses on sector specific related issues

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Thank you for your attention !