FVO reports – Import controls for plant health in Italy and Xylella fastidiosa crisis

In case you are still surprised about the Xylella fastidiosa outbreak in the Region Apulia, in the south of Italy, which between 2014 and 2015 nearly destroyed the Italian olives harvest, you should read the following Food and Veterinary Office’s reports (n. 2014-7327, Nov. 2014, 2015-7212, June 2015 and 2015-7580, Nov. 2015) and my former article about the topic, “Plant health: Xylella fastidiosa outbreak in Italy and damages to olive trees”.

The overall picture is still not encouraging after 2 years…

Plant health import controls

“This report (2015-7603) describes the outcome of an audit carried out in Italy from 8 to 17 September 2015. The objectives were to audit the capability and the performance of the official bodies responsible for import controls and the adequacy and effectiveness of import checks carried out for plant health purposes to ensure compliance with EU requirements.

Particular attention was paid to follow up on the action taken in Italy in response to the recommendations of previous reports. Overall, some progress has been made in Italy since the previous audit (2013). The planned (comprehensive) national computer-based manual of procedures has become operational recently. It has a significant potential to address a number of the weaknesses of the plant health import control system. Certain recommendations of the previous audits have now been satisfactorily addressed, and the actions planned in response to the remaining recommendations are ongoing, albeit with a delay.

Many of the shortcomings identified during the previous audit are still present, in particular, the shortage of resources, the lack of instructions and specific technical training to carry out meticulous plant health checks. In most of the regions visited, phytosanitary risks presented by the imported commodities are not taken into account and adequate inspection facilities, although available, are not used. Therefore, the current plant health import control system does not ensure that these controls are risk based and effective. This is reflected in the number of interceptions notified by Italy of imported plant consignments and of wood packaging material originating in all Third Countries which is low compared to the volume of trade.

Xylella fastidiosa (Nov. 2014 – follow up Feb. 2014)

This report (2014-7327) describes the outcome of an audit carried out by the Food and Veterinary Office (FVO) in Italy, from 18 to 25 November 2014, following an earlier audit in February 2014.

The objective of the audit was to evaluate the plant health situation and control measures applied for Xylella fastidiosa (Well and Raju), in particular, the implementation of Commission Implementing Decision 2014/497/EU of 23 July 2014.

The audit team found that: Extensive human and financial resources have been made available for research and containment of Xylella fastidiosa, and there is a good level of awareness about the problem. With one exception, none of the eradication measures required by Decision 2014/497/EU, have been carried out. The situation has deteriorated since the last audit and Xylella fastidiosa continues to spread rapidly. The current Italian policy for the Infected Zone is now containment of Xylella fastidiosa and measures aiming at full eradication of the pest are not carried out. The current controls do not ensure that host plants not fulfilling the requirements of the EU Decision remain in the Demarcated Area. All the existing garden centres located in the Demarcated Area have not been identified and, therefore are not officially controlled. There is a possibility that not all host plant species have been identified and pathogenicity tests for a range of genera (including Vitis and Citrus) have not been concluded.

Until the precise host range of Xylella fastidiosa is known, the movement restrictions in place (although applied to a wider range of species than required in the Decision) do not provide adequate security that no infected plants leave the area. The proposed intensive surveys in the Eradication Zone, Buffer Zone and Security Zone, will help in the early detection of Xylella fastidiosa and enable the implementation of rapid eradication. This strategy could also limit the natural spread of the insect vector to new areas. However, taking into account the high populations and the passive mobility of the insect vector (vehicles, wind), the protective function of the two zones is questionable. There is a significant risk of further spreading of Xylella fastidiosa outside the Demarcated Area.

Xylella fastidiosa (June 2015)

This report (2015-7212) describes the outcome of an audit carried out by the Food and Veterinary Office (FVO) in Italy from 8 to 19 June 2015. The objectives of the audit were to evaluate the plant health situation and control measures applied for Xylella fastidiosa in Italy and in particular, the implementation of Commission Implementing Decisions 2014/497/EU and 2015/789/EU.

The audit was carried out in addition to the planned FVO programme following a further significant and rapid spread of Xylella fastidiosa in Apulia in early spring 2015 and the declaration of a state of emergency by the Italian Council of Ministers of February 2015.

The authorities responsible for the official controls of Xylella fastidiosa have developed a plan for the implementation of national legislation and the EU Decisions, which provides a sound basis for the control of Xylella fastidiosa, including surveillance, agricultural measures to suppress the vectors, movement restrictions for plants, the eradication of new outbreaks and infected plants and communication with producers and stakeholders. The FVO team found no evidence at the time of the audit, of any critical technical, resource, or general legal constraints which would prevent the authorities from implementing these measures, especially since the declaration in February 2015 of a state of emergency for Xylella fastidiosa in the Apulia region.

However, it was found that many of these measures have only been partially implemented or not implemented at all. In particular, a total of only 111 trees have been destroyed in Apulia since the first confirmation of Xylella fastidiosa in 2013. In the specific case of the Oria outbreak, only seven of the 37 infected trees have been eradicated since the outbreak in March 2015. There are now 52 infected trees in that area. The existing programme of surveys is not effective to allow for the timely detection of new outbreaks or the accurate determination of the true extent of the spread of Xylella fastidiosa.

The measures implemented so far have clearly not been sufficient to prevent the further rapid spread of Xylella fastidiosa within the Demarcated Area and, in the absence of concerted action, and full implementation of the necessary measures and effective engagement with stakeholders, the further rapid onward expansion of the disease is inevitable.

Xylella fastidiosa (Nov. 2015)

This report (2015-7580) describes the outcome of an audit carried out by the Food and Veterinary Office (FVO) in Italy from 10 to 20 November 2015. The objective of the audit was to evaluate the situation and control measures applied for Xylella fastidiosa in Italy and in particular, the implementation of Commission Implementing Decision 2015/789/EU of 18 May 2015 setting out protective measures. The action taken to address the recommendations of the previous audit on this topic was also evaluated.

This was the fourth audit to Italy on this topic; it followed developments in the national measures for X. fastidiosa, including the adoption of an action plan, and a further significant and rapid spread of the disease. The audit found that there have been some positive developments since the previous audit on this topic in June 2015. An action plan, aimed at the eradication and containment of X. fastidiosa within the demarcated area, and supported by a revised legal basis and the payment of compensation for some of the losses arising from the removal of plants, was in place.

An annual survey for the presence of X. fastidiosa has been carried out, and no evidence of the presence of the disease outside of the demarcated area has been found. However, the limited number of sites monitored in the general territory reduces the reliability of the claimed lack of presence of X. fastidiosa on the territory. This is particularly so in the area of Puglia north of the surveillance zone, which is at the highest risk from the natural spread of the disease, but which was subject to no, or only minimal, inspections. Surveys have also been carried out in the demarcated area, however the level of visual inspections applied in the surveillance zone and buffer zone is very significantly below that required by Articles 8(2) and 6(7) of Decision 2015/789/EU. The existing programme of surveys still does not ensure the timely detection of new outbreaks or the accurate determination of the true extent of the spread of X. fastidiosa in the demarcated area.

Action is now being taken in response to findings of X. fastidiosa in the demarcated area. The felling programme, which is subject to a number of significant constraints, is ongoing, however there is still a very substantial number of infected plants and host plants within 100m radius of such plants to be removed, outside of the province of Lecce.

The limited removal of plants is not in compliance with Article 6(2) of Decision 2015/789/EU, which requires that such plants are immediately removed and destroyed. There is a similarly substantial number of infected plants in the containment zone, within a distance of 20km of the border of the Province of Lecce, which have also not been removed and destroyed immediately, as required by Article 7(2)(c) of the Decision. A significant number of the plants concerned are subject to ongoing legal appeals, however it is of real concern that so many infected plants, and plants at very high risk of infection remain in place, given the evident consequences for producers in the affected areas and the onward and rapid spread of the disease to new areas and new producers.

Unless effective eradication and containment measures are implemented, the further rapid spread of the disease throughout the region is inevitable.

Canada – CFIA recognises a role for private standards within the regulatory framework

This interesting policy, released by the Canadian Food Inspection Agency (CFIA), has to be considered probably a “best practice” and I am sure in future we will see more and more similar public-private cooperation models.

Since the international private standards are so widely used in the food chain, and since they set higher standards then public regulations, why don’t we start to consider them as an helpful tool to prioritize official controls and optimise a risk based approach to food safety? Looking to the current globalisation and to the lack of resources that affect most of the competent authorities, it seems quite a reasonable option. This will be also an incentive to companies and private standard’s owners to ensure that their schemes are consistently implemented and auditing systems are effective. The application of a  recognised standard will result in less burdens and controls from the public competent authorities on the food business operator.

Here below some paragraphs from CFIA policy, that comes into effect on September 3rd, 2015.

Policy Statement

In determining the level of risk associated with a regulated party or their establishment, the CFIA may assess the requirements of a private certification scheme used by the regulated party against food safety regulatory requirements and factor the assessment results into its risk-based planning and prioritization.

It should be noted that there is no requirement by virtue of this policy for a regulated party to become certified to any private certification scheme nor does this negate regulatory oversight.

Objectives

  1. Support an understanding of voluntary, industry-adapted private certification schemes, and the role such private certification schemes may play in achieving compliance with CFIA food safety regulatory requirements;
  2. Provide direction on how industry’s investment in an appropriate private certification schemes will be considered within the CFIA risk-based regulatory framework; and
  3. Provide a foundation to inform future discussions on broader consideration of private certification schemes within the CFIA regulatory framework.

This policy aligns with the direction and requirements provided in the CFIA Program Policy Management Framework for the management of CFIA program policies.

Scope

As private certification has a much wider market penetration in food safety, and that the CFIA food safety program is more advanced in its modernization efforts, while initially this policy will apply to program design and delivery of CFIA‘s risk-based oversight of domestic and imported food, as it relates to food safety, the CFIA is committed to expanding the scope to other aspects (e.g. labelling) and the plant and animal health programs as applicable.

The CFIA will continue to explore other approaches to leveraging industry’s use of private certification schemes in support of public policy objectives.

Background

Private certification schemes are voluntary systems that set process and product requirements as well as the means of demonstrating conformity with these requirements. Companies implement private certification schemes to manage risk, facilitate effective management of products along the supply chain and differentiate products. In recognition of the importance of public endorsement by regulatory bodies, some private certification schemes have been developed with government support and regulatory oversight.

Private certification schemes are a prominent part of the world food supply system and are increasingly being used by industry as a means of achieving food safety and other outcomes. Demand for food safety private certification schemes comes from both the food industry and consumers.

There is a wide range of private certification schemes and many suppliers are facing requirements for multiple audits and certifications. As a result, international efforts are underway to harmonize private certification scheme requirements in order to help reduce costs and improve predictability in market requirements. With respect to food safety, there are global benchmarking initiatives such as the Global Food Safety Initiative (GFSI) and the International Federation of Organic Agriculture Movements (IFOAM) that provide a platform for collaboration between some of the world’s leading food safety experts from industry, international organizations, academia and government on global benchmarking of private certification schemes.

The Canadian Food Inspection Agency (CFIA) is transforming how it delivers its food safety programs and activities to better meet the needs of today’s consumer and industry. The CFIA recognizes that private certification schemes may play an important role in helping industry achieve food safety regulatory objectives, provided they can be assessed as being effective, credible and aligned with public policy objectives.

Private certification has been identified as one of several factors that CFIA will consider in its modernized approach to risk-based oversight. While the CFIA has always incorporated risk into its approach to food safety oversight, a modernized approach will enable improved risk-management by using private certification data to inform CFIA risk-based planning and prioritization within the regulatory framework, and as a resulting consequence, more targeted compliance verification.

Private certification is not intended to replace regulatory enforcement authorities; however, it may complement food safety regulatory oversight. The CFIA will continue to verify compliance of regulated parties; the type, frequency, and intensity of the CFIA‘s oversight activities will be proportional to the risks that need to be managed.

Changing Global Economy

The ways in which food, animals and plants are produced and marketed have changed dramatically. The complexity of the production and distribution landscape has increased, driven by changes in methods of production and processing and increases in international trade. As a result, the challenges of carrying out regulatory oversight are multiplying. Given the growing importance and prevalence of private certification systems, it is important and timely to understand the challenges and opportunities that they present to the CFIA.

Fixed Resource Base

Compounding the inherent complexities associated with a changing global economy, the CFIA is mandated to manage multiple demands and risks (e.g., safety, consumer protection, market access) across multiple sectors (i.e., food, plant, animal). Given that it operates within a fixed resource base, the Agency must optimize its resources by investing in priority areas (e.g. highest risk) and in areas that produce the most significant return (e.g. reduced risk) on investment of effort/resources.

Risk-Based Approach

With pressures from increased globalization and advances in science and technology, the CFIA is modernizing its approach to inspection to maintain a robust approach to human, animal and plant health and consumer protection. The move towards a more preventative and systems-based approach under the Integrated Agency Inspection Model (IAIM) enables both the CFIA and regulated parties to more readily adapt to emerging risks and global and scientific trends.

Furthermore, the CFIA is developing a systematic, transparent and documented method of comparing risks within and across its business lines in order to align strategies, priorities and resources accordingly. This will be accomplished through the development of the CFIA Integrated Risk Management (IRM) Framework.

Expanding Authorities in Food

Currently, the CFIA can license register establishments for activities that relate to some food commodities The new Safe Food for Canadians Act includes provisions that will enable the CFIA to use licensing and registration for all food commodities. In particular, the current non-federally registered sector is a large and diverse food sector that has not previously been subject to CFIA registration or licensing requirements. With an estimated 50,000 regulated parties, many of whom were previously unknown to the Agency, this sector alone represents a significant increase to the number of establishments for which the Agency must consider in its risk-based oversight. It is anticipated that many of these establishments will have implemented a type of private certification scheme. Certification to a private scheme that has been assessed as meeting some or all regulatory requirements will be extremely useful information in assessing risk and determining appropriate regulatory response and oversight for all food commodities.

Existing Agency Initiatives

There are several existing Agency initiatives that have informed the development and implementation of successful programming in support of this policy such as the Food Safety Recognition Program (FSRP), the CFIA use of the Animal Nutrition Association of Canada Feed Assure program, the Canada Organic Regime and Seed Certification System. The FSRP will be particularly instrumental to the development of programming in support of this policy.

The FSRP process involves an evaluation of the technical soundness and administrative effectiveness of food safety systems developed and implemented by Canada’s national (or equivalent) industry organizations. National food industry organizations from the on-farm or post-farm non-federally registered sectors can voluntarily submit their food safety systems to the CFIA FSRP team.

To date, the CFIA has not taken the investments companies have made in the FSRP into consideration in its risk-based oversight approach. The CFIA Private Certification Policy (Food Safety) will be a bridge between the FSRP and theCFIA risk-based oversight.

(Source: CFIA website)