Guidelines for Single Integrated MultiAnnual National Control

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Guidelines for Single Integrated Multi-Annual
National Control

• Presentation to workshop Implementation of
  Regulation 882/2004
• Brussels 28 June 2005
• By
• Maura Waters,
• Deputy Head of Unit F6 Quality Planning and
  Development
• (Food and Veterinary Office, DG SANCO)

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Background I

• Regulation 178/2002
• food law must be based on risk
• traceability
• imports shall meet EU standards/equivalent
  standards/standards laid down in agreement
• unsafe food shall not be placed on the market
• Article 17 (2) Member States shall
• enforce food law and monitor and verify that
  relevant requirements are met
• maintain a system of official controls and other
  appropriate surveillance and monitoring
  activities covering all stages of production,
  processing and distribution of feed and food

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Background II

• Regulation (EC) No 882/2004 of the European
  Parliament and of the Council of 29 April 2004 on
  official controls performed to ensure the
  verification of compliance with feed and food
  law, animal health and animal welfare rules
• (Official Feed and Food Control Regulation)
• (OJ L 165, 30.4.2004, p.1 and corrigenda OJ L
  191, 28.5.2004, p.1 )

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Control Framework

• Articles 41 to 46 of 882/2004
• Integrated national control plans (MANCP)
  (Articles 41 and 42)
• National audit systems (Article 4.6)
• National reports (Article 44.1)
• Commission guidelines (Article 43 44.2)
• Commission controls (Articles 45 46)
• Commission reports (Article 44.4 -44.6)

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Legal Basis

• Article 41
• In order to ensure the effective implementation
  of Article 17 (2) of Regulation (EC) No 178/2002,
  of animal health and welfare rules and of Article
  45 of this regulation each Member State shall
  prepare a single integrated multi-annual national
  control

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Commission Guidelines for NCPs Procedures and
Objectives

• Guidelines non-binding but MS shall take
  account
• be revised in the light of annual reports or
  audits and controls by the Commission
• promote consistent, comprehensive and integrated
  approach covering all sectors and stages
• reflect standards and recommendations made by
  relevant international bodies regarding
  operation of official services
• encourage adoption of best practices at all levels

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COM Guidelines for NCPs preparation

• Work advanced at Commission level
• Internal DG SANCO and external Inter-Service
  consultations ongoing
• Consultation with MS in working group
• Working Group on Audit Guidelines has met
• Legal form a Commission Decision establishing
  guidelines set out in Annex
• Adoption by Commission following consultation
  with MS through Standing Committee (advisory
  procedure)

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Commission Guidelines for NCPs Phase 1

• to be developed incrementally
• lay down criteria for conduct of internal audits
  of national competent authorities
• lay down the structure of, and information to be
  included in
• (a) national control plans, and
• (b) annual reports thereon
• presentation of information from third countries

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COM Guidelines for NCPs Phase 2 and later

• lay down performance indicators to be applied in
  assessing national control plans
• identify risk based and other priorities and most
  effective control procedures
• identify points in chain which provide most
  reliable and indicative information about
  compliance with law
• provide advice on development of systems to
  record performance and results of control actions
• encourage the development of effective
  traceability systems

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Guideline for MANCP (1)

• Target must be realistic and achievable by all
  Member States
• Impact of new legislation
• No legal requirement to establish a separate body
  for purpose of developing and managing MANCP
• MS will be asked to nominate single contact point
  for correspondence regarding plan
• Control plans should cover all points mentioned
  in Article 42.2
• Good description of organisation and management
  of various control services and cover all
  activities and stages of production

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Guideline for MANCP (2)

• Article 41 - Single integrated multi-annual
  control plan
• Article 42.2 - General information on structure
  organisation of national control systems
• strategic objectives and how reflected in
  prioritisation of controls and allocation of
  resources
• designation of competent authorities and their
  tasks at central, regional and local level, and
  resources available
• general organisation and management of official
  control systems at all levels including
  individual establishments

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Guideline for MANCP (3)

• Article 42.2 continued
• systems applied in different sectors and
  co-ordination between different services in
  charge of these sectors
• where appropriate, delegation of tasks to control
  bodies
• methods to ensure compliance with requirements
  regarding
• operational criteria
• documentation of procedures
• training of staff performing official controls
• contingency plans for disease and other
  emergencies
• organisation of co-operation and mutual assistance

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Guideline for MANCP (4)

• Guidelines will not prescribe how controls should
  be carried out, i.e. control activities, methods,
  techniques and frequency of controls will not be
  indicated
• Control activities must comply with specific
  requirements of Community legislation where
  applicable
• MANCP will not replace requirement for specific
  control plans required by other Community
  legislation
• MS will have to justify that the control measures
  in place are effective and suitable to achieve
  objective
• Guidance on the form and extent of the
  information required will be provided
• Plan should provide for compilation of supporting
  evidence to allow verification of compliance,
  effectiveness and suitability

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Guideline for MANCP (5)

• General guidance on requirements
• Guidance on Format
• Overall national strategic objectives
• Designation, structure and organisation of
  competent authorities
• Organisation and management of official controls
  by CA and delegated bodies
• Resources human, facilities and infrastructure
• Co-ordination of activities, cooperation,
  contingency plans and mutual assistance
• Arrangements for audit of competent authorities
• Measures to ensure compliance with operational
  criteria of regulation 882/2004
• Procedures for review and adjustment

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National Control Plan

• Control plans to take account of identified risks
• experience and knowledge from previous controls
• reliability of operators own controls
• suspicion of non compliance
• cover all stages of production
• frequency of controls appropriate to achieve
  objectives

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Operational Criteria (1)

• Official controls must be effective
• Staff free from conflicting interest
• Adequate laboratory capacity
• Adequate facilities and equipment
• Legal powers
• Contingency plans
• Impartiality, quality and consistency
• Internal or external audits of all CA

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Operational Criteria (2)

• Co-ordination and co-operation within and between
  all CAs
• Art. 4.3 - competence conferred on an authority
  other than CCA, such as regional or local
  authorities, there must be efficient and
  effective coordination between all authorities
• Article 4.5 where more than one unit within CA
  involved there must be efficient and effective
  coordination and cooperation

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Operational Criteria (3)

• Continuous training of staff
• Documented procedures
• Verification procedures
• Transparency
• Delegation of control tasks
• Reports

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• Integrated National Control Plans must be
  implemented by 1 January 2007 at the latest
• (Article 42.1 (a) 882/2004)

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• Thank You
• Maura Waters
• Deputy Head of Unit F6 Quality Planning and
  Development
• Food and Veterinary Office
• Tel. [phone]
• Email Maura.Waters _at_cec.eu.int