SA PIP COLEACP PRESENTATION

1
SA PIP COLEACP PRESENTATION

• Part 1
• European regulations food safety requirements
  for fresh fruit vegetables
• from South African growers
• ------------------------------------
• Expectations of European clients

2
What is COLEACP ?

• Europe Africa Caribbean Pacific Liaison
  Committee for the promotion of
• ACP horticultural exports.
• ---------
• David Hirst
• UK Representative
• Website www.coleacp.org

3
COLEACP structure

• Not-for-profit professional association
• Membership /- 100
• ACP exporters
• Exporter associations
• Cooperatives
• Marketing boards
• EU importers
• Representative bodies (e.g. FPC)

4
COLEACP activities

• Private sector focus for EU funding
• Pesticide Initiative Programme (PIP)
• Partnership building
• Information transfer (trade, regulations)
• Joint consultations (Freshfel, FPC, etc)
• Liaison with authorities (EU Commission, ACP
  Secretariat, Governments)
• Representing ACP interests

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PESTICIDES Is there a problem ?
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So what is the fuss all about?

• Confusion over EU and national MRLs
• Barriers to cross-border movements
• Out-dated scientific data
• Public health and consumer food safety concerns
• Environmental concerns
• Health and safety at work
• Pressure groups (greens consumer groups)
• Media
• Food scares

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FEAR
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Fear of what?

• Damage to health
• Genetic interference
• Risks for children and vulnerable groups
• Unknown cocktail effects
• Lack of control over movements (BSE, FM)
• Damage to environment (Silent Spring,
  desertification)
• Unsafe working environments
• Loss of nutrient quality ? (vs organic)

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Response by the European Commission

• 1
• Review of Existing (1993)
• and
• new Active Substances

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EU Directive 91/414/EEC Situation September
2004(DG Sanco Doc 3010 09/2004)

• Existing A.S.
• List Nr a.s Annex 1 Withdrawn
  On-going Date of completion
• 1 90 AS 40 27
  23 2005
• 2 148 AS - 97
  51 2005
• 3 400 AS - 238
  162 2008
• 4 341 AS - 87
  254 2008
• Total 979 40 449
  490
• New A.S.
• Annex 1 Withdrawn On-going
  Total
• 53 7 48
  108
• Annex I 93
• withdrawn 491 (incl. 18 not PPP and 24 banned)

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Response by the European Commission

• 2
• Review of
• Maximum Residue Levels (MRLs)

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Directives 76/895, 86/362, 86/363, 90/642EEC
Situation September 2004

• Status of EU MRLs.
• Annex 1 likely to stay Harmonised
  Not harmonised
• Existing AS 40 490
  94 323
• New AS 53 101
  39 62
• Total 91 591 133
  ca. 385
• Withdrawn
  Harmonised Not harmonised
• Existing AS 449
  66 383
• New AS 7
  0 7
• Banned (79/117/EEC) 24 24
  0
• Total 480
  90 ca. 390
• Grand Total 223 ca. 775

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Effects on SA Producers/Exporters

• Loss of pesticide options, especially for minor
  crops
• Increased risk of diseases and pests resistence
• Lower yields
• Loss of crop quality
• Increased costs
• Reduced profits
• Exclusion of some crops
• Loss of some markets
• SERIOUS HEADACHES

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Are there any solutions?

• Import Tolerances (Doc. 7196/VI/99 rev.1)
• An IT is an MRL for imported products of which
  are not
• produced in the EU
• - PPP with approved use in RSA
• - National certificate of registration
• - Adequate data package
• - GAP
• - No significant health or environmental
  risk

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Are there any solutions? (cont)

• Extrapolation (Doc. 7525/VI/95-rev.7)
• Transfer of MRL between crops of similar type,
  and between regions with similar growing
  conditions
• - Crop grouping
• - 75 similarity in growth cycle
• - comparable GAP
• - suggestion to use as often as
  possible

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MRL extrapolation a practical example

• Extrapolation for a post harvest pesticide MRL is
  
• more likely to be possible, while that for a
  pre-harvest pesticide can be more complicated.
• COLEACP has introduced a request for
  extrapolation
• of the MRL (15 mg/kg) of Syngentas post
  harvest
• fungicide Thiabendazole (TBZ) from ware
  potatoes
• to tropical root vegetables such as yam,
  cassava and sweet potato

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Thiabendazole MRL extrapolation

• Documents required for the MRL
  extrapolation
• A certificate of registration in an EU country
  for
• TBZ on ware potato obtained by Syngenta
• A consumer risk assessment based on the
• WHO GEMS/ Food Regional Diets (revised
• version 2003) showing that the TMDI (Total
• Maximum Daily Intake) is smaller than the
• ARfD (Acute Reference Dose)
• A certificate of registration in the application
• country (in this case Jamaica or Ghana) for
  TBZ
• on tropical root vegetables

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Expectations of EU importers and retailers

• Due diligence defence against prosecution
• Protection of commercial image/reputation/market
  share
• Commercial advantage in competitive market
• Food safety consumer confidence
• Traceability (beyond EU legal requirement)
• Transparency
• Quality assurance - HACCP
• Codes of practice certification (according to
  client)
• PROFIT

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Consequences of non-compliance

• In case of MRL exceedence
• Brand naming and shaming (UK may become EU)
• Prosecution
• Possible fines/imprisonment
• Withdrawal of product
• Fines up to 72,000 on supplier (if withdrawn)
• De-listing of producer
• Loss of image for origin

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SA PIP COLEACP PRESENTATION

• Part 2
• How COLEACP represents the interests
• of ACP producers and exporters and assists
• them to adapt to the changing EU regulations
• through the PIP

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COLEACP Pesticides Initiative Programme (PIP)

• Background
• EC review of AS (91/414 EEC) and MRLs lack of
  communication. Trade (apart from UK) unaware of
  threat
• COLEACP directed trade and EU Commission
  attention to implications for ACP exports -
  June 1999
• Initiation of impact study and trade enquiry -
  1999
• Joint approach with FPC/NRI (DfID) to EC - 1999
• Submission of proposed 3 - year action plan
  April 2000
• Launch of 5 - year PIP 28.8 July 2001

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COLEACP Pesticides Initiative Programme (PIP)

• Objectives principles
• Alleviate negative impact of EU pesticide
  regulations for ACP exports (special needs of
  tropical/sub tropical minor crops)
• Interventions in response to requests from
  private sector
• Cost- sharing of programmes (max 50 ACP
  contribution)
• Sustainable solutions and adaptation of practices
  to ensure compliance of export produce
• Local capacity-building for ACP companies,
  institutions, service-providers, laboratories,
  Task Forces
• Establish and maintain on-going information
  communication.

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COLEACP Pesticides Initiative Programme (PIP)

• Structure - PIP-MU - 4 Main components
• Good Company practice
• Regulation and residues
• Capacity-building
• Information communication
• Training Unit (since Jan 2004)

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Good Company Practicecomponent

• Accepts applications from ACP companies or groups
  for assistance to achieve (or maintain)
  compliance
• Develops tailored support plans for successful
  applicants according to needs (training,
  quality/traceability systems, ICM/IPM, progress
  towards commercial code certification)
• Signs Memoranda of Agreement and sets up
  financing plans
• Local service-providers used wherever possible.
• To date
• 254 intervention applications received from 21
  ACP countries
• 144 MoA signed, 110 under review
• 94 companies with total 300,000 t/a (70 of trade
  flow)

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Regulation and Residuescomponent

• Identifies key problem areas for ACP producers
  resulting from new EU regulations, review of
  pesticide approvals and MRLs
• Works closely with DG Sanco to ensure that
  specific needs of tropical/minor crops are taken
  into account
• Review of crop protocols for 9 selected crops
  (avocado, mango, papaya, passion fruit,
  pineapple, green beans, cherry tomato, okra,
  mangetout peas)
• Partnership agreements signed with Crop Life
  International and major pesticide manufacturers
  leading to-
• Cooperation in establishing field trials for new
  crop protocols and preparation of Import
  Tolerance files where necessary
• Contribution to harmonisation of ACP local
  regulations

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Field trials results

• Cherry tomato (Senegal) 23 AS tested no MRLs
  exceeded no IT request
• French beans (W.Africa) 24 AS tested 7 ITs
  required
• French beans (Kenya) residue results due Dec 2004
• Papaya (W.Africa, Jamaica) results due Dec 2004
• Mango (W.Africa) results due end Nov 2004
• Pineapple (W.Africa) results due Dec 2004
• Avocado, Passion fruit, Mangetout trials planned

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Capacity-building component

• Works hand-in-hand with other components
• Capacity-building support for
• Companies with PIP programmes
• Sector support structures
• Quality of services
• Setting up and functioning of local Task Forces
• Encourages synergies with other programmes (World
  Bank, Pro-Invest, UMOEA Quality Programme)
• To date
• 44 C-B agreements being implemented, 50 under
  review
• 9 TFs in place, 6 in WA, 2 in EA, 1 in Carib

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Information communication component

• Represents a one-stop source of information on
  pesticides, residues and EU regulations for
  stakeholders
• Provides an on-line question/answer service by
  email or via website (questions _at_coleacp.org -
  www. coleacp.org/pip)
• Gives regular regional briefings in ACP countries
• Present at main trade events
• Programme of relations with specialised media,
  articles in trade journals, radio/TV programmes
  etc
• Regular Info-PIP newsletter (also on website)
• Quarterly PIP magazine (also on website)
• Links to other websites and information sources

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Training Unit

• Operational since Jan 2004
• Steered by Gembloux Agronomy Faculty (Belgium)
• Training local instructors (sustainability
  cornerstone)
• Quality traceability managers
• Company production out-grower managers
• Packhouse and hygiene managers
• 22 Group training workshops in 2004
• à la carte in-company training sessions
• Published 8 Training Modules multi-choice
  questionnaires
• Future decentralised training courses as CD-ROMs

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How can SA producers adapt?

• Carry out comprehensive audit to ensure
• Substances to be used on a crop are approved for
  use
• Residues resulting from correct use are less than
  MRL
• If an approval has been withdrawn in the EU and a
  residue above LOD results from local
  label-recommended use
• try less critical crop protocol (consult
  manufacturer)
• look for an alternative chemical
• seek an alternative crop protection method
• initiate work to establish an Import Tolerance
• explore the possibilities for extrapolation
• Frequently check EC and other websites (COLEACP,
  PSD, SAPIP?) to keep up with regulations changes
  taking place

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Useful contacts

• Always keep in close touch with your EU customers
• Two things to remember
• Say before you spray
• If in doubt, give em a shout
• EC websites
• www. europa.eu.int/comm/food/plant/protection/eval
  uation/index_en.htm
• www. europa.eu.int/comm/food/plant/protection/eval
  uation/exis02_a.pdf
• http//europa.eu.int/eur-lex/en/search
• COLEACP PIP website www.coleacp.org/pip
• UK PSD website - www.pesticides.gov.uk

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Small Producers Guide

• SMALL PRODUCERS IN EXPORT HORTICULTURE
• A Guide to Best Practice
• CD-ROM produced by DFID and NRI (with COLEACP
  and other trade consultation)
• Explains the procedures that must be followed
  throughout the supply chain to supply
  horticultural products of the quality demanded by
  European customers.