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SA PIP COLEACP PRESENTATION

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European regulations & food safety requirements for fresh fruit & vegetables ... fungicide Thiabendazole (TBZ) from ware potatoes ... – PowerPoint PPT presentation

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Title: 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

5
PESTICIDES Is there a problem ?
6
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

7
FEAR
8
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)

9
Response by the European Commission
  • 1
  • Review of Existing (1993)
  • and
  • new Active Substances

10
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  • List Nr a.s Annex 1 Withdrawn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)

11
Response by the European Commission
  • 2
  • Review of
  • Maximum Residue Levels (MRLs)

12
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

13
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

14
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

15
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

16
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

17
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

18
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

19
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

20
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

21
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

22
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.

23
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)

24
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)

25
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

26
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

27
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

28
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

29
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

30
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

31
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

32
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.
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