EUROPEAN COMMISSION HEALTH & CONSUMERS DIRECTORATE-GENERAL
Directorate F - Food and Veterinary Office
DG (SANCO)/7596/2007 - CP Final
FINAL COUNTRY PROFILE OF POLAND
ON FOOD AND FEED SAFETY, ANIMAL HEALTH, ANIMAL WELFARE AND PLANT HEALTH
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TABLE OF CONTENTS
INTRODUCTION...... 3
1. COMPETENT AUTHORITIES AND OVERALL DISTRIBUTION OF RESPONSIBILITIES...... 4
2. COMPETENT AUTHORITIES AND DISTRIBUTION OF RESPONSIBILITIES IN RELATION TO INDIVIDUAL CONTROL SYSTEMS...... 14 2.1. Control system for animal health ...... 14 2.2. Control system for food of animal origin...... 17 2.3. Control system for imports of animals and food of animal origin...... 20 2.4. Control system for feedingstuffs and animal nutrition...... 22 2.5. Control system for TSE/ABP...... 24 2.6. Control system for veterinary medicines and residues...... 29 2.7. Control system for foodstuffs and food hygiene...... 32 2.8. Control system for imports of food of plant origin ...... 37 2.9. Control system for plant protection products (PPP)...... 40 2.10. Control system for animal welfare ...... 45 2.11. Control system for plant health ...... 48 3. FOLLOW-UP OF FVO INSPECTIONS ...... 51 3.1. Animal health...... 55 3.2. Food of animal origin...... 59 3.3. Imports of animals and food of animal origin...... 61 3.4. Feedingstuffs and animal nutrition...... 63 3.5. TSE/ABP...... 63 3.6. Veterinary medicines and residues...... 67 3.7. Foodstuffs and food hygiene ...... 67 3.8. Imports of food of plant origin...... 68 3.9. Plant Protection Products ...... 69 3.10. Animal welfare...... 70 3.11. Plant health...... 71 3.12. Overview of more recent inspections...... 72 ANNEX I – ACRONYMS, ABBREVIATIONS AND SPECIAL TERMS ...... 73
ANNEX II – OVERVIEW OF STAFF RESOURCES...... 76
ANNEX III – TRAINING SYSTEMS...... 77
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INTRODUCTION
This country profile has been drawn up by the Food and Veterinary Office (FVO), a directorate of the Directorate-General for Health and Consumers of the European Commission.
The aim is to present in summary form the latest information available to the FVO on how control systems for food and feed safety, animal health, animal welfare and plant health are organised in Poland.
The information in the country profile has been compiled from:
• recent written submissions and background documentation from the Polish authorities detailing how control systems are organised;
• the results of missions to Poland carried out in recent years by teams from the FVO and, in particular, the general review mission in Poland in December 2007 to analyse the full range of control systems for food and feed safety, animal health, animal welfare and plant health.
The country profile is presented in three parts:
• Part 1 describes the overall organisation of the Polish authorities and the respective responsibilities of the ministries and government agencies in relation to the different components of the control system. A chart is used to help the reader better understand the inter-relationships between the responsibilities of the different bodies.
• Part 2 gives a more detailed description of the main responsibilities for each of the eleven separate systems that form the complete range of control systems in Poland covering the whole chain of plant, animal and food production. Flow charts are used to help the reader.
• Part 3 contains an overview of the missions carried out by the FVO to Poland since 2003 and, for each control system, gives an assessment of specific recommendations reviewed in the general review mission of December 2007.
The country profile will be updated at regular intervals based on the results of future missions and other relevant information received by the Commission from the Polish competent authorities.
Acronyms are used extensively throughout this report for the sake of brevity. A list of acronyms, abbreviations and special terms is given in Annex I to the report as a guide for the reader.
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1. COMPETENT AUTHORITIES AND OVERALL DISTRIBUTION OF RESPONSIBILITIES
The Republic of Poland has an organisational structure consisting of a central level, 16 Voivodships (regions), 379 Poviats (districts) and 2,478 Gminas (municipalities).
In relation to the control systems for food and feed safety, animal health, animal welfare and plant health, the central level has overall responsibility. Most implementation and enforcement activities are carried out at Voivodship and/or Poviat level, with a vertical chain of command between central, Voivodship and Poviat levels. The number of sub- units at Poviat level varies slightly between the different organisations.
The main organisations involved are the Ministry of Agriculture and Rural Development (MARD) and the Ministry of Health (MH). Co-operation and information exchange between the ministries is governed by co-operation agreements, which are replicated at regional and district levels.
The following table lists the relevant authorities with responsibility for animal health, feed and food safety, animal welfare and plant health in Poland. Where available, links to internet web pages are also given. An overview of the staff resources of these authorities is given at Annex II.
Website (if Central level available) MARD Ministry of Agriculture and Rural http://www.minrol. Development gov.pl GVI General Veterinary Inspectorate http://www.wetgiw. gov.pl/ ARMA Agency for Restructuring and Modernisation http://www.arimr.g of Agriculture ov.pl/ MISPHSIS Main Inspectorate of State Plant Health and http://www.piorin. Seeds Inspection Service gov.pl/ MIAFQI Main Inspectorate of Agricultural and Food http://www.ijhars.g Quality Inspection ov.pl MH Ministry of Health http://www.mz.gov. pl CSI Chief Sanitary Inspectorate of the State http://www.gis.gov. Sanitary Inspection (SSI) pl/ MPI Main Pharmaceutical Inspectorate http://www.gif.gov. pl MF Ministry of Finance http://www.mofnet. gov.pl
MT Ministry of Transport RTI Road Transport Inspection (under the http://www.gitd.go Ministry of Transport) v.pl Regional/District Level CC Custom Chambers http://www.mf.gov. pl VVI Voivodship Veterinary Inspectorate (regional level) PVI Poviat Veterinary Inspectorate (district level) BVI Border Veterinary Inspectorate VSPHSIS Voivodship Inspectorate of SPHSIS 4 Valid as of April 2007
Field and Border units of SPHSIS VSES Voivodship Sanitary and Epidemiological http://www.gis.gov. Station (of CSI) pl/ PSES Poviat Sanitary and Epidemiological Station http://www.gis.gov. (of CSI) pl/ BSES Border Sanitary and Epidemiological Station http://www.gis.gov. (of CSI) pl/ VPI Voivodship Pharmaceutical Inspectorate www.gif.gov.pl VTI Voivodship Transport Inspectorates VIAFQI Voivodship Inspectorate of Agricultural and Food Quality Inspection
Laboratories NVRI The National Veterinary Research Institute http://www.piwet.pu situated in Pulawy lawy.pl RVL 16 Regional Veterinary Laboratories (+ 16 branches) SSI 16 integrated official food control laboratories http://www.gis.gov. (Regional level) pl/ National Institute Reference laboratory www.pzh.gov.pl of Public Health - National Institute of Hygiene (NIPH - NIH) Food and Reference laboratory www.izz.waw.pl Nutrition Institute (FNI) VSES Rzeszow - Reference laboratory (GMO in food) http://www.pis.rzesz Tarnobrzeg ow.pl/ division CL of SPHSIS Central Laboratory of the Main Inspectorate of the SPHSIS RL of the Regional Laboratories of VSPHSIS (16) VSPHSIS SPHSIS BIP Diagnostic Units in Border Inspection Posts (12) PPI Plant Protection Institute with 5 branches RIPF Research Institute of Pomology and Floriculture IIOC Institute of Industrial Organic Chemistry AFQIL 12 official MIAFQI laboratories at national level Other Bodies PCA Polish Centre for Accreditation www.pca.gov.pl/
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Ministry of Agriculture and Rural Development (MARD)
The Department of Food Safety and Veterinary Matters (DFSVM) is responsible for the transposition of Community legislation relating to: veterinary protection of public health; protection of animal health and welfare; and the quality of feeding stuff. It is responsible for presenting legislation to Parliament.
The General Veterinary Inspectorate (GVI), the Main Inspectorate of the State Plant Health and Seed Inspection Service (SPHSIS), and the Main Inspectorate of Agricultural and Food Quality Inspection (MIAFQI), are the Central Competent Authorities (CCA) responsible for implementation, enforcement and supervision of areas within their competence.
The Ministry of Finance (MF) funds the services at central level. The regional and district levels are funded by MF through the Voivodship, under the Ministry of Interior and Administration (MIA).
General Veterinary Inspectorate (GVI)
The GVI is headed by the Chief Veterinary Officer (CVO), appointed by the Prime Minister on the proposal of the Minister for Agriculture and Rural Development. Deputy Chief Veterinary Officers (DCVO) are appointed by the Minister of MARD on the proposal of the CVO.
At central level, the relevant operational units are: - Animal Health and Welfare Office (AHWO) - Hygiene of Foodstuffs of Animal Origin Office (HFAOO) - Animal Feedingstuffs, Pharmacy and Rendering Office (AFPRO) - Border Inspection Office (BIO) - Controlling Office (CO) - The European Union and Foreign Cooperation Office - Legal and Organising Office - Budget and Financial Office
The GVI prepares annual work plans for its central, regional and district levels, which report back on progress in implementing these plans. It also prepares guidelines and instructions applicable to all sectors, which are available on the GVI website.
The GVI is operationally divided into 10 Border Veterinary Inspectorates (BVI), 16 Voivodship (Region) Veterinary Inspectorates (VVI) and 304 Poviat (District) Veterinary Inspectorates (PVI). These are headed by Border Veterinary Officer (BVO), Regional Veterinary Officer (RVO) and District Veterinary Officer (DVO) respectively. A typical VVI will have a RVO, a Deputy RVO, and units dealing with infectious animal diseases, hygiene of food of animal origin and animal feed, biological materials and laboratories, pharmacy and animal welfare. The structure of a PVI is similar to that at VVI level.
The GVI employs 44 veterinarians at central level, the VVI 215, the PVI 1,476 and the BVI 68. A total of 192 veterinarians are employed in the official veterinary laboratories. GVI estimates that there is still a considerable staff shortfall, despite having recently recruited an additional 304 inspectors in the feed area, or one per PVI. Previous difficulties experienced in acquiring adequate funding from the Ministry of Finance to recruit and pay the necessary staff seem to have been somewhat alleviated. According to the CA, funds for recruiting and paying an additional 796 veterinarians dealing with animal health were made available to the PVI with effect from 1 March 2008. Funds for
6 Valid as of April 2007 a further 25 posts in the BVI have also been made available, in connection with a plan to create a new BVI at Gdansk. The relatively low level of remuneration, which has led in the past to a high turnover of veterinarians, who often move to higher paid jobs outside of the ministry once they have been trained, may be addressed by the provision of new funding permitting higher monthly salaries to be paid. The PVI may designate private veterinary practitioners (PVP) to carry out certain official tasks, such as: ante and post-mortem examinations of slaughter animals; sampling; issuing of health certificates; supervision of certain types of establishments; vaccinations; basic tasks in relation to the disease control programmes; and controls on animal welfare. In all, there are 5,200 PVP employed in this area.
The BIO has administrative and supervisory responsibilities for all Border Inspection Posts (BIP) and also co-operates with other sectors of the GVI. The GVI has a co-ordinating role over the Voivodships and Poviat levels relating to veterinary issues. The PVI or BVI are responsible for the supervision of customs/free warehouses and ship suppliers. Agency for Restructuring and Modernisation of Agriculture (ARMA)
ARMA is a paying agency with a network of offices in all regions and districts of the country. It is responsible for the registration system for holdings and the operation of the central database. Thirty staff are employed in the central office and some 1,753 at Voivodship and Poviat level.
The central database for cattle, pigs, sheep and goats has been established in accordance with the relevant EU requirements and is accessible from all ARMA offices. GVI staff have full on-line access to the database.
State Plant Health and Seeds Inspection Service (SPHSIS)
The Main Inspectorate (MI) is responsible for controls of plant health and the marketing and use of pesticides. The Main Inspector is nominated by the Prime Minister on the proposal of the Minister of MARD. At regional level, there are 16 Voivodship Inspectorates (VSPHSIS), 269 field units and 12 SPHSIS border inspection points.
The MI supervises and controls VSPHSIS activities, co-ordinates inspections, prepares training programmes and draws up instructions and guidelines. The MI also evaluates appeals against VSPHSIS decisions, collaborates with MARD on drafting legislation and maintains contacts with other Competent Authorities and scientific Institutions. At Voivodship level, meetings with field unit managers are held each month on instructions and decisions of the MI.
At the end of September 2007, the SPHSIS had 2,248 staff, who cover all plant-related issues, together with 68 in the MI. The total is made up of some 1,600 inspectors, 300 laboratory analysts and 350 administrative and other staff.
Agricultural and Food Quality Inspection (AFQI)
This has a limited role in food safety, except for GMO, where it is responsible for controls at processors and wholesalers on the commercial quality of GMO in foodstuffs and for labelling, within the scope of Regulation (EC) 1830/2003 on traceability and labelling.
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It is managed by the Chief Inspector, nominated by the Prime Minister on the proposal of the Minister of MARD, his deputies and sixteen Voivodeship Inspectors. The Poviats are not involved.
There is one person at the central level and one in each voivodship involved in the above- mentioned controls.
Ministry of Health (MH)
The MH is responsible for the co-ordination of food safety, under Ordinance of 18 July 2006, and for the transposition of Community legislation in the areas of general food hygiene, pesticide residues, contaminants, and import controls of food of non-animal origin. It is responsible for presenting legislation to Parliament.
The Chief Sanitary Inspector (CSI) is the CCA responsible for implementation, enforcement and supervision of areas within its competence. The CSI is appointed by the Prime Minister on the proposal of the Minister of Health. He co-ordinates and supervises the activities of the State Sanitary Inspection (SSI). He also appoints the State Voivodship Sanitary Inspector, who, in turn, appoints the State Border and State Poviat Sanitary Inspectors. The structure of the CSI was changed on 1 January 2007, with some Departments being renamed.
The MH receives funding from the Ministry of Finance to cover the needs of the SSI at all levels.
State Sanitary Inspection (SSI)
The SSI is responsible for: official control of the hygiene of foodstuffs; pesticide residues in food; contaminants and imports of food of non-animal origin, materials and articles intended to come into contact with food; food additives; GMO in food; food supplements; and novel foods. The Department for Safety of Food and Nutrition (DSFN) is directly responsible for these areas at central level. It is also responsible for policy development, contact with international bodies (such as the European Commission and Codex Alimentarius) and overseeing food processing. Other responsibilities include: co- ordination of enforcement; supervision of subordinate levels; collating data on controls; and providing the national contact point for the Rapid Alert System for Food and Feed (RASFF). The national contact sub-point is located in the GVI.
The tasks of SSI are discharged at regional level by 16 Voivodship Sanitary and Epidemiological Stations (VSES), and at district level by 318 Poviat Sanitary and Epidemiological Stations (PSES) and 10 Border Sanitary and Epidemiological Stations (BSES). The central office provides VSES with information concerning, inter alia: guidance on monitoring; sampling schedules; guidelines on implementation of EU and national legislation; official procedures for food control; information on the RASFF system; and training. The VSES are responsible for ensuring that guidelines, training and instructions are passed on to the PSES and maintain an annual plan for their supervision.
Co-operation between the SSI and the GVI is governed by a Framework Agreement of 21 September 2007, laying down detailed conditions and rules of co-operation and collaboration regarding supervision of foodstuffs.
In the food safety area, some 1,000 staff are employed at Voivodship level and some 2,500 at Poviat level.
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Main Pharmaceutical Inspectorate (MPI)
The Main Pharmaceutical Inspectorate (MPI), headed by the Main Pharmaceutical Inspector is responsible for the issuing, refusal of issuing and withdrawal of authorisations for the manufacture and importation of VMP. The MPI supervises the manufacturing and importation of human and veterinary medicines. The MPI employs 15 inspectors, some of whom supervise manufacturing and importation of veterinary products.
Ministry of Transport (MT)
The Road Transport Inspection (RTI) is responsible for controls on animal welfare during transport. It consists of the General Inspectorate of Road Transport and 16 Voivodeship Road Transport Inspectorates. The RTI carries out checks of livestock vehicles as part of their roadside controls.
Ministry of Finance (MF)
The Customs Services, under MF, co-operate with: GVI on controls of imports of animals, food of animal origin and feedingstuffs; SPHSIS on controls of exports and imports of regulated plants and plant material; and SSI on controls of imports of food of plant origin.
Co-operation between Customs and the other relevant CA concerning border controls is based on either formal or informal agreements, at central, regional and district level, which include regulations on co-operation between GVI and Customs authorities and between SSI and Customs authorities.
Laboratory Services
GVI
The National Veterinary Research Institute (NVRI) is responsible for co-ordinating the activities of the 16 Regional Veterinary Laboratories (RVL). Its functions include: monitoring of infectious diseases in animals (list-A diseases and others) including zoonotic diseases and agents thereof; monitoring of residues of foreign substances in food of animal origin and feedingstuffs; supervision of RVL; and providing technical assistance to the GVI and MARD.
The RVL provide services in the areas of protection of animal health, including disease diagnosis, and microbiological testing of food for human consumption and of animal feedingstuffs. The strategy for accreditation of RVL includes prioritisation by the CVO regarding methods and location.
In accordance with Article 23(3) of the Act on Veterinary Inspection, official laboratory analyses are carried out by:
• The 16 RVL, which constitute a part of the VVI; • Veterinary Laboratories, which constitute a part of organisational units of the GVI other than mentioned above; • National Reference Laboratories (NRL), as specified in EU legislation; • Laboratories approved by the CVO on the basis of Article 24 of the Act on Veterinary Inspection.
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The results of analyses conducted in official veterinary laboratories serve as a basis for the GVI to issue administrative decisions with regard to: infectious animal diseases; food of animal origin not meeting the requirements of complete consumer safety; biomaterials; animal feed; and animal by-products.
RVL conduct official examinations and tests on behalf of Regional, District and Border Veterinary Officers, and PVP authorised to carry out official tasks.
SPHSIS
These laboratories include: the Central Laboratory of the Main Inspectorate; the Voivodship Laboratories in the 16 regions; and diagnostic units in the 12 Border Inspections Posts (BIP).
These laboratories co-operate with the Plant Protection Institute (PPI) and the Institute of Industrial Organic Chemistry (IIOC) with regard to Plant Protection Product (PPP) quality tests. PPP residue analyses are conducted by the Central Laboratory, the PPI and its five branches, and the Research Institute of Pomology and Floriculture.
SSI
These laboratories are the official food control laboratories under EC regulations 882/2004 and 852/2004. Their analytical work covers: general food hygiene; contaminants; microbiology; GMO in food; pesticide residues in food; food additives; food contact materials and baby foods.
There are 16 regional laboratories, with up to four branches each in some regions. There are also three nominated NRL: the National Institute of Public Health - National Institute of Hygiene (NIPH - NIH); the Food and Nutrition Institute (FNI); and VSES Rzeszow, Tarnobrzeg division (reference laboratory for GMO in food). All these official laboratories are accredited.
AFQI
Analyses of agricultural and food products are conducted in 12 official AFQI laboratories. A specialised laboratory in Warsaw carries out analyses on GMO agricultural and food products.
All AFQI laboratories are accredited by the Polish Centre for Accreditation (PCA) according to PN-EN ISO/IEC 17025 standard.
Multi-annual National Control Plan (MANCP)
The provisions of Regulations (EC) No. 853/2004, (EC) No. 854/2004 and (EC) No. 882/2004 are transposed into national legislation through the Act of 16 December 2005 on Products of Animal Origin, with regard to food of animal origin. The Act of 22 July 2006 on feed establishes the competent authorities for those aspects of EU Regulations that are directly applicable and do not require transposition into national law. This Act implements the provisions of Regulation (EC) No. 882/2004 on controls to be performed to ensure the verification of compliance with feed and food law, animal health and animal welfare rules.
The Act of 25 August 2006 on Food and Nutrition Safety lays down the necessary provisions to implement Regulations (EC) No. 852/2004 and (EC) No. 882/2004. This Act replaces the Act on the health condition of food and nutrition. Among other things, it regulates all issues connected with food safety and general hygiene. It gives the 10 Valid as of April 2007 responsibility to the SSI to co-ordinate the MANCP. The plan itself was completed and submitted to the Commission in February 2008. It is a three-year plan, from 2007 to 2009, operating on a rolling basis. A co-ordination team, comprising representatives of the SSI, GVI, SPHSIS and Office of Competition and Consumer Protection, meet regularly to monitor implementation and to adjust or update the plan, as required. Competent Authority Audit Systems
GVI
The Controlling Office (CO), reporting directly to the CVO, was set up in 2002, with the purpose of checking that the VVI and PVI correctly perform their duties. An annual control plan determines the number and scope of controls to be carried out, with some flexibility for any ad hoc controls which may be required. Audits are announced in advance and conclude with an inspection report listing any remedial action to be taken. An annual report is sent to the CVO. In 2007, CO carried out 25 audits in PVI and 4 ad hoc audits in VVI.
In addition, VVI audit their respective PVI, based on guidelines from the CO. These guidelines are currently being updated. VVI are responsible for following up the recommendations in their districts. They also carry out "reality checks" by accompanying inspectors during their field work. Audits are also carried out by the different offices at GVI central level on the corresponding sections at regional and district levels.
Five auditors are assigned to the CO, all of whom are qualified veterinarians with extensive experience at central, regional and district levels, and whose competence covers matters relating to animal health, animal welfare, feed and public health.
ARMA
The Department of Audit and Control is responsible for internal audit. An annual control plan is drawn up on the basis of risk assessment, which among other things includes the registration system for animals and holdings, and the operation of the central database. Each Regional Office has an internal control section, with its own control plan covering all ARMA’s activities. The regions act autonomously, with general guidance from the central office and submit a report of their controls to that office.
SPHSIS Controls may be on the basis of annual plans or as ad hoc inspections. In 2007, SPHSIS carried out 32 internal controls in VSPHSIS. Apart from supervision by the SPHSIS, internal controls are also carried out annually in each field unit by specialists from the relevant section of the VSPHSIS. These include "reality checks” on the spot.
SSI The Department for Supervision and Controls (DSC) is responsible for internal audit and prepares the annual internal control plan. Controls are carried out at the various levels of the SSI and include different areas of activities, not only food safety. The DSC performs both comprehensive controls, covering all aspects of a given VSES activity, and thematic controls, including checks on the implementation of official food control carried out by the VSES in question. These controls may include visits to Poviats, but not to establishments. The Voivodship Sanitary Inspector is responsible for notifying the SSI of follow-up to recommendations. The DSC plans to undertake audits of four Voivodships each year. The officials performing these audits are drawn from different departments of SSI, including DSFN. In 2007, DSC carried out a comprehensive audit in one VSES and thematic audits in two others. 11 Valid as of April 2007
The VSES control their respective districts and internal controls are also carried out in the regional, district and border stations by the head of station.
Three auditors are assigned to they DCS, all of whom have at least five years technical experience in their specific field. The quality system in SSI conforms to ISO 9001 standard. DSC is in the process of reorganisation.
National accreditation bodies (Laboratories) Polish laboratories are accredited by PCA (Polish Centre for Accreditation), a national body authorised for the accreditation of certification and inspection bodies, testing and calibration laboratories and other entities conducting conformity assessments and verifications.
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The following chart gives an overview of the distribution of responsibilities in relation to control systems and operational levels. More detailed descriptions of the allocation of responsibilities between authorities in relation to each control system are given in the following chapters.
Co- Risk assessment, Policy Implementation Sector ordination Laboratories scientific co-ordination of controls of controls advice
1. Animal Health MARD GVI VVI/PVI NVRI NRL ARMA ARMA 2. Food of Animal Origin MARD GVI VVI/PVI NVRI NRL MH SSI VSES/PSES 3. Imports of animal and MARD GVI/BIO VVI/PVI/BVI NVRI NRL food of animal origin MF Customs Customs Service Chambers 4. Feedingstuffs MARD/MF GVI/BIO VVI/PVI/BVI NVRI, PPI, NRL NFL Customs Customs Service Chambers 5. TSEs/ABP MARD GVI/ARMA GVI/PVI NVRI NRL MH, ME SSI VVI/VSES/PSES 6. Veterinary medicines MH MPI VPI NRL - authorisation, marketing &distribution Veterinary medicines MARD GVI VVI/PVI NVRI NRL - residues 7. Foodstuffs and MH SSI VSES/PSES NFNI NRL Food hygiene NIPH-NIH 8. Imports of food of plant MH, MARD, MF SSI, GVI VSES/BSES NIPH-NIH NRL origin Customs Customs Service Chambers 9. Plant protection MARD SPHSIS VSPHSIS/ No reference NRL laboratory products - authorisation, PPP Commission Field Units marketing and use Plant protection MH SSI VSES/PSES/BSES NIPH-NIH NRL products - residues 10. Animal Welfare MARD GVI VVI/PVI/BVI NVRI NRL MT RTI 11. Plant Health MARD SPHSIS VSPHSIS: Central Lab NRL SPHSIS Field Units
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2. COMPETENT AUTHORITIES AND DISTRIBUTION OF RESPONSIBILITIES IN RELATION TO INDIVIDUAL CONTROL SYSTEMS
2.1. Control system for animal health
MARD Ministry of Agriculture and Rural Development DFSVM Department of Food Safety and Veterinary Matters NVRI National Veterinary Research Institute GVI General Veterinary Inspectorate AHWO Animal Health and Welfare Office ARMA Agency for Restructuring and Modernisation of Agriculture VVI Voivodship Veterinary Inspectorate(s) PVI Poviat Veterinary Inspectorate(s)
Competent Authorities The GVI is CA for implementation of policy and control. The AHWO is responsible for animal health matters. The GVI prepares guidelines and instructions and is responsible for the annual work plan.
Holding registration, animal identification and movement controls ARMA is responsible for the registration system for animals and holdings, and for the movement of animals. The Laws of 2 April 2004, 6 May 2005 and 16 February 2007, and their implementing regulations, govern the system for identification and registration of animals. Registration and the issue of animal passports are done at Poviat level by local ARMA offices. All holdings of bovine, caprine, ovine and porcine animals in Poland are registered. As at May 2008, there were 6,341,080 cattle, 310,885 sheep, 42,761 goats and 38,928,054 pigs registered in the central database, and a total of 1,237,606 animal holdings.
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The Polish Horse Breeders Association is responsible for, inter alia: managing and updating the horse central database; keeping registers of horses for breeding and production; and for issuing passports. Identification of horses is compulsory and they cannot leave the holding of origin without a passport.
On-the-spot inspections are performed on 10% of bovine holdings, as required by Commission Regulation (EC) No. 1082/2003, and on 3% of ovine and caprine holdings comprising at least 5% of animals, in accordance with the Commission Regulation 1505/2006. These are carried out by official veterinarians (OV) and by PVP: during inspections of milk production farms; during animal welfare inspections; and within the monitoring programme of bovine infectious diseases. OV are required to check the identification details for bovines being sent to other Member States against the information held on the central database. The inspections also provide information to enable ARMA to conduct a risk-based selection of holdings for inspection.
Animal health controls
Eradication and/or surveillance programmes are in place for rabies, bovine brucellosis and bovine tuberculosis (TB), enzootic bovine leucosis (EBL), bovine spongiform encephalopathy (BSE), caprine scrapie, avian influenza (AI), Aujeszky's disease (AD) in Lubuskie region and salmonella in breeding flocks of Gallus gallus. In addition, a number of other diseases included in the monitoring regulation are monitored, such as classical swine fever (CSF), foot and mouth disease (FMD) and swine vesicular disease. Poland has been declared free of brucella melitensis. Certain regions in Poland have been recognised as free of enzootic bovine leucosis (EBL). A monitoring programme for bluetongue vectors has recently been established, while monitoring of chronic wasting disease in cervide animals is carried out on the basis of the EU regulations. All bovine animals over six weeks of age are TB-tested once every three years and all bulls and breeding females over 12 months of age are tested for bovine brucellosis once every three years. All bovine animals over 24 months are tested once every three years for EBL in Poviats where EBL has not occurred during the previous two years. Testing is carried out by approved PVP. Test reports and invoices are submitted to the DVO, who checks that the number of animals tested is in line with information on the central database before authorising payment.
The CCA submits interim and final reports on the TB, bovine brucellosis, rabies, EBL and BSE programmes to the Commission each year.
GVI is responsible for carrying out veterinary checks in the intra-Community trade of live animals, as well as for approval and supervision of approved sites.
The GVI and the SSI have an agreement to immediately inform each other about suspected or confirmed cases of zoonoses in either humans or animals. This agreement also applies to Voivodships and Poviats, which exchange information and co-operate in the investigation of food-borne disease outbreaks.
Contingency plans
EU-approved contingency plans are in place for CSF, FMD, AI and Newcastle Disease. These plans are based on the national template and composed of three sections, covering general information, the manual of operations and the annexes with contact lists of persons and institutions involved at regional and district level. Where an outbreak is confined to a district, the DVO takes control. Where it spreads to another district, the RVO becomes responsible and where it spreads between regions, the central office takes overall control. In 2006, two simulation exercises were carried out, one in Krakow for 15 Valid as of April 2007
AI, the other in Lublin for CSF. In 2008, simulation exercises are planned in some VVI for infectious diseases such as FMD, CSF and AI. The first part of the CSF exercise took place in March and it will be completed in November.
Plans have also been developed for African swine fever, BSE, swine vesicular disease, including one for fish diseases (viral haemorrhagic septicaemia and infectious haemopoietic necrosis).
Laboratories
The NRVI is responsible for monitoring infectious diseases in animals. The 16 RVL carry out serological testing under the national monitoring programme. All the laboratories are integrated in the contingency plans and laboratory staff participate in the National Crisis Team. The laboratories participate regularly in ring-tests organised by the relevant Community Reference Laboratory.
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2.2. Control system for food of animal origin
MARD Consultation MH (DFSVM) cooperation
Legislation
GVI Technical advice NVRI SSI (HFAOO)
Guidelines, instructions, checklists & audit
VVI + Co-ordination & VSES + laboratories control laboratories
Supervision Control plan Supervision, PVI registration, PSES (OV & PVP) approval & sampling Control, registration
Primary production & Retail food processing sector establishments
MARD Ministry of Agriculture and Rural Development DFSVM Department of Food Safety and Veterinary Matters MH Ministry of Health GVI General Veterinary Inspectorate NVRI National Veterinary Research Institute HFAOO Hygiene of Foodstuffs of Animal Origin Office SSI State Sanitary Inspection VVI Voivodship Veterinary Inspectorate(s) PVI Poviat Veterinary Inspectorate(s) VSES Voivodship Sanitary and Epidemiological Station(s) PSES Poviat Sanitary and Epidemiological Station(s)
Competent authorities
MARD, in consultation with MH, is responsible for supervising the official control of food of animal origin.
The CA for implementation of policy and control is the GVI. The HFAOO is responsible for the supervision of production, including direct sales. In addition, the control of foodstuffs of animal origin manufactured or stored in a production plant which manufactures other food products may be entrusted to both GVI and SSI.
The PVI carry out most of the official tasks. The DVO may authorise PVP to carry out official tasks, such as ante-mortem and post-mortem inspections, sampling, issuing of health certificates and supervision of certain types of establishments.
17 Valid as of April 2007
The GVI prepares guidelines, check-lists and instructions on: ¾ the frequency of inspection of food business operators officially supervised by the GVI, based on risk analysis; ¾ procedures to be followed by the PVI for registration, approval, conditional approval, or suspension and withdrawal of approval, of establishments, including specific arrangements for transitional establishments; ¾ controls of the microbiological sampling of food of animal origin and contact surfaces carried out by the establishments;
¾ the performance of official controls regarding traceability of animals, foodstuffs, substances intended to be added to food as well as marking of products of animal origin;
¾ the scope and method of carrying out National Residue Control Plan of prohibited substances, chemical, biological, drug residues and radioactive contamination in animals, in their secretions and excreta, in tissues or organs of animals, in foodstuffs of animal origin, in water intended for animals and in animal feeding stuffs;
¾ rules for handling Specified Risk Material in slaughterhouses and cutting plants;
¾ the scope and method of implementing the national Rapid Alert System for Food and Feed and the obligation to inform consumers about dangerous foodstuffs and feeds;
¾ official control methodology;
¾ procedures applied by official veterinary officers in the course of their supervision of raw milk control under Regulation (EC) No. 853/2004;
¾ the scope and method of implementation of the national programme of control tests for dioxins, furans, dioxin-like polychlorinated biphenyls (dl- PCBs) in animals and products of animal origin.
An agreement between the GVI and the SSI defines their respective responsibilities and a framework for similar agreements exists at Voivodship and Poviat levels. A working group has been set up between the two bodies to focus particularly on coldstores and catering establishments.
The main CA responsible for official controls in the baby foods sector is the SSI, except in the case of production of infant formulae, follow-on formulae and baby foods under the scope of Regulation (EC) 853/2004, where the CA is the GVI.
Registration and approval of establishments
Registration and approval of establishments are performed in accordance with Articles 19-22 of the Act of 16 December 2005 on products of animal origin. Depending on the specific activity carried out, registration is done by either the GVI or the SSI.
The CVO instruction of 11 September 2007, based on national legislation, lays down that all establishments considered "low capacity establishments" approved for the national market prior to 1 January 2006 be allowed to continue supplying the national market only, until they become fully compliant with the legislation in force. Otherwise, they will have to stop activities by 31 December 2009. This instruction requires DVO to inform
18 Valid as of April 2007 food business operators (FBO) to assess their establishments and to prepare a timetable to carry out appropriate remedial action, including the setting of deadlines for addressing deficiencies. Over 1,440 establishments are in this category and their deadline for compliance is based on Article 4 of Regulation (EC) No. 2076/2005. Poland is well advanced in approving these establishments and has set a national deadline of 31 March 2009, to ensure that any appeals and follow-up are dealt with by the statutory deadline of 31 December 2009.
Registration of establishments is done at district level by the PVI or the PSES. Updated lists of establishments registered with the GVI are included in a centralised database. This database is being adapted to comply with the format defined in Annex III to Regulation (EC) No. 853/2004.
Complete lists of establishments registered with the SSI are not available at central level. New software for this purpose is being prepared and is expected to be operational in 2007/2008.
Official controls and inspection at establishments
The DVO, or OV authorised by the DVO, issue administrative decisions and carry out inspections in accordance with the provisions of Regulations (EC) No. 852/2004, (EC) No. 853/2004, (EC) No. 178/2002 and (EC) No. 1774/2002. Minimum frequencies for inspections to be carried out by the VVI and PVI are laid down in CVO instruction of 14 August 2007, based on risk analysis.
The DVO are responsible for the direct supervision of all establishments. OV are permanently present in slaughterhouses during the slaughter process and on a daily basis in high capacity cutting plants. Other food processing establishments are visited regularly, in accordance with CVO instruction 500/11/07.
Ante-mortem inspection of animals for slaughter, as well as post-mortem inspection of carcasses and offal, including examination for Trichinella, is carried out by designated PVP. Their work is supervised by OV, who are in turn controlled by the DVO.
Reports are drawn up in standardised format after each control. The SPIWET (checklist) inspection protocol, containing the requirements of Regulation (EC) No. 852/2004 (Annex 2), is used for the assessment of establishments. More specific SPIWET inspection protocols containing requirements of particular sections of Regulation (EC) No. 853/2004 are being developed. SPIWET inspection protocols have also been developed for assessing the work of OV and PVP.
Official controls on identification mark and traceability
Polish legislation on health marking requirements for fresh meat, game meat and game products and milk and milk products was adopted in 2004. Intensified official controls have been carried out to enforce the requirements related to health marking and packaging.
The GVI is responsible for supervising the implementation of Regulation (EC) No. 1760/2000 on beef labeling, insofar as slaughterhouses, cutting plants, minced meat plants and storage are concerned. The CVO instruction of 4 April 2007 regulates such activities. The SSI is responsible for the retail sector.
19 Valid as of April 2007
2.3. Control system for imports of animals and food of animal origin
MARD Ministry of Agriculture and Rural Development DFSVM Department of Food Safety and Veterinary Matters MF Ministry of Finance GVI General Veterinary Inspectorate BIO Border Inspection Office VVI Voivodship Veterinary Inspectorate(s) PVI Poviat Veterinary Inspectorate(s) BVI Border Veterinary Inspectorate
Competent authorities
The GVI is the CA for implementation of policy and controls and the recruitment and supervision of BIP staff. The Border Inspection Office (BIO), reporting to the CVO, is responsible for import controls and for BIP, where a total 69 veterinarians are employed.
Import controls
The GVI supervises and co-ordinates the BVI and PVI, whose responsibilities include the control of: customs-free warehouses; warehouses in free zones; customs warehouses approved for storing products of animal origin non-compliant with EU import requirements; and ship suppliers approved in accordance with Council Directive No. 97/78. The service also incorporates sixteen regional laboratories and their sixteen branches.
The CVO issues guidelines, recommendations and instructions on import controls methodology.
20 Valid as of April 2007
The BIO, comprising five staff, is responsible for supervising the import and transit control system and carrying out audits of the BIP. This was previously the responsibility of the CO. The BIO has commenced audits of BIP and customs warehouses for storing non-compliant products of animal origin and plans to carry out at least one full audit of each customs warehouse annually.
BIP receive RASFF messages directly from the EU server, and these are forwarded to the GVI contact sub-point.
A formal agreement on co-operation between the GVI and Customs was signed in September 2005 at central level. Meetings have been held both at central and local levels, and local agreements between PVI and Customs Offices are in place concerning implementation of Regulation (EC) No. 2004/745. Local agreements between BVI and Customs Offices at the Polish external border of EU are also in place. The information on seized products of animal origin at all border crossings is collected annually by GVI and sent to the Commission.
Customs authorities co-operate with BVI on the basis of guidelines prepared by Ministry of Finance in the case of products of animal origin not complying with EU import requirements. The guidelines concern customs warehouses and transit.
Co-operation on travellers’ pets is based on Chapter 4a of the Act of 11 March 2004, as amended, on the protection of animal health and eradication of animal diseases, implementing Regulation (EC) No. 998/2003 and Regulation of the Council of Ministers of 25 January 2005, on co-operation of Customs with other units of public administration and other national and local units. The Act of 7 January 2005 and MARD Regulation of 17 April 2007 lay down the list of border checkpoints at which Customs perform an inspection of pet animals imported for non-commercial purposes (up to five animals).
Checks on personal luggage and consignments are carried out in accordance with Commission Regulation (EC) No. 745/2004. Some responsibilities for these controls are delegated to Border Guards, operating under the Ministry of Internal Affairs and Administration. Checks on postal consignments are carried out in co-operation with the postal services, under the Department of Post in the Ministry of Transport. A new electronic identification of vehicular traffic at border crossings has been introduced, which facilitates checks at road BIP.
The following 12 BIP are approved in Poland, in accordance with Commission Decision 2001/881/EC as last amended by Commission decision 2007/276/EC:
Bezledy (Road) Dorohusk (Road) Gdansk (Port) Gdynia (Port) Hrebenne (Road) Korczowa (Road) Kukuryki-Koroszczyn Kuznica Bialostocka (Road) Swinoujscie (Port) (Road) Szczecin (Port) Terespol-Kobylany (Rail) Warsaw Okecie (Airport)
21 Valid as of April 2007
2.4. Control system for feedingstuffs and animal nutrition
MARD (DFSVM)
Legislation Central Laboratories National GVI RASFF Veterinary (AFPRO) Research Instructions Institute National Control Plan audit National VVI + Laboratory for BVI laboratories Feedingstuffs
Supervision Plant Protection Controls Institute PVI sampling
Controls, approvals, sampling (also GMO in feedingstuffs)
Producers, traders, Imported farms consignments
MARD Ministry of Agriculture and Rural Development DFSVM Department of Food Safety and Veterinary Matters GVI General Veterinary Inspectorate AFPRO Animal Feedingstuffs, Pharmacy and Rendering Office VVI Voivodship Veterinary Inspectorate(s) PVI Poviat Veterinary Inspectorate(s) BVI Border Veterinary Inspectorate RASFF Rapid Alert System for Feed and Food
Competent authorities
The DFSVM of MARD is responsible for the development of national policy for animal feed at central level. A Parliamentary Act on Animal Feedingstuffs incorporates the changes introduced in Regulations (EC) No. 882/2004 and (EC) No. 183/2005.
The GVI is CA for policy and controls. In practice, direct supervision of animal feedingstuffs and approvals is carried out at PVI level. Their activities are controlled and co-ordinated by the GVI and VVI, through the AFPRO. Import controls are carried out by the BVI. GMO in feedingstuffs is also handled by the GVI.
22 Valid as of April 2007
Registration and approval of establishments and intermediaries
Under Regulation (EC) No. 183/2005, all operators in the sector of animal feedingstuffs are obliged to be registered or approved by a PVI. This information is stored in the central database maintained by AFPRO. As of September 2006, some 2,780 operators were approved and 2,340 registered. Approximately 1.2M entities produce animal feedingstuffs for own use, of which some 60% applied for registration.
Official controls
The official contact sub-point for RASFF in the GVI is AFPRO and a contingency plan for emergencies in feed has been adopted. A single annual National Control Programme for official controls of animal feedingstuffs is prepared at central level on the basis of results of previous controls, risk assessment and Commission instructions. This includes: sampling plans; guidelines; methods to be applied; tests to be carried out; and frequency of controls, with the following target: twice a year (minimum) for animal feed manufacturers; once a year for traders in animal feed; once a year for 5% of farmers keeping food-producing animals. OV include animal feed as part of their on-farm checks.
Besides the periodic checks specified in the frequency programme, OV undertake other visits on a case-by-case basis, according to the requirements of the situation, such as: suspicion of illegality; the extent of an own-control system; past results; risks posed by types of feed produced; volume of production; and complaints made. The emphasis for controls in 2008 is to increase checks on farms producing own mixes.
Training on new laws and procedures is organised every two months for regional inspectors, who in turn inform the district inspectors. In addition, twinning training projects have been arranged with Italy and the Netherlands, under PHARE.
At GVI central level, four staff have specific responsibilities for controls on animal feedingstuffs, with 22 staff in the VVI and 304 staff in the PVI also involved in controls. A further 304 inspectors for feedingstuffs and rendering have recently been recruited at PVI level.
With regard to feed imports, Customs carry out similar controls as for import of animals and food of animal origin.
Laboratories
Laboratory tests of animal feedingstuffs are carried out by the RVL and three reference laboratories, the NVRI, the PPI and the National Laboratory for Feedingstuffs (NLF). The RVL are currently undergoing an accreditation process. The NVRI organises ring tests.
The RVL in Poznan, Opole, and Bialystok also have responsibilities for GMO analysis in animal feedingstuffs.
23 Valid as of April 2007
2.5. Control system for TSE/ABP
TSE
MARD (DFSVM)
Legislation
Technical NVRI GVI ARMA (AFPRO/ advice (LHF) AHWO)
Monitoring, Co-ordination and instructions & audit control of laboratories
VVI labs (MAT) labs rapid tests for TSE Advisory checks on holdings Supervision & & input from farmers monitoring regarding animal ID and registration PVI (OV&PVP)
PAP- SRM Feed controls, sampling Controls controls TSE fallen animals testing Slaughter- Feed mills Farms houses
Rendering plants
MARD Ministry of Agriculture and Rural Development DFSVM Department of Food Safety and Veterinary Matters GVI General Veterinary Inspectorate AFPRO Animal Feedingstuffs, Pharmacy and Rendering Office AHWO Animal Health and Welfare Office NVRI National Veterinary Research Institute LHF Laboratory for Hygiene of Foodstuffs ARMA Agency for Restructuring and Modernisation of Agriculture VVI Voivodship Veterinary Inspectorate(s) PVI Poviat Veterinary Inspectorate(s)
Competent authorities
The GVI is the CA for controls on TSE, through AFPRO and AHWO. The PVI may designate PVP to carry out certain official tasks, such as ante-mortem and post-mortem examinations and some disease control tasks.
24 Valid as of April 2007
Epidemio-surveillance
A number of training sessions on epidemio-surveillance have been carried out and a contingency plan is in place. Under the monitoring programme, samples for BSE testing are taken in slaughterhouses, in rendering plants or, if appropriate, at farm level (from suspect animals and fallen stock). In the rendering plants, the sampling is carried out by the OV. ARMA makes payments for collection of fallen animals. During 2006, the total number of animals tested increased to 625,438, from 515,976 in 2005. Up to end of July 2007, 352,911 animals were tested. The system of reporting the number of samples is constantly modified to conform to Commission requirements.
The GVI has introduced a system of central and regional monitoring of BSE sampling. This is done by regional and national co-ordinators, who provide materials, resources and harmonised forms, supervise training and sample collection, and ensure the flow of information.
The CVO has issued an instruction on BSE surveillance, covering all epidemiological aspects related to suspicion, confirmation, eradication and further control. The instruction is regularly revised and up-dated. Another CVO instruction requires that the cattle identification and registration database must always be used to support BSE controls.
Specified Risk Material (SRM)
Steps have been taken to control the flow of SRM from removal to disposal. Harmonised forms and a checklist “SPIWET” are used for these controls, which are carried out by the PVI. SRM is normally collected and processed together with other Category I material.
Total Feed Ban
An instruction from the CVO established an official control programme for the detection of Processed Animal Protein (PAP) in ruminant feed. It sets out the minimum frequency of inspections to be performed by each PVI: once every three months in feed mills; once a year on farms; and whenever non-compliance is suspected at dealers and storage points. All consignments of imported fishmeal are controlled.
The national control programmes for feed provides for a specified number of samples of animal feedingstuffs to be checked for the presence of prohibited PAP. At the same time, a guide on risk analysis has been prepared for PVI officers, allowing the introduction of a feed sampling programme at points where cross-contamination is likely to occur. All PVI veterinarians have been instructed to prepare inspection plans and to take samples as part of official monitoring and inspection, based on this instruction. The central level determines the number of samples to be taken in each region on the basis of the size of the region, its volume of production and the number of irregularities discovered. The VVI then allocates the samples to be taken by each PVI using similar criteria, although the number of operators is also considered. The main decisions regarding the targeting of samples are taken by the PVI.
An amendment to the MARD Decree of Veterinary Requirements for Soil Improvers entered into force on 25 December 2007. It requires farmers intending to purchase soil improvers to seek prior approval from the DVO and to mark Category 2 and 3 animal meal intended for use as a soil improvers in a mixture of meal and lime-based fertiliser.
25 Valid as of April 2007
The CVO initiated measures in June 2005 to inform those involved in the feed chain of their obligations under Regulation (EC) No. 183/2005. All district inspectors were provided with relevant training and meetings for industry and officials were arranged at regional level. In February 2008, a Polish/Danish Twinning Light Project began, covering training on HACCP, GMO, risk assessment in feedingstuffs and fertiliser procedures.
Relevant guides for good manufacturing practice, including HACCP, have been produced.
Laboratories
The NVRI is responsible for co-ordinating and supervising the activities of the RVL, as well as providing technical assistance to the GVI. Samples are examined by rapid BSE tests in six RVL in Krakow, Wroclaw, Gdansk, Leszno, Siedlce and Warsaw. The RVL in Siedlce is the latest RVL established for TSE examination. The NRL examines BSE suspects, carries out confirmatory tests and organises ring-tests.
The Laboratory for Hygiene of Feedingstuffs at the NVRI is NRL for the detection of PAP in feed. Sixteen RVL are responsible for testing feed for PAP. Microscopic Analysis Test (MAT) is used and the NRL has to confirm inconclusive results and positive results upon request.
26 Valid as of April 2007
ABP
MARD MH ME (DFSVM)
Legislation
GVI Environmental SSI (AFPRO) authorities
Audit, Audit, instructions, instructions checklists
VVI VSES
Supervision, Controls on waste Supervision audit
PVI PSES
Controls Controls approval/registration
ABP processing plants, Retail outlets Not covered by slaughter-houses, pet wholesale ABP Regulation food, intermediate and incineration plants, hauliers, ABP users, technical plants, catering facilities, buyers of MBM as soil improvers
MARD Ministry of Agriculture and Rural Development DFSVM Department of Food Safety and Veterinary Matters MH Ministry of Health ME Ministry of the Environment GVI General Veterinary Inspectorate AFPRO Animal Feedingstuffs, Pharmacy and Rendering Office SSI State Sanitary Inspection VVI Voivodship Veterinary Inspectorate(s) PVI Poviat Veterinary Inspectorate(s) VSES Voivodship Sanitary and Epidemiological Station(s) PSES Poviat Sanitary and Epidemiological Station(s)
Competent Authorities
The GVI is the CA for Animal By-Products (ABP) and is the main body responsible for policy implementation and enforcement in this sector, through the AFPRO.
The SSI is responsible for supervision and controls on food of animal origin at retail and wholesale level.
For waste falling outside the scope of the ABP regulation, the specific authorities under the ME are responsible.
27 Valid as of April 2007
Approval of ABP plants and other premises
Plants to be approved under the ABP Regulation have to pass a prior satisfactory inspection. The plants send a request to the competent PVI and an OV carries out the inspection and issues the approval or refusal, depending on the outcome of the inspection. Independent hauliers of ABP also have to be authorised. Approved plants and other authorised entities are then entered on a GVI official list, which is available on both its own and the EU website. There are almost 2,100 approved ABP plants and other related premises.
Official Controls
GVI has drawn up specific official check lists (SPIWET) to be used during the on-the- spot visits to each type of plant, such as processing, intermediate, storage, incineration, co-incineration and pet food plants, independent hauliers, kennels and fur farms. Special attention is given to the existence of agreements between rendering plants and hauliers. The instructions include the forms to be used by ABP plants and also set the minimum frequency of inspections for the various categories and types of establishments, as follows:
- once a month for Category 1 processing plants; - quarterly for other processing plants; - twice a year for slaughterhouses, pet food, intermediate and incineration plants; - once a year for hauliers, ABP users, technical plants, catering facilities and BIP; - every two years for buyers of meat and bone-meal (MBM) as soil improvers.
Monthly reports are compiled on the amounts of ABP produced in establishments and these are submitted by the PVI to central level.
CVO has instructed officials to perform microbiological checks on processed products of animal origin and to issue administrative decisions requiring deficiencies in ABP plants to be corrected.
The rendering capacity of the Category I rendering plants is approximately 160,000 tonnes per year.
28 Valid as of April 2007
2.6. Control system for veterinary medicines and residues
Legislation and Controls on residues and authorisation of veterinary use of veterinary medicines medicines
MARD MH Legislation Legislation
Co-operation NVRI Technical ORMP GVI on authorisations, (NRL) assistance (Register) registration
NRCP, Co-ordination and instructions, audits control
VVI + MPI Collaborate laboratories VPI
Supervision Autorisation of and controls on manufacturing PVI and importation Controls on selling and use of VMPs Controls on residues Controls on and use of VMPs residues
Wholesalers, Farms, slaughter- Producers, veterinary clinics feed mills, houses, Importers
MARD Ministry of Agriculture and Rural Development MH Ministry of Health NVRI National Veterinary Research Institute NRL National Reference Laboratory GVI General Veterinary Inspectorate ORMP Office for Registration of Medicinal Products VVI Voivodship Veterinary Inspectorate(s) PVI Poviat Veterinary Inspectorate(s) MPI Main Pharmaceutical Inspectorate VPI Voivodship Pharmaceutical Inspectorate(s)
Veterinary Medicinal Products (VMP)
Competent Authorities
MARD is responsible for legislation on the marketing and use of VMP, as well as for controls on residues of veterinary medicines/unauthorised substances in food of animal origin. MH is the lead ministry for legislation and approval of VMP.
29 Valid as of April 2007
Authorisation of VMP
The MPI, within the MH, is responsible for issuing, refusal to issue and withdrawal of authorisations for the manufacture and importation of VMP.
The Office for Registration of Medicinal Products Medical Devices and Biocidal Products (ORMPM) of MH is responsible for registration of VMP in Poland and monitoring of their adverse effects (pharmacovigilance).
Official controls on marketing/use
VVI are responsible for routine controls on VMP wholesalers at least once a year, and on veterinary clinics at a rate of 10% per year. PVI are responsible for routine controls on farms (10% per year) and feed mills (twice a year).
On 1 May 2007, an amendment to the Pharmaceutical Law transferred the supervision of manufacturing and importation of VMP to the MPI. This work is carried out by some of the 15 inspectors employed by the MPI. Most of the VMP for food-producing animals are 'prescription-only'. VMP are classified in three categories: medicines which are administered by practitioners only; medicines which are 'prescription only'; and 'over the counter' medicines. VMP in the first two categories are only available in veterinary clinics. Similarly, feed mills can only obtain pre-mixes from authorised traders on prescription from veterinary practitioners. According to new legislation, medicated feeding stuffs can only be manufactured by specially approved feed mills. The Act of 22 July 2006 on feedingstuffs also permits dealers to manufacture intermediary products and trade in medicated feedingstuffs, as well as manufacturing medicated feedingstuffs from intermediary products for own use.
Residues
Competent Authorities
The GVI is the CA for the control of residues in live animals and animal products, with responsibilities broken down as follows: ¾ The GVI at central level is responsible for preparing (with the help of the NRVI, which is the NRL), issuing and supervising the annual National Residue Control Plan (NRCP); ¾ The VVI are responsible for supervision of the NRCP at regional level; ¾ The PVI, together with eight veterinary laboratories and the NRVI, are responsible for the implementation of the NRCP.
Official controls on residues
On the basis of the original NRCP, a more detailed plan, tailored to each VVI, is prepared and sent to each VVI, with an indication of the RVL in charge of the analysis. This plan contains details on the number of samples to be taken at PVI level, and the relevant matrix. Training on sample taking is organised by the VVI for PVI inspectors.
The GVI is responsible for processing the information on the general results of the NRCP. Each VVI has its own residues programme co-ordinator who, in accordance with specific instructions for sample collection, reports to GVI every three months on the results of sampling and analyses. Each PVI informs the relevant VVI on a monthly basis on samples taken.
30 Valid as of April 2007
Laboratories
The laboratory network responsible for tests under the NRCP comprises nine public laboratories: the NVRI acting as NRL for all groups of substances and the RVL in Bialystok, Gdansk, Katowice, Lodz, Olsztyn, Poznan, Warszawa and Wroclaw. Regular meetings between the RVL representatives take place in the NRL.
The annual distribution of samples to the laboratories takes account of their capacity and the availability of analytical methods. The samples are dispatched to the nominated laboratory, which returns the results to the PVI where the sample was collected. The NRL organises proficiency tests every quarter for the RVL.
The strategy for accreditation and validation of methods in the RVL aims at widening the scope of examinations, spreading the specific tests evenly over the territory and achieving greater specialisation.
In 2006, a total of 10,830 samples were analysed for group A substances and 16,595 for group B substances. A total of 124 non-compliant results were detected, of which 16 for group A and 108 for group B substances. In 2007, a total of 99 non-compliant results in the target plan were detected. All of them were for group B substances. Only two cases of group A substances - chloramfenicol – occurred, both in on-farm suspected cows.
31 Valid as of April 2007
2.7. Control system for foodstuffs and food hygiene
MARD Consultation MH (GVI) cooperation
SSI Scientific NIPH- RASFF (DSFN) support NIH
Annual plans, instructions, audit NFNI
VSES labs + Reference branches laboratories
Supervision, audit
PSES
Controls, sampling, approval
Production of food of Retail, wholesale, non-animal origin catering
MARD Ministry of Agriculture and Rural Development GVI General Veterinary Inspectorate MH Ministry of Health SSI State Sanitary Inspection DSFN Department for Safety of Food and Nutrition NIPH - NIH National Institute of Public Health - National Institute of Hygiene NFNI National Food and Nutrition Institute VSES Voivodship Sanitary and Epidemiological Station(s) PSES Poviat Sanitary and Epidemiological Station(s)
Competent Authorities
MH is responsible for the execution of government food safety control, in consultation with MARD where appropriate.
The SSI is the CA responsible for official food controls. Within the SSI, the DSFN is directly responsible for this area.
Co-operation between the SSI and GVI is governed by an Ordinance and a framework agreement, under which further agreements at Voivodship and Poviat levels have been concluded.
Legislation is prepared by the SSI in co-operation with experts from the scientific institutions reporting to the MH. Guidelines and instructions on newly published
32 Valid as of April 2008 secondary legislation are prepared and training sessions organized by the SSI to harmonise the interpretation of new legislation. Training is normally provided by central level and passed on by cascade to lower levels. In addition, VSES are responsible for the provision of training to their PSES.
An Act of November 2006 incorporates all the changes required under EU Regulations (EC) No. 852/2004 and (EC) No. 882/2004. MARD has a separate Ordinance for its responsibilities in this area.
Licensing and registration of food premises
Under the new legislation, all food establishments must be registered and approved. This is arranged at district level by the PSES inspectors, following a request by the Food Business Operator (FBO). The inspector has the power to suspend or withdraw approval, if necessary. The PSES maintains a list of establishments in each district.
Official controls of food premises
PSES inspectors perform controls, including the taking of samples, on: the health quality of food; the use of authorised food additives and other ingredients; hygiene of production and distribution of foodstuffs (including HACCP); catering; and materials and articles in contact with food. They supervise food products placed on the market (both of plant and animal origin) and production of food of plant origin. Where food products of animal origin are manufactured or stored in a production plant which also manufactures other food products, the controls may be carried out by the GVI and/or the SSI.
The SSI provides VSES with information on: annual plans; sampling schedules; instructions regarding the activity of SSI; guidelines on particular issues and on implementation of EU and national legislation; official procedures for food control; alerts delivered under the RASFF system; and training. The VSES inspectors are responsible for the delivery of the information obtained from the SSI to the PSES and for supervising its application.
Work is at an advanced stage to develop a risk analysis system for controlling establishments, which will eventually be operated electronically. At present, the frequency of inspections is based on specific Ordinances, or laws.
The PSES and PVI agree at local level which service is responsible for which controls, except for controls in meat establishments which are exclusively the responsibility of PVI.
With regard to inspection of Baltic Sea salmon, it is planned to commence taking samples in 2008 and to sub-contract a laboratory for their analysis.
Good Hygiene Practice Guides (GHP)
The guides are prepared by the FBO organisations and approved by the SSI. A list of the GHP and HACCP guides is published on the SSI website and sent to the Commission.
33 Valid as of April 2008
RASFF
The national contact point for the RASFF is in the SSI, while the national contact sub- point, which notifies on feed and food of animal origin, is in the GVI. Other authorities involved in the area of feed and food control and which participate in the RASFF are: SPHSIS; AFQI; Trade Inspectorate; Ministry of Finance; Customs; and National Institute of Public Health – National Institute of Hygiene (NIPH-NIH). The SSI has set up a risk assessment team comprising more than 30 scientific experts of the NIPH-NIH, National Food and Nutrition Institute (NFNI) and NVRI.
Laboratories
With regard to risk assessment, the NFNI reports to the SSI on analyses relating to consumption and nutrition, while the NIPH-NIH reports to the SSI on analyses of contaminants, such as pesticides, mycotoxins, 3-MPCD, additives, microbiology, HAP, and materials and articles likely to come into contact with food. These institutes are reference laboratories and also provide specific support in the preparation of annual sampling plans, risk assessment and the training of SSI staff. There is a network of laboratories consisting of 16 regional laboratories, with 50 branches. Accreditation of laboratories in accordance with EN ISO 17025 is obligatory. According to the CCA, all SSI laboratories are already accredited by the PCA and the scope of accreditation is steadily increasing. Analyses of potentially irradiated foods are carried out by the Nuclear Chemistry and Technology Institute in Warsaw. The provision of a laboratory for these analyses within the SSI is planned for 2007/2008.
34 Valid as of April 2008
GMO
MARD Ministry of Agriculture and Rural Development MH Ministry of Health AFQI Agricultural and Food Quality Inspection SPHSIS State Plant Health and Seeds Inspection Service SSI State Sanitary Inspection NFNI National Food and Nutrition Institute NVRI National Veterinary Research Institute VAFQI Voivodship Agricultural Food Quality Inspection VSPHSIS Voivodship State Plant Health and Seeds Inspection Service(s) VSES Voivodship Sanitary and Epidemiological Station(s) PSPHSIS Poviat State Plant Health and Seeds Inspection Service(s) PSES Poviat Sanitary and Epidemiological Station(s)
Competent authorities
The SSI is the CA for GMO in foodstuffs, including labelling, production, importation and marketing, under Regulation (EC) No. 1829/2003.
GVI is responsible for control of GMO in feedingstuffs (see section 2.4).
35 Valid as of April 2008
AFQI is responsible for controls at processors and wholesalers on the commercial quality of GMO in foodstuffs and for labelling, under Regulation (EC) No. 1830/2003 on traceability and labelling of GMO.
The SPHSIS is responsible for supervision of production and marketing of propagating material, including inspection, sampling and labelling. It is also responsible for official seed control and for GMO issues in the area of seed material.
Official controls of GMO in food, including at import
Controls for GMO in food are based on annual sampling plans prepared by the SSI, in consultation with the NFNI and GMO laboratories. In addition, methodological guidelines are prepared, annual reports compiled and training for inspectors organised. The VSES prepare more detailed plans, taking into account local conditions. The SSI prepares the sampling plan, in which imported vegetables such as tomatoes and potatoes from third countries are included. The PSES and BSES implement the plan, under the supervision of the VSES. Regular meetings are held between the heads of VSES and central level and quarterly reports are made to central level on the execution of the plan.
Co-operation and communication between AFQI and SSI is informal. However, AFQI law obliges them to notify results of controls to "appropriate authorities", which is considered to include SSI.
Annual control plans are drafted by AFQI central office and executed by the AFQI Voivodship offices.
Official controls of GMO in propagating material
According to the CA, within the last two years no GM seed material of the varieties listed in the common catalogue were produced in Poland, no imports of such varieties took place and no GM crops were grown for seed material production. Furthermore, no national authorisation in accordance with Commission Decision No. 2004/842/EC has been granted for experimental purposes.
In 2005/2006, SPHSIS organised screening tests of rape seed samples, which were analysed for the presence of GMO. In the case of five samples, 35S promoter from CaMV and pat gene from Streptomyces viridochromogenes were detected. The GM content in each sample did not exceed the detection level (one out of three performed reactions gave a positive result). Taking into account the results of the screening test, SPHSIS took 209 samples of rape seed material in 2006, which were analysed in the Central Laboratory of SPHSIS.
Laboratories
The SSI laboratories in Poznan, Tarnobrzeg and Bialystok are responsible for GMO analysis in foodstuffs, of which the Tarnobrzeg laboratory is the NRL.
The Central Laboratory of SPHSIS caries out confirmatory varietal identification of cereal and fruit plant cultivars, as well as testing of conventional seed material for the presence of genetic modification.
36 Valid as of April 2008
2.8. Control system for imports of food of plant origin
MARD MH MF
Legislation Legislation
SSI Co-operation Instructions GVI laid down Customs (DFSN) in legislation
Instructions, Instructions, audit audit RASFF VSES BVI VVI Customs labs + Chambers branches
Supervision, Supervision, audit audit Controls
PVI + BSES PSES BVI Controls, Controls, sampling Controls. sampling Consignments sampling of food of non- animal origin Consignments of feed of non- animal origin
MARD Ministry of Agriculture and Rural Development MH Ministry of Health MF Ministry of Finance GVI General Veterinary Inspectorate SSI State Sanitary Inspection DFSN Department of Food Safety and Nutrition BVI Border Veterinary Inspectorate VVI Voivodship Veterinary Inspectorate(s) PVI Poviat Veterinary Inspectorate(s) VSES Voivodship Sanitary and Epidemiological Station(s) BSES Border Sanitary and Epidemiological Station(s) PSES Poviat Sanitary and Epidemiological Station(s)
Competent Authorities
The MH is responsible for legislation in this area and for the execution of government food control, in consultation with MARD where appropriate.
The SSI is the CA responsible for import controls of products of plant origin. Within the SSI, the DSFN is directly responsible. It is the national contact point of RASFF and is responsible for transmission to the EC of data on all rejections of imports of foodstuffs of non-animal origin, which constitute a direct or indirect risk to human health.
37 Valid as of April 2008
Import controls of feedingstuffs of plant origin are the responsibility of the GVI. All food of non-animal origin is under SSI control.
The Customs Service establishes import control procedures under the Community Customs Code. These procedures cover restrictions on import, including those related to health controls. There is a Customs Chamber in each of the 16 Voivodships which are responsible for the control and, where necessary, inspection of products presented for import. They are linked by means of a standardised computer system, which allows simultaneous access by different customs offices to the same document. The system is updated daily.
A specific MH regulation provides for co-operation between the SSI and Customs.
Import controls Import procedures are jointly the responsibility of Customs and the SSI. Inspections of products at the entry points fall under the responsibility of the BSES, which report to the VSES. All products entering the country subjected to Commission Decisions have to physically pass through the entry point before customs clearance.
Communication between all levels of the SSI is by e-mail, conventional mail and fax. Regular meetings or audio-conferences are held to support the reporting and planning processes. Training is normally provided by central level, which is then transmitted by cascade to lower levels. VSES are responsible for the provision of training to their PSES.
Third country imports arriving in Poland, either by Form T1 transfers from other Member States (MS) or directly, must be notified by the importer to the relevant BSES 48 hours in advance. On arrival of the goods, customs officials transfer all relevant data into an electronic network, which is based upon the CELINA system (declaration entry system operated by the Polish Customs authority). Once the data is entered, the system provides information about controls to be performed, including when border sanitary inspection is necessary, and documentation required in order to release the goods into free circulation. It does not allow customs clearance of imports which have not been the subject of controls, as defined by the Regulation of the MH of 15 April 2004 on commodities subject to border sanitary controls.
SSI inspectors perform documentary and physical checks on arriving goods, and sample the consignments for laboratory testing where necessary. BSES inspectors issue a decision of wholesomeness of the consignment and notify Customs if all checks performed show compliance with legislation. This allows Customs to complete the data entry in the CELINA system and to release the products into free circulation.
SSI officials may order the rejection immediate destruction of consignments not found to be in compliance with legal requirements, or may decide whether the foodstuffs can be used for another specified purpose. Execution of the order is controlled by Customs on a documentary basis. Importers may request a second analysis if initial results show non- compliance.
Laboratories
The NIPH-NIH is the national reference laboratory for food. As a reference laboratory, it is responsible for a number of activities, such as the provision of technical assistance and the co-ordination of proficiency tests for the RVL.
38 Valid as of April 2008
Within the SSI there are 16 official foodstuffs control laboratories and 50 branches at Voivodship level.
All the official food control laboratories are accredited to ISO 17025 by the PCA, including for mycotoxin and Sudan dyes.
39 Valid as of April 2008
2.9. Control system for plant protection products (PPP)
Legislation on PPP Technical MARD classification, MH commission assistance packaging, labelling
Legislation
Main Inspectorate Plant of SPHSIS Protection Institute + Control plan, branches instructions
Quality VSPHSIS analyses
Supervision
Field Units Customs
Controls on Controls on marketing/use, imported PPP sampling, trials
Retailers, wholesalers, Importers users
PPP Plant Protection Products MARD Ministry of Agriculture and Rural Development MH Ministry of Health SPHSIS State Plant Health and Seeds Inspection Service VSPHSIS Voivodship State Plant Health and Seeds Inspection Service(s)
Competent authorities
MARD is responsible for legislation on PPP. However, some legislation on packaging, classification, labelling and chemical substances is the responsibility of the MH.
SPHSIS is the CA responsible for supervision of marketing and use of PPP. It co- ordinates and supervises the activity of VSPHSIS Inspectors, who are responsible for 269 field units.
SPHSIS has co-operation agreements with the Border Guard and the Police, both under the Ministry of the Interior and Administration (MIA), the Road Transport Inspection (RTI) and Customs.
40 Valid as of April 2008
Authorisation of PPP
MARD is responsible for the authorisation of PPP. A commission of experts provides technical support to MARD by preparing assessments and reports concerning PPP. Its members are: NIPH-NIH in Warsaw; Bureau of Chemical Substances and Preparations in Łódź; PPI in Poznań; University of Warmia and Mazury in Olsztyn; and Institute of Environmental Protection in Warsaw. Official controls on marketing/use of PPP
The SPHSIS prepares an annual sampling plan, issues instructions and guidelines and prepares staff training programmes. Meetings with field unit managers are held monthly at Voivodship level. Six-monthly activity reports and specific reports are drawn up by the VSPHSIS and sent to the central office. Each field unit is controlled at least once annually by the VSPHSIS.
Each VSPHSIS prepares its own annual work plan, based on the central plan but adjusted to regional and local requirements, in collaboration with the field units. The field units are responsible for: - registration of entrepreneurs marketing and re-packing PPP; - carrying out inspections at retailers, wholesalers, re-packers and users of PPP; - authorisation and supervision of bodies carrying out official training on marketing and re-packaging and use of PPP; - authorisation of bodies performing examinations of sprayers; - sampling for PPP quality checks and "pre-harvest" residues monitoring programme; - monitoring of PPP usage.
The SPHSIS also authorises organisational units to carry out efficacy trials of PPP.
Controls on marketing of PPP are planned each year on the basis of the current number of wholesalers and retailers, and the results of inspections from the previous year. The PPP quality checks and the "pre-harvest" residues monitoring programme are planned at central level by the SPHSIS Plant Protection and Technical Division (PPTD).
At field level, inspectors generally perform controls in both plant health and PPP. The staff at the SPHSIS and the inspectors at the VSPHSI are all graduates.
Customs is responsible for controls of imported PPP.
As of November 2007, a total of 750 PPP were registered by MARD for marketing and use. Farmers may obtain technical information on pest control from an advisory board, or directly from inspectors.
Obsolete pesticides
The competent authority responsible for the detection, supervision and disposal of obsolete pesticides are local government authorities, i.e. Poviats (districts) and Gminas (boroughs). In many cases, individual Voivodships assume responsibility for supervising the disposal of obsolete pesticides. The Environmental Protection Inspectorate, the Polish State Geological Institute and the ME compile inventories of liquidated and existing stocks of such substances. Substantial amounts of obsolete pesticides exist in concrete wells, old military bunkers, ground pits, warehouses, farms and at manufacturers, but is
41 Valid as of April 2008 estimated that these will be disposed of by 2010. The National Fund for Environmental Protection and Water Management Funds provides for disposal. Waste incinerators are available in Dąbrowa Górnicza.
Laboratories
SPHSIS co-operates with the PPI branch in Sośnicowice, Department of Plant Protection Products Analyses and the Institute of Industrial Organic Chemistry, Department of Pesticides Application and Formulation, on official control of PPP quality tests. Analyses target the identity and the content of the active substances. The co-formulants and the solvents are also analysed. Physicochemical properties are also verified. The laboratory performed quality analyses on 410 samples in 2006.
The control of the information on the labels against the analyses is carried out at the laboratory and the relevant VSPHIS is informed of the final results. An internal quality control system in accordance with ISO standards is in place.
42 Valid as of April 2008
Residues
MH
Legislation
SSI Technical NIPH- RASFF (DSFN) assistance NIH
Control plan, instructions, audit
VSES + labs
Supervision, audit
PSES + BSES
Controls, sampling
Food commodities
MH Ministry of Health SSI State Sanitary Inspection DSFN Department for Safety of Food and Nutrition NIPH-NIH National Institute of Public Health - National Institute of Hygiene VSES Voivodship Sanitary and Epidemiological Station(s) PSES Poviat Sanitary and Epidemiological Station(s) BSES Border Sanitary and Epidemiological Station(s)
Competent Authorities
The MH is responsible for legislation on pesticide residues and for setting maximum residue levels (MRL). The CA responsible for implementation and controls is the DSFN of SSI.
The SSI provides VSES with information on: annual plans; sampling schedules; instructions; guidelines on particular issues and on implementation of EU and national legislation; official procedures for food control; information from RASFF system; and training. The VSES are responsible for the delivery of SSI instructions to the PSES and for ensuring their implementation.
43 Valid as of April 2008
Official controls on residues
Samples are taken at all marketing stages, including at import. The sampling plan is drafted by the NIPH-NIH and submitted to SSI for approval. The plan reflects national and EU laws, results of food safety research and monitoring, and the population of the country. Pesticide residues form an integral part of the overall plan for official control of food. The plan specifies the number of samples to be taken by each VSES, the commodities to be sampled, the scope of the laboratory analysis for the different commodities, and the analytical methods.
The PSES and, for imports, BSES, are responsible for inspections, sampling and follow- up. Results are sent quarterly and annually in electronic format to the SSI on standardised forms and include comprehensive analytical reports for all samples.
Laboratories
NIPH-NIH is the NRL for pesticide residues. In addition, nineteen laboratories perform analyses of pesticide residues. The current focus is on completing the accreditation process and extending the number of validated analytical methods, which is expected to increase from 98 to 108 in 2008.
PPP residues analyses are conducted by the Central Laboratory of SPHSIS, PPI and its organisational units and the Research Institute of Pomology and Floriculture, Laboratory of Contaminations and Pesticides Residue Analyses. In 2006, almost 1,800 samples were analysed, with 42 notified to RASFF as exceeding the MRL.
44 Valid as of April 2008
2.10. Control system for animal welfare
MARD MT (DFSVM)
Legislation
Formal GVI agreement RTI (AHWO) on co-operation Instructions, audit Roadside checks, sometimes with PVI VVI BVI
Supervision Controls on animals at the PVI Controls, border route plans, authorisation of transporters
Farms, Slaughter- Transporters markets houses
MARD Ministry of Agriculture and Rural Development DFSVM Department of Food Safety and Veterinary Matters MT Ministry of Transport GVI General Veterinary Inspectorate AHWO Animal Health and Welfare Office RTI Road Transport Inspection VVI Voivodship Veterinary Inspectorate(s) BVI Border Veterinary Inspectorate PVI Poviat Veterinary Inspectorate(s)
Competent Authorities
MARD, and MT as regards the transport of animals, are responsible for animal welfare matters. GVI is the CA for animal welfare and is responsible for policy and controls in this sector. It is responsible for issuing instructions and guidelines to the VVI and PVI and for monitoring and supervising their work. The instructions are available on the GVI website, which is accessible to the public. In the AHWO, one official works part-time on animal welfare issues. At VVI and PVI levels, there is a legal requirement to have an inspector dedicated specifically to animal welfare issues. However, due to staff and financial constraints, inspectors usually deal with animal welfare issues in the context of their other control tasks.
45 Valid as of April 2008
VVI have overall management responsibility for animal welfare policy and controls within their regions. They are also responsible for providing information on the interpretation of guidelines and regulations to PVI inspectors. Furthermore, VVI are responsible for organising training for Voivodship and Poviat officials, as well as for PVP. Where agreements exist, they provide training for staff of the RTI of MT. They also liaise with the RTI on certain co-ordinated inspections.
Official controls on farm
PVI are responsible for: keeping records of holdings; performing checks on farms; practical implementation of all animal health and welfare policies; public health measures; animal movement controls; health certificates and journey logs; and authorisation of transporters. They appoint and monitor PVP who conduct animal welfare controls. All animal holdings are required to keep a log, which must be regularly updated with details of all events relating to the animals. Consignments of farm animals in trade are checked by OV at both loading and unloading stages. Traceability of movement of farm animals across the territory of Poland is carried out by GVI using the Identification and Registration System of animals.
GVI supervises compliance with the legal provisions on animal protection. Farms are checked by PVI inspectors and PVP, with a target of 5% of farms to be visited annually. Standardised checklists are used and results are reported to the centre, via the VVI.
The local Mayor, in co-operation with the DVO, is responsible for issuing legal notices to enable the seizure and confiscation of animals.
Official controls during transport
GVI has a centralised system in place for the authorisation of transporters and the organisation of checks on the transport of animals. The system includes documented procedures, training, internal audits, supervision and reporting.
RTI carries out checks of livestock vehicles as part of their roadside controls. In 2007, they inspected 2,171 vehicles with live animals and detected 141 infringements, mainly for lack of documentation. Fines were imposed on the offenders. RTI also performs joint checks with OV. An agreement is in place between RTI and GVI on co-operation in respect of animal welfare issues. This includes: the organisation of joint inspections; the mutual exchange of information and reports; and the annual submission to GVI of the results of RTI checks. BVI is responsible for inspections at BIP on animal welfare during transport.
In 2006, two combined controls of road transporters were carried out on main roads linking Poland with neighbouring countries, involving the RTI, GVI, Customs and Police. These controls were not just for animal welfare purposes, but also covered other areas, such as smuggling. GVI issued an updated checklist to take into account the requirements of Regulation (EC) No. 1/2005 on checks for approval of animal transporters. Databases of vehicles and transporters authorised for long journeys are available on the GVI website. This data is provided by PVI from their own registers on a regular basis.
GVI has instructed that a control on animal welfare must form part of the checks carried out at assembly centres.
46 Valid as of April 2008
Official controls at slaughter
Each slaughterhouse is subject to ongoing monitoring by the OV or PVP, who carries out supervision in accordance with procedures developed by the GVI. This includes the completion of a daily log book to record irregularities. In addition, unannounced inspections by DVO and RVO take place. An annual summary report of controls is submitted by the PVI to the VVI, which in turn report to the Centre.
47 Valid as of April 2008
2.11. Control system for plant health
MARD (DBPP)
Legislation
Main Inspectorate Technical Central Laboratory of SPHSIS (PSD) advice of SPHSIS (NRL)
Control plan, instructions
SPHSIS Training. labs + branches instructions
Supervision
Field Units + BIP
Controls, sampling, issuing plant passports, internal market checks
Retailers, wholesalers, users
MARD Ministry of Agriculture and Rural Development DBPP Department of Breeding and Plant Protection SPHSIS State Plant Health and Seeds Inspection Service PSD Psytosanitary Supervision Division NRL National Reference Laboratory
Competent authorities
The Department of Breeding and Plant Protection (DBPP) of MARD is responsible for legislation on Plant Health. The SPHSIS is the single and central authority in Poland within the meaning of Article 1 (4) of Council Directive No. 2000/29/EC and the responsible official body according to Article 2 (g). It represents Poland at international level and is responsible for the implementation of the relevant EU legislation.
The SPHSIS consists of several Divisions, of which the Phytosanitary Supervision Division (PSD) is responsible for the control of harmful organisms.
The VSPHSIS provide the Centre with six-monthly, annual and ad-hoc reports. In addition, the SPHSIS controls VSPHSIS activities through comprehensive checks of overall or specific activities. The VSPHSIS conduct internal controls at least once a year in each field unit.
48 Valid as of April 2008
The SPHSIS issues instructions and guidelines and prepares training programmes for its staff. At VSPHSIS level, monthly meetings with field unit managers are held in order to communicate instructions and interpretations from the Centre.
Plant passport system and internal market checks
VSPHSIS responsibilities include: - plant health checks and laboratory testing of plant, plant products and all contact materials, including at import; - registration and issuing of decisions on the control of harmful organisms, including risk assessment; - planning and carrying out inspections and surveys at places of production; - carrying out import and export certification and other controls; - maintaining the register of producers, issuing plant passports, supervision of units authorised to issue plant passports; - issuing certificates for producers using integrated plant production.
At field unit level, inspectors generally perform controls on both plant health and PPP. In 2007, almost 65,000 controls of registered plant producers were carried out and over 41,000 plant health controls (first six months only). All data relating to controls are entered by the inspectors in the database Integrated System of Information on Plant Health and Seed Inspection.
Each VSPHSIS prepares an annual work plan of the activities to be carried out, in collaboration with the field units. Plant health controls are planned on the basis of the crops and the relevant estimated areas of production, taking into account any specific problems. The number of surveys to be carried out and the relevant areas are indicated. The plan may be updated during the year.
SPHSIS is the sole authority for issuing plant passports; no traders or producers have been authorised for this purpose up to now.
SPHSIS keeps all relevant parties informed of legislative and technical issues by various means, including a website. At VSPHSIS level, information is sent to farmers and retailers through media coverage or by posters describing plant diseases and pests. Farmers also receive technical information on pest control from an advisory board.
Import controls
SPHSIS prepares the control plan for imports in collaboration with the VSPHSIS. The documentation relating to all consignments containing plants or plant material, whether regulated or non-regulated articles, is re-directed by Customs to the plant health service. The documentary, identity and plant health checks of regulated articles are carried out at the BIP of entry. The system for sampling is based on an official procedure.
Co-operation agreements have been signed with the Border Guard and the Police, under the MIA, with the RTI of the MT, and with Customs. Meetings are organised between these bodies as required. Corresponding regional co-operation agreements are also in place.
49 Valid as of April 2008
Laboratories
The Central Laboratory at Toruń is an integral part of the SPHSIS and is the NRL for plant health matters. It conducts plant health testing, supervises the laboratories of the VSPHSIS and border inspection points and verifies positive and doubtful results. It also provides training and instructions for staff, and determines the responsibilities of each laboratory, based mainly on the availability of equipment and trained staff.
Voivodship Laboratories are responsible for examination of plants, plant products and objects, including those destined for export and re-export. Diagnostic Units of the BIP perform some analyses of imported plant material.
50 Valid as of April 2008
3. FOLLOW-UP OF FVO INSPECTIONS
Summary of follow-up status This part of the country profile gives an overview of the action taken on the recommendations made by the FVO to the Polish authorities in its inspection reports. 1 At the time of the general review mission to Poland in December 2007, a total of 339 recommendations had been made in the 44 finalised inspection reports for Poland in the period since 2003.
Prior to the 2007 general review mission, the Commission had closed 295 of these recommendations, either on the basis of action taken2 by the CA or because they were no longer relevant. The remaining 44 recommendations were followed up during the general review mission in December 20073. These consisted of 11 recommendations classified in the 2006 country profile as “In progress”(9) or "Action still required"(2) and 33 recommendations requiring follow up from inspection mission reports which had reached the closeout stage in the meantime. In the case of these more recent recommendations, the response of the CA was considered to be unsatisfactory in 3 cases and verification of promised action by the CA was considered necessary in 30 cases. The position is summarised in the following table:
Pre-General Review Post- General Mission 2007 Review Mission 2007 Action taken / 295 324 No longer relevant Outstanding / 5 4 Action still required For verification / 39 11 In progress Total number of 339 339 recommendations
1 Those in respect of which the technical assessment by the FVO had been finalised (“closeout”) at the time of the general review mission. 2 For the purpose of the country profile the terms: "Action taken," "In Progress", “No longer relevant” and "Action still required" are defined as follows: "Action taken": Appropriate measures to address the recommendation have been implemented by the Competent Authority. The recommendation is therefore closed. "No longer relevant": For administrative, technical or legal reasons follow up of the recommendation is no longer appropriate. The recommendation is therefore closed. "In Progress": Appropriate measures to address the recommendation have been initiated by the Competent Authority but not all of the measures have been implemented. The recommendation therefore remains open. "Action still required": Appropriate measures to address the recommendation have not been initiated by the Competent Authorities. The recommendation therefore remains open. 3 It should be noted that the number of recommendations in this overview does not represent, of itself, a measurement of the degree of responsiveness by the Competent Authorities or of the seriousness of problems. Some recommendations may be related to minor technical aspects while others may refer to more problematic, systemic, issues. 51 Valid as of April 2008
This assessment is based on information and documentation received and reviewed during meetings with the Competent Authorities in the course of the 2007 general review mission. Given the nature and scope of the general review mission, no verification through inspection on the spot was carried out. The assessment undertaken through the general review mission is considered complementary to other follow up actions and verifications that may be necessary and carried out as part of future sectoral inspections by the FVO. In this regard, unless otherwise indicated, recommendations classified as “In progress" or "Action still required" are not considered to require any immediate specific legal or administrative action on the part of the Commission. These recommendations will remain the subject of monitoring by the Commission to assess progress. If, as a result of this monitoring, the Commission considers the situation in regard to any of these recommendations warrants additional action on its part, it will take the appropriate measures.
The following table gives an overview of FVO missions to Poland and the assessment in relation to the 44 recommendations identified for further follow up during the 2007 general review mission. The findings in relation to individual recommendations are presented in a separate chapter for each control system.
X: No recommendations identified for follow-up during the FVO general review mission of December 2007 A: recommendations on which action has been taken P: recommendations on which action is still in progress R recommendations on which action is still required N: recommendations which are no longer relevant *: recent inspections for which responses from the CCA are awaited or are being assessed by the FVO S: Scheduled FVO mission
in g
Inspection reference number and
objectives of the inspection
in iene g yg Animal health originFood of animal and of animals Imports food of animal ori animal and Feedingstuffs nutrition TSE\ABP medicines Veterinary residues and Foodstuffs and food h of plant of food Imports ori products protection Plant Animal welfare Plant health Pre-accession X mission BSE/animal nutrition Pre-accession Veterinary X mission residues/VMPs Pre-accession Public health/animal X mission health Pre-accession Public health/animal X mission health Food of plant origin Pre-accession (hygiene, contaminants X mission and pesticide residues) Pre-accession Public health - poultry, X mission fish and eggs Pre-accession Plant health and X mission pesticides Pre-accession Import controls (BIP) X
52 Valid as of April 2008
in g
Inspection reference number and
objectives of the inspection
in iene g yg Animal health originFood of animal and of animals Imports food of animal ori animal and Feedingstuffs nutrition TSE\ABP medicines Veterinary residues and Foodstuffs and food h of plant of food Imports ori products protection Plant Animal welfare Plant health mission Pre-accession Veterinary X mission residues/VMPs Pre-accession X mission BSE/animal nutrition Pre-accession X mission Import controls (BIP) Pre-accession X mission Plant health Pre-accession Public health/animal X mission health Pre-accession X mission Animal welfare Food of plant origin Pre-accession (hygiene, contaminants X mission and pesticide residues) Pre-accession Disease controls- X mission zoonoses /Rabies) Public health/animal X 7177/2004 health 7320/2004 Plant health (potatoes) X Animal health - semen X 7325/2004 collection centres Food of plant origin – X 7336/2004 import controls X 7518/2005 Animal by products Food of plant origin – X 7521/2005 hygiene 7594/2005 Import controls (BIP) X 7598/2005 Plant health (potatoes) X Public health/animal X 7612/2005 health 2A
7638/2005 Animal welfare 2R 7651/2005 General review mission X X X X X X X X X X X 2A
7665/2005 Pesticides 1P 7683/2005 Plant health (passports) X 7693/2005 TSE/animal nutrition X 3A
7728/2005 Import controls (BIP) 1P 7773/2005 Plant pest outbreak X Contaminants 2A 8003/2006 (Dioxins) 8063/2006 Import Controls (BIP) 2A GMO feed and food X 8106/2006 controls 2A
8132/2006 Import Controls 2P Disease eradication – X 8141/2006 salmonella
53 Valid as of April 2008
in g
Inspection reference number and
objectives of the inspection
in iene g yg Animal health originFood of animal and of animals Imports food of animal ori animal and Feedingstuffs nutrition TSE\ABP medicines Veterinary residues and Foodstuffs and food h of plant of food Imports ori products protection Plant Animal welfare Plant health 2A 2P 8169/2006 Trade in live animals 1R Identification, X 8210/2006 Certification 8289/2006 General review mission X X X X X X X X X X X 8310/2006 BSE/Total feed ban X 8320/2006 Food hygiene package X Infant formulae/baby * 7153/2007 foods 7245/2007 BSE 6A 4A
7259/2007 ABP 1P Animal welfare - * 7334/2007 horses 1A 2P 7361/2007 Rabies eradication 1R Intra-Community trade * 7372/2007 - horses 7376/2007 Plant health * Meat, milk and their 3A
7442/2007 products 2P 7596/2007 General review mission X X X X X X X X X X X Disease contingency * 7789/2008 plans Food safety, meat and S 7810/2008 milk Import and transit S 7760/2008 controls and BIPs Animal welfare – on farms, in transport and S 7693/2008 at slaughter Disease eradication S 7794/2008 control programme
54 Valid as of April 2008
3.1. Animal health
Since 2003 the FVO has carried out 4 pre-accession missions and 5 inspections in Poland in relation to animal health.
Out of a total of 67 recommendations contained in the reports of these missions, 9 were identified for follow-up during the 2007 general review mission. All of them were contained in reports that had reached closeout stage since the 2006 general review mission.
The following table summarises the FVO’s assessment of the position on these recommendations following the 2007 general review mission. Recommendations reaching closeout stage since the 2006 general review mission. MR 8169/2006 of 20/03/2006 on Intra-Community Trade
Reference no. and Findings Assessment Recommendation (25570) To ensure that CA provided a list of national legislation incorporating the Action taken national legislation requirements of Council Directive 64/432/EEC, and made accords with the specific reference to the laws on approval of premises for intra- requirements of Community trade (ICT). Council Directive CVO instructed DVO to take action where the requirements for 64/432/EEC, ICT were not being met. DVO issued Administrative Decisions particularly regarding amending the instructions for, and practices in, these centres, the approval of with a deadline for implementation. Follow up is planned to premises used to gather ensure that corrective action is being taken. consignments of live animals intended for Deputy CVO issued a letter to DVO (copy provided to the intra-Community trade. Commission) that only OV may approve movement for ICT in these centres. The template stamp for such approval was
changed, to more easily identify the signatory. In its reply to the draft country profile, CA stated that the National Law implementing Directives 64/432, 91/68, 90/426 established that animals (cattle, sheep, goats, pigs and horses) can be put on market either directly from the farm or through animal assembly centre. In case of sheep and goats intended for slaughter it is permitted to export them from the collecting centre. Detailed rules on the composition of consignments of animals on the basis of national law have been described in the letter nr ŻWzz/tm-462-13/2008 (MARD) and GIWz.400/T-20-5/07 (GVI), copies of which were provided to the FVO. The question of supervising the implementation of these, and other, rules is covered under recommendation (25572). (25571) To fully CA submitted a lengthy initial response to this In progress implement the recommendation, pointing out that the CVO had been making requirements of repeated requests for funding additional staff to the Ministry of Articles 4 and 6 of Finance, via MARD, since 2001, but was still understaffed by Regulation (EC) No. approximately 1,100 officials. CA explained that the problem 882/2004, and in was not only a lack of funding to provide new posts, but also particular to ensure that inadequate remuneration packages to retain staff once they sufficient numbers of were recruited and trained. This leads to a big turnover of staff, suitably qualified, with a resulting lack of experience in the existing staff pool. trained and CA stated that it has significantly increased the level of training experienced staff are of its personnel as well as of OV appointed to carry out specific employed so that functions, in particular as regards activities relating to the official controls and introduction of live animals into intra-Community trade. control duties can be
55 Valid as of April 2008
MR 8169/2006 of 20/03/2006 on Intra-Community Trade
Reference no. and Findings Assessment Recommendation carried out efficiently In addition, relevant instructions on intra-Community trade and effectively. have been updated. CA stated that its resources at Central level were insufficient to carry out an exercise in order to prioritise the work done at local level. In its reply to the draft country profile, CA confirmed that the budget for the 796 new posts to help combat Aujesky's Disease had been granted. Training in trade of animals, identification and animal welfare is ongoing. It remains unclear when these posts will actually be filled and whether they will be sufficient to ensure that controls are carried out efficiently and effectively. (25572) To ensure that CA's initial reply listed the measures taken to address this In progress official controls are recommendation. Detailed instructions were issued by the CVO carried out effectively to RVOs and DVOs on rectifying the irregularities discovered and that corrective during the FVO inspection. actions are taken when CA confirmed that training is systematically provided by needed, in accordance cascade to OV following the issue of new instructions, to with the requirements ensure that they are correctly and consistently implemented. of Article 8 of CA stated that there was a reduced number of complaints being Regulation (EC) No. made in relation to intra-Community trade 882/2004. Although it had been indicated during the FVO inspection that RVOs carried out regular inspections of assembly centres, it was unclear whether, in reality, OV were actually supervised by the RVO and DVO on the spot during official controls. In its reply to the draft country profile, CA confirmed that a training course for RVOs in June 2008 included instructions to be passed on to DVOs to pay extra attention when supervising the work of OV, especially those dealing with trade in animals and controls of the animal welfare and identification of animals. The FVO will review this recommendation again when reports of the effect of this extra supervision become available. (25575) To ensure that CA's initial response referred to various instructions issued by Action still required the testing regimes the CVO to RVOs and DVOs, which provide uniform adopted for animal guidelines for the procedures to be followed when carrying out diseases, in particular control tests or when combating bovine Brucellosis or bovine Brucellosis, Tuberculosis. These instructions require testing to be done on a comply with the 3-year cycle, which the CA interprets as the required frequency requirements of under Council Directive 64/432/EE to ensure the maintenance Annexes A and D of of officially free status. Training of DVO inspectors on the Council Directive implementation of these guidelines was carried out. 64/432/EEC and that CA confirmed that testing is carried out in accordance with a the officially disease- control plan established at DVO level, using ARMA statistics free status of herds is on animal numbers and locations. The plans are submitted to suspended if they are the RVO, who compiles the details for the whole region, before not tested within the sending them to the CVO. intervals prescribed. In the initial reply, the CVO stated that work was being done on
the use of software by the GVI to suspend automatically the [disease-free] status of a herd in case testing had not been carried out in that herd at the appropriate time, and to inform the DVO of this fact. Overall, CA does not accept that bovine herds must be tested at
56 Valid as of April 2008
MR 8169/2006 of 20/03/2006 on Intra-Community Trade
Reference no. and Findings Assessment Recommendation least once every two years in order to be considered officially free of the disease, as specified in Annex 2 of Council Directive 64/432/EEC.
(25577) To ensure that CA's initial response listed the measures taken to address this Action taken checks are performed recommendation. CVO organised training on the carrying out on live animals at their of non-discriminatory checks on live animals at their destination in destination. All irregularities are recorded by the DVO and accordance with the reported to the CVO, via the RVO. A central register of requirements of Article irregularities is maintained. CVO analyses the information and 5 of Council Directive informs the CA of the originating country accordingly. 90/425/EEC, that the CVO reported that, as a result of these measures, there has been corrective actions set a significant increase in the number of notifications of out in Article 6 of that irregularities uncovered. Directive are applied if necessary and that the CVO issued instructions to DVOs on 27 September 2007 on results of all checks are checks of animals at their destination and the recording of the recorded in the manner results of these checks as recommended by Commission prescribed by Regulation (EC) No. 599/2004. (Copy of instruction provided Commission to the FVO). Regulation (EC) No. 599/2004.
MR 7361/2007 of 07/05/2007 on Rabies eradication programme Reference No and Findings Assessment recommendation (1) To ensure proper The GVI has repeatedly applied for additional posts. In most In progress staffing at all levels of cases, the number of posts created does not correspond to actual the CAs and needs. In addition, there is high rate of turnover of employees. laboratories, in order to (See also Findings to Recommendation (25571) of MR perform the prescribed 8169/2006). tasks without delays. In its reply to the draft country profile, CA confirmed that for 2008 the GVI received 796 additional posts for PVI for eradication of infectious diseases. GVI will apply for additional posts also for central and regional level. (3) To improve co- The 2007 agreement between the RVO for Warmińsko- Action taken ordination with Mazurskie and the Border Guard of the Russian Federation neighbouring countries, provides that, following an application by the Polish in order to have the veterinary services, aircrafts distributing the vaccine will be international borders allowed to fly across border regions unhindered, so that there and adjacent areas are no areas along the border with the Kaliningrad District effectively vaccinated where vaccine is not distributed. and protected. An agreement between the CVOs of Poland and Ukraine provides for the creation of a 70-km buffer zone along the Polish-Ukrainian border; the Ukrainian side will also take part in the vaccination campaign. The CA has asked the EU Commission about the possibility to finance vaccinations in Ukraine's border regions.
57 Valid as of April 2008
MR 7361/2007 of 07/05/2007 on Rabies eradication programme Reference No and Findings Assessment recommendation (5) To ensure that the The CVO wrote to the RVOs (letter no. GIWz.400/W-34- In progress minimum number of 8 1/07), recommending more effective co-operation with foxes / 100 Km² District Hunting Associations. Hunters must indicate age and collected for sex of the fox in a covering letter. DVOs in their agreements monitoring purposes is with hunting associations should ensure that the foxes are effectively applied in collected throughout the whole territory of the District. all Regions, covering CA stated that there was good, close co-operation between the both vaccination GVI and the Hunters Associations, but the contacts are campaigns, and that the informal and not covered by law. The CVO has decided that data on dynamics of the sample collection should be coordinated at RVO, rather the fox population, age than DVO level. CA believes that the goal of 8 foxes/100Km² and sex are analysed in is likely to be met in 2008. order to guide the further development of In its reply to the draft country profile, CA provided a table of the eradication strategy for particular foxes shot for testing in 2007. In some regions the target of 8 vaccination campaigns. foxes/100 Km² was met or slightly exceeded. In others it was slightly less. The CVO has written twice to the Hunters Associations inviting discussions on the problems of monitoring and on the establishment of rules of more effective co-operation with GVI. No reply has been received to date.
(6) To ensure that the Action still required According to the CA, control of the fox population is not a population trend is task for the GVI. Accordingly, in letter no. GIWz.400/W-34- followed during 2/07, the CVO provided the Minister of the Environment with planning of vaccination information about the need to shoot foxes as a means of campaigns and to controlling the population. However, CA stated that the very implement a national low premium paid to hunters for collecting foxes did not hunting strategy to provide them with sufficient incentive to shoot foxes. keep the fox population under control between these campaigns. In its reply to the draft country profile, CA reiterated that GVI was not responsible for the strategy of controlling the population of wild animals, which falls within the competence of the Ministry of the Environment.
58 Valid as of April 2008
3.2. Food of animal origin
Since 2003 the FVO has carried out one pre-accession mission and 4 inspections in Poland in relation to food of animal origin.
Out of a total of 46 recommendations contained in the reports of these missions, 5 were identified for follow-up during the 2007 general review mission. All of them were contained in reports that had reached closeout stage since the 2006 general review mission.
The following table summarises the FVO’s assessment of the position on these recommendations following the 2007 general review mission. Recommendations reaching closeout stage since the 2006 general review mission.
MR 7442/2007 of 04 June 2007 on official controls related to the safety of food of animal origin, in particular meat and milk
Reference no. and Findings Assessment Recommendation (1) To finalise the New legislation has been drawn up and Action taken. updating of legislation, instructions and guidelines have been issued, or instructions and are under preparation, to address this guidelines in line with recommendation. These cover, inter alia: the the requirements of the approval and registration of FBO; uniformity of new EU hygiene controls by OV on establishments and on PVP; legislation. supervision of OV by RVO; frequency of controls based on risk analysis.
(4) To put in place a Action taken. The instruction on approval of FBO mentioned system for non under recommendation (1) also covers this approved recommendation. Preliminary assessments have establishments that already been done on 1,547 affected before 1 January 2006 establishments. CA provided statistics to the were allowed to place Commission on the breakdown of this figure in food of animal origin relation to the intentions of FBO to comply or on the national market cease operating. A deadline of March 2009 has as foreseen in Article 4 been set by the CA to have the action finalised, in (5) of Regulation (EC) order to allow sufficient time for any follow-up by No 853/2004, in order the statutory deadline of 31 December 2009. to ensure that all of them comply with EU requirements by the end of 2009
59 Valid as of April 2008
MR 7442/2007 of 04 June 2007 on official controls related to the safety of food of animal origin, in particular meat and milk
Reference no. and Findings Assessment Recommendation (6) To take further Action taken. CVO Instruction No GIWhig-500-11/07 of 14 measures in order to August 2007 on defining, on the basis of risk ensure the uniformity assessment, the frequency of controls of FBO, as and consistent quality well as the Instruction No GIWhig-500-3a/07 of of the official controls 11 September 2007 on procedures during plant so that only fully approval, conditional approval as well as compliant registration of food industry plants, suspension establishments are and withdrawal of approval for these plants approved in accordance regulates the uniform control approach for all with Article 3 of GVI levels. Regulation (EC) No 854/2004 and to ensure Training of control staff is carried out routinely that FBOs comply with the general and specific following the issue of instructions, to ensure a hygiene requirements standardised interpretation. laid down in Council Regulations (EC) No 852/2004 and 853/2004.
(7) To ensure that In progress. The CVO, in her letter No GIWhig- 501 - 392/07 traceability is of 30 July 2007, ordered intensification of established at all stages controls on labelling in milk establishments and of production and on traceability of the product, including intestines processing as required supplied to the processing plant. in Article 18, 1 of Regulation (EC) No 178/2002 and that food GVI carried out training of control staff on the implementation of the CVO’s Instruction No placed on the market is adequately labelled or GIWhig-500-4/07 of 4 April 2007 on the identified. performance of official controls regarding traceability of animals, foodstuffs, substances intended to be added to food as well as marking of products of animal origin. Further training will be provided in 2008. An overview of the enforcement of traceability at all stages of production and processing is planned to be completed by end 2008. (8) To further improve In progress. It is planned to provide OV with guidelines, the official controls drawn up in co-operation with scientists of the over raw milk quality National Veterinary Research Institute in Pulawy, and assess the for carrying out controls of raw milk quality and reliability of the interpretation of results for OLB and the number controls carried out of somatic cells. These were to be issued in with regard to the January 2008. Supervision of OV is planned criteria for raw milk. during 2008 to see how instructions are implemented on the ground. (Approximately 340 milk establishments plus over 2,000 milk collection points involved).
60 Valid as of April 2008
3.3. Imports of animals and food of animal origin
Since 2003 the FVO has carried out 2 pre-accession missions and 3 inspections in Poland in relation to imports of animals and food of animal origin.
Out of a total of 39 recommendations contained in the reports of these missions, 6 were identified for follow-up in the 2007 general review mission, of which 4 were carried over from the country profile of 2006 and 2 were contained in reports that had reached closeout stage since the 2006 general review mission.
The following table summarises the FVO’s assessment of the position on these recommendations following the 2007 general review mission. Recommendations carried over from the country profile of December 2006.
MR 7728/2005 of 18 November 2005 on Border Inspection Posts Reference no. and Findings Assessment Recommendation (22664) To complete Overtaken by recommendation (27434) of MR Action taken the development of 8063/2006. adequate co-operation with other involved authorities for the identification and selection of the consignments of veterinary interest entering or transiting EU territory, in particular regarding the access or exchange of relevant information as required in Regulations (EC) No 136/2004 and (EC) No 282/2004. (22667) To complete Earlier financial problems preventing the In progress the rectification of the completion of work at Bezledy BIP have been deficiencies noted resolved. The shortcomings in infrastructure will during the previous be rectified after the finalisation of tender mission concerning procedures. The plans have been already prepared infrastructure for live by an architectural company and completion of animals in Bezledy and works was foreseen for spring 2008. Warszawa Okecie. According to the CA, the problems in Warsaw- Okecie airport BIP involve the whole building. As it is not feasible to reconstruct the building, the solution found was to establish procedures for staff movement in order to avoid cross contamination. A copy of the procedure was received by the FVO. (22668) To further Overtaken by recommendation (27434) of MR Action taken develop the system for 8063/2006. identification and selection of consignments to ensure that live animals or products of animal origin will be presented for the veterinary checks as required in 61 Valid as of April 2008
MR 7728/2005 of 18 November 2005 on Border Inspection Posts Reference no. and Findings Assessment Recommendation Directives 91/496/EEC and 97/78/EC and the associated Regulations and Decisions. (22671) To ensure that CA confirmed that a check of personal luggage is Action taken the requirements for carried out on every border crossing on the checks on personal external border of the EU where the movement of luggage are goods or persons from third countries is noted. implemented as The list of border crossings was sent to all PVI to foreseen in Regulation ensure that the control is carried out at each point (EC) No 745/2004, in of entry. The controls are carried out by Customs, particular regarding or in some ports by the Border Guard, under the checks on postal Ministry of the Interior. consignments. Regarding postal consignments, according to a letter dated 19 May 2006 from the Department of Post in Ministry of Transport, a check of such consignments is carried out in co-operation with Customs and GVI. The proper equipment for storage and identification of such parcels is in place. Following several reorganisations of the supervision of the State Post, a meeting is planned to discuss the present status and update the procedures, as required.
Recommendations reaching closeout stage since the 2006 general review mission.
MR 8063/2006 of 13 November 2006 on Import controls and border inspection posts Reference no. and Findings Assessment Recommendation (27433) To complete the CA confirmed that all the construction Action taken. construction of the proposed works have been finalised and all BIP and to ensure that all equipment is installed. All buildings and facilities and equipment facilities are fully operational and comply comply with the requirements with the legal requirements. of Directive 97/78/EC and Decision 2001/812/EC.
(27434) To develop a system CA stated that at the meeting between Action taken. for the identification and representatives of the CVO and Customs selection of the consignments Service on 2 February 2007, local of veterinary interest, agreements were concluded between BIP especially regarding electronic and the Customs Service concerning access systems for the analysis of to data required by border veterinary relevant intelligence, as laid officers and obtained from customs down in Art. 6 and 7 of databases. Taking into account the Regulation (EC) No specificities of individual border crossings 136/2004. (road, maritime and rail crossings), the agreements provide border veterinary Refer also to officers with access to data which are recommendations (22664) and essential for carrying out cross-checks (22668) of MR 7728/2005. whilst at the same time complying with the applicable rules on the handling of data from the Customs Service's information systems.
The customs system Isztar II has been updated and a new list of goods to be 62 Valid as of April 2008
MR 8063/2006 of 13 November 2006 on Import controls and border inspection posts Reference no. and Findings Assessment Recommendation subject to veterinary control according to Dec. 2007/275 was included to automatically inform customs that the particular goods need to be presented to the BIP. It is operational in the whole country.
3.4. Feedingstuffs and animal nutrition
Since 2003 the FVO has carried out one pre-accession mission.
Out of a total of 6 recommendations contained in the report of this mission, none was identified for follow-up during the 2007 general review mission.
3.5. TSE/ABP
Since 2003 the FVO has carried out one pre-accession mission and 5 inspections in Poland in relation to TSE and ABP.
Out of a total of 62 recommendations contained in the reports of these missions, 11 were identified for follow-up during the 2007 general review mission. All of them were contained in reports that had reached closeout stage since the 2006 general review mission.
The following table summarises the FVO’s assessment of the position on these recommendations following the 2007 general review mission. Recommendations reaching closeout stage since the 2006 general review mission.
MR 7245/2007 of 17/04/2007 on BSE
Reference No and Findings Assessment recommendation (1) To continue the CA confirmed that 304 new control staff Action taken efforts to recruit staff (veterinarians or zoo-technicians), or one per PVI, required to implement were recruited during 2007, with most already in BSE controls, notably their posts by the end of 2007. CA insisted that in the areas of the total these officials were in addition to, rather than feed ban and the use of replacing, existing staff, and would concentrate on OF/SI. controls in the areas of the total feed ban and the use of OF/SI. MR 8310/2006 made a similar They will undergo a 6-month training programme recommendation. in 2008, targeted at their specific duties.
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MR 7245/2007 of 17/04/2007 on BSE
Reference No and Findings Assessment recommendation (3) To take measures to The CVO has issued standardised rules of Action taken ensure a consistent procedure for the GVI with regard to risk approach to performing assessment. This instruction is supported by a risk analyses for checklist and sample letter to users. CA provided carrying out official copies of the instruction and check-list to the controls regarding the FVO. total feed ban set out in Annex IV to Regulation (EC) No 999/2001. (4) To put in place a The Act of 24 May 2007 amending the Act on the Action taken system of sanctions for Protection of Animal Health and the Eradication non-compliance with of Infectious Diseases in Animals, and the Act on the requirements of Border Veterinary Controls introduced provisions Regulation (EC) No which increased the penalties for infringement of 181/2006 and the total the ban laid down in Regulation (EC) No feed ban required by 999/2001: an infringement of the ban is now Regulation (EC) No treated as a crime within the meaning of criminal 999/2001 and which law, and not, as previously the case, as a are effective, misdemeanour. A new fast-track system of proportionate and judicial procedure was introduced by the amended dissuasive as required Code of Criminal Procedure Act, which was by Art. 55 of approved on 16 November 2006, allowing the Regulation (EC) No prompt imposition of sanctions. Failure to observe 882/2004. the requirements of Regulation (EC) No 181/2006 is also punishable in accordance with the above MR 8310/2006 made a Act. similar recommendation. CA announced an increase in the number of prosecuted cases reported by DVO. (5) To consider CA confirmed that MARD has drawn up an Action taken requiring farmers to amendment to the Decree on Veterinary provide information Requirements for Soil Improvers (Official Gazette concerning the No 84, item 583), which entered into force on 25 anticipated date of December 2007. This requires farmers intending delivery and use of to purchase a soil improver to seek approval from OF/SI to help target the DVO, stating the approximate anticipated date controls. of purchase. The approval expires after 30 days. The buyer must also provide details of the
supplier. This procedure is designed to facilitate targeted controls. A copy of the amended Decree was provided to the FVO. (6) To take the CA referred to the obligation of purchasers of soil Action taken measures necessary to improvers to apply for DVO prior approval, which ensure that processed assists inspectors in assessing potential risks. CA products derived from confirmed that once soil improvers are spread, the the processing of ABP field is immediately ploughed. In addition, there is in a processing plant of a requirement to mark Category 2 and 3 animal are not applied as such meal intended for use as a soil improver in a directly to land where mixture of meal and lime-based fertiliser with a farmed animals might content of 10 - 30% (see also findings to have access, as set out recommendation (7)). in Art. 6(2) of Regulation (EC) 181/2006.
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MR 7245/2007 of 17/04/2007 on BSE
Reference No and Findings Assessment recommendation (7) To ensure marking CA has introduced a Decree amending the Decree Action taken of Category 2 on the Veterinary Requirements for Soil processed products Improvers, Art 12 of which provides for the used as OF/SI as laid application of lime-based fertilisers to the marking down in Article 5(2c) of animal meal. CA confirmed that the new of Regulation (EC) Decree is currently being applied. No 1774/2002. MR 8310/2006 made a similar recommendation.
MR 7259/2007 of 17/04/2007 on ABP
Reference no. and Findings Assessment Recommendation (1) To pursue efforts to See under Recommendation (1), MR 7245/2007. Action taken ensure that sufficient resources are available within the PVIs to enable the system of official controls to be implemented effectively throughout the ABP chain, as required by Art. 4(2)(c) of Regulation (EC) No 882/2004. MR 8310/2006 made a similar recommendation. (2) To ensure that all CVO letters Nos. GIW puf. 710ui.40/07 and In progress ABP plants are 40a/07 of 28 June and 17 July 2007 respectively approved as required instructed the DVO to carry out controls of the by Chapters III and IV disposal of ABP in slaughterhouses and food- of Regulation (EC) No processing plants, devoting special attention to 1774/2002 and that the persons who receive ABP, who must be approved list of approved plants in accordance with Regulation 1774/2002. The is kept up to date as CVO also ordered the immediate transmission of required by Art. 26 of information on new entities and on those which that regulation. have ceased activity to the GVI, via RVO, which will allow prompt updates of the lists of entities.
The DVO and the Regional Health Inspector must take part in the controls. CA undertook to provide, by January 2008, a report on the results of controls in 2007, covering the number and type of irregularities discovered, the numbers of administrative decisions and fines imposed. This has not yet been received.
65 Valid as of April 2008
MR 7259/2007 of 17/04/2007 on ABP
Reference no. and Findings Assessment Recommendation (3) To enhance efforts CVO letter No. GIWpuf.710ui.40a/07 of 17 July Action taken to ensure that 2007 set out the correct procedure for completing commercial documents commercial documents and instructed RVO and are properly completed DVO to take special care in ensuring that and used, as laid down commercial documents are completed in in Annex II to the ABP accordance with that procedure. This includes, Regulation. inter alia, checking that the consignee's address is correct. A copy of this letter was provided to the MR 8310/2006 made a FVO. similar recommendation. (4) To ensure that the CVO wrote a letter No. GIWpuf.710up.74/07 of Action taken documentary 17 July 2007 to SSI, which is responsible for the requirements set down supervision of former foodstuffs. SSI followed up in Regulation (EC) No with a letter to all VSES, requiring sanitary 197/2006 are respected inspectors to pay special attention during controls where former of establishments to ensure that the FBO respects foodstuffs are the documentary requirements for transport and consigned or treatment of former foodstuffs. A copy of this transported. letter was provided to the FVO. (5) To ensure that CVO letter No. GIWpuf.710ui.40a/07 of 17 July Action taken operators supplying 2007 instructed the RVO and DVO to pay milk products for use particular attention to the correct disposal of waste in feed fulfil the matter obtained from centrifuges as part of official appropriate conditions controls in milk-processing plants. The milk laid down in the products in question must always be subjected to Annexes to Regulation heat treatment. A copy of this letter was provided (EC) No 79/2005. to the FVO.
66 Valid as of April 2008
3.6. Veterinary medicines and residues
Since 2003 the FVO has carried out 2 pre-accession missions and one inspection in Poland in relation to veterinary medicines and residues.
Out of a total of 22 recommendations contained in the reports of these missions, 2 were identified for follow-up during the 2007 general review mission, both of which were contained in reports that had reached closeout stage since the 2006 general review mission.
The following table summarises the FVO’s assessment of the position on these recommendations following the 2007 general review mission. Recommendations reaching closeout stage since the 2006 general review mission.
MR 8003/2006 of 20 February 2006 on controls on dioxins in Baltic Sea fish Reference no. and Findings Assessment Recommendation (25410) To ensure without Consumer advice to limit consumption of fish where there Action taken delay that no fish or fishery are elevated levels of dioxins and dioxins-like PCBs is products with dioxins levels available on the website of the NIPH - NIH. SSI indicated exceeding the maximum level that they would start to perform controls in 2008 on laid down in Commission compliance with Regulation (EC) No 466/2001 (as Regulation (EC) No 466/2001 amended by Regulation (EC) No 1881/2006) at retail are placed on the EU market. level. The CVO, in her letter of 11 October 2007, instructed DVO to perform dioxin and dioxin-like PCB analyses during official controls of establishments producing cod livers.
(25411) To ensure that CA confirmed that all the dioxin and dioxin–like PCB Action taken Commission Recommendation analyses are carried out in the NRL in Pulawy which is not 2004/705/EC and the draft accredited laboratory in dioxin and dioxin-like PCB Commission Recommendation analyses with regard to the monitoring of background levels of CA provided copies of the CVO's manual on the dioxins and dioxin–like PCBs implementation of the monitoring programme for 2008, in foodstuffs, is implemented. together with tables showing the results on control on dioxins in Baltic Sea in 2006 and 2007.
3.7. Foodstuffs and food hygiene
Since 2003 the FVO has carried out one pre-accession mission and 2 inspections in Poland in relation to foodstuffs, food hygiene and GMO.
Out of a total of 34 recommendations contained in the reports of these missions, none was identified for follow-up during the 2007 general review mission.
67 Valid as of April 2008
3.8. Imports of food of plant origin
Since 2003 the FVO has carried out one pre-accession mission and 2 inspections in Poland in relation to imports of food of plant origin.
Out of a total of 15 recommendations contained in the reports of these missions, 4 were identified for follow-up during the 2007 general review mission. These were all contained in reports which had reached closeout stage since the 2006 general review mission.
The following table summarises the FVO’s assessment of the position on these recommendations following the 2007 general review mission. Recommendations reaching closeout stage since the 2006 general review mission.
MR 8132/2006 of 10 December 2006 on Import controls on food and feed of non-animal origin Reference no. and Findings Assessment Recommendation (27991) The State Sanitary SSI is responsible for official controls of GMO, Action taken Inspectorate and the customs including import controls. The 2007 control plan service should ensure that made provision for taking 580 samples and for there is an adequate level of testing these in the SSI laboratories which are co-ordination at all times as fully accredited for GMO analyses. required under Art 24 of Regulation No (EC) While Customs perform some GMO analyses, 882/2004. these analyses are focused on customs duties and do not form part of the official control programme for GM food. Customs' analyses are performed in their own laboratory, which is not accredited.
Under an informal agreement, the Customs Laboratory informs SSI of any case where GM material is detected in food. Since January 2007 Customs have detected no GM material in products declared as foodstuffs.
SSI plans to invite around 30 Customs staff for training in 2008 under the EU 2006 Transition Facility project Improving Implementation of Food Safety Surveillance.
(27992) The SSI should The progress made by the SSI in developing a In progress develop procedures for the harmonised audit procedure is described in implementation of Art 4(6) of Chapter 1 of this country profile. Regulation No (EC) 882/2004 concerning internal audits to ensure that the relevant authorities are achieving the objectives of this Regulation and that they are open and transparent to independent scrutiny.
(27993) The National Contact As at 7 December 2007, 57 consignments had Action taken Point for the RASFF system been notified to the Commission as rejected at the in the SSI should ensure that point of import during 2007. all rejections are notified to the Commission Service as The CA stated that, in addition, there were required by Art 50 of approximately 15 notifications which were based Regulation No (EC) on the results of screening analyses at the point of
68 Valid as of April 2008
MR 8132/2006 of 10 December 2006 on Import controls on food and feed of non-animal origin Reference no. and Findings Assessment Recommendation 178/2002. import.
(27994) The SSI should The draft MH ordinance, which will amend In progress amend their import control import control procedures, was expected to enter procedures to ensure that all into force in December 2007. CA undertook to provisions of Art 21 of send a copy to the FVO in January 2008. This has Regulation (EC) No 882/2004 not yet been received. are complied with..
3.9. Plant Protection Products
Since 2003 the FVO has carried out one pre-accession mission and one inspection in Poland in relation to plant protection products.
Out of a total of 14 recommendations contained in the reports of these missions, 3 were identified for follow-up in the 2007 general review mission, all of which were carried over from the country profile of 2006.
The following table summarises the FVO’s assessment of the position on these recommendations following the 2007 general review mission. Recommendations carried over from the country profile of December 2006.
MR 7665/2005 of 4 July 2005 on Controls of pesticides in food of plant origin Reference no. and Findings Assessment Recommendation In progress (21761) The competent The CA provided the FVO with the July 2007 authorities should identify the progress report from the Ministry of exact quantities of obsolete Environment, which showed that 12,984 tonnes pesticides in “tombs”, of obsolete pesticides had been destroyed from warehouses, farms and at 150 sites and that 3,247 tonnes of obsolete manufacturers, and co- pesticides from 112 sites remained to be ordinate activities for their destroyed. The Ministry of the Environment supervision and safe stated that the destruction of all obsolete destruction, in order to avoid pesticides remained on schedule for completion possible contamination of before the end of 2010. food, feed and the environment.
(21762) Accreditation of the All VSES laboratories have been instructed to Action taken laboratories carrying out implement the procedures laid down in pesticide residue analysis Commission document No 10476/2003 on should be finalised. The “procedures of quality control for pesticide laboratories should take residues analysis”. Relevant training has been measures to avoid possible provided. cross-contamination between standards and samples, carry The FVO received a table on the progress to date out regular recovery tests, and in proficiency testing and in the planned support the reported limits of extension of accreditation. The CA confirmed that determination by recovery all SSI laboratories are accredited. data. The procedure for sample preparation should ensure that the analytical portion is representative, as 69 Valid as of April 2008
MR 7665/2005 of 4 July 2005 on Controls of pesticides in food of plant origin Reference no. and Findings Assessment Recommendation required by point 4.8 of the Annex of Commission Directive 2002/63/EC.
(21763) The competent The range of pesticides is being systematically Action taken authorities should continue to extended and the sampling plan was extended for increase the range of 16 new pesticides in 2006, one in 2007 and 10 pesticides and metabolites in expected in 2008, bringing the number to 108. the analytical screens, so as to The Laboratories of the SSI are obliged to better reflect those substances implement and validate the methods as soon as being marketed and to ensure possible. A report on progress in 2006 was adequate enforcement of provided to the FVO. pesticide MRL as specified in Council Directives 76/895/EEC, 86/362/EEC and 90/642/EEC as amended.
3.10. Animal welfare
Since 2003 the FVO has carried out one pre-accession mission and one inspection in Poland in relation to animal welfare:
Out of a total of 18 recommendations contained in the reports of these missions, 4 were identified for follow-up during the 2007 general review mission, all of which were carried over from the country profile of 2006.
The following table summarises the FVO’s assessment of the position on these recommendations following the 2007 general review mission. Recommendations carried over from the country profile of December 2006.
MR 7638/2005 of 27 June 2005 on Animal welfare on farms Reference no. and Findings Assessment Recommendation (23443) To correctly MARD issued a Decree on 13 September 2005 amending Action taken. transpose and/or take the Decree on the minimum living conditions of measures to bring into effect: individual species of farm animals (Official Gazette No. 181, item 1514) to respond to this recommendation. a) The provision, where appropriate, of dry comfortable bedding to sick or injured animals (Annex to Directive 98/58/EC, point 4).
b) The maintenance of a record of the number of mortalities found at each inspection (Annex to Directive 98/58/EC, point 5).
(23445) To take measures to Polish legislation is in place relating to the imposition of Action still required. ensure that sanctions have the sanction. The penal provisions for persons who do not 70 Valid as of April 2008
MR 7638/2005 of 27 June 2005 on Animal welfare on farms Reference no. and Findings Assessment Recommendation necessary effect of ensure adequate living conditions for farm animals are discouraging offenders specified in art. 37 of of the Act of 21 August 1997 on the (Directive 91/630/EEC, Protection of Animals. The penal provisions can be as Article 11 (1) and Directive follows: a penalty of arrest, a fine, forfeiture of the animal, 99/74/EC, Article 13). forfeiture of instruments or objects used to commit the offence. The CA is obliged to apply to the court (misdemeanour court) for penal provisions for offenders. The court decides on the kind of the penal provision that shall be adjudged. However, experience shows that action in cases brought to court is generally unsuccessful, as the sanctions of these courts are considered disproportionately heavy for animal welfare offences. The CA introduced a draft amendment to the Parliament on the imposition of sanctions, but this was rejected. CA indicated that they are looking at other ways to impose sanctions in cases of non-compliance., and confirmed that MARD is responsible for amending the existing law. (23447) To further develop In its reply to the draft country profile, CA confirmed that Action taken. the regional supervision of all 304 PVI were inspected by their respective RVO district level in order to regarding supervision of animal welfare provisions, improve the quality of animal specifying the areas to be controlled. A report on the welfare inspections and results of these inspections has been sent to the FVO, reporting of results. providing details and statistics of the discrepancies found, and indicating that recommendations were issued in such cases. (23449) To take measures to A new procurement process was to be launched in the first Action still required. ensure that an adequate quarter of 2008 for the necessary equipment. Instructions, methodology is adopted for and training on their application, were to be provided to the inspection of holdings and OV by the end of the first quarter of 2008. that appropriate equipment is available to measure space In its reply to the draft country profile, CA stated that it allowance and parameters had not obtained the necessary additional funds, so the such as light, noise and central procedure for purchasing the equipment for adequacy of ventilation. measurement of certain parameters in the holdings has not been launched. Because of this, RVO are now responsible for providing the required equipment to their PVI. This is expected to happen by the end of 2008.
Updated guidelines GIWz.400/AW-14/08 of 30 January 2008 on the procedure for control of on-farm animal welfare and reporting about performed controls was provided to the FVO. A meeting with VVI on the updated guidelines took place on 27 February 2008.
3.11. Plant health
Since 2003 the FVO has carried out one pre-accession mission and 4 inspections in Poland in relation to plant health:
Out of a total of 16 recommendations contained in the reports of these missions, none was identified for follow-up during the 2007 general review mission.
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3.12. Overview of more recent inspections
In addition to 44 finalised inspection reports and recommendations arising from these reports which are dealt with in chapters 3.1 - 3.11 above, 4 further inspections which had not reached the "close out" stage by the date of the general review mission, have been carried out. The following tables give a brief summary of state of play on these inspections as of April 2008.
MR 7153/2007 of 22 October 2007 on Controls over the production and placing on the market of infant formulae, follow-up formulae and baby foods
The draft report was sent to the Polish CA on 6 March 2008, with a 25-day deadline to address five recommendations and provide an action plan. The main issues of concern relate to:
• Approval/re-approval of some establishments operating in the baby food sector; • Shared responsibilities for official controls between two CA are not implemented in practice.
MR 7334/2007 of 22 October 2007 on Animal Welfare during the transport of equidae for slaughter
The final report was sent to the Polish CA on 22 May 2008. The main issues of concern relate to:
• Lack of legal powers to take action when deficiencies on means of transport detected; • Shortage of OV at local level to participate in joint road-side checks; • Inadequate training of OV on certain aspects relating to fitness of animals for transport and means of transport.
MR 7372/2007 of 22 October 2007 on Intra-Community trade in equidae
The final report was sent to the Polish CA on 22 April 2008. The main issues of concern relate to:
• National legislation relating to horses transiting through non-approved canters prior to dispatch. (Similar to recommendation 25570 of MR 8169/2006, on Intra-Community trade in live animals); • Traceability of horses, passports, and reliability of the horse identification database; • Controls on animals at destination.
MR 7376/2007 of 19 November 2007 on Import controls for plant health
The final report was sent to the Polish CA on 16 April 2008. There were no major issues of concern.
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ANNEX I – ACRONYMS, ABBREVIATIONS AND SPECIAL TERMS
ACRONYM DESCRIPTION ABP Animal by-products AFPRO Animal Feedingstuffs, Pharmacy and Rendering Office AFQI Agricultural and Food Quality Inspection AHWO Animal Health and Welfare Office ARMA Agency for Restructuring and Modernisation of Agriculture BIP Border Inspection Post(s) BIO Border Inspection Office BSE Bovine Spongiform Encephalopathy BSES Border Sanitary and Epidemiological Station(s) BVI Border Veterinary Inspectorate BVO Border Veterinary Officer CA Competent Authority CCA Central Competent Authority CELINA Customs database CO Controlling Office CP Contingency Plan MPI Main Pharmaceutical Inspectorate CSI Chief Sanitary Inspectorate CRL Community Reference Laboratory CSF Classical Swine Fever Common veterinary entry document for products of animal origin CVED and for live animals DBPP Department of Breeding and Plant Protection (D)CVO (Deputy) Chief Veterinary Officer DFSVM Department of Food Safety and Veterinary Matters DG SANCO Directorate General for Health and Consumer Protection DSFN Department for Safety of Food and Nutrition DSC Department for Supervision and Controls DVO District Veterinary Officer ELISA Enzyme Linked Immuno Sorbent Assay EU European Union FMD Foot and Mouth Disease FBO Food Business Operator FVO Food and Veterinary Office GMO Genetically modified organism(s) GVI General Veterinary Inspectorate HACCP Hazard Analysis Critical Control Point HFAOO Hygiene of Foodstuffs of Animal Origin Office IIOC Institute of Industrial Organic Chemistry LA Local/Municipal/Metropolitan Authorities LDCC Local Disease Control Centre
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ACRONYM DESCRIPTION LHF Laboratory for Hygiene of Feedingstuffs MANCP Multi Annual National Control Plan MARD Ministry of Agriculture and Rural Development MAT Microsopic Analysis Test MBM Meat and Bone Meal ME Ministry of Environment MF Ministry of Finance MH Ministry of Health MI Main Inspectorate MIA Ministry of Interior and Administration MoI Ministry of Infrastructure MPI Main Pharmaceutical Inspectorate MRL Maximum Residue Level(s) MS Member State MT Ministry of Transport NDCC National Disease Control Centre NFNI National Food and Nutrition Institute NIPH - NIH National Institute of Public Health - National Institute of Hygiene NLF National Laboratory for Feedingstuffs NRCP National Residue Control Plan NRL National Reference Laboratory NVRI National Veterinary Research Institute OFFC Official Food and Feed Control (Regulation (EC) No. 882/2004) OLD Organisation and Legal Department of the CSI ORMP Office for Registration of Medicinal Products OV Official Veterinarian(s) PAP Processed Animal Proteins PCA Polish Centre for Accreditation PPI Plant Protection Institute in Poznan (pesticides)) PPP Plant Protection Product(s) PPTD Plant Protection and Technical Division PSD Phytosanitary Supervision Division PSES Poviat Sanitary and Epidemiological Station(s) PSPHSIS Poviat State Plant Health and Seeds Inspection Service(s) PVI Poviat Veterinary Inspectorate(s) PVP Private Veterinary Practitioner(s) RASFF Rapid Alert System for Feed and Food RTI Road Transport Inspectorate RVL Regional Veterinary Laboratories RVO Regional Veterinary Officer RIPF Research Institute for Pomology and Floriculture SPHSIS State Plant Health and Seeds Inspection Service SPIWET Checklist SRM Specified Risk Material 74 Valid as of April 2008
ACRONYM DESCRIPTION SSI State Sanitary Inspection SVSI State Voivodship Sanitary Inspector TC Third Countries TRACES Trade Control and Expert System introduced by TRACES Commission Decision 2004/292/EC TSE Transmissible Spongiform Encephalopathy VMP Veterinary Medical Product(s) VSES Voivodship Sanitary and Epidemiological Station(s) VSPHSIS Voivodship State Plant Health and Seeds Inspection Service(s) VI Veterinary Inspection VPI Voivodship Pharmaceutical Inspectorate(s) VVI Voivodship Veterinary Inspectorate(s)
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ANNEX II – OVERVIEW OF STAFF RESOURCES
The table below represents the total number of Full Time Equivalent Staff (FTE), including administrative staff.
Number of Staff Acronym Organisation (full time equivalent) Central level Ministry of Agriculture and Rural MARD Development General Veterinary Inspectorate GVI 74 (of which 44 OV) Agency for Restructuring and Modernisation ARMA of Agriculture 30 Main Inspectorate of State Plant Health and MISPHSIS Seeds Inspection Service 68 Main Inspectorate of Agricultural and Food MIAFQI Quality Inspection 1 MH Ministry of Health Chief Sanitary Inspectorate of the State Sanitary Inspection. (Overall SSI staff numbers, covering regions and districts, SSI include 905 staff in laboratories) 20 MPI Main Pharmaceutical Inspectorate 21 MT Ministry of Transport RTI Road Transport Inspection 294 Regional/District Level Voivodship Veterinary Inspectorate (regional 1,414 (of which 215 OV in VVI level) (including RVL) VVI + 192 OV in RVL) 2,754 (of which 1,476 OV) PVI Poviat Veterinary Inspectorate (district level) (5,200 PVP) BVI Border Veterinary Inspectorate 102 (of which 68 OV) 2,248 (of which 1,600 Voivodship Inspectorate of SPHSIS + Field inspectors, 300 laboratory VSPHSIS Units and 348 administrative) Voivodship Sanitary and Epidemiological VSES Station (of SSI) 1,000 Poviat Sanitary and Epidemiological Station PSES (of SSI) 2,048 Border Sanitary and Epidemiological Station BSES (of SSI) 330 Voivodship Inspectorate of Agricultural and VIAFQI Food Quality Inspection 16 Agency for Restructuring and Modernisation ARMA of Agriculture 1,753 12,173 Total (excluding 5,200 PVP)
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ANNEX III – TRAINING SYSTEMS
Training has been provided to staff of all CCA in their specific areas within the framework of TAIEX and PHARE programmes since 2002.
GVI
All staff are subject to the rules of training of civil servants. Training is standardised by GVI central office. Training, both theoretical and practical, is organised on a continuous basis covering topics such as traceability, Regulations (EC) No. 852/2004 and (EC) No. 853/2004, HACCP, intra-Community trade, eradication of contagious diseases. Once a new instruction is introduced, training is arranged on its correct interpretation and implementation. A selected number of RVO or DVO are trained and a cascade system is applied to transmit the knowledge to lower levels, including PVP. The new staff recruited to control TSE and feed in the PVI will receive six months initial training. The VVI train RTI staff on welfare issues relating to transport of animals.
The NVRI, which supervises work of the RVL, organises training for their staff. The GVI provides the NRVI with electronic copies of its instructions, for passing on to trainees as appropriate.
The Veterinary Training Office of Post-Gradate Study, situated at NVRI, provides post- gradate training for veterinarians who wish to extend their knowledge and obtain additional specialisation.
Training is organised for staff of the BVI and is sometimes extended to Customs staff, where appropriate.
Some 600 SPHSIS inspectors have participated recently in training on the improvement of food safety control in plant production, under a twinning project with UK and Italy. A further 300 inspectors have taken part in training on the system of supervision on the coexistence of GMO with conventional and organic farming.
SSI
The SSI is responsible for organising central training. Each VSES provides training programmes according to the requirements of the subordinated PSES. Under a PHARE project with France "Implementation of food safety strategy", training has been provided to laboratory staff covering pesticide residues in food, mycotoxins in food and determination of different substances in food.
AFQI
Training Centre of MIAFQI is responsible for coordination of planning and organisation of training, which covers all matters for which AFQI is responsible, of which GMO labelling is relevant to this country profile.
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