cp final poland 7596/2007 country profileec.europa.eu/food/fvo/country_profiles/cp_poland.pdf ·...

Valid as of April 2008

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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.

Central level Website (if available)

MARD Ministry of Agriculture and Rural Development

http://www.minrol.gov.pl

GVI General Veterinary Inspectorate http://www.wetgiw.gov.pl/

ARMA Agency for Restructuring and Modernisation of Agriculture

http://www.arimr.gov.pl/

MISPHSIS Main Inspectorate of State Plant Health and Seeds Inspection Service

http://www.piorin.gov.pl/

MIAFQI Main Inspectorate of Agricultural and Food Quality Inspection

http://www.ijhars.gov.pl

MH Ministry of Health http://www.mz.gov.pl

CSI Chief Sanitary Inspectorate of the State Sanitary Inspection (SSI)

http://www.gis.gov.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

Ministry of Transport) http://www.gitd.gov.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

http://www.minrol.gov.pl/


http://www.ijhars.gov.pl/

http://www.ijhars.gov.pl/

http://www.mz.gov.pl/

http://www.mz.gov.pl/

http://www.mofnet.gov.pl/

http://www.mofnet.gov.pl/

http://www.gitd.gov.pl/

http://www.gitd.gov.pl/

http://www.mf.gov.pl/

http://www.mf.gov.pl/


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Field and Border units of SPHSIS VSES Voivodship Sanitary and Epidemiological

Station (of CSI) http://www.gis.gov.pl/

PSES Poviat Sanitary and Epidemiological Station (of CSI)


BSES Border Sanitary and Epidemiological Station (of CSI)


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 situated in Pulawy

http://www.piwet.pulawy.pl

RVL 16 Regional Veterinary Laboratories (+ 16 branches)

SSI 16 integrated official food control laboratories (Regional level)


National Institute of Public Health - National Institute of Hygiene (NIPH - NIH)

Reference laboratory www.pzh.gov.pl

Food and Nutrition Institute (FNI)

Reference laboratory www.izz.waw.pl

VSES Rzeszow - Tarnobrzeg division

Reference laboratory (GMO in food) http://www.pis.rzeszow.pl/

CL of SPHSIS Central Laboratory of the Main Inspectorate of the SPHSIS

RL of the VSPHSIS

Regional Laboratories of VSPHSIS (16)

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


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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


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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.


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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.

Sector Policy co-ordination

Co-ordination of controls

Implementation of controls Laboratories

Risk assessment,scientific

advice

1. Animal Health MARD

ARMA

GVI

ARMA

VVI/PVI NVRI NRL

2. Food of Animal Origin MARD

MH

GVI

SSI

VVI/PVI

VSES/PSES

NVRI NRL

3. Imports of animal and food of animal origin

MARD

MF

GVI/BIO

Customs Service

VVI/PVI/BVI

Customs Chambers

NVRI NRL

4. Feedingstuffs MARD/MF GVI/BIO

Customs Service

VVI/PVI/BVI

Customs

Chambers

NVRI, PPI, NFL

NRL

5. TSEs/ABP MARD

MH, ME

GVI/ARMA

SSI

GVI/PVI

VVI/VSES/PSES

NVRI NRL

6. Veterinary medicines - authorisation, marketing &distribution

MH MPI VPI NRL

Veterinary medicines - residues

MARD GVI VVI/PVI NVRI NRL

7. Foodstuffs and Food hygiene

MH SSI VSES/PSES NFNI

NIPH-NIH

NRL

8. Imports of food of plant origin

MH, MARD, MF SSI, GVI

Customs Service

VSES/BSES

Customs Chambers

NIPH-NIH NRL

9. Plant protection products - authorisation, marketing and use

MARD

PPP Commission

SPHSIS VSPHSIS/

Field Units

No reference laboratory

NRL

Plant protection products - residues

MH SSI VSES/PSES/BSES NIPH-NIH NRL

10. Animal Welfare MARD

MT

GVI

RTI

VVI/PVI/BVI NVRI NRL

11. Plant Health MARD SPHSIS VSPHSIS:

Field Units

Central Lab SPHSIS

NRL


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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


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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(DFSVM)

GVI(HFAOO) NVRI

VVI +laboratories

PVI(OV & PVP)

Primaryproduction &

food processingestablishments

Guidelines, instructions,checklists & audit

SupervisionControl plan

Co-ordination &control

Technical advice

Supervision,registration,

approval& sampling

Legislation

MHConsultationcooperation

VSES +laboratories

PSES

SSI

Retailsector

Control, registration

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.


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The GVI prepares guidelines, check-lists and instructions on:

the frequency of inspection of food business operators officially supervised by the GVI, based on risk analysis;

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;

controls of the microbiological sampling of food of animal origin and contact surfaces carried out by the establishments;

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;

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;

rules for handling Specified Risk Material in slaughterhouses and cutting plants;

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;

official control methodology;

procedures applied by official veterinary officers in the course of their supervision of raw milk control under Regulation (EC) No. 853/2004;

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


19

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.


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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


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.


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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 (Road)

Kuznica Bialostocka (Road) Swinoujscie (Port)

Szczecin (Port) Terespol-Kobylany (Rail) Warsaw Okecie (Airport)


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2.4. Control system for feedingstuffs and animal nutrition

MARD

(DFSVM)

GVI(AFPRO)

BVI

NationalVeterinaryResearchInstitute

VVI +laboratories

PVI

Producers, traders,farms

Importedconsignments

PlantProtectionInstitute

NationalLaboratory forFeedingstuffs

National Control Plan

Supervision

Controls, approvals,sampling

(also GMO in feedingstuffs)

CentralLaboratories

Instructionsaudit

Controlssampling

Legislation

RASFF

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


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.


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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.


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2.5. Control system for TSE/ABP

TSE

MARD(DFSVM)

GVI(AFPRO/AHWO)

NVRI(LHF)

VVI labs (MAT)labs rapid tests for

TSE

PVI(OV&PVP)

Farms

Supervision & monitoring

Monitoring,instructions & audit

Feed mills Slaughter-houses

PAP-controls

Feed controls, samplingfallen animals

Co-ordination and control of laboratories

Technicaladvice ARMA

Advisory checks on holdings & input from farmers

regarding animal ID andregistration

Legislation

TSEtesting

Rendering plants

SRMControls

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)


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.


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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.


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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.


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ABP

MARD(DFSVM) MH ME

GVI(AFPRO) SSI Environmental

authorities

VVI VSES

PVI PSES

ABP processing plants,slaughter-houses, petfood, intermediate andincineration plants,hauliers, ABP users,technical plants,catering facilities,buyers of MBM as soilimprovers

Retail outletswholesale

Audit,instructions,checklists

Audit,instructions

Controlsapproval/registration

Supervision Supervision,audit

Controls

Legislation

Not covered byABP Regulation

Controls on waste

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)


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.


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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.


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2.6. Control system for veterinary medicines and residues

NVRI(NRL) GVI ORMP

(Register)

MARDLegislation

MHLegislation

VVI +laboratories

PVI

Farms, feed mills,

Producers,Importers

MPI VPI

Autorisation of and controls on manufacturing

and importation

Co-ordination andcontrol

Co-operationon authorisations,

registration

Technicalassistance

Wholesalers, veterinary clinics

Controls on sellingand use of VMPs

slaughter-houses,

Controls on residuesand use of VMPs

Controls onresidues

NRCP,instructions, audits

Controls on residues and use of veterinary medicines

Legislation and authorisation of veterinary

medicines

Supervision

Collaborate

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)


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.


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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


The GVI is the CA for the control of residues in live animals and animal products, with responsibilities broken down as follows:

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);

The VVI are responsible for supervision of the NRCP at regional level;

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.


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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.


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2.7. Control system for foodstuffs and food hygiene

MH

SSI(DSFN)

VSESlabs +

branches

PSES

NIPH-NIH

NFNI

Production of food of non-animal origin

Retail, wholesale, catering

Scientificsupport

Annual plans,instructions, audit

Referencelaboratories

Controls,sampling,approval

Supervision,audit

RASFF

MARD(GVI)

Consultationcooperation

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)


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


33

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.


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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.


35

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)


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).


36

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.


37

2.8. Control system for imports of food of plant origin

MH MF

CustomsSSI(DFSN)

VSESlabs +

branches

BSES

Consignmentsof food of non-animal origin

Instructions,audit

Controls

Co-operationlaid down

in legislation

Supervision,audit

Controls,sampling

PSES

MARD

GVI

VVI

PVI +BVI

Consignmentsof feed of non-animal origin

Instructions,audit

Supervision,audit

Controls,sampling

LegislationLegislation

CustomsChambers

RASFFBVI

Instructions

Controls.sampling

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)


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.


38

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.


39

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.


40

2.9. Control system for plant protection products (PPP)

MARD

Main Inspectorateof SPHSIS

PlantProtectionInstitute +branches

VSPHSIS

Retailers,wholesalers,

users

Control plan,instructions

Legislation

Qualityanalyses

PPPcommission

Field Units

Supervision

Controls onmarketing/use,sampling, trials

Technical assistance

Customs

Importers

Controls onimported PPP

MHLegislation onclassification,packaging, labelling

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)


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.


41

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


42

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.


43

Residues

MH

SSI(DSFN)

VSES +labs

PSES +BSES

NIPH-NIH

Foodcommodities

Technical assistance

Control plan,instructions, audit

Supervision,audit

RASFF

Legislation

Controls,sampling

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)


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.


44

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.


45

2.10. Control system for animal welfare

MARD(DFSVM) MT

GVI(AHWO) RTI

VVI

PVI

Farms,markets

Slaughter-houses Transporters

BVI

Instructions,audit

Supervision

Roadside checks,sometimes with PVI

Controls onanimals at the

borderControls,route plans,

authorisation oftransporters

Formalagreement

on co-operation

Legislation

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)


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.


46

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.


47

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.


48

2.11. Control system for plant health

MARD(DBPP)

Main Inspectorateof SPHSIS (PSD)

Retailers,wholesalers,

users

Control plan,instructions

Field Units +BIP

Supervision

Legislation

SPHSISlabs + branches

Central Laboratoryof SPHSIS (NRL)

Technicaladvice

Training.instructions

Controls, sampling,issuing plant

passports, internalmarket checks

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


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.


49

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.


50

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.


51

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 Mission 2007

Post- General Review Mission 2007

Action taken / No longer relevant 295 324

Outstanding / Action still required 5 4

For verification / In progress 39 11

Total number of recommendations 339 339

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.


52

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

Inspection reference number and objectives of the inspection

Ani

mal

hea

lth

Food

of a

nim

al o

rigin

Impo

rts o

f ani

mal

s and

fo

od o

f an

imal

orig

in

Feed

ings

tuff

s and

ani

mal

nu

tritio

n

TSE\

AB

P

Vet

erin

ary

med

icin

es

and

resi

dues

Fo

odst

uffs

and

food

hy

gien

e Im

ports

of f

ood

of p

lant

or

igin

Plan

t pro

tect

ion

prod

ucts

Ani

mal

wel

fare

Plan

t hea

lth

Pre-accession mission BSE/animal nutrition X

Pre-accession mission

Veterinary residues/VMPs X


Public health/animal health X




Food of plant origin (hygiene, contaminants and pesticide residues)

X


Public health - poultry, fish and eggs X


Plant health and pesticides X

Pre-accession Import controls (BIP) X


53


Ani

mal

hea

lth

Food

of a

nim

al o

rigin

Impo

rts o

f ani

mal

s and

fo

od o

f an

imal

orig

in

Feed

ings

tuff

s and

ani

mal

nu

tritio

n

TSE\

AB

P

Vet

erin

ary

med

icin

es

and

resi

dues

Fo

odst

uffs

and

food

hy

gien

e Im

ports

of f

ood

of p

lant

or

igin

Plan

t pro

tect

ion

prod

ucts

Ani

mal

wel

fare

Plan

t hea

lth

mission Pre-accession mission

Veterinary residues/VMPs X

Pre-accession mission BSE/animal nutrition X

Pre-accession mission Import controls (BIP) X

Pre-accession mission Plant health X



Pre-accession mission Animal welfare X


Food of plant origin (hygiene, contaminants and pesticide residues)

X


Disease controls-zoonoses /Rabies) X

7177/2004 Public health/animal health X

7320/2004 Plant health (potatoes) X

7325/2004 Animal health - semen collection centres X

7336/2004 Food of plant origin – import controls X

7518/2005 Animal by products X

7521/2005 Food of plant origin –hygiene X

7594/2005 Import controls (BIP) X 7598/2005 Plant health (potatoes) X

7612/2005 Public health/animal health X

7638/2005 Animal welfare 2A 2R

7651/2005 General review mission X X X X X X X X X X X

7665/2005 Pesticides 2A 1P

7683/2005 Plant health (passports) X 7693/2005 TSE/animal nutrition X

7728/2005 Import controls (BIP) 3A 1P

7773/2005 Plant pest outbreak X

8003/2006 Contaminants (Dioxins) 2A

8063/2006 Import Controls (BIP) 2A

8106/2006 GMO feed and food controls X

8132/2006 Import Controls 2A 2P

8141/2006 Disease eradication – salmonella X


54


Ani

mal

hea

lth

Food

of a

nim

al o

rigin

Impo

rts o

f ani

mal

s and

fo

od o

f an

imal

orig

in

Feed

ings

tuff

s and

ani

mal

nu

tritio

n

TSE\

AB

P

Vet

erin

ary

med

icin

es

and

resi

dues

Fo

odst

uffs

and

food

hy

gien

e Im

ports

of f

ood

of p

lant

or

igin

Plan

t pro

tect

ion

prod

ucts

Ani

mal

wel

fare

Plan

t hea

lth

8169/2006 Trade in live animals

2A 2P 1R

8210/2006 Identification, Certification X

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

7153/2007 Infant formulae/baby foods *

7245/2007 BSE 6A

7259/2007 ABP 4A 1P

7334/2007 Animal welfare - horses *

7361/2007 Rabies eradication

1A 2P 1R

7372/2007 Intra-Community trade - horses *

7376/2007 Plant health *

7442/2007 Meat, milk and their products 3A

2P

7596/2007 General review mission X X X X X X X X X X X

7789/2008 Disease contingency plans *

7810/2008 Food safety, meat and milk S

7760/2008 Import and transit controls and BIPs S

7693/2008

Animal welfare – on farms, in transport and at slaughter

S

7794/2008 Disease eradication control programme S


55

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 Recommendation Findings Assessment

(25570) To ensure that national legislation accords with the requirements of Council Directive 64/432/EEC, particularly regarding the approval of premises used to gather consignments of live animals intended for intra-Community trade.

CA provided a list of national legislation incorporating the requirements of Council Directive 64/432/EEC, and made specific reference to the laws on approval of premises for intra-Community trade (ICT).

CVO instructed DVO to take action where the requirements for ICT were not being met. DVO issued Administrative Decisions amending the instructions for, and practices in, these centres, with a deadline for implementation. Follow up is planned to ensure that corrective action is being taken.

Deputy CVO issued a letter to DVO (copy provided to the 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).

Action taken

(25571) To fully implement the requirements of Articles 4 and 6 of Regulation (EC) No. 882/2004, and in particular to ensure that sufficient numbers of suitably qualified, trained and experienced staff are employed so that official controls and control duties can be

CA submitted a lengthy initial response to this recommendation, pointing out that the CVO had been making repeated requests for funding additional staff to the Ministry of Finance, via MARD, since 2001, but was still understaffed by approximately 1,100 officials. CA explained that the problem was not only a lack of funding to provide new posts, but also inadequate remuneration packages to retain staff once they were recruited and trained. This leads to a big turnover of staff, with a resulting lack of experience in the existing staff pool.

CA stated that it has significantly increased the level of training of its personnel as well as of OV appointed to carry out specific functions, in particular as regards activities relating to the introduction of live animals into intra-Community trade.

In progress


56



carried out efficiently and effectively.

In addition, relevant instructions on intra-Community trade 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 official controls are carried out effectively and that corrective actions are taken when needed, in accordance with the requirements of Article 8 of Regulation (EC) No. 882/2004.

CA's initial reply listed the measures taken to address this recommendation. Detailed instructions were issued by the CVO to RVOs and DVOs on rectifying the irregularities discovered during the FVO inspection.

CA confirmed that training is systematically provided by cascade to OV following the issue of new instructions, to ensure that they are correctly and consistently implemented. CA stated that there was a reduced number of complaints being made in relation to intra-Community trade

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.

In progress

(25575) To ensure that the testing regimes adopted for animal diseases, in particular bovine Brucellosis, comply with the requirements of Annexes A and D of Council Directive 64/432/EEC and that the officially disease-free status of herds is suspended if they are not tested within the intervals prescribed.

CA's initial response referred to various instructions issued by the CVO to RVOs and DVOs, which provide uniform guidelines for the procedures to be followed when carrying out control tests or when combating bovine Brucellosis or Tuberculosis. These instructions require testing to be done on a 3-year cycle, which the CA interprets as the required frequency under Council Directive 64/432/EE to ensure the maintenance of officially free status. Training of DVO inspectors on the implementation of these guidelines was carried out.

CA confirmed that testing is carried out in accordance with a control plan established at DVO level, using ARMA statistics on animal numbers and locations. The plans are submitted to the RVO, who compiles the details for the whole region, before sending them to the CVO.

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

Action still required


57



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 checks are performed on live animals at their destination in accordance with the requirements of Article 5 of Council Directive 90/425/EEC, that the corrective actions set out in Article 6 of that Directive are applied if necessary and that the results of all checks are recorded in the manner prescribed by Commission Regulation (EC) No. 599/2004.

CA's initial response listed the measures taken to address this recommendation. CVO organised training on the carrying out of non-discriminatory checks on live animals at their destination. All irregularities are recorded by the DVO and reported to the CVO, via the RVO. A central register of irregularities is maintained. CVO analyses the information and informs the CA of the originating country accordingly.

CVO reported that, as a result of these measures, there has been a significant increase in the number of notifications of irregularities uncovered.

CVO issued instructions to DVOs on 27 September 2007 on checks of animals at their destination and the recording of the results of these checks as recommended by Commission Regulation (EC) No. 599/2004. (Copy of instruction provided to the FVO).

Action taken

MR 7361/2007 of 07/05/2007 on Rabies eradication programme

Reference No and recommendation Findings Assessment

(1) To ensure proper staffing at all levels of the CAs and laboratories, in order to perform the prescribed tasks without delays.

The GVI has repeatedly applied for additional posts. In most cases, the number of posts created does not correspond to actual needs. In addition, there is high rate of turnover of employees. (See also Findings to Recommendation (25571) of MR 8169/2006). 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.

In progress

(3) To improve co-ordination with neighbouring countries, in order to have the international borders and adjacent areas effectively vaccinated and protected.

The 2007 agreement between the RVO for Warmińsko-Mazurskie and the Border Guard of the Russian Federation provides that, following an application by the Polish veterinary services, aircrafts distributing the vaccine will be allowed to fly across border regions unhindered, so that there are no areas along the border with the Kaliningrad District where vaccine is not distributed.

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.

Action taken


58

MR 7361/2007 of 07/05/2007 on Rabies eradication programme


(5) To ensure that the minimum number of 8 foxes / 100 Km² collected for monitoring purposes is effectively applied in all Regions, covering both vaccination campaigns, and that the data on dynamics of the fox population, age and sex are analysed in order to guide the further development of the eradication strategy for particular vaccination campaigns.

The CVO wrote to the RVOs (letter no. GIWz.400/W-34-1/07), recommending more effective co-operation with District Hunting Associations. Hunters must indicate age and sex of the fox in a covering letter. DVOs in their agreements with hunting associations should ensure that the foxes are collected throughout the whole territory of the District.

CA stated that there was good, close co-operation between the GVI and the Hunters Associations, but the contacts are informal and not covered by law. The CVO has decided that the sample collection should be coordinated at RVO, rather than DVO level. CA believes that the goal of 8 foxes/100Km² is likely to be met in 2008.

In its reply to the draft country profile, CA provided a table of foxes shot for testing in 2007. In some regions the target of 8 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.

In progress

(6) To ensure that the population trend is followed during planning of vaccination campaigns and to implement a national hunting strategy to keep the fox population under control between these campaigns.

According to the CA, control of the fox population is not a task for the GVI. Accordingly, in letter no. GIWz.400/W-34-2/07, the CVO provided the Minister of the Environment with information about the need to shoot foxes as a means of controlling the population. However, CA stated that the very low premium paid to hunters for collecting foxes did not provide them with sufficient incentive to shoot foxes.

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.

Action still required


59

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.




MR 7442/2007 of 04 June 2007 on official controls related to the safety of food of animal origin, in particular meat and milk


(1) To finalise the updating of legislation, instructions and guidelines in line with the requirements of the new EU hygiene legislation.

New legislation has been drawn up and instructions and guidelines have been issued, or are under preparation, to address this recommendation. These cover, inter alia: the approval and registration of FBO; uniformity of controls by OV on establishments and on PVP;supervision of OV by RVO; frequency of controls based on risk analysis.

Action taken.

(4) To put in place a system for non approved establishments that before 1 January 2006 were allowed to place food of animal origin on the national market as foreseen in Article 4(5) of Regulation (EC) No 853/2004, in order to ensure that all of them comply with EU requirements by the end of 2009

The instruction on approval of FBO mentioned under recommendation (1) also covers this recommendation. Preliminary assessments havealready been done on 1,547 affected establishments. CA provided statistics to the Commission on the breakdown of this figure in relation to the intentions of FBO to comply or cease operating. A deadline of March 2009 has been set by the CA to have the action finalised, in order to allow sufficient time for any follow-up by the statutory deadline of 31 December 2009.

Action taken.


60

MR 7442/2007 of 04 June 2007 on official controls related to the safety of food of animal origin, in particular meat and milk


(6) To take further measures in order to ensure the uniformity and consistent quality of the official controls so that only fully compliant establishments are approved in accordance with Article 3 of Regulation (EC) No 854/2004 and to ensure that FBOs comply with the general and specific hygiene requirements laid down in Council Regulations (EC) No 852/2004 and 853/2004.

CVO Instruction No GIWhig-500-11/07 of 14 August 2007 on defining, on the basis of risk assessment, the frequency of controls of FBO, as well as the Instruction No GIWhig-500-3a/07 of 11 September 2007 on procedures during plant approval, conditional approval as well as registration of food industry plants, suspension and withdrawal of approval for these plantsregulates the uniform control approach for all GVI levels.

Training of control staff is carried out routinely following the issue of instructions, to ensure a standardised interpretation.

Action taken.

(7) To ensure that traceability is established at all stages of production and processing as required in Article 18, 1 of Regulation (EC) No 178/2002 and that food placed on the market is adequately labelled or identified.

The CVO, in her letter No GIWhig- 501 - 392/07 of 30 July 2007, ordered intensification of controls on labelling in milk establishments and on traceability of the product, including intestines supplied to the processing plant.

GVI carried out training of control staff on the implementation of the CVO’s Instruction No GIWhig-500-4/07 of 4 April 2007 on 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. 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.

In progress.

(8) To further improve the official controls over raw milk quality and assess the reliability of the controls carried out with regard to the criteria for raw milk.

It is planned to provide OV with guidelines, drawn up in co-operation with scientists of the National Veterinary Research Institute in Pulawy,for carrying out controls of raw milk quality and interpretation of results for OLB and the number of somatic cells. These were to be issued inJanuary 2008. Supervision of OV is planned during 2008 to see how instructions are implemented on the ground. (Approximately 340 milk establishments plus over 2,000 milk collection points involved).

In progress.


61

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.


Recommendations carried over from the country profile of December 2006.

MR 7728/2005 of 18 November 2005 on Border Inspection Posts


(22664) To complete the development of 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.

Overtaken by recommendation (27434) of MR 8063/2006.

Action taken

(22667) To complete the rectification of the deficiencies noted during the previous mission concerning infrastructure for live animals in Bezledy and Warszawa Okecie.

Earlier financial problems preventing the completion of work at Bezledy BIP have been resolved. The shortcomings in infrastructure will be rectified after the finalisation of tender procedures. The plans have been already prepared by an architectural company and completion of works was foreseen for spring 2008.

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 forstaff movement in order to avoid cross contamination. A copy of the procedure was received by the FVO.

In progress

(22668) To further develop the system for 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

Overtaken by recommendation (27434) of MR 8063/2006.

Action taken


62

MR 7728/2005 of 18 November 2005 on Border Inspection Posts


Directives 91/496/EEC and 97/78/EC and the associated Regulations and Decisions.

(22671) To ensure that the requirements for checks on personal luggage are implemented as foreseen in Regulation (EC) No 745/2004, in particular regarding checks on postal consignments.

CA confirmed that a check of personal luggage is carried out on every border crossing on the external border of the EU where the movement of goods or persons from third countries is noted. The list of border crossings was sent to all PVI to ensure that the control is carried out at each point of entry. The controls are carried out by Customs,or in some ports by the Border Guard, under the Ministry of the Interior.

Regarding postal consignments, according to aletter dated 19 May 2006 from the Department of Post in Ministry of Transport, a check of suchconsignments 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.

Action taken


MR 8063/2006 of 13 November 2006 on Import controls and border inspection posts


(27433) To complete the construction of the proposed BIP and to ensure that all facilities and equipment comply with the requirements of Directive 97/78/EC and Decision 2001/812/EC.

CA confirmed that all the construction works have been finalised and all equipment is installed. All buildings and facilities are fully operational and comply with the legal requirements.

Action taken.

(27434) To develop a system for the identification and selection of the consignments of veterinary interest, especially regarding electronic systems for the analysis of relevant intelligence, as laid down in Art. 6 and 7 of Regulation (EC) No 136/2004.

Refer also to recommendations (22664) and (22668) of MR 7728/2005.

CA stated that at the meeting between representatives of the CVO and Customs Service on 2 February 2007, local agreements were concluded between BIPand the Customs Service concerning access to data required by border veterinary officers and obtained from customs databases. Taking into account the specificities of individual border crossings (road, maritime and rail crossings), the agreements provide border veterinary officers with access to data which are essential for carrying out cross-checks 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

Action taken.


63

MR 8063/2006 of 13 November 2006 on Import controls and border inspection posts


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.




MR 7245/2007 of 17/04/2007 on BSE


(1) To continue the efforts to recruit staff required to implement BSE controls, notably in the areas of the total feed ban and the use of OF/SI.

MR 8310/2006 made a similar recommendation.

CA confirmed that 304 new control staff (veterinarians or zoo-technicians), or one per PVI, were recruited during 2007, with most already in their posts by the end of 2007. CA insisted that these officials were in addition to, rather than replacing, existing staff, and would concentrate on controls in the areas of the total feed ban and the use of OF/SI.

They will undergo a 6-month training programme in 2008, targeted at their specific duties.

Action taken


64

MR 7245/2007 of 17/04/2007 on BSE


(3) To take measures to ensure a consistent approach to performing risk analyses for carrying out official controls regarding the total feed ban set out in Annex IV to Regulation (EC) No 999/2001.

The CVO has issued standardised rules of procedure for the GVI with regard to risk assessment. This instruction is supported by a checklist and sample letter to users. CA provided copies of the instruction and check-list to the FVO.

Action taken

(4) To put in place a system of sanctions for non-compliance with the requirements of Regulation (EC) No 181/2006 and the total feed ban required by Regulation (EC) No 999/2001 and which are effective, proportionate and dissuasive as required by Art. 55 of Regulation (EC) No 882/2004.


The Act of 24 May 2007 amending the Act on the Protection of Animal Health and the Eradication of Infectious Diseases in Animals, and the Act on Border Veterinary Controls introduced provisions which increased the penalties for infringement of the ban laid down in Regulation (EC) No 999/2001: an infringement of the ban is now treated as a crime within the meaning of criminal law, and not, as previously the case, as a misdemeanour. A new fast-track system of judicial procedure was introduced by the amended Code of Criminal Procedure Act, which was approved on 16 November 2006, allowing the prompt imposition of sanctions. Failure to observe the requirements of Regulation (EC) No 181/2006 is also punishable in accordance with the above Act.

CA announced an increase in the number of prosecuted cases reported by DVO.

Action taken

(5) To consider requiring farmers to provide information concerning the anticipated date of delivery and use of OF/SI to help target controls.

CA confirmed that MARD has drawn up an amendment to the Decree on Veterinary Requirements for Soil Improvers (Official Gazette No 84, item 583), which entered into force on 25 December 2007. This requires farmers intending to purchase a soil improver to seek approval from the DVO, stating the approximate anticipated date 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.

Action taken

(6) To take the measures necessary to ensure that processed products derived from the processing of ABP in a processing plant are not applied as such directly to land where farmed animals might have access, as set out in Art. 6(2) of Regulation (EC) 181/2006.

CA referred to the obligation of purchasers of soil improvers to apply for DVO prior approval, which assists inspectors in assessing potential risks. CA confirmed that once soil improvers are spread, the field is immediately ploughed. In addition, there isof a requirement to mark Category 2 and 3 animal meal intended for use as a soil improver in a mixture of meal and lime-based fertiliser with a content of 10 - 30% (see also findings to recommendation (7)).

Action taken


65

MR 7245/2007 of 17/04/2007 on BSE


(7) To ensure marking of Category 2 processed products used as OF/SI as laid down in Article 5(2c) of Regulation (EC) No 1774/2002.


CA has introduced a Decree amending the Decree on the Veterinary Requirements for Soil Improvers, Art 12 of which provides for the application of lime-based fertilisers to the marking of animal meal. CA confirmed that the new Decree is currently being applied.

Action taken

MR 7259/2007 of 17/04/2007 on ABP

Reference no. and

Recommendation Findings Assessment

(1) To pursue efforts to 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.


See under Recommendation (1), MR 7245/2007. Action taken

(2) To ensure that all ABP plants are approved as required by Chapters III and IV of Regulation (EC) No 1774/2002 and that the list of approved plants is kept up to date as required by Art. 26 of that regulation.

CVO letters Nos. GIW puf. 710ui.40/07 and 40a/07 of 28 June and 17 July 2007 respectively instructed the DVO to carry out controls of the disposal of ABP in slaughterhouses and food-processing plants, devoting special attention to persons who receive ABP, who must be approved in accordance with Regulation 1774/2002. The CVO also ordered the immediate transmission of information on new entities and on those which 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.

In progress


66

MR 7259/2007 of 17/04/2007 on ABP

Reference no. and

Recommendation Findings Assessment

(3) To enhance efforts to ensure that commercial documents are properly completed and used, as laid down in Annex II to the ABP Regulation.


CVO letter No. GIWpuf.710ui.40a/07 of 17 July 2007 set out the correct procedure for completing commercial documents and instructed RVO and DVO to take special care in ensuring that commercial documents are completed in accordance with that procedure. This includes, inter alia, checking that the consignee's address is correct. A copy of this letter was provided to the FVO.

Action taken

(4) To ensure that the documentary requirements set down in Regulation (EC) No 197/2006 are respected where former foodstuffs are consigned or transported.

CVO wrote a letter No. GIWpuf.710up.74/07 of 17 July 2007 to SSI, which is responsible for the supervision of former foodstuffs. SSI followed up with a letter to all VSES, requiring sanitary inspectors to pay special attention during controls of establishments to ensure that the FBO respects the documentary requirements for transport and treatment of former foodstuffs. A copy of this letter was provided to the FVO.

Action taken

(5) To ensure that operators supplying milk products for use in feed fulfil the appropriate conditions laid down in the Annexes to Regulation (EC) No 79/2005.

CVO letter No. GIWpuf.710ui.40a/07 of 17 July 2007 instructed the RVO and DVO to pay particular attention to the correct disposal of waste matter obtained from centrifuges as part of official controls in milk-processing plants. The milk products in question must always be subjected to heat treatment. A copy of this letter was provided to the FVO.

Action taken


67

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.



MR 8003/2006 of 20 February 2006 on controls on dioxins in Baltic Sea fish


(25410) To ensure without delay that no fish or fishery products with dioxins levels exceeding the maximum level laid down in Commission Regulation (EC) No 466/2001 are placed on the EU market.

Consumer advice to limit consumption of fish where there are elevated levels of dioxins and dioxins-like PCBs is available on the website of the NIPH - NIH. SSI indicated that they would start to perform controls in 2008 on compliance with Regulation (EC) No 466/2001 (as amended by Regulation (EC) No 1881/2006) at retail 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.

Action taken

(25411) To ensure that Commission Recommendation 2004/705/EC and the draft Commission Recommendation with regard to the monitoring of background levels of dioxins and dioxin–like PCBs in foodstuffs, is implemented.

CA confirmed that all the dioxin and dioxin–like PCB analyses are carried out in the NRL in Pulawy which is not accredited laboratory in dioxin and dioxin-like PCB analyses CA provided copies of the CVO's manual on the implementation of the monitoring programme for 2008, together with tables showing the results on control on dioxins in Baltic Sea in 2006 and 2007.

Action taken

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.


68

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.



MR 8132/2006 of 10 December 2006 on Import controls on food and feed of non-animal origin


(27991) The State Sanitary Inspectorate and the customs service should ensure that there is an adequate level of co-ordination at all times as required under Art 24 of Regulation No (EC) 882/2004.

SSI is responsible for official controls of GMO, including import controls. The 2007 control plan made provision for taking 580 samples and for testing these in the SSI laboratories which are fully accredited for GMO analyses.

While Customs perform some GMO analyses, 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 CustomsLaboratory informs SSI of any case where GMmaterial 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.

Action taken

(27992) The SSI should develop procedures for the implementation of Art 4(6) of 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.

The progress made by the SSI in developing a harmonised audit procedure is described in Chapter 1 of this country profile.

In progress

(27993) The National Contact Point for the RASFF system in the SSI should ensure that all rejections are notified to the Commission Service as required by Art 50 of Regulation No (EC)

As at 7 December 2007, 57 consignments had been notified to the Commission as rejected at the point of import during 2007.

The CA stated that, in addition, there were approximately 15 notifications which were based on the results of screening analyses at the point of

Action taken


69

MR 8132/2006 of 10 December 2006 on Import controls on food and feed of non-animal origin


178/2002. import.

(27994) The SSI should amend their import control procedures to ensure that all provisions of Art 21 of Regulation (EC) No 882/2004 are complied with..

The draft MH ordinance, which will amend import control procedures, was expected to enter into force in December 2007. CA undertook to send a copy to the FVO in January 2008. This has not yet been received.

In progress

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.



MR 7665/2005 of 4 July 2005 on Controls of pesticides in food of plant origin


(21761) The competent authorities should identify the exact quantities of obsolete pesticides in “tombs”, warehouses, farms and at manufacturers, and co-ordinate activities for their supervision and safe destruction, in order to avoid possible contamination of food, feed and the environment.

The CA provided the FVO with the July 2007 progress report from the Ministry of Environment, which showed that 12,984 tonnes of obsolete pesticides had been destroyed from 150 sites and that 3,247 tonnes of obsolete pesticides from 112 sites remained to be destroyed. The Ministry of the Environment stated that the destruction of all obsolete pesticides remained on schedule for completion before the end of 2010.

In progress

(21762) Accreditation of the laboratories carrying out pesticide residue analysis should be finalised. The laboratories should take measures to avoid possible cross-contamination between standards and samples, carry out regular recovery tests, and support the reported limits of determination by recovery data. The procedure for sample preparation should ensure that the analytical portion is representative, as

All VSES laboratories have been instructed to implement the procedures laid down in Commission document No 10476/2003 on “procedures of quality control for pesticide residues analysis”. Relevant training has been provided.

The FVO received a table on the progress to date in proficiency testing and in the planned extension of accreditation. The CA confirmed that all SSI laboratories are accredited.

Action taken


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MR 7665/2005 of 4 July 2005 on Controls of pesticides in food of plant origin


required by point 4.8 of the Annex of Commission Directive 2002/63/EC.

(21763) The competent authorities should continue to increase the range of pesticides and metabolites in the analytical screens, so as to better reflect those substances being marketed and to ensure adequate enforcement of pesticide MRL as specified in Council Directives 76/895/EEC, 86/362/EEC and 90/642/EEC as amended.

The range of pesticides is being systematically extended and the sampling plan was extended for 16 new pesticides in 2006, one in 2007 and 10 expected in 2008, bringing the number to 108. The Laboratories of the SSI are obliged to implement and validate the methods as soon as possible. A report on progress in 2006 was provided to the FVO.

Action taken

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.



MR 7638/2005 of 27 June 2005 on Animal welfare on farms


(23443) To correctly transpose and/or take measures to bring into effect:

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).

MARD issued a Decree on 13 September 2005 amending the Decree on the minimum living conditions of individual species of farm animals (Official Gazette No. 181, item 1514) to respond to this recommendation.

Action taken.

(23445) To take measures to ensure that sanctions have the

Polish legislation is in place relating to the imposition of sanction. The penal provisions for persons who do not

Action still required.


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MR 7638/2005 of 27 June 2005 on Animal welfare on farms


necessary effect of discouraging offenders (Directive 91/630/EEC, Article 11 (1) and Directive 99/74/EC, Article 13).

ensure adequate living conditions for farm animals are specified in art. 37 of of the Act of 21 August 1997 on the Protection of Animals. The penal provisions can be as follows: a penalty of arrest, a fine, forfeiture of the animal, 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 the regional supervision of district level in order to improve the quality of animal welfare inspections and reporting of results.

In its reply to the draft country profile, CA confirmed that all 304 PVI were inspected by their respective RVO regarding supervision of animal welfare provisions, specifying the areas to be controlled. A report on the results of these inspections has been sent to the FVO, providing details and statistics of the discrepancies found, and indicating that recommendations were issued in such cases.

Action taken.

(23449) To take measures to ensure that an adequate methodology is adopted for the inspection of holdings and that appropriate equipment is available to measure space allowance and parameters such as light, noise and adequacy of ventilation.

A new procurement process was to be launched in the first quarter of 2008 for the necessary equipment. Instructions, and training on their application, were to be provided to OV by the end of the first quarter of 2008.

In its reply to the draft country profile, CA stated that it had not obtained the necessary additional funds, so the central procedure for purchasing the equipment for 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.

Action still required.

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 fiverecommendations 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

CVED Common veterinary entry document for products of animal origin 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


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ACRONYM DESCRIPTION SSI State Sanitary Inspection SVSI State Voivodship Sanitary Inspector TC Third Countries

TRACES TRACES Trade Control and Expert System introduced by 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.

Acronym Organisation Number of Staff (full time equivalent)

Central level

MARD Ministry of Agriculture and Rural Development

GVI General Veterinary Inspectorate 74 (of which 44 OV)

ARMA Agency for Restructuring and Modernisation of Agriculture 30

MISPHSIS Main Inspectorate of State Plant Health and Seeds Inspection Service 68

MIAFQI Main Inspectorate of Agricultural and Food Quality Inspection 1

MH Ministry of Health

SSI

Chief Sanitary Inspectorate of the State Sanitary Inspection. (Overall SSI staff numbers, covering regions and districts, include 905 staff in laboratories) 20

MPI Main Pharmaceutical Inspectorate 21 MT Ministry of Transport RTI Road Transport Inspection 294

Regional/District Level

VVI Voivodship Veterinary Inspectorate (regional level) (including RVL)

1,414 (of which 215 OV in VVI + 192 OV in RVL)

PVI Poviat Veterinary Inspectorate (district level)

2,754 (of which 1,476 OV) (5,200 PVP)

BVI Border Veterinary Inspectorate 102 (of which 68 OV)

VSPHSIS Voivodship Inspectorate of SPHSIS + Field Units

2,248 (of which 1,600 inspectors, 300 laboratory and 348 administrative)

VSES Voivodship Sanitary and Epidemiological Station (of SSI) 1,000

PSES Poviat Sanitary and Epidemiological Station (of SSI) 2,048

BSES Border Sanitary and Epidemiological Station (of SSI) 330

VIAFQI Voivodship Inspectorate of Agricultural and Food Quality Inspection 16

ARMA Agency for Restructuring and Modernisation of Agriculture 1,753

Total 12,173 (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.

cp final poland 7596/2007 country profileec.europa.eu/food/fvo/country_profiles/cp_poland.pdf ·...

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