guidance on drafting export health certificates ehcs final.pdf · g. notes for guidance for generic...
TRANSCRIPT
1
Guidance on drafting Export Health
Certificates
Global Animal Health March 2010
2
Contents Purpose p 3 Definitions p 4 The 12 principles of certification p 6 General obligations related to certification p 9 Certificate structure p 11 The 618 NDC procedure p 13 General principles p 14 Drafting a certificate Stage 1: Preparatory work p 16 Stage 2: Options for drafting p 18 Stage 3: The Notes for Guidance p 22 Stage 4: Getting agreement p 25
Annexes
A. Export health Certificate: an example p 27
B. Notes for Guidance : an example p 33
C. Typical 618 NDC p 48
D. Drafting a certificate: Flowchart p 49
E. UKECP p 50
F. Generic certificate: an example p 51
G. Notes for Guidance for generic certificates p 53
H. Procedure for using generic certificates p 55
I. Import requirements : examples p 57
J. Useful contacts and resources p 59
3
Purpose This document is intended to help vets with their role when they are involved in drafting an Export Health Certificate (EHC) and associated Notes for Guidance (NFG)and other documents. It highlights the key principles of certificate drafting, and provides useful information on how to produce a document which meets the requirements of the certifying Official Veterinarian, the exporter, Defra, the Devolved Administrations and the importing country. Such certificates will facilitate trade with Third Countries. The Royal College of Veterinary Surgeons describes a certificate as a "written statement of fact made with authority", the authority in this case coming from the Official Veterinarian‟s official and professional status. As a certificate drafter, you must ensure that the final document you produce abides by the 12 principles of certification and therefore can be signed by that person. This guidance is intended to be used by:
Defra Veterinary Advisors (VAs) who are new to Global Animal Health (GAH);
Private sector vets; and
Animal Health vets It is intended that the process described will help you to create an initial draft of a certificate which is acceptable and accurate. The guidance also attempts to standardise the approach to certificate drafting, so that in future certificates will be more consistent, regardless of who drafted them. You should remember that, as a preliminary drafter of certificates, your job is to start the process. Once you have produced your initial draft, experienced colleagues in Defra GAH will check it, and provide ultimate clearance. You should liaise with them when necessary. Please don‟t forget that initial drafts of certificates cannot be used for trade purposes. The 12 principles of certification should act as the basic guidelines for your certificate. The RCVS and GAH regularly exchange information via the Certification Sub-Committee, in order to ensure that the profession is being well served by the certificates produced by Defra.
4
Definitions An Export Health Certificate (EHC) is a document based on conditions received from the importing country which provides assurance that the recognised animal or human health risks identified by the importing country associated with the animal, product or germplasm have been addressed. In cases where it has not been possible to get import conditions, an EHC may be a generic document intended to facilitate trade. An example is provided at Annex A, page 25. The EHC therefore facilitates trade, by attesting to the truth of certain stated facts. A draft certificate is one produced in the early stages, which has not yet been quality assured or cleared by GAH. A draft certificate should be clearly watermarked with the word “DRAFT” on every page, or the header of each page should indicate in large bold print that the document is a draft. A draft certificate should include, in the footer, the version number, date of production and name of the author.
An agreed certificate is one has been agreed by the importing country based on import conditions provided by that country. Older certificates are annotated 0000 EHC (Regs) (day/month/year). More recently produced certificates are annotated 0000 EHC (Agreed) (day/month/year).
A cleared certificate is one that is used at the exporter‟s risk when:
details of import conditions have been provided by the exporter but are not supported by authentic evidence supplied by the Government of the importing country; or
details of import conditions have been provided by the importing county but the certificate has not been agreed with the importing country; or
the exporter and Defra have no details of the importing country's requirements
Cleared certificates are annotated 0000 EHC (Cleared) (day/month/year) Cleared certificates must never be used for live animals. All certificates must be supported by specific Notes for Guidance (NFGs). The NFGs supplement and interpret the certificate, and often provide additional information or guidance. The NFG are not part of the certificate and are not sent with the consignment. An example is provided at Annex B, page 31. Sometimes a checklist forms part of the certification process, or is provided to help avoid mistakes being made if the certification process is particularly complicated. The checklist is not part of the certificate and is not sent with the consignment.
5
A supplementary certificate is an additional certificate, which should accompany the main certificate, and is usually used under circumstances when the conditions for export have been temporarily changed. This may be necessary, for example, following a disease outbreak, where additional assurances may be requested by importing countries. A supplementary certificate may also be required for unusual travel arrangements, such as animals flying from non-UK airports. Supplementary certificates are annotated XXXX SUP. The numerical element (XXXX) is not necessarily the same as the main certificate, as a supplementary certificate may be used for multiple EHCs. A support certificate may be required if there are parts of a certificate which an individual would not be able to certify without further proof from another veterinarian. For example, if a consignment of day-old chicks is assembled from a number of different hatcheries, there may be a need for the veterinarian at one or more of the hatcheries of origin to certify certain facts to the official veterinarian who is completing the export certificate. Support certificates are annotated “XXXX” SPT, and do not carry the Crest header or watermark. The Notes for Guidance should clarify which paragraphs require support certification. The support certificate is not part of the certification, and should not accompany the consignment.
6
The Twelve Principles of Certification As a drafter of certificates, you should be very familiar with the twelve principles, which are reproduced here in full, including the additional guidance which was added to ensure correct interpretation of principle twelve. A veterinary certificate is regarded by the veterinary profession as 'a statement of fact made with authority'. False, misleading or negligent certification can lead to charges of professional misconduct brought by the Royal College of Veterinary Surgeons (RCVS) or civil or criminal legal proceedings. In order to provide veterinarians with a foundation for signing certificates, the Royal College of Veterinary Surgeons, the British Veterinary Association and Defra have produced 'the twelve principles of certification'. They are as follows: 1. A veterinarian should be asked to certify only those matters which are within his own knowledge, can be ascertained by him personally or are the subject of a supporting certificate from another veterinarian who does have personal knowledge of the matters in question and is authorised to provide such a supporting document. Matters not within the knowledge of a veterinarian, and not the subject of such a supporting certificate, but known to other persons, e.g. the farmer, the breeder or the truck driver, should be the subject of a declaration by those persons only. 2. Neither a veterinarian nor any person described in paragraph 1 above should be requested or required to sign anything relating to matters which cannot be verified by the signatory. 3. Veterinarians should not issue a certificate which might raise questions of a possible conflict of interest, e.g. in relation to their own animals. 4. All certificates should be written in terms which are as simple and easy to understand as possible. 5. Certificates should not use words or phrases which are capable of more than one interpretation. 6. Certificates should be: i. produced on one sheet of paper or, where more than one page is required, in such a form that any two or more pages are part of an integrated whole and indivisible; ii. given a unique number, with records being retained by the issuing authority of the persons to whom certificates bearing particular numbers were supplied. 7. Certificates should be written in the language of the veterinarian signing them, and accompanied by an official translation of the certificate into a language of the country of ultimate destination. 8. Certificates should identify animals individually, except in cases where this is impractical, e.g. day-old chicks. 9. Certificates should not require a veterinarian to certify that there has been
7
compliance with the law of the Community or a third country unless the provisions of the law are set out clearly on the certificate or have been provided to him by the issuing authority. 10. Where appropriate, notes for guidance should be provided to the certifying veterinarian by the issuing authority, indicating the extent of the enquiries he is expected to make, the examinations he is required to carry out, or to clarify any details of the certificate which may require further interpretation. 11. Certificates should always be issued and presented in the original. Photocopies are not acceptable. Provided that: i. a copy of the certificate (clearly marked 'COPY') should always be provided to the authority by whom the certificates were issued - see paragraph 6 above; and ii. where, for any good and sufficient reason (such as damage in transit), a duplicate certificate is authorised and supplied by the issuing authority, this must be clearly marked 'DUPLICATE' before issue. 12. When signing a certificate, a veterinarian should ensure that:
he signs, stamps and completes any manuscript portions in a colour of ink which does not readily photocopy, i.e. a colour other than black;
the certificate contains no deletions or alterations, other than those which are indicated on the face of the certificate to be permissible, and subject to such changes being initialed and stamped by the certifying veterinarian;
the certificate bears not only his signature but also, in clear lettering, his name, qualifications and address and (where appropriate) his official or practice stamps;
the certificate bears the date on which the certificate was signed and issued and (where appropriate) the time for which the certificate will remain valid;
no part of the certificate is left blank so that it could subsequently be completed by some person other than the certifying veterinarian.
The following additional guidance has been agreed between the RCVS, Defra and
Animal Health on the correct interpretation of principle 12:
Any stamps, signatures or initials must be applied carefully and placed so that
text in the certificate is not obscured, preferably in the margin.
Manuscript entries on the certificate must be legible, preferably typewritten or
handwritten in block capitals.
Manuscript entries on the certificate, the signature and stamp must be made in
a colour other than black, unless directed otherwise by instructions on the
certificate or in accompanying notes for guidance.
Manuscript entries on the certificate should not be stamped or initialled unless
this is specifically requested by instructions on the certificate or in
8
accompanying notes for guidance. Alteration of manuscript entries must be
avoided, but on the rare occasion that this is not possible, the alteration must
be stamped and initialled.
Deletions of non-applicable pre-printed options or alternatives should be made
before signing the certificate. Alteration or deletion of other pre-printed text
must only be carried out in accordance with an official derogation or instructions
on the certificate or in accompanying notes for guidance; such alterations or
deletions must be stamped and initialled.
No part of the certificate should be left blank such that it could subsequently be
completed by somebody other than the certifying veterinarian. Such spaces
should be ruled off, but only stamped and dated after the last line of a separate
schedule. Schedules may be „fan folded‟ and stamped and dated.
9
General Obligations related to certification Ideally, the following requirements and conditions apply: however, realistically, some requirements are flexible, and in some cases the conditions are only partially applied. The Terrestrial Animal Health Code identifies a number of essential elements which relate to international certification of animals and animal products. The intention is to permit unimpeded trade between countries without incurring unacceptable risks to human and animal health. In order to maximise harmonisation, countries are expected to base their import requirements on OIE standards. Requirements should be exact and concise, and should clearly convey the wishes of the importing country. There are responsibilities for both importing and exporting countries. Import requirements which are more demanding than existing OIE standards may be allowed if the associated risk analysis indicates that more stringent measures are appropriate. However, import requirements relating to diseases already present in the importing country should never be greater than the measures in place as part of that country‟s official control programme. In some cases, it is appropriate to allow risk levels to rise in order to get trade started. The OIE standards generally apply, in the first instance to diseases of economic importance, and these are listed in the Code. Non-listed diseases have slightly looser standards. For diseases which are not OIE listed, the importing country should be able to show that a risk analysis indicates a significant risk associated with the disease in question. You should note, however, that risk-associated information is not always available. The Competent Authority of importing country should provide copies of import conditions to the relevant veterinary authority, as well as the proposed exporter, so that the authenticity of the conditions is not in doubt. Changes to import conditions are most frequently identified from import permits. Via the OIE, the exporting country is expected to provide information on the national disease situation, including details of regulations and procedures in place to maintain freedom from disease. By this route, the occurrence of notifiable disease is notified to the importing country, and full details of control measures and the structure of veterinary services should always be made available. Additional technical information on relevant laboratory tests and vaccines should also be provided. If a disease is detected, the exporting country has an obligation to inform the importing country of any consignments of animals, germplasm or animal products which may pose a potential risk to the importing country‟s disease status. Competent Veterinary Authorities should have procedures for authorizing certifying veterinarians, and provide instructions and training to them when necessary. Their activities should be monitored to verify their integrity and impartiality. Overall, the Competent Veterinary Authority of the exporting country must carry responsibility for
10
veterinary certification. If fraud is suspected, investigations must be made and appropriate sanctions applied according to national legislation. You should also be aware of Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002, laying down the general principles and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety. Article 2 of 178/2002 defines “food”. This expressly excludes live animals, unless they are prepared for placing on the market for human consumption – this is generally understood to mean commodities such as live bivalve mollusks for immediate consumption.
Article 12, which relates to food and feed exported from the Community only, requires exports from the EU of food and feed must meet the same standards as products circulated within the EU. Exceptionally, food and feed which do not meet EU requirements can be exported or re-exported if the competent authorities of the country of destination have expressly agreed, after having been fully informed of the reasons for which and the circumstances in which the food or feed concerned could not be placed on the market in the EU. However, food or feed which is injurious to human or animal health cannot be exported or re-exported at all. Where the provisions of a bilateral agreement concluded between the Community or one of its Member States and a third country are applicable, food and feed exported from the Community or that Member State to that Third Country shall comply with the agreed provisions. An example of this type of trade is the export of bovine feet. In summary, this means that food or feed which is not of a suitable standard for trade within the EU cannot be traded with a Third Country unless the Third Country is fully aware of the status of that food or feed.
11
Certificate structure All EHCs have the same basic function, which is to assure the recipient of the animal or product (both the individual importer involved and the authorities of the importing country) that the perceived health risks associated with that animal or product have been addressed and minimized. Annex A illustrates a typical certificate, and Annex B shows the relevant Notes for Guidance. Although every certificate is different, there are certain key sections which a typical EHC contains.
1. Header information The header for the EHC identifies the basis for the certificate (the animal or product covered by the document, and the recipient country or countries). For example, “Export of breeding cattle to South Korea”. Further clarification can be provided, if needed, in the Scope section of the NFG. The header also incorporates the Crest, and the names of the Government Departments which have issued the certificate. Finally, this section includes the unique certificate number, in keeping with certification principle number 6.
2. Footer information
This includes the certificate number and status, and the version date
3. Identification information
This part identifies the consignment, linking it to the certificate.
4. Information on origin This section indicates where the consignment came from. For animal products, the registration number (if it exists) of the establishment should be recorded here if requested by the importing country.
5. Information on destination
This section indicates where the consignment is intended to go, when and how.
6. Health information
12
This section contains the information required by the importing country which is the actual basis for the agreement, although some certificates include pieces of information which are the subject of negotiation and agreement in addition to health information. It may contain statements about the consignment itself, tests, vaccinations, inspections or examinations carried out, the disease status of the place or country of origin of the consignment or confirmation that specific conditions (such as pre-export isolation) have been met. It may include elements which have two or more options available. The certifying veterinarian must select the relevant option and delete those which do not apply. It is important that this section is written as clearly as possible, to avoid ambiguity and prevent misinterpretation. This section may also include information which can only be certified on the basis of support documentation. If this is the case, the Notes for Guidance must provide clarification on the form or content of support documentation which should be used. Support certification or documentation does not usually form part of the certificate, and should be retained by the certifying official veterinarian. If this is not the case, and the importing country requires copies of laboratory reports or other documents, this must be made clear in the Notes for Guidance.
7. Attestation/certification This is the section where the official veterinarian signs the document, and applies the appropriate official stamp. In some cases, the validity of the OV‟s signature must be countersigned by a whole time Veterinary Officer.
8. Silhouette Some certificates incorporate an equine identification silhouette. Adequate information should be supplied to clarify completion requirements, including use of red ink and written description rules. The certificate should, where relevant, be clearly linked to the animal‟s microchip number, passport number or other registration document number.
9. Schedules Some certificates have associated official additional schedules, which are part of the certificate, and allow the certifying Official Veterinarian to identify the individual components of a large consignment (for example, a consignment of 200 calves, or a mixed consignment of 15 different meat products). If no official schedule is available, a document may be produced by the signatory, which conforms to the expected format: namely, each page of the schedule should be headed “Schedule to certificate number XXXXXXX” and have a page number. The Notes for Guidance should clarify correct usage of the Schedule, with particular reference to anti-fraud measures.
13
The 618 NDC procedure Many export certificates for animals and animal products include statements certifying that specified areas or the entire country of origin are free of certain notifiable or non-notifiable, diseases. These statements cannot be certified by an Official Veterinarian (OV) without specific authorisation from Animal Health.
In this situation, a document called 618 Notifiable Disease Clearance is issued. An example of a 618 NDC appears at Annex C, page 46.
This document gives authority only in respect of the particular paragraphs and particular certificates specified on the individual document and is always time-limited, usually for 10 days.
If you are drafting a certificate which will require 618 NDC support, you should ensure that the relevant paragraphs are simple and refer to notifiable diseases only. In particular, references to residency of stock should not be the subject of a 618 NDC. If residency must be certified, this should be for the OV to do.
If disease outbreaks occur during the ten days of 618 NDC validity, the relevant issued certificates are withdrawn.
14
General principles
Make sure that your certificate complies with all of the twelve principles of certification (available on page 6 of this document);
In particular, ensure that your certificate asks the OV to certify things which have happened. Events or actions which are expected to occur during the journey cannot be certified, and can only be confirmed on the basis of a declaration. An example of this is inclusion of a paragraph in an EHC certifying the route of export. This cannot be certified by the OV;
Be pragmatic, adapting existing documents for your certificate if possible;
If feasible and available, use a generic certificate as the basis for your new certificate, particularly if import conditions are not provided;
Use standard text for as much of your certificate as you can;
Use plain English. There are many guides to doing this, and a good example is the Plain English Campaign. The Defra website contains advice too, at http://intranet/clear-english/index.asp
Keep sentences short, ideally no more than 15 – 20 words;
You should, however, reflect the way the conditions of importation are expressed whenever possible (unless they are confusing, unclear or ambiguous) by using the wording provided;
Ensure that your certificate is practical: provide appropriately sized spaces for the entry of information;
Use the standard paragraph and sub-paragraph numbering system (see sample certificates at Annexes A and B for worked examples);
Avoid the use of the numeral (i), as it causes interpretation problems;
Avoid the use of the first person; for example, say “I certify that each animal has been vaccinated” rather than “I certify that I vaccinated each animal”. This allows greater flexibility, as certificates can be signed on the basis of support certificates. Clearly, if the import conditions specify the wording you may not be able to avoid this constraint;
Use the phrase “I certify that the animal was examined on (date)” rather than “I have this day examined the animal”. This avoids problems associated with replacement certification (for example, consignments delayed due to bad weather);
Do not waste time on formatting the certificate as you draft it;
15
Try and future-proof your certificate. For example, don‟t quote current legislation, which may change in future. Make more general references to “current requirements”, or refer to parent legislation and include the phrase “as amended”. Don‟t include contact information for individuals, for the same reason;
Use current technical terminology (for example, say teschovirus encephalomyelitis, rather than Teschen disease)
Unless the importing country is completely insistent on the use of full time veterinary officers as signatories, your certificate should be drafted to be signed by an Official Veterinarian;
Unless there is a specific reason otherwise, certificates should always be drafted to apply to the UK, not GB;
If possible, separate notifiable disease conditions from non-notifiable disease conditions. There is a full list of notifiable diseases on the intranet at http://defraweb/foodfarm/farmanimal/diseases/atoz/notifiable.htm
And on the Defra website at http://www.defra.gov.uk/foodfarm/farmanimal/diseases/atoz/notifiable.htm
16
Drafting a certificate You may find it useful to refer to the flowchart which appears at Annex D, page 47 Information on the history, structure and function of UKECP is provided in Annex E
Stage 1: Preparatory work
1. You might receive a request to draft a certificate for a specific purpose from a variety of places, for example:
Within Defra;
An industry contact;
Animal Health Central Operations, Carlisle; or
The importing country.
2. Firstly, check that a suitable certificate does not already exist (either available or on hold). To do so, contact Carlisle Central Operations. Contact details are as follows:
E-mail: [email protected]
Tel: 01228 403600 Fax: 01228 591900
3. If the certificate is available, inform the enquirer and provide details of the
certificate number.
4. If the certificate is available, but listed as “on hold” (OH), find out why, and inform the enquirer. This information is sometimes available from CENTAUR.
5. If the reason for the EHC being on hold has been resolved but no action has been taken to reinstate it on CENTAUR, inform your contact in GAH and, once actioned, inform the enquirer.
6. If the EHC is still justifiably on hold, but action is in progress, inform the enquirer of the situation. Be cautious about suggesting a timescale for reinstatement of the certificate, unless you are completely certain about the timescale for taking the EHC off hold.
7. If the reason for putting the EHC on hold has not been resolved, inform the enquirer of this. Again, be cautious about suggesting a timescale for reinstatement of the certificate.
8. You should also check to make sure a colleague is not already working on the certificate in question.
17
9. There should be evidence of substantial trade interest in the certificate; drafting
certificates is an expensive and resource-intensive process, so certificates which are unlikely to be used much are uneconomic. This, however, does not apply in the same way to certificates for pet or zoo animals, including horses. A pragmatic approach is needed if requests are made for certificates which will rarely be used.
10. It is important to mark your certificate as a draft: it should be clearly watermarked with the word “DRAFT” on every page, or the header of each page should indicate that the document is a draft.
11. Version control is essential. The footer of your certificate should contain the version number (V 1, V2, V3 etc), date of production and your name. Minor version changes may rise by decimal fractions (V 1 becomes V 1.1), but major changes should rise by a whole number.
12. When you provide a draft to GAH, always complete the Subject bar of the e-mail, indicating the importing country and the commodity.
13. If you are circulating a draft for comment, provide a reasonable deadline, so that recipients have a chance to read the document, consider it and respond constructively.
14. In every case, record your actions and make sure all people involved are informed.
18
Stage 2: Options for drafting
You have a number of options, which are:
Adapt an existing certificate;
Use a generic certificate (See example at Annex F, page 49);
Draft a certificate from scratch (unlikely and impractical).
15. During your enquiries, you might identify a certificate which performs a similar function - for example, an existing goat certificate which might be adapted to apply to the country in question. This may be useful for the next stage.
16. Generic certificates exist for a variety of purposes These include:
Model certificates forming part of existing Directives (adapt them carefully, removing certain references to EU origin, and replacing with “UK”, and modifying the text so that it refers to exports);
Generic meat certificates
Generic hides and skins certificates Annex F, page 49, provides an example of a generic certificate for hides and skins, and Annex H, page 53, provides some additional guidelines for certificate drafters using generic certificates.
17. Using a generic certificate will speed up the process considerably, so use one if you can. However: if you have been supplied with import conditions, the generic certificates may not be suitable. Annex I, page 55, provides examples of import conditions.
18. The enquirer may already have obtained the import conditions. This may be in the form of an import permit, or a list of import health conditions. If this is so, get the document and use it as the basis for your certificate. If the conditions are not presented in English, a translation must be obtained, preferably by the exporter.
19. It is also sometimes possible to use and adapt import conditions from another neighbouring country, and offer them as a starting point. Take account of the relationship between the two countries, and seek advice from GAH when necessary.
20. It is always the exporter‟s responsibility to try to obtain import conditions first. Dependent on the country in question and availability of resources, Defra staff may approach officials to obtain import conditions if the exporter has not been successful, but this should not be taken for granted.
19
21. If you are aware of similar agreed certificates (for example, certificates for the
same animal or product from a closely related country, or certificates for similar animals or products which may be adaptable), refer to them to compare wording, terminology and structure of the health declaration. The associated NFGs may also be useful to you, as they often provide clarification on interpretation of words and phrases used previously in negotiation with the country involved.
22. Particular problems may be encountered with:
Requirements to comply with the importing country‟s legislation (which may or may not be fully known to you. See the 9th Principle of Certification);
Complex testing, vaccination or treatment regimes (this may be overcome by using standard paragraphs);
Inclusion of unreasonable or unnecessary testing requirements (for example, a requirement to test for AHS is not necessary as the UK is currently officially free of this disease);
Translation difficulties, when the original wording in the import conditions loses some of its meaning or translates unclearly;
Clauses with multiple requirements (for example, mentioning both notifiable and non-notifiable diseases in the same sentence);
Health information sections requiring deletions, particularly when the section includes multiple different options (using standard numbering should help);
Non-specific requirements (for example, a requirement to certify that meat is “of good quality as to its organoleptic indicators”);
Requirement to certify dates of inspection for animal products. It is preferable to include this information, but it sometimes proves difficult to achieve, particularly with products like hides and skins, which lack individual identification and may be produced over a protracted period of time;
Uncertifiable statements such as what will happen to the consignment;
Area or country freedom for non-notifiable diseases. This requirement should be certified for premises of origin only;
Vaccination requirement for diseases for which is vaccination is not routinely practiced in the country of origin;
20
Clinical inspections which broadly refer to freedom from contagious and infectious diseases. The Notes for Guidance should provide advice on what is being asked here;
Treatments and vaccination with licensed products. In some cases the cascade procedure should be followed and the use of legally imported vaccines may be needed. Where the treatment or vaccination required is not available in the UK, GAH VAs should be consulted in order to seek an exemption or change in the import requirements;
Laboratory or clinical tests that are not available in the UK;
Welfare requirements under different welfare codes (IATA, CITES etc); the Notes for Guidance should clarify and provide links to the relevant web sites;
Evidence for the OV certification: in some cases the certifying veterinarian will have to obtain support evidence in order to sign some statements. The wording of the paragraph in the certificate should make this clear. Standard wording should be used whenever possible: for example, “to the best of my knowledge”, “as far as can be determined” and “based on an exporter/owner‟s declaration”. The Notes for Guidance should advise that it is the OV that needs to be satisfied that enough enquiries have been made, and obtain the evidence needed to back the statement;
Official freedom in compliance with statutory testing requirements in the country of origin. If these requirements are not compulsory for the species being certified, then alternative wording should be used: for example, testing under a voluntary but equivalent programme to that in other species where it is compulsory.
You should note that this list is not exhaustive.
23. Your Notes for Guidance should help clarify all of the above.
24. If importation requirements refer to specific diseases, make absolutely sure that you have interpreted the disease and pathological agent properly.
25. Where relevant, reference should be made to the current OIE Terrestrial Animal Health Code:
http://www.oie.int/eng/normes/mcode/en_sommaire.htm
26. In all cases where there is reference to a requirement for pre-export testing or diagnostic work, you should refer to the VLA test list at:
http://www.defra.gov.uk/vla/services/ser_services.htm
21
and confirm that the tests requested are available and validated. If tests are prescribed by the OIE, or alternatives are available, this should ne mentioned.
27. You should use the standard numbering protocol, which is evident in the attached sample certificates (Annexes A and B) and avoid using the letter (i) as a paragraph number as it can be confused with roman numeral (i). Your NFGs should indicate that paragraph (i) has been excluded deliberately.
22
Stage 3: The Notes for Guidance
28. Annex B contains an example. It is better not to spend a lot of time drafting the NFGs until the certificate is in its final form, which may be radically different from the first version. You can begin to design the NFGs at this stage, however.
29. The official veterinarian relies on the NFGs to clarify the text and requirements of the certificate. Your NFGs should be:
Helpful, not patronizing. Don‟t repeat the obvious;
Logically structured, following the sections and paragraphs of the certificate in order;
Unambiguous. For example, compare “20 day old chicks” with “20 day-old chicks”;
Comprehensive. Your NFGs should cover all sections of the EHC;
Accurate. For example, if a specific lab test is required, provide full details, and do not leave the OV to find out which of three possible tests is acceptable;
Clearly linked to the certificate in question.
30. There are a number of standard paragraphs which should appear in all NFGs. They should only be omitted or altered under exceptional circumstances. The standard paragraphs are:
The “Important” header, which specifies that the NFGs are not intended to operate as standalone documents but must be read in conjunction with associated EHC. This header also reminds exporters of the need to verify the requirements of the importing country by contacting the appropriate veterinary authorities, or their representatives in the UK, in advance of each consignment. This header should always be the first item on the NFG;
The Scope, which includes the title of the certificate and the requirement for supplementary documents, checklists or other documentary essentials. It may also set out certain parameters within which the certificate may be used. This might include species of origin of meat products, age limits, conditions of storage or any other variable which needs definition;
The Disclaimer, which points out that the certificate is provided on the basis of information available at the time and may not necessarily comply fully with the requirements of the importing country, and that it is the exporter‟s responsibility to check the certificate against any relevant import permit or any advice provided by the competent authority in the importing country.;
23
The requirement for Welfare to be taken into account. (for live animals only)
Additionally, the NFGs should always indicate the requirement for additional documentation with consignment, if needed.
31. If there are other certificates available for similar animals or products (for example, minced meat, MRM and poultry meat), point this out early in the NFG. This will prevent accidental completion of incorrect, inappropriate certification. The title of the EHC should be as clear as possible.
32. Sometimes, in order to comply with the 12 principles of certification, an exporter's declaration is needed. This tends to happen when one or more of the conditions of export cannot be certified by the OV. The exporter must supply a written declaration including exactly the same wording as the matters to be certified. This must be signed by someone who has knowledge of and responsibility for the relevant parts of the production process and is aware of the requirements. The declaration should include a clause indicating that the signatory is aware that making a false declaration may be an offence. It is an offence to not comply with any requirement of The Animals and Animal Products (Import and Export) (England) Regulations 2006 (and parallel legislation in Scotland and Wales). The Fraud Act 2006, and the Perjury Act 1911 may also be applicable.
33. The OV should examine the declaration and if required make any other enquiries considered appropriate to verify the statement. Where possible, supporting evidence (for example health certificates for raw materials showing their country of origin) should be called for and put on file. The statement must not be attached to the certificate but should be retained by the OV for record purposes.
34. The RCVS Guide to Professional Conduct states that [Veterinary Surgeons] "must not recklessly confirm what other people have stated".
35. Your NFGs should clarify the basis upon which certain parts of the certificate may be signed. For example, you could say that paragraphs 4, 5 (a) and 7 (b) (ii) can be signed on the basis of provision of a valid 618 NDC (Notifiable Disease Clearance form), as the certifying Official Veterinarian would not be in a position to certify area or country clearance from notifiable disease. You should emphasise the importance of date validity of support documents. Page 13 contains additional information on 618 NDC procedures, and Annex C, page 46, provides a typical example.
36. Provide specific links to relevant websites (for example, www.lex.europa.eu), so that your NFGs are automatically updated if conditions change.
37. Avoid referring to legislation by name or number, as this will make your certificate time limited. Instead, refer to “current legislation” or “existing legal controls”.
24
38. It is helpful if the NFGs indicate clearly that additional documentation (typically
an import permit) is needed as well as the export certificate, or if a supplementary certificate is required.
39. A support certificate may be required if there are parts of a certificate which an individual would not be able to certify without further proof from another veterinarian.
40. An air certificate is occasionally needed to guarantee that the consignment travels from the premises of origin directly to the airport in a sealed container. An official (normally an OV) at the airport then certifies the opening of the seal on arrival at the airport.
41. For live animals, there may be a need to certify the cleansing and disinfection of the cargo compartment prior to loading.
25
Stage 4: Getting agreement
42. Once you have produced a preliminary draft, it needs to be passed to your admin contact in GAH. Use one of the following mailboxes:
or
or
Within GAH, appropriate quality assurance processes will be applied, and, once an experienced VA is content the draft will be returned to you for amendment.
43. Once your GAH contact has given approval to your draft in principle, you can complete the drafting of the NFGs, and, again, ensure that they are seen by an experienced VA before circulating further.
44. Now you can circulate the draft certificate and NFGs to the exporter, and the exporter may find it useful to ask the certifying Official Veterinarian for comments. Comments should be attributable: either by adding notes or comments to the text which include the contributor‟s name or initials, or by supplying a version with tracked changes and an amended footer, again indicating the contributor‟s name or initials. Beware of duplicated initials!
45. Other interested individuals may also be copied in at this stage: stakeholders, industry representatives or producers.
46. It is crucial that all those receiving versions of the certificate understand that the draft is not yet cleared, and therefore cannot be used.
47. It is always good practice to include a reasonable deadline for comments. If there is a reason for urgency, this should be explained.
48. Incorporate the relevant comments into your draft, discussing them constructively with the contributors if you disagree with their suggestions. Once the comments have been incorporated, re-circulate the draft. Again, define a deadline for final comments.
49. Send the re-drafts, with attributable comments and additions clearly included, to your GAH contact again.
50. Once the GAH VA is happy with the final draft, Defra will negotiate with the relevant country to get the certificate agreed by the Competent Authority.
26
51. Once agreed, the footer of the certificate and relevant associated documents will
be edited to reflect this. All these documents will then be sent to Carlisle for loading and use. In some cases a Customer Information Note will be issued in relation to the new certificate.
27
Annex A Export Health Certificate: an example
DEPARTMENT FOR ENVIRONMENT, FOOD AND RURAL AFFAIRS
SCOTTISH GOVERNMENT - RURAL DIRECTORATE
WELSH ASSEMBLY GOVERNMENT, DEPARTMENT FOR RURAL AFFAIRS
DEPARTMENT OF AGRICULTURE AND RURAL DEVELOPMENT NORTHERN IRELAND
EXPORT OF PORK AND PIG PRODUCTS TO THE REPUBLIC OF KOREA
HEALTH CERTIFICATE No: .............
EXPORTING COUNTRY: UNITED KINGDOM
FOR COMPLETION BY: OFFICIAL VETERINARIAN
I Identification of consignment
(a) Description of the
products:...........................................
(b) Type and number of
packages:...........................................
(c) Net and gross weight of consignment:..............................
.................................................................
..........
(d) Seal
number:...........................................................
(e) Container number:.................................................
.....
(f) Veterinary approval number of final plant of production:..........
.................................................................
..........
II Origin of products
(a) Name and address and veterinary approval number(s) of the
slaughterhouse(s) of origin:
................................................................
................................................................
................................................................
........
28
1171EHC (Agreed 23/09/2009)
Slaughter date(s) or period(s):
............................................
(b) Name(s), address(es) and veterinary approval number(s) of the
processing/cutting plant(s):
.................................................................
.................................................................
.................................................................
.................................................................
.................................................................
.........................
Processing date(s) or period(s):
................................................................
....
(c) Name, address and approval number of the cold store:
................................................................
................................................................
..........
Storage date or
period:..............................................
III Destination of products
(a) The product will be despatched from the United Kingdom to:
....................................................................
.
(country and place of destination)
(b) Name and address of exporter:....................................
................................................................
................................................................
...............
(c) Name and address of consignee:...................................
................................................................
................................................................
...............
29
1171EHC (agreed 23/09/2009)
(d) Means of transportation (including name of ship, flight number,
port of
departure:......................................................
(e) Intended date of loading:
................................................................
....................................
IV. Health Information
I, the undersigned, certify that the consignment described at I above
meets the following requirements:
a) the meat was derived from animals which were born and reared in
the United Kingdom;
b) the United Kingdom has been free from foot and mouth disease
without vaccination in accordance with the OIE International
Animal Health Code for the past 12 months and vaccination against
this disease is not permitted in the United Kingdom;
c) prior to loading no outbreak of the following diseases has
occurred in the United Kingdom and vaccination against these
diseases is not permitted in the United Kingdom:
i. vesicular stomatitis, and swine vesicular disease during the past two
years;
ii. rinderpest and African swine fever during the past three
years;
d) the premises from which the pigs used to produce the meat were
derived have had no evidence of the following diseases prior to
slaughtering:
i. brucellosis for three years;
ii. classical swine fever (hog cholera) and Aujeszky’s disease
for one year,
iii. anthrax for six months;
e) the premises from which the pigs used to produce the meat were derived are
not situated in an area subject to official restrictions due to a notifiable
disease – brucellosis, classical swine fever, Aujeszky’s disease and anthrax,
to which pigs are susceptible;
f) the premises used to produce, process and store the meat prior to export are
not situated in a area subject to official restrictions due to a notifiable
disease to which pigs are susceptible.
30
1171EHC (agreed 23/09/2009)
g) While working to export pork to the Republic of Korea, the export premises
did not handle cloven-hoofed animals or products from the countries from
which the Republic of Korea government bans the import of cloven-hoofed
animals or products, or cloven-hoofed animals or products that have transited
through such banned countries;
h) i. the consignment of pig meat / pig meat products described
at
paragraph I above was derived from premises listed at
paragraph II which are under government hygiene supervision
according to the provisions of Regulation (EC) No 854/2004
(as amended) of the European Parliament and of the Council
of the European Union laying down specific rules for the
organisation of official controls on products of animal
origin intended for human consumption;
ii. all the premises listed at paragraph II have complied with
the provisions of Regulation (EC) No 854/2004 (as amended)
at all the regular inspections carried out in the last 12
months, and no problems were found in the regular hygiene
test conducted by government;
j) the animals from which the meat was derived were subjected to
ante mortem and post mortem inspection under veterinary control.
No clinical evidence of notifiable disease was noted. The meat
was not subject to any animal health restriction and was found
fit for human consumption. In particular, there was no evidence
of trichinosis, cysticercosis or echinococcosis;
k) the slaughterhouse(s), cutting premises, processing plant and
cold store is / are currently approved by the Government
Authorities of the Republic of Korea for the export of meat to
the Republic of Korea;
l) a written declaration has been received from owner(s) of each of
the slaughterhouse(s), cutting premises, processing plant and
cold store described at paragraph II above, stating that all the
carcases or products produced in these premises are of the same
health status of those for export to Korea and are not of a
lesser health or hygiene status;
m) the meat has been processed, packaged, stored and transported in
a hygienic manner so as to prevent its contamination with any
agents known to cause infectious diseases of domestic animals
and humans and the packaging is approved for use for human
foodstuffs;
n) the meat described at paragraph I above meets United Kingdom
food sanitary regulations;
o) The meat does not contain, on the basis of national testing
programmes, the following contaminants: antibiotics, synthetic
anti-microbial drugs, hormone preparations, agrochemicals, heavy
metals and radioactive material, and pathogenic bacteria in
31
excess of permitted levels as set by the Korean Government1;
1171EHC (agreed 23/09/2009)
p) The meat has not been the object of administration of ionising
rays, ultraviolet rays or components such as meat processing
elements which have adverse effects on the constitution and
characteristics of meat;
q) the transport vehicles or containers and the loading conditions
of this consignment meet the hygiene requirements laid down in
legislation currently in force in the United Kingdom;
r) the refrigerated container in which the meat is transported has
been sealed under veterinary supervision after loading. The
container and seal number are given in paragraphs I d) and e)
above;
s) The pork/pig products are derived from animals slaughtered in
the UK, which has been free from Trichinellosis² for the last 25
years prior to the date of slaughter and export to Korea.
Date of issue:
Affiliation: *Department for Environment Food and Rural
Affairs/*Department for Agriculture and Rural
Development Northern Ireland/*Welsh Assembly
Government, Department for Rural Affairs/*Scottish
Government – Rural Directorate
*delete as appropriate
Stamp Signed
............................................
Name in block letters
...................................................
Official Veterinarian
Address.........................................
...
................................................
...
32
1171EHC (agreed 23/09/2009)
Footnote:
¹ as at 2004 following an inspections visit by the Korean National Veterinary
Research and Quarantine Service (NVRQS) when the residues inspection programme in
the UK was confirmed in writing to be equivalent to the Korean slaughterhouse
hygiene control standard inspections schedule.
² freedom from trichinellosis in domestic pigs on UK holdings is based on negative
results from all tests performed nationally since 1979.
33
Annex B Notes for Guidance: an example
No: .............
EXPORT OF PORK AND PIG PRODUCTS TO THE REPUBLIC OF KOREA -
1171EHC
NOTES FOR THE GUIDANCE OF OFFICIAL VETERINARIANS AND EXPORTERS
IMPORTANT NOTE
These guidance notes are not intended to operate as a standalone document but
must be read in conjunction with Export Health Certificate 1171EHC.
We would also strongly advise exporters to verify the requirements of the
importing country by contacting the appropriate veterinary authorities, or
their representatives in the UK, in advance of each consignment.
1. SCOPE OF CERTIFICATE
Export health certificate 1171EHC may be used for the
export of chilled/frozen pig meat and pig meat products
from the United Kingdom to the Republic of Korea (RoK).
2. APPROVAL OF ESTABLISHMENTS
Before exports can commence, all UK meat establishments
must be officially recognised by the Korean authorities as
eligible to export pig meat and pig products to the RoK.
Further details of approval procedures are at paragraph 11
of these notes.
3. IMPORT PERMIT
Prior to making arrangements to export pig meat/pig meat
products to RoK, exporters are advised to contact the
Livestock Trade and Investment Team at the British Embassy,
Seoul for up to date information on requirements for any
import documentation. The contact e-mail address is as
follows: [email protected]
1171NFG (agreed 23/09/2009)
34
4. CERTIFICATION BY AN OFFICIAL VETERINARIAN
This certificate may be signed in Great Britain by a Local
Veterinary Inspector (LVI) appointed by the Department for
Environment, Food and Rural Affairs (Defra), the Scottish
Government Rural Directorate or the Welsh Assembly
Government Department for Rural Affairs who is appointed to
the appropriate export panel as an Official Veterinarian
for export purposes.
The certificate may be signed in Northern Ireland by an
Authorised Veterinary Inspector (AVI) of the Department of
Agriculture and Rural Development Northern Ireland (DARDNI)
who is appointed to the appropriate export panel as an
Official Veterinarian for export purposes.
The certifying Official Veterinarian should sign the
certificate and affix the "Official Veterinarian" stamp in
ink of any colour other than black.
5. FURTHER GUIDANCE FOR THE COMPLETION OF SECTIONS I, II AND
III OF CERTIFICATE 1171EHC
Certifying Official Veterinarians should take note of the
following additional guidelines for the completion of the
certificate:
Paragraph I(f): the Korean authorities have requested
that the approval number of the final establishment of
production before export is recorded here;
Paragraph II(a) - (c): veterinary approval numbers for
the slaughterhouse and cutting plant, and approval
number for cold stores must be entered in the format
UK/Licence No/EC (e.g.: UK/1234/EC);
Paragraph II(a) – (c): enter the start and finish dates
for slaughtering, processing and storage as appropriate.
Exporters must ensure that the meat has been slaughtered
or processed at the export premises after the date(s) of
approval by the RoK government for all plants involved.
Paragraph III(e) – the intended date of loading means
the date on which the container is sealed and the health
certificate completed and signed.
1171NFG (agreed 23/12/2009)
35
6. ORIGIN OF THE ANIMALS FROM WHICH THE EXPORTED MEAT IS
DERIVED
Paragraph IV(a) refers. This paragraph can be certified on
the basis of the Official Veterinarian’s familiarity with
the procurement policy at the slaughterhouse/s and
examination of appropriate records.
Supporting statements may be required from the farms of origin
confirming that the UK residency requirements of this
paragraph have been met.
7. OFFICIAL DISEASE CLEARANCES
Paragraphs IV(b), IV(c), IV(d), IV(e), IV(f) and IV(s) refer.
The certifying Official Veterinarian may certify country
freedoms, area freedoms from official restrictions and
premises freedoms from the diseases listed in this
paragraph provided written authority to do so has been
obtained on a valid form 618NDC issued by Animal Health or
DARDNI.
9. LIST OF COUNTRIES PERMITTED TO EXPORT TO THE REPUBLIC OF
KOREA
Paragraph IV(g) refers. The countries from which the
import of cloven-hoofed animals or products thereof into
the RoK is permitted are as follows: United States,
Canada, Australia, New Zealand, Japan, Denmark, Sweden,
Finland, France, Switzerland, Ireland and United Kingdom.
All other countries may be considered as banned countries
for the purposes of certifying this paragraph.
For the purposes of this certificate, the term ‘working to
export pork’ means the handling and processing of export-
eligible live animals, carcases, exposed meat or product up
to and including final packaging.
Official Veterinarians should note that this paragraph
applies not only to meat originating from banned countries,
but also to meat from permitted countries that may have
transited through a banned country.
1171NFG (Agreed 23/09/2009)
36
10. EU REGULATIONS 852/2004, 853/2004 AND 854/2004 as amended
(The EU ‘Food Hygiene Package’)
Paragraphs IV(h), IV(n) and IV(q) may be certified on the
basis of the application of the oval health mark or
identification mark on the exported meat or packaging
thereof, indicating that the slaughterhouse, cutting plant
and manufacturing premises (if applicable)are officially
approved and operating in accordance with the above
Regulations and the Meat Hygiene Service Manual for
Official Controls.
In the case of standalone cold stores, Paragraphs IV(h),
IV(n) and IV(q) may be certified on the basis that the cold
store is approved under the above Regulations by the Local
Authority in whose area it is located.
Paragraph IV(h)(ii) may be certified on the basis that
exporting premises have effective systems in place to
ensure that any deficiencies found in the course of routine
audit by the Official Veterinarian are rapidly and
effectively resolved.
The certifying Official Veterinarian should contact Central
Operations for Exports in Carlisle
([email protected]) for further
advice in the case of deficiencies at the plant that are
not, in the opinion of the certifying Official
Veterinarian, satisfactorily resolved by the Food Business
Operator.
11. APPROVAL OF MEAT PLANTS AND COLD STORES TO EXPORT TO THE
REPUBLIC OF KOREA
Paragraph IV(k) refers. All slaughterhouses, cutting
premises, manufacturing premises and cold stores intending
to export pork and pig meat products to the RoK require
specific approval. Each establishment in the supply chain
must be included on the current list of approved
establishments maintained by the Korean veterinary
authorities.
Further details on establishment checklists and procedures
for approval of establishments to export to the RoK can be
obtained by contacting the Central Operations for Exports
in Carlisle at the following address:
1171NFG (agreed 23/09/2009)
37
12. OWNER WRITTEN DECLARATION OF CARCASE / PRODUCT STATUS
Paragraph IV(l) refers. Certifying Official Veterinarians
should obtain the written declaration required by this
paragraph.
Slaughterhouses
In the case of slaughterhouses, the owner declaration may
be given on the basis that all carcases from which the meat
for export to the RoK is derived are produced from animals
meeting the animal health conditions described in health
certificate 1171EHC.
All eligible carcases from which the meat for export to the
RoK is derived must be stored separately in chillers and
completely segregated from any other carcases prior to
further processing for export to the RoK in accordance with
the conditions laid down in the relevant approval
checklist.
In order to ensure Korean requirements for traceability and
segregation, meat eligible for export to Korea must be
clearly identified throughout the entire export chain.
Cutting and Processing Establishments
In the case of cutting and processing establishments, the
owner declaration may be provided on the basis that all
meat intended for export to the RoK is handled and
processed separately from meat not intended for export to
the RoK and that complete segregation is maintained up to
and including final packaging and cold storage.
Meat eligible for export to Korea must be clearly
identified throughout the entire export chain. The
packaged meat must be stored in designated areas and
segregated from meat not intended for export to the RoK in
accordance with the conditions laid down in the relevant
approval checklist.
Boxes of meat eligible for export to RoK must not contact
boxes of ineligible meat. Recommended horizontal separation
should be no less than 15cm (6”) between boxes. Boxes of
meat eligible for export to RoK must not be stacked
vertically above or below boxes of ineligible meat.
1171NFG (agreed 23/09/2009)
38
Cold Stores
In the case of cold stores, the owner declaration may be
provided on the basis of compliance of the premises with
the procedures for handling and segregation of packaged
meat intended for export to the RoK, as laid down in the
relevant approval checklist. Meat eligible for export to
Korea must be clearly identified throughout the entire
export chain.
Particular attention should be given to the following
points (taken from the guidance notes for Official
Veterinarians and Food Business Operators on the completion
of checklists for premises intending to export to the
Republic of Korea):
evidence of controls on non-UK pig meat in storage areas
together with a description how non-UK meat is prevented
from possible accidental introduction into consignments
intended for export to RoK. This might include a
dedicated, clearly delineated storage area within a
chamber for goods intended for export to RoK.
written procedures for the immediate removal of such
product to another chamber or separate area in order to
minimise the risk of damaged or out of date products
being present in the same cold store chamber as goods
for export to RoK.
Boxes of meat eligible for export to RoK must not contact
boxes of ineligible meat. Recommended horizontal separation
should be no less than 15cm (6”) between boxes. Boxes of
meat eligible for export to RoK must not be stacked
vertically above or below boxes of ineligible meat.
13. RESIDUES, RADIATION AND MICROBIOLOGICAL TESTING
Paragraph IV(o) refers. With regard to the monitoring of
antibiotics, synthetic anti-microbial drugs, hormone
preparations, agrochemicals, heavy metals and radioactive
material, the Korean authorities confirmed in 2004 that the
residues inspection programme in the UK was determined to
be equivalent to the Korean slaughterhouse hygiene control
standard inspections schedule.
Levels of these substances are therefore considered not to
be in excess of permitted levels as set by the Korean
government and may be certified on this basis.
1171NFG (agreed 23/09/20090
39
With regard to microbiological testing of exported meat,
the Korean veterinary authorities have agreed the testing
schedule and criteria at Annex 1 to these notes.
Certifying Official Veterinarians must ensure that
operators of slaughterhouses and processing plants have
implemented the testing regimes as described and that the
numbers of micro-organisms do not exceed prescribed levels.
14. ADMINISTRATION OF IONISING RAYS, ULTRAVIOLET RAYS OR OTHER
MEAT PROCESSING ELEMENTS
Paragraph IV(p) refers. This paragraph may be certified on
the basis of the Official Veterinarian’s familiarity with
EU legislation (see paragraph 10 above) and with the
operation and records of the slaughterhouse/s, cutting
plant(s) and processing plant(s) throughout the export
chain.
Supporting statements may be required from meat establishments
confirming that the requirements of this paragraph have
been met.
15. COMPLIANCE OF ESTABLISHMENTS WITH KOREA APPROVAL CHECKLISTS
Prior to gaining approval to export pig meat and meat
products to the RoK, operators of all premises are required
to complete a checklist, which must be countersigned by an
Official Veterinarian.
Official Veterinarians certifying exports to Korea should
carry out appropriate checks on a regular basis and at
least annually to ensure continuing compliance of the
premises with the conditions described in the checklists.
Any payment for checklist audits is a matter between the
Official Veterinarian and the Food Business Operator.
The Official Veterinarian should retain evidence of
checklist audits. These should be made available to
authorised inspectors, including the Korean authorities, in
the event of an audit or inspection of the establishment.
The certifying Official Veterinarian should contact Central
Operations for Exports in Carlisle for further advice in
the case of deficiencies at the plant that are not, in the
opinion of the certifying Official Veterinarian,
satisfactorily resolved by the Food Business Operator.
40
1171NFG (agreed 23/09/2009)
16. NO PARAGRAPH IV(i)
The omission of a paragraph IV(i) is deliberate to avoid
any confusion between the letter ‘i’ used alphabetically
and ‘i’ used as a Roman numeral in sub-paragraphs.
17. COMPLETION OF THE CERTIFICATE AND RETURN OF CERTIFIED COPY
A certified copy of the completed certificate must be sent
to Animal Health Central Operations for Export at Carlisle
within seven days of signing, or in the case of Northern
Ireland to DARDNI, Dundonald House, Belfast.
Official Veterinarians are also advised to retain a copy of
the certificate for their own records.
18. DISCLAIMER
The DEFRA disclaimer (Form 372DMR) will be issued to the
exporter with this certificate for his/her information.
The certificate is provided on the basis of information
available at the time and may not necessarily comply fully
with the requirements of the importing country. It is the
exporter’s responsibility to check the certificate against
any relevant import permit or any advice provided by the
competent authority in the importing country. If these do
not match, the exporter should contact the Central
Operations for Exports in Carlisle via the link below:
http://www.defra.gov.uk/animalhealth/about-us/contact-
us/centrops.htm
1171NFG (agreed 23/09/2009)
41
Annex 1
REQUIREMENTS FOR MICRO-ORGANISM INSPECTION FOR MEAT AND MEAT
PRODUCTS EXPORTED TO THE REPUBLIC OF KOREA
GENERAL
Scope of Sampling Requirements
The veterinary authorities of the Republic of Korea (RoK)
specify that food safety and monitoring microbiological tests
must be carried out on pig meat to be exported from the UK to
the RoK. Two testing regimes are required:
1. Routine sampling of pig carcases by an approved carcase
swabbing method for E coli, Salmonella and Total Viable
Count (Aerobic Plate Count); and
2. Testing of 25gm samples taken from the cuts of pig meat
making up each consignment for E coli and Total Viable
Count (Aerobic Plate Count)
Duties of the Food Business Operator (FBO)
The FBO shall undertake to carry out the following duties:
to collect samples in accordance with the sampling
techniques, methodology and frequency requirements
described below;
to obtain analytic results;
to maintain records of such analytic results
to make the testing records available at the request of
authorised inspectors and the veterinary authorities of the
RoK.
Written procedures
The FBO shall prepare written specimen collection procedures
which identify the following:
1171NFG (agreed 23/09/2009)
42
employees designated to collect samples
location(s) of sampling
how sampling randomness is achieved
handling of samples to ensure sample integrity.
The written procedure shall be made available to authorised
inspectors on request.
SAMPLE COLLECTION
1. SLAUGHTERHOUSE – PIG CARCASES
Sampling method
Samples are taken after the pig carcases have been finally
inspected by the Meat Hygiene Service and prior to chilling.
Carcases must be chosen at random and samples taken from the
ham, belly and jowl areas in accordance with standard non-
destructive surface sampling techniques, using a template
measuring 10cm x 10cm. Appendix 1 to these notes gives an
example of a template and indicates the three sampling sites.
Samples should be taken first from the belly area followed by
the ham area using the template and same surface of the swab.
The jowl area should then be sampled using the template and the
unused surface of the swab.
The swab is then placed into a sterile container and analysed in
either an on-site or off-site laboratory in accordance with
standard methodology.
Sampling frequency
A minimum of three pig carcases must be sampled per week of
operation.
1171EHC (agreed 23/09/2009)
43
2. CUT MEAT MAKING UP AN EXPORT CONSIGNMENT
Sampling Method
Samples must be taken from either fresh or frozen cuts of meat
making up a consignment intended for export to RoK. Samples may
be taken from meat leaving the cutting room immediately prior to
final packing for export to RoK or from packages of frozen meat
once they are identified as making up an export consignment.
25 gm samples of meat should be taken randomly using sterile
instruments and kept refrigerated or frozen in accordance with
standard procedures.
Sampling Frequency
A minimum of three 25 gm samples per consignment of meat
exported to the RoK should be tested for E Coli and Total Viable
Count (Aerobic Plate Count).
ANALYSIS OF SAMPLES
Laboratories may use any officially approved quantitative method
for analysis of E. coli, Salmonella and Total Viable Count
(Aerobic Plate Count).
1171NFG (agreed 23/09/2009)
44
RECORDING AND EVALUATION OF TEST RESULTS
1. PIG CARCASES
E coli
The FBO shall maintain accurate records of all test results, in terms of
colony forming units (CFU)/cm2 of surface area swabbed. Results shall be
recorded onto a process control chart or table showing at least the most
recent 13 test results, by type of livestock slaughtered. Records shall be
retained at the establishment for a period of 12 months and shall be made
available to authorised inspectors on request.
An establishment taking samples by swabbing carcases is operating within the
standard when the most recent E. coli test result does not exceed the upper
limit (M), and the number of samples, if any, testing positive at levels
above the lower limit (m) is three or fewer out of the most recent 13 samples
(n) taken, as follows:
Type of
livestock
(m)
Lower limit
of marginal
range
(M)
Upper limit of
marginal range
(n)
Number of
samples
tested
(c)
Maximum number
permitted in
marginal range
Pig
10 CFU/ cm2
10,000 CFU/ cm2
13
3
Salmonella
Samples may not test positive for Salmonella at a rate exceeding
the standard as follows:
Slaughterhouse Base level allowed to be
contaminated by salmonella
bacteria
Rate of
salmonella
contamination
(% per year) No. of
samples
Max. No. of samples
allowed to be
contaminated
Pig
26
2
Below 7%
Total Viable Count (Aerobic Plate Count)
Category Total Viable Count (Aerobic Plate Count)
Pig Carcase
Below 1 x 105 CFU/ cm2
45
1171NFG (agreed 23/09/09)
2. CUT MEAT IN MEAT PACKAGING AREA
Total Viable Count (Aerobic Plate Count) and E coli
Category Total Viable Count
(Aerobic Plate
Count)
E coli
Pork meat
Below 1 x 107 CFU/gm
Below 1 x 104 CFU/gm
POST IMPORT TESTING OF CONSIGNMENTS
FBOs exporting to the RoK are advised that additional
microbiological testing is carried out by the RoK authorities on
arrival of the first consignment of imported meat from a new
exporter and then at random thereafter. Monitoring tests are
carried out for the following micro-organisms:
Salmonella spp
E coli 0157:H7
Listeria monocytogenes
In the case of fresh pig meat, if any of these micro-organisms
is found to be present in a consignment, the Korean Authorities
will notify the UK Central Competent Authority accordingly. The
FBO will be notified and must then take appropriate steps to
rectify the problem. Failure to do so may result in a temporary
suspension of the FBOs approval status.
In the case of imported meat products, the Korean Authorities
have indicated that the discovery of any of these micro-
organisms will result on the rejection of the entire
consignment.
More detailed investigative inspections may be carried out for
the following micro-organisms:
Staphylococcus aureus
Clostridium perfringens
Campylobacter jejuni / coli
Yersinia enterocolytica
E coli serotypes O26, O111 and O128.
46
1171EHC (agreed 23/09/2009)
Discovery of contamination by pathogens likely to cause food
poisoning may result in the consignment being subjected to heat
treatment prior to release or it may be rejected.
1171NFG (Agreed 23/09/2009)
47
Appendix 1
TEMPLATE AND SWABBING SITES FOR PIG CARCASES
Example of sampling template (not to scale)
Site of belly swab
Site of jowl swab All skin below an imaginary line from the atlanto-axial joint to the ventral midline is considered to be jowl for the purposes of carcase swabbing.
Site of ham swab
48
Version 3 Linda Smith
11th February 2010
Annex C
Typical 618 NDC
DEPARTMENT FOR ENVIRONMENT, FOOD AND RURAL AFFAIRS
SCOTTISH EXECUTIVE ENVIRONMENT AND RURAL AFFAIRS DEPARTMENT
NATIONAL ASSEMBLY FOR WALES
FORM EC 618 - CLEARANCE OF NOTIFIABLE DISEASES UNDER THE ANIMAL HEALTH
ACT 1981, OF CERTAIN SPECIFIC NON-NOTIFIABLE DISEASES AND CERTIFICATION OF
HERD/FLOCK DISEASE STATUS
Authority to certify paragraph(s)
of export health certificate EC
and serially numbered
is hereby given on the understanding that this authority may be
immediately revoked by notification from this office should the
disease position deteriorate between now and the day of export
This authority is valid for 10 (TEN) days
Signature
Officer of the Minister
Name in BLOCK LETTERS
Official Stamp
Date:
Department for Environment, Food and Rural Affairs
Nobel House
17 Smith Square
London
SW1P 4JR
49
Version 3 Linda Smith
11th February 2010
Annex D
Drafting a certificate: Flowchart
Please note that you should use the drafting guidelines in association with this flowchart.
50
Version 3 Linda Smith
11th February 2010
Annex E
UKECP Since 2002, Defra has been part of a partnership arrangement with the livestock and livestock products industry, firstly via the Export Certification User Group (ECUG) and more recently via the UKECP (UK Export Certification Partnership) model. The ECUG was set up following FMD in 2001, with the specific intention of helping the Department focus its resources on the key priorities for market recovery and market access. Following the FMD outbreak in 2007 the ECUG was put on a more formal footing in the form of UKECP with the key objective of combining Defra and industry resource and skills in order to get trade operational again.
UKECP is a Defra/industry partnership that:
Liaises with the UK livestock and livestock products industries to establish export market priorities;
Provides a forum to discuss the use of Defra agents to negotiate export health certificates on behalf of the UK; and
Assists in the drafting of export health certificates, supporting documentation and other related documents which are generally required before exports can take place
UKECP is match funded by Defra and the relevant industries, via a limited company, Export Certification Limited (ECL). The successes of the group have, it seems, led to considerable trade income and consequent benefit to the UK economy.
Equally, as ECL provides certificate drafting services, GAH has benefitted from the sharing of resources and more rapid progression of certification required.
51
Version 3 Linda Smith
11th February 2010
Annex F Generic certificate: an example
Draft version
DEPARTMENT FOR ENVIRONMENT, FOOD AND RURAL AFFAIRS
THE SCOTTISH EXECUTIVE ENVIRONMENT AND RURAL AFFAIRS DEPARTMENT
NATIONAL ASSEMBLY FOR WALES
DEPARTMENT OF AGRICULTURE AND RURAL DEVELOPMENT NORTHERN IRELAND
EXPORT OF UNPROCESSED HIDES AND SKINS TO country HEALTH CERTIFICATE
EXPORTING COUNTRY: UNITED KINGDOM
FOR SIGNATURE BY: OFFICIAL VETERINARIAN
I Details of consignment
(a) Description of the products : ..............................................
............................................................................
(b) Type and number of packages : ..............................................
............................................................................
(c) Net weight: ................................................................
(d) Identification marks : .....................................................
............................................................................
(e) Container Number: ..........................................................
............................................................................
II Origin of products
(a) Name and address of exporter : .............................................
............................................................................
............................................................................
(b) Name and address of premises of despatch : .................................
.............................................................................
.............................................................................
III Destination of products
Name and address of consignee : ..................................................
.............................................................................
.............................................................................
Means of transportation : …………………………………………………………………………
IV Health information
I, the undersigned, hereby certify that:
1. the products were obtained from animals slaughtered in a
slaughterhouse, underwent veterinary inspection and were fit, as a
result of such inspection, for slaughter in accordance with Community
legislation;
2. the products were:
(a) either* produced in the UK which is a country officially
recognised free of FMD, without vaccination, according to
Article 2.2.10.2 of the World Organisation for Animal Health
52
Version 3 Linda Smith
11th February 2010
(OIE) Terrestrial Animal Health Code (2007 edition);
(b) or* salted for at least 28 days in sea salt containing 2%
sodium carbonate as recommended in Article 3.6.2.4. of the
World Organisation for Animal Health (OIE), Terrestrial Animal
Health Code (2007 Edition) for inactivation of FMD virus in raw
hides and skins;
(c) or* legally imported into the UK in accordance with the
requirements laid down in Chapter VI of Annex VIII to
Regulation (EC) No 1774/2002;
All precautions have been taken to avoid any contact of the products with
live animals or other animal products presenting a risk of spreading
serious transmissible disease.
Draft EHC (05/08/2008)
Signed ............................ MRCVS
............................................ Name in block letters
............................................
OFFICIAL VETERINARIAN
53
Version 3 Linda Smith
11th February 2010
Annex G
Notes for guidance for generic certificates
No: .............
EXPORT OF UNPROCESSED HIDES AND SKINS TO country
NOTES FOR GUIDANCE OF THE OFFICIAL VETERINARIAN
IMPORTANT
These notes provide guidance to Official Veterinarians (OV) and exporters.
The NFG should have been issued to you together with export certificate
Draft EHC. The NFG should not be read as a standalone document but in
conjunction with certificate Draft EHC. We strongly suggest that exporters
obtain full details of the importing country’s requirements from the
veterinary authorities in the country concerned, or their representatives
in the UK, in advance of each consignment.
1. Scope
Export health certificate Draft EHC may be used for the export of
unprocessed hides and skins to country.
Associated Documents: Draft EHC, 618NDC and 372DMR.
2. Certification by an Official Veterinarian (OV)
This certificate may be signed by a Local Veterinary Inspector
appointed by the Department for Environment, Food and Rural Affairs
(Defra), Scottish Executive Environment and Rural Affairs Department
(SEERAD), Welsh Assembly Government (WAG) or an Authorised Veterinary
Inspector (AVI) appointed by the Department of Agriculture and Rural
Development Northern Ireland (DARDNI), who is an Official
Veterinarian (OV) on the appropriate panel for export purposes. OVs
should sign and stamp the health certificate with the OV stamp in any
colour OTHER THAN BLACK.
A certified copy of the completed certificate must be sent to the
issuing local Animal Health Divisional Office (AHDO) within seven
days of issue.
OVs should keep a copy for his/her own records.
3. Paragraph I(a) refers. The consignment description should include
reference to the species of origin of the product.
4. Paragraphs IV 1(b), IV 1(c), IV 2 and IV 3 refer. These paragraphs
may be certified on the basis of familiarity with the factory
processes in place supported by relevant documentation and/or
suitable records (such as slaughter/treatment/testing records,
commercial documentation, veterinary certification).
The certifying OV should be familiar with the conditions of
Regulation (EC) No 1774/2002. Electronic copies of this Regulation
and subsequent amendments, as well as other pieces of EU legislation,
can be obtained by searching the EU Commission’s website via the
following link:
http://www.europa.eu.int/eur-lex/lex/RECH_legislation.do
5. Notifiable disease clearance
54
Version 3 Linda Smith
11th February 2010
Paragraph IV 1(a) may be signed on behalf of the Department provided
you are in receipt of written authority (form 618NDC) which will be
sent to you by the issuing local Animal Health Divisional Office
(AHDO) 10 days before shipment.
6. Disclaimer
The DEFRA disclaimer (Form 372DMR) will be issued to the exporter
with this certificate for his/her information. The certificate is
provided on the basis of information available at the time and may
not necessarily comply fully with the requirements of the importing
country. It is the exporter’s responsibility to check the certificate
against any relevant import permit or any advice provided by the
competent authority in the importing country. If these do not match,
the exporter should contact Animal Health via the appropriate address
in the link given below.
http://www.defra.gov.uk/animalh/int-trde/general/contacts.htm
55
Version 3 Linda Smith
11th February 2010
Annex H
Procedure for using generic certificates
Procedures for the use of the ECUG Generic Model Certificates for Hides, Skins, Wool and Animal Hair for non-EU countries
Please note that the authorities in importing countries can change their import requirements (including their veterinary certification requirements), at any time and for any reason. These changes are often proposed and implemented by importing authorities without informing the UK either via Defra or via the British Embassy or British High Commission in that country. Therefore, neither Defra nor Animal Health can guarantee that any Export Health Certificate (EHC) issued for the export of any live animal or animal product to a country outside the European Union will be sufficient to ensure the safe introduction of the commodity into that country. As such, all EHCs are used entirely at the exporter‟s risk and neither Defra nor Animal Health can be held responsible for any costs incurred should the importing authorities refuse the consignment because the EHC presented did not meet with their requirements. The risks of a consignment being detained, returned or destroyed are obviously greater in cases where the competent authorities in the importing country have not offered any form of written confirmation that the specific EHC meets their requirements. The following process will maximize the likelihood of an export consignment being successfully received: 1. The exporter contacts Carlisle to see if a suitable EHC is available for issue. 2. If a suitable EHC is available for issue, the exporter applies as normal. 3. If a suitable EHC exists but is not currently available for issue, the EHC needs
to be assessed by GAH and Animal Health (Carlisle), taking into account any known trade restrictions and whether or not the EHC can be signed.
(a) If the EHC is signable and no known trade restrictions are in place, a
specimen EHC can be given to the exporter, who should seek the acceptance of the importing authorities. This may be via an informal approach by the exporter to overseas contacts.
(i) If, after this informal approach, the exporter is content to use the EHC
at their own risk, Carlisle may issue the EHC to the exporter‟s certifying Official Veterinarian following receipt of a suitable application form.
(ii) If, after this informal approach, amendments have been requested by
the importing country to meet their latest import conditions, or by the exporter to better reflect their specific commodity, their production
56
Version 3 Linda Smith
11th February 2010
methods or sourcing arrangements, then these amendments will be considered on a case by case basis and the level of priority given will depend on whether or not the specific country and commodity appears on the ECUG priority table for hides, skins, wool and hair markets.
(b) If there is a known trade restriction or the EHC cannot currently be signed
then the next steps will be considered by GAH on a case by case basis and the level of priority given will depend on whether or not the specific country and commodity appears on the ECUG priority table for hides, skins, wool and hair markets.
4. If no suitable EHC exists, a specimen of the appropriate generic model
certificate can be provided to the exporter via ECUG members or GAH to instigate informal negotiations via importer or other contacts. The intention is to seek confirmation from the importing authorities that an EHC based on the generic draft certificate, relating it specifically to that country would be acceptable.
(a) If the feedback strongly suggests that the importing authorities would accept a
country-specific EHC based on the generic model, then a numbered EHC can be created by GAH and made available for use at the exporters risk via an application to Carlisle in the normal way.
(b) If the feedback indicates that some amendments are required, these will be
considered by GAH on a case by case basis and the level of priority given will depend on whether or not the specific country and commodity appears on the ECUG priority table for hides, skins, wool and hair markets.
57
Version 3 Linda Smith
11th February 2010
Annex I
Import requirements: examples Some are very complex- for example http://www.daffa.gov.au/aqis/cat-dogs/countries/cat2?name=United%20Kingdom However, some are simpler- for example:
MINISTRY OF AGRICULTURE, LAND AND ANIMAL PRODUCTION ANIMAL PRODUCTION AND HEALTH DIVISION
------------------------------------------------------------------------------------------- Permit number 655/09/09 The Animals (Importation) Control Regulations 1955 And the Animals (Importation) Control (Amendment) Regulations 1959 Made under the Animals (Diseases and Importation) Ordinance 1954 Import Permit for non-poultry birds Permission is hereby granted to ………………. of ……………………. to import …………………………………………………………………… from England during the period ………………………………………… into Trinidad and Tobago subject to the following conditions:
1. The bird(s) must be accompanied by a health certificate issues by a Government veterinary officer stating: (a) Within five days of shipment the bird(s) showed no clinical signs
of infectious and contagious diseases including Newcastle disease, Avian Influenza, West Nile disease, Avian Chlamydophilosis.
(b) That the country/region of exportation is free from velogenic Newcastle disease and notifiable Avian influenza.
(c) That the premises of origin where the birds to be exported were kept free from Avian Chlamydophilosis.
(d) That the birds were hatched in, and never left, the country of origin.
58
Version 3 Linda Smith
11th February 2010
(e) That the birds are captive bred. (f) The birds were kept in quarantine approved by the Government
Veterinary Services since they were hatched or at least twenty-one (21) days prior to shipment and showed no clinical signs of infection with the diseases as in (a) above. (For imports from the United States the quarantine facility must be mosquito proof)
(g) That Psittacine birds were kept under veterinary supervision for
forty-five (45) days prior to the shipment and were treated against Avian Chlamydophilosis using Chlortetracycline, doxycycline or any other approved tetracycline.
(h) The birds were subject to a diagnostic test seven to fourteen (7-
14) days prior to shipment to demonstrate freedom from infection with a virus which would be considered to be Avian Influenza.
(i) The birds have not been vaccinated against Avian Influenza.
2. The birds are transported in new containers on a direct flight to
Trinidad and Tobago.
3. The bird(s) are found healthy on arrival by the Inspector.
4. The Inspector may take samples for testing.
5. The Veterinary Officer, quarantine Tel 868 662-5986, must be given 48 hours notice of the bird(s) time of arrival.
6. Please note that under the Animal Disease and Importation Act, no fees are to be paid to either veterinarians or quarantine attendants providing this service.
59
Version 3 Linda Smith
11th February 2010
Annex J
Useful contacts and resources Defra:
http://defraweb/foodfarm/animaltrade/noneu/index.htm Global Animal Health Defra Nobel House 17 Smith Square London SW1P 4JR e-mail: [email protected] or
[email protected] or [email protected]
Tel: 020 7238 3000 Fax: 020 7238 3087 International Trade Centre for Exports Hadrian House Wavell Drive Rosehill Industrial Estate Carlisle CA1 2TB e-mail: [email protected] Tel: 01228 403600 Fax: 01228 591900 UKECP: http://www.ukecp.com/cms OIE: www.oie.int : particularly useful sections at http://www.oie.int/eng/normes/mcode/en_sommaire.htm http://www.oie.int/eng/normes/mmanual/A_summry.htm VLA website (tests and services):
60
Version 3 Linda Smith
11th February 2010
http://www.defra.gov.uk/vla/services/ser_services.htm Royal College of Veterinary Surgeons: http://www.rcvs.org.uk Particularly useful sections on certification at http://www.rcvs.org.uk/Templates/Internal.asp?NodeID=89717&int1stParentNodeID=89642 and http://www.rcvs.org.uk/Templates/PreviousNext.asp?NodeID=89764&int2ndParentNodeID=89738&int1stParentNodeID=89642 BVA: http://www.bva.co.uk