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EUROPEAN COMMISSION HEALTH and CONSUMERS DIRECTORATE-GENERAL Directorate F - Food and Veterinary Office

DG (SANCO)/8104-2009- CP-FINAL

COUNTRY PROFILE OF FRANCE

ON FOOD AND FEED SAFETY, ANIMAL HEALTH, ANIMAL WELFARE AND PLANT HEALTH

Valid as of December 2009 2

TABLE OF CONTENTS

EXECUTIVE SUMMARY................................................................................................. 3

INTRODUCTION............................................................................................................... 8

1. COMPETENT AUTHORITIES AND OVERALL DISTRIBUTION OF RESPONSIBILITIES.................................................................................................. 9

2. COMPETENT AUTHORITIES AND DISTRIBUTION OF RESPONSIBILITIES IN RELATION TO INDIVIDUAL CONTROL SYSTEMS................................................................................................................. 20

2.1 Control system for animal health .................................................................... 20

2.2 Control system for food of animal origin........................................................ 25

2.3 Control system for imports of animals and food of animal origin .................. 30

2.4 Control system for feedingstuffs and animal nutrition.................................... 33

2.5 Control system for Transmissible Spongiform Encephalopathy (TSEs)/ Animal By-Products (ABPs) ........................................................................... 38

2.6 Control system for veterinary medicinal products (VMP) and residues ......... 45

2.7 Control system for foodstuffs and food hygiene............................................. 51

2.8 Control system for imports of food of plant origin ......................................... 58

2.9 Control system for plant protection products (PPP) and residues................... 61

2.10 Control system for animal welfare .................................................................. 67

2.11 Control system for plant health ....................................................................... 69

3. FOLLOW-UP OF FVO INSPECTIONS .................................................................. 73

3.1 Animal health .................................................................................................. 77

3.2 Food of animal origin...................................................................................... 91

3.3 Imports of animals and food of animal origin................................................. 99

3.4 Feedingstuffs and animal nutrition................................................................ 113

3.5 TSEs/ABP ..................................................................................................... 114

3.6 Veterinary medicines and residues................................................................ 119

3.7 Foodstuffs and food hygiene ......................................................................... 120

3.8 Imports of food of plant origin...................................................................... 124

3.9 Plant protection products............................................................................... 126

3.10 Animal welfare .............................................................................................. 128

3.11 Plant health.................................................................................................... 130

3.12 Overview of more recent inspections............................................................ 131

ANNEX I – ACRONYMS, ABBREVIATIONS AND SPECIAL TERMS .................. 132

ANNEX II - PRODUCTION, CONSUMPTION AND TRADE OVERVIEW............. 138

ANNEX III - OVERVIEW OF STAFF RESOURCES.................................................. 146


EXECUTIVE SUMMARY

Overview

France is divided into 26 regions (22 in metropolitan France and four in the Overseas Departments (DOMs)) and 100 Departments (96 in metropolitan France and four Overseas Departments. The prefect is the representative of the government with responsibility for the implementation, administrative control and co-ordination of government policies. Twenty-two prefects in metropolitan France and four in the DOMs exercise a dual role, namely that of prefect of their own Department and also the designated region prefect.

The Departmental prefects are not linked in any hierarchical structure with the region prefect. The role of the latter is to provide co-ordination across the Departments which comprise the region.

The Ministry of Food, Feed and Agriculture and Fisheries (MAAP), the Ministry of Health and Sport (MHS) and the Ministry of Economy, Industry and Employment (MEIE) are the principal control agencies in France. These Ministries operate at national, regional and Departmental level. The Health service of the armed forces (SSA) under the Ministry of Defence (MD) is the competent authority for this sector.

General Review of public policies

A global review of how public services are delivered in France is on-going. There are 6 objectives of this reform, including the modernisation and simplification the organisation of the State and the delivery of services. New structures have been implemented at regional level. Four new bodies have been created, each linked to their respective Ministries:

• MAAP: Regional Directorate for Food, Agriculture and Forestry (DRAAF) containing a Regional Food Service (SRAL). The SRAL, under the authority of the Region Director, is responsible for implementation of the national programme number 206 steered by DGAL-Food safety and quality;

• MEIE: Regional Directorate for Enterprise, Competition, Consumers and Employment (DIRECCTE), containing a specialised unit for consumer protection - "Pole C"

• MHS: Regional Health Agency (ARS)

• MD: Regional Directorate of the Health Service of the armed forces (DRSSA)

Decree no 2008-1406 of 19 December 2008 created the DRAAF structure. Decrees establishing DIRECCTE and ARS had not been adopted at the time of the mission.


The role of the Region Prefect (with the assistance of the Secretariat General for Regional Affairs-SGAR) is to steer State policy in the region. Programmes and budgets are established centrally. The regional level has responsibility for the allocation of financial and human resources to the Departmental services.

Structures at Departmental level had still to be finalised and were expected to come into effect from 1 January 2010. Services at this level will consist of a Departmental Directorate for social cohesion and protection of the population (DDCSPP) or a Departmental Directorate for the protection of the population (DDPP). These structures will replace the existing (DDSVs) Departmental Directorate for Veterinary Services and UDCCRFs and will assume all of their tasks. There are 8,246 full-time equivalent staff and some 12,500 part time staff employed in food and feed safety, animal health, animal welfare and plant health controls in France. Of these, around 1,400 are employed at central level, around 1,000 at regional level and the majority at departmental level, mainly in the veterinary service directorates.

In February 2006, an inter-ministerial committee was established to prepare the first multi-annual national control plan (MANCP) covering 2007 to 2009. DGAL is the designated contact point for the MANCP. The MANCP was provided to the Commission in April 2007.

The 2007-09 plan will be extended and updated progressively for 2010 in order to introduce the modified structures at Department and Region levels.

The Annual report on the MANCP for 2007 was provided to the Commission on 24 November 2008. The Annual Report for 2008 was provided on 4 December 2009.

Inspections in France by the Food and Veterinary Office (FVO)

In the period 1999 to 2003, the FVO carried out 50 inspections in France. Since 2004, 34 inspections and 3 general review missions in France were carried out. The following table shows the sectors covered by these inspections since 2004 and shows general review missions carried out in the period.

SECTOR 2004 2005 2006 2007 2008 2009 Total

Animal Health 3 0 2 1 1 7

Food of Animal Origin 1 0 2 1 1 5

Imports of animal and food of animal origin 0 2 1 0 1 4

Feedingstuffs and animal nutrition 0 0 0 1 0 1

TSEs/ABP 1 1 0 1 2 5

Veterinary medicines and residues 0 1 0 0 0 1

Foodstuffs and food hygiene 0 0 1 2 0 3


Imports of food of plant origin 0 0 0 1 0 1

Plant Protection Products 0 0 1 0 0 1

Animal Welfare 1 0 1 2 0 1 5

Plant Health 0 1 0 0 0 1

Totals 6 5 9 9 6 3 34

General Review 0 0 1 0 1 1 3

Note: Part 3 of the country profile provides an overview of FVO inspections to France for the period 1999-2008 and a breakdown of recommendations by sector.

Progress on FVO recommendations

For 32 of the 34 inspections carried out, final reports had been issued and action plans received from the French authorities setting out how they had responded or intended to respond to the 284 recommendations made. These action plans had been assessed by the Commission to determine whether sufficient progress was being made by the French authorities to deal with the weaknesses in control systems identified in the inspections.

On the basis of these assessments and following earlier general review missions, the Commission had closed 186 of these recommendations either on the basis of action taken by the Competent Authorities or because they were no longer relevant.

During the most recent general review mission in France in June 2009 progress on the remaining 99 recommendations was reviewed.

The outcome of this review is presented in the following Table:

Recommendation status Pre-General Review Mission 2009

Post- General Review Mission 2009

Action taken / No longer relevant Of which carried over from 2003

186 221

Outstanding / Action still required Of which carried over from 2003

42 1

15 -

For verification / In progress Of which carried over from 2003

57 49 1

Total number of recommendations

Of which carried over from 2003

285

1

285

1

For 4 of the inspections carried out, the process has not yet reached final assessment stage.


Main issues1

The main issues that have been identified in France through FVO inspections and still require to be addressed by the authorities include: Horizontal issues

There are no horizontal issues for France.

Sector specific issues

Animal Health

• Arrangements for the identification and registration of ovine and caprine animals are

not in compliance in that there is no single register.

• Bluetongue: Measures applied following suspicion or confirmation of bluetongue are insufficient to effectively prevent the spread of the disease.

• Bovine and caprine tuberculosis: An Order to bring national provisions fully into line with Regulation (EC) No 853/2004 is in preparation. Instructions to require the use of callipers for reading intradermal tuberculination tests were planned to be operational early in 2010

Food of Animal origin

• Performance of ante-mortem examinations by veterinary technicians which is contrary to EU Regulations (Red meat and poultry).

• Certification: In order to bring arrangements into line with EU requirements, France is introducing a new category of “Certifying veterinarians” with a status similar to civil servants. However, the most recent mission (2009-8231) concluded that the proposed new arrangements would not achieve full compliance.

• Establishments: A number of non-compliant establishments continued in operation notwithstanding the earlier deadlines set by the French authorities.

• Arrangements in place in the following areas are not in compliance with EU

1 Issues arising in missions subsequent to the general review mission and, which have not yet reached final assessment stage, are denoted with an asterisk together with reference to the mission


requirements: controls on pet animals, supervision of custom warehouses/ship suppliers, serological sampling of live animals, and maintenance of registers at the BIPs.

Future FVO inspections

France will be subject to a general audit in 2010 which will include 10 specific audits covering the following sectors:

Ref No. Mission Start Date Sector Subject of Inspection

2010-8390 01/02/2010 Animal welfare Animal welfare on farms and during transport

2010-8435 22/02/2010 Veterinary medicines and residues

Residues and contaminants and the use of veterinary medicinalproducts in food producing animals

2010-8618 12/04/2010 Foodstuffs and food hygiene

GMOs

2010-8523 26/04/2010 Food of animal origin Fishery products

2010-8464 18/05/2010 Feedingstuffs Feed and feed hygiene

2010-8506 14/06/2010 Food of animal origin Operation of controls over the traceability of beef and beefproducts

2010-8554 20/09/2010 Imports of animals and food of animal origin

Import/transit control system and border inspection posts

2010-8596 18/10/2010 Imports of food of plant origin

Import controls; pesticides

2010-8605 08/11/2010 Plant health Outbreaks of Anoplophora, Rhynchoporus, PSTVd

2010-8406 29/11/2010 Animal health Bovine tuberculosis


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 France and to provide a summary of progress by France on the implementation of FVO recommendations.

The information in the country profile has been compiled on the basis of a general review mission, which was carried out by the FVO in France in June 2009. The scope of this mission comprised:

• An analysis of information provided by the French authorities detailing how control systems are organised;

• A review of progress made on the implementation of recommendations made to the French authorities by the FVO following its audits and inspections in recent years.

The country profile is presented in three parts:

• Part 1 describes the overall organisation of the French authorities and the respective responsibilities of the relevant ministries 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 (pre-reform) for each of the eleven separate systems that form the complete range of control systems in France covering the whole chain of plant, animal and food production. As in Part 1, organisation charts are used to help the reader.

• Part 3 provides an overview of progress made on FVO recommendations in each control system and gives an assessment of the current state of implementation, highlighting any cases where action is still required on the part of the national authorities. Part 3.12 also provides an overview of more recent inspections which had not been finalised at the time of the general review mission.

The FVO revisits the Member States regularly to monitor progress in relation to the open recommendations. The country profile will be updated at regular intervals based on the results of future FVO missions and other relevant information received by the Commission from the French authorities.

Acronyms are used extensively throughout this report for the sake of brevity. A list of acronyms, abbreviations special terms and websites (where applicable) is given in Annex I to the country profile as a guide for the reader.

Valid as of December 2009

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1. Competent Authorities and overall distribution of responsibilities

France is divided into 26 regions (22 in metropolitan France and four in the Overseas Departments (DOMs)) and 100 Departments (96 in metropolitan France and four Overseas Departments. The prefect is the representative of the government with responsibility for the implementation, administrative control and co-ordination of government policies. Twenty-two prefects in metropolitan France and four in the DOMs exercise a dual role, namely that of prefect of their own Department and also the designated Region Prefect.

The Departmental prefects are not linked in any hierarchical structure with the regional prefect. The role of the latter is to provide co-ordination across the Departments which comprise the region.

The Ministry of Food, Feed, Agriculture and Fisheries (MAAP), the Ministry of Health, Youth, Sport and Social life (MHS) and the Ministry of Economy, Industry and Employment (MEIE) are the principal control agencies in France. These Ministries operate at national, regional and Departmental level. The Health service of the armed forces (SSA) under the Ministry of Defence (MD) is the competent authority for this sector. The National Institute for origin and quality (INAO) is responsible for controls on identification marks and quality of food and feed products.

General Review of public policies

A global review of how public services are delivered in France is on-going. There are 6 objectives of this reform, including the modernisation and simplification the organisation of the State and the delivery of services. New structures have been implemented at regional level. Four new bodies have been created, each linked to their respective Ministries:

• MAAP: Regional Directorate for Food, Agriculture and Forestry (DRAAF) containing a Regional Food Service (SRAL). The SRAL is responsible for implementation of the national programme number 206 of DGAL-Food safety and quality;

• MEIE: Regional Directorate for Enterprise, Competition, Consumers and Employment (DIRECCTE), containing a specialised unit for consumer protection - "Pole C"

• MHS: Regional Health Agency (ARS)

• MD: Regional Directorate of the Health Service of the armed forces (DRSSA)

Decree no 2008-1406 of 19 December 2008 created the DRAAF structure. Decrees establishing DIRECCTE and ARS had not been adopted at the time of the mission.

The role of the Regional Prefect (with the assistance of the Secretariat General for Regional Affairs-SGAR) is to steer State policy in the region. Programmes and budgets


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are established centrally. The regional level has responsibility for the allocation of financial and human resources to the Departmental services.

Structures at Departmental level had still to be finalised and were expected to come into effect from 1 January 2010. Services at this level will consist of a Departmental Directorate for social cohesion and protection of the population (DDCSPP) or a Departmental Directorate for the protection of the population (DDPP).

Arrangements for plant health had to be clarified as, under the former arrangements, the service was based at regional level only.

As the services at Departmental level will be integrated, previous arrangements for inter-service cooperation will no longer be relevant.

The hierarchical link of the Ministries with their respective regional and Departmental services is presented below:

MAAP MEIE MSS MD

DGAL DGCCRF DGS SSA

Region Prefect & SGAR

DRAAF Direccte ARS* DRSSA

SRAL Pôle C

Reporting Hierachial link

Reporting

Reporting

Coordination

Harmonisation

Coordination

Steering

Harmonisation

Coordination

Harmonisation

Department Prefect (100)

DDCSPP or DDPP

(DDI)

(from 1.1.2010)

Controls

Implementation


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* The links between the ARS and the Prefects have yet to be determined.

The Ministry for Ecology, Energy, Sustainable Development and the Sea (MEEDDM) and the Ministry of Labour (ML) also contribute to the overall control system which is described in the following sections.

Strategic objectives and co-operation between the Ministries

The "Food safety and quality programme" of MAAP and the "Health monitoring and safety" programme of the MHS, set out the main objectives. In addition, the consumer safety action, in the programme "Development of Enterprises and Employment" of MEIE, also covers food safety.

A protocol of co-operation established on 29 December 2006 between the Food Directorate General (DGAL), the Directorate General for Competition, Consumer Affairs and Fraud Repression (DGCCRF) and the Directorate General for Health (DGS) assures the implementation of EU Food Safety rules. This protocol was to be reviewed in the light of the new structures. The Directors General of the three Ministries meet at least every 2 months.

The general allocation of responsibilities may be summarised as follows:

DGAL DGAL, DGCCRF and DGS

DGCCRF

• Primary production (animal and plant) • Animal welfare • Slaughterhouses

• Processing • Restaurants • Direct sale • By products • Animal feed • Transport and storage

• Processing (food of non-animal origin) • Non-food products

The SSA, the competent authority for the armed forces, has a corps of veterinarians who undertake controls in close cooperation with DGAL. This is covered by an agreement between the two Ministries (2007/1 of 27 April 2007).

Ministry of Food, Feed, Agriculture and Fisheries(MAAP)

Directorate General for Food (DGAL)

DGAL employs 227 agents, mainly civil servants, 66% of whom are administrative staff. About 75% of the total are professional staff (veterinarians, engineers, technicians).

Decree 2008-636 of 30 June 2008 as amended defines the structure and organisation of the central services of MAAP.


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An organisation chart of DGAL is available at

http://agriculture.gouv.fr/sections/ministere/organigrammes-missions/administration-centrale

DGAL consists of 3 services and six sub-directorates:

Food service

• Sub-Directorate for food safety (SDSSA)

• Sub-Directorate for food quality (SDQA)

Service for the prevention of health risks and primary production

• Sub-Directorate for plant quality and protection (SDQPV)

• Sub-Directorate for animal health and welfare (SDSPA)

Service for the coordination of actions

• Sub-Directorate for horizontal policies (SDPPST)

• Sub-Directorate for European and international health matters (SDASEI)

In addition, there are 4 horizontal support/technical structures:

• General Affairs mission (MAG)

• Mission for performance development (MAAPP)

• Mission for health emergencies (RASFF contact point) (MUS)

• National Brigade for veterinary and phytosanitary investigation (BNEVP)

There are 14 Regional Directorates for maritime affairs (DRAMs) and 26 DDAMs. The DDAMs operate under MEEDDM, but act on behalf of MAAP(DGAL) as regards: the authorisation of production; health surveillance; classification and management of shell fish production areas; monitoring of water quality; and documentary controls.

The DDAMs employ some 560 staff, of which 61 have responsibility for shellfish production.

National Brigade for veterinary and plant health investigation (BNEVP)

BNEVP is a service of the DGAL authorised to investigate infringements of veterinary and plant health regulations. It intervenes in co-operation with, or in support of, the Regional Food Services (SRALs) [DDSVs until 31 December 2009]. It also provides technical support to the Department of Justice as well as the Police services.




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Services at Regional and local levels

The SRALs have responsibility for the coordination of activities at Department level and for the allocation of human and financial resources. They have responsibility for specific tasks as part of quality assurance. They include a unit called the “pôle mutualisation” which undertakes controls across a number of Departments.

In 2009, SRALs also had responsibility for harmful organisms, controlling the use of pesticides, pesticide residues and for cultivation of GM crops.

At Departmental level, the DDCSPP or DDPP [DDSVs until 31 December 2009], operating under the authority of the prefect of the Department, are the veterinary administrations with responsibility for safeguarding public and animal health and protection of the environment.

Overall, these structures employ approximately 4,580 staff directly and avail of the service of some 12,500 veterinary practitioners on a part-time basis working under approved veterinarians (VS) to undertake certain tasks.

Five main categories of staff are engaged in official controls:

• Veterinary public health inspectors (ISPV): mainly officials who have received specialised training in the national veterinary services school in Lyon. Those who are qualified veterinarians, are designated as "official veterinarians" (OVs);

• Contract official veterinary (OVs): qualified veterinarians who are not statutory civil servants. They are trained to assume responsibilities as official veterinarians;

• Engineers of bridges, water and forests, with competence mainly in the area of plant health;

• Agricultural and environment engineers (IAE): civil servants who carry out control tasks where it is not legally necessary to be a designated OV;

• Technicians: civil servants who carry out controls under the authority of the ISPVs, OVs and engineers, in relation to animal health, animal welfare, and food and feed safety and quality and plant health. All of these categories of staff are conferred with police powers under the "rural code". They may: propose criminal proceedings to State prosecutors; require persons to take corrective actions in cases of non-compliance; and propose certain measures to the prefect or to the Ministries (such as suspension of activity or product recall).

In addition to the five staff categories outlined above, the SRAL [DDSVs until 31 December 2009] may (under Article 221-11 of the "rural code") authorise private veterinary practitioners to carry out certain tasks. The mandate is given to the veterinarian by the prefect (Article 221-4-1 of the "rural code" which inter alia sets out the responsibilities of the VS).


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In certain cases, these approved veterinarians (VS) receive payments directly from farmers and operators for duties performed on holdings and in assembly centres and for disease prevention. At holdings and assembly centres, VSs are responsible for: clinical inspection; assessing the fitness for transport of animals intended for intra-community trade (ICT); and issuing the relevant official documents.

Ministry of Economy, Industry and Employment (MEIE)

Directorate General for Competition, Consumers and the Repression of Fraud (DGCCRF)

An organisation chart of DGCCRF is available at: http://alize.finances.gouv.fr/dgccrf/orgdgccr.htm.

DGCCRF consists of a central service based in Paris, 23 Regional Directorates (DRCCRF) and 101 Departmental Directorates (UDCCRF) situated in each Department. Regional Directorates lead and co-ordinate the work of Departmental Directorates.

The DGCCRF has three objectives:

• to guarantee the proper functioning and transparency of markets;

• to protect consumer interests;

• to protect consumer safety and health.

For the food chain, the activities of the DGCCRF are primarily aimed at ensuring the safety and integrity of food and feed. It also participates in the control of substances present in food/feed. This includes those added intentionally (additives, flavourings, novel ingredients, etc) and those added unintentionally (biological and chemical contaminants of agricultural, industrial or environmental origin). These controls are undertaken at import, primarily as part of strengthened Community controls, and at the premises of producers, importers and distributors. They cover domestic, EU and imported produce.

The central service of DGCCRF consists of seven sub-directorates, organised in two services. Each sub-directorate consists of a number of offices. Two sub-directorates of the central administration and a service with national competence, have relevant responsibilities for food safety controls, namely the "Consumer and Safety Directorate"; the "Agricultural and Food products Directorate"; and the "National Directorate for enquiries on competition, consumer affairs and repression of fraud" (DNECCRF). The DNECCRF is empowered to act alone, or in co-operation with Departmental Directorates, throughout the whole national territory.

The DNECCRF and the BNEVP co-ordinate their actions and may pursue joint operations.

The office for safety and alert networks (C2), within the sub-directorate "Consumer policy and safety" and offices D2, D3 and D4 of the sub-directorate "Agriculture and food products", are responsible for planning controls on food safety. Office C2 is the national contact point for RASFF. Within the sub-directorate "Consumer policy and

http://alize.finances.gouv.fr/dgccrf/orgdgccr.htm


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safety", Office C3 “Integrity” is responsible for the planning of controls in relation to labelling of foodstuffs, GMO, organic production and other quality labels.

DGCCRF agents are conferred with judicial and administrative police powers under the "consumer code". They may: propose criminal proceedings to State prosecutors and may require persons to take corrective actions in cases of non-compliance. They may also propose certain measures to prefects or Ministries, such as suspension of activity or product recall.

Control Data

A copy of the Annual Report of DGCCRF is available at

http://www.minefi.gouv.fr/directions_services/dgccrf/dgccrf/rapports_activite/2006/index.htm

Ministry of Budget, public accounts and the public service

The Directorate-General for Customs and Indirect Taxation (DGDDI), of the Ministry of Budget, Public Accounts and the Public Service, is responsible for the customs service "Customs" comprising a total of 18,173 staff. The central administration is based in Montreuil and there are 12 interregional directorates and 44 regional directorates. In addition, the overseas territories include one regional directorate and four services.

An organisation chart of the DGDDI is available at http://douane.gouv.fr/page.asp?id=138

The DGCCRF and the DGDDI share a network of 11 State Laboratories attached to the respective Ministries. This is the Common Laboratory Service (SCL).

Ministry of Health and Sport

The Health Directorate General (DGS) of the MHS is responsible for health policy as defined in the public health code and contributes to its implementation in liaison with the other directorates and services of the MSS, as well as other competent agencies. The DGS is responsible for co-ordinating responses to health emergencies, including those resulting from foodborne illnesses.

The National Institute of health surveillance (INVS), under the aegis of the MHS has responsibility for surveillance, vigilance and alert in all areas of public health. It investigates foodborne illness outbreaks and zoonoses. The INVS has a number of inter-regional units (Cire). These are located in the ARS [DRASS until 31 December 2009]. These units provide Regional and Departmental State services with expert support.

A sub-directorate of DGS is responsible for management of environmental health risks, including those relating to drinking water and food. This sub-directorate contributes to risk analysis in these areas in collaboration with the other competent authorities. It provides information to the public and to professionals on risks and policies. It contributes to the development and monitoring of the national health-nutrition programme. It also supports the work of the DUS.



http://douane.gouv.fr/page.asp?id=138


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A dedicated Department (DUS) in DGS deals with emergency situation. It receives and processes all information potentially giving rise to emergencies. It works in cooperation with other State agencies, including the French Agency for Health Safety and Health Products (AFSSAPS).

Another sub-directorate "Practices and Health products policy" (office PP3) contributes to inter-ministerial policy on veterinary medicinal products.

An organisation chart of DGS is available at http://www.sante-sports.gouv.fr/

Within the scope of the country profile, the objectives for the ARS and new structures at Department level [Regional Directorates for Health and Social Affairs (DRASS) and the Departmental Directorates for Health and Social Affairs (DDASS) until 31 December 2009] include two food safety objectives:

• to protect human health through sustainable improvement in the quality of the water supply and bottled water; and

• to contribute to the improvement of food safety and the management of crisis situations involving food, and to monitor foodborne diseases.

For both of these objectives, performance indicators are defined in relation to the number of establishments visited and the incidence of foodborne diseases.

Regional service

The 26 Regional Directorates for Health and Social Affairs (DRASS) were set to be replaced by Regional Health Agencies (ARS) from 1 January 2010 under the Law on the reform of hospitals, patients and territories which was adopted on 21 July 2009.

Local service

Pending the introduction of new structures, there are 100 DDASSs and DSDS which operate under the authority of the Departmental prefects. DDASS comprise two divisions:

• public health including safety of drinking water and management of infectious disease outbreaks; and

• social affairs.

The public health division of the DDASS includes the "environmental health service" which co-ordinates with SRAL [DDSV until 31 December 2009] and UDCCRF on the control of certain food establishments. The DDASS participates in controls on certain catering establishments, including hospitals. In the case of establishments producing food of animal origin, the environmental health service inspectors undertake controls on water quality in conjunction with SRAL. Controls on water bottling plants are undertaken by DDAS (quality) and by UDCCRF (packaging and traceability on the market).

The public health division of DDASS is responsible for the management of foodborne illness cases. This local level management, in conjunction with SRAL [DDSV until 31 December 2009] and/or UDCCRF and the DUS could be transferred to national level depending on the results of investigations. The DDAS manages the alerts, transmits the

http://www.sante-sports.gouv.fr/


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obligatory declarations to the INVS and, as required, obtains the support of the Cire units in its investigations.

[Note: In the future, DRASS and DDASS will be replaced by ARS and a new coordination arrangement is to be defined between ARS, SRAL, Pole C of DIRECCTE and DDPP (or DDCSPP)]

Ministry of Defence

Since October 2006, the Health Department of the armed forces (SSA) is the competent authority for food safety (canteens, animal welfare and research) in the services. The SSA comprises 78 veterinarians and 35 technical agents.

The service includes Regional Directorates of the Health Service of the armed forces (DRSSA)

Ministry for Ecology, Energy, Sustainable Development and the Sea (MEEDDM)

The MEEDDM (Directorate General for the prevention of risks (DGPR)), has produced instructions and a number of orders on the control of waste water and material collected from the treatment of waste water at ABP premises.

Ministry of Labour (ML)

The Ministry of Labour has a role in relation to legislation on the classification, packaging and labelling of plant protection products (as regards, in particular, protection of workers using pesticides).

French Food Safety Agency (AFSSA)

AFSSA (the French Food Safety Agency) is an independent public institution with some 1,100 staff. It is under the auspices of the three Ministries responsible for health, agriculture and consumers (MHS, MAAP and MEIE). AFSSA carries out risk assessment on issues related to food safety (nutrition and health), including drinking water, animal feed and animal health on its own initiative, or at the request of DGAL, DGCCRF, DGS or by approved consumer associations. It also has responsibility for the evaluation of risks/benefits relating to plant protection products and fertilisers as part of the pre-authorisation procedure. AFSSA is consulted by the three Ministries on all draft legal texts in the areas of food safety, animal health and plant protection products. In relation to veterinary medicinal products, AFSSA has specific functions exercised through the National Agency for Veterinary Medicinal Products (ANMV).

The Agency does not undertake official controls. It has a network of 11 laboratories at 10 sites, providing research and scientific and technical support. Many of these are designated National Reference Laboratories.http://www.afssa.fr/

AFSSA is designated as Community Reference Laboratory in 8 areas.

http://www.afssa.fr/


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National Agency for veterinary medicines (ANMV)

The National Agency for Veterinary Medicines (ANMV) is a part of AFSSA under the auspices of the Ministries responsible for health and agriculture. It has responsibility for the assessment and authorisation (on behalf of AFSSA) for placing on the market of Veterinary Medicinal Products (VMPs); the inspection and control of veterinary pharmaceutical establishments (production, wholesale of VMPs); and the control of the quality of these products. It has a staff of 80 persons. ANMV is also responsible for the certification of Good Manufacturing Practice (GMP), Good Laboratory Practice (GLP) and exports as regards veterinary medicines.

The ANMV unit for quality control of pharmaceuticals is accredited by the Accreditation Committee of France (COFRAC) since September 2000 according to EN NF ISO/CEI 17025 (extended in 2008).

MANCP

DGAL is the designated contact point for the MANCP. The MANCP was provided to the Commission in April 2007.


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Competent Authorities Distribution of responsibilities in relation to control systems The following chart gives an overview of the distribution of responsibilities in relation to control systems and operational levels.

Sector Policy co-ordination

Co-ordination of controls

Implementation of controls

Laboratories Risk assessment, scientific

advice

1. Animal Health DGAL DGAL DDSV-SRAL, DRAM

Laboratories approved by MAAPand

NRL

AFSSA, NRL including IFREMER

2. Food of Animal Origin

DGAL, DGCCRF DGAL, DGCCRF

DDSV-SRAL, BNEVP,

DDASS, INVS, DCCRF, DDAM

SCL

Laboratories approved by

MAAPand NRL

AFSSA, NRL including IFREMER

3. Imports of animal and food of animal origin DGAL, DGDDI DGAL, DGDDI SRAL, DGDDI,

DDAM


MAAPand NRL AFSSA

4. Feedingstuffs and animal nutrition DGAL, DGCCRF DGAL,

DGCCRF DDSV-SRAL,

UDCCRF

SCL –Laboratories approved by

MAAPand NRL

AFSSA

5. TSEs/ABP DGAL DGAL,

DGCCRF SRAL, UDCCRF SCL –


NRL (AFSSA)

AFSSA

6. Veterinary medicines - authorisation, marketing &distribution

MAAP, MHS, MEIE, ANMV ANMV ANMV, DDSV-

SRAL, DRASS AFSSA AFSSA

Veterinary medicines - residues

MAAP, MHS, MEIE DGAL DDSV-SRAL

AFSSA, SCL –


NRL

AFSSA, INVS

7. Foodstuffs and Food hygiene DGAL, DGCCRF,

DGS

DGAL, DGCCRF,

DDGS

DDSV-SRAL, UDCCRF, DDASS,

DDAM

SCL – Laboratories approved by MAAPand

NRL

AFSSA, IFREMER

8. Imports of food of plant origin

DGCCRF UDCCRF, DGDDI UDCCRF, DGDDI SCL -

9. Plant protection products - authorisation, marketing and use

MAAP, MEIE DGCCRF, DGAL UDCCRF, SRAL

SCL, Laboratories approved by

MAAP and NRL

AFSSA

Plant protection products - residues

MAAP, MEIE DGCCRF, DGAL UDCCRF

SCL,


MAAP and NRL AFSSA

10. Animal Welfare DGAL DGAL DDSV-SRAL - AFSSA

11. Plant Health DGAL DGAL SRAL

LNPV, Laboratories approved by

MAAP and NRL

AFSSA


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2. Competent Authorities and distribution of responsibilities in relation to individual control systems

2.1 Control system for animal health

MAAP

DGAL

SDSPA

DGALSDSPA

SRAL(22)

DRAM(14)

DDSV(100)

DDAM(26)

DepartmentalPrefect

Holdings

EDEControls

Data notificationsand first level

control

Primary shellfishproduction

Second Level controls

National Animalidentification

Database

LocalDatabases

Data to NationalDatabase

Assembly centresMarkets

Slaughterhouses

Controls

AuthorisedDepartmental

Laboratory

Approval

Results

AFSSANRLs

IFREMERLaboratory

MD

SSA

MAAP Ministry of Agriculture and Fisheries MD Ministry of Defence AFSSA French Agency for Food Safety NRL National Reference Laboratory DGAL Directorate-General for Food SDSPA Sub-Directorate for Animal Health and Welfare SRAL Regional Food Services DRAM Regional Directorate for maritime affairs EDE Department livestock body DDAM Departmental Directorate for maritime affairs IFREMER National Institute for Sea Fishing Research SSA Health Department of the armed forces


21

Competent authorities

The Central Competent Authority (CCA) for animal health is the DGAL. The SSA has responsibility for animals held by the armed forces.

Within DGAL, two of the four offices of the SDSPA are responsible for aspects of controls:

• the Office for animal health (contagious and emerging diseases, animal health policy and epidemio-surveillance); and • the Office for animal identification and movement control (BICMA).

At local level, 100 Departmental Directorates (SRALs) operate under Department prefects. Twenty-two SRALs have been designated responsibility for co-ordinating the DDSV in their regions. The Regional Veterinary Inspectors (VCR) are based at the DSV, but have additional responsibility for their region, such as: development and updating of contingency plans; organisation of simulation exercises; and training courses for staff.

The staff of the DDSV comprise veterinary inspectors (civil servants); contract veterinary inspectors; approved veterinarians (VS); and technical/administrative staff.

Approved Veterinarians (VS) are suitably qualified veterinary practitioners authorised by the prefect in accordance with the "rural code" to carry out certain approved tasks on animal holdings and in assembly centres. The VS operate under the authority and direction of the director of the DDSV for tasks allocated by the State. Farmers choose their VS and the VS receive payment directly from farmers/operators or directly from the State for such duties performed on holdings/assembly centres. The rates of payment are fixed by the administration.

Herd owners form Departmental animal health defence co-operatives (GDS) funded by contributions from farmers to provide education and complementary financial support to members in the event of disease outbreaks, and contribute in combating certain diseases.

Holding registration, animal identification and movement controls

The office for animal identification and movement control (BICMA) defines the rules and enforcement instructions for identification and registration.

Registration of bovine, porcine, ovine and caprine holdings is managed under national legislation by the Departmental holdings establishments (EDEs), and approved by individual Departmental prefects. The functions delegated to the EDEs are:

• the registration of holdings; • to provide the means of identification to herd owners and deliver passports; • to input identification and movement data in local databases for onward transmission to the national database (BDNI).

In addition, the EDEs have responsibility to inform animal holders of their obligations and to undertake a first level control on compliance. They must notify the DDSV of any non-compliance detected.

The central database is managed by the MAAP- EDE. The CDB is accessible at SRAL and EDE levels.


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Each year, the CDB, via the EDE, requests herd owners to update the inventory of animals by 1 January. Ear tags are not provided if the keeper does not return the completed inventory.

The DDSV and DDAF exercise supervision over the EDEs and are responsible for the second level of official control on holdings.

All holdings, except for poultry, are included in the CDB. Pig movements are included in the database since 2007. Sheep and goat movements were due to be included by April 2009.

The following table shows the number of holdings and registered animals:

Number of holdings Number of animals

Cattle 241,000 20 000,000

Goats 40, 000 880,000 (>6 months)

Sheep 140,000 6,040,000 (>6 months)

Controls at holdings are undertaken by SRALs (health, identification, traceability and specific aspects of cross-compliance) and DDAF (certain aspects of cross-compliance and eligibility for Common Agricultural Policy premia payments). DGAL has standardised inspection checklists to ensure harmonised controls.

For cattle, at least 5% of holdings in each Department are inspected annually for the purposes of traceability, cross compliance and eligibility for premia payments. These holdings are selected based on risk analysis (75%) and randomly (25%). At least 20% of assembly centres and markets are inspected for traceability.

For pigs, the minimum frequency of visits to holdings is not defined. These controls fall under the animal health programme and are based on risk analysis.

Animal health controls

The information system of the Directorate General for Food (SIGAL) contains detailed animal health information on holdings.

Commission Decision 2003/467/EC recognises France as officially free from TB, brucellosis (Brucella abortus) and enzootic bovine leucosis (EBL). 64 Départements are recognised as being officially brucellosis (Brucella melitensis) free (Commission Decision 93/52/EC).

Monitoring and eradication programmes are in place for brucellosis (Brucella melitensis) in sheep and goats (compulsory), Aujeszky´s disease in pigs (compulsory) and Infectious Bovine Rhinotracheitis / Infectious Pustular Vulvovaginitis in cattle (voluntary). For cattle, compulsory eradication programmes are in place in respect of tuberculosis, brucellosis and enzootic bovine leucosis.


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Approved Veterinarians (VS) visit all bovine holdings at least once in every two years. The VS may take samples at animal holdings. The SRAL decides on any follow-up action. In suspect cases, the VS must inform the DDSV for follow-up. Laboratory results from the LDAs are returned to the DDSV (and copied to VS). Results are entered in SIGAL. VS have indirect access to SIGAL as regards relevant holdings.

During the 2006-2007 campaign, VS visited all bovine holdings. From 2008, the scope of visits has been widened to cover general risk management on holdings. Note de Service N2007-8272 of 5 November 2007 established compulsory biennial health inspections on cattle farms. Such inspections, to be carried out by VS cover the field of veterinary public health (Regulations (EC) Nos 183/2005, 852/2004, 853/2004 and 882/2004). The aim is to help the DDSV to plan official controls according to the health risk posed by farms and increase dialogue between VS and farmers on veterinary public health issues. Results are entered directly into SIGAL. In 2008 101,822 visits were made to bovine holdings.

Contingency Plans.

Alerts from the DDSVs are received by the Centre for the operational surveillance of alerts which is part of the Mission for health emergencies (MUS) and the SDSPA depending on the circumstances. Alerts to the MUS give rise to triggering of contingency plans. Actions taken at national level are prepared or monitored by the MUS, drawing from expertise within DGAL or from external experts.

The prefect approves Departmental contingency plans prepared by the SRAL. In the event of an emergency, the prefect has the authority to invoke support from the police, firemen, public works, and other civil organisations. For the implementation of the CP, he delegates most of his tasks to the director of the SRAL. A Departmental committee for animal health and protection evaluates the local CP and co-ordinates the awareness campaigns for epizootic diseases.

In the event of a disease outbreak, the prefect establishes the Local Disease Control Centre (LDCC) in the prefecture. The main body responsible for dealing with a disease outbreak is the DDSV, assisted by other relevant governmental services. The LDCC provides the permanent command centre (PCF). In addition, an operational command centre (PCO) is created to serve as an operational unit near to the outbreak.

Updated CPs are in place for Avian Influenza (AI), Newcastle disease, Foot and mouth disease (FMD), Bluetongue and swine fevers. During 2007, a total of 91 simulation exercises were undertaken covering these diseases. For 2008, 87 simulation exercises were carried out for these diseases.

Laboratories

The National Reference Laboratory, both for FMD and Classical Swine Fever (CSF) is AFSSA. For FMD, analysis is carried out at Maison-Alfort. For CSF, analysis is carried out at Ploufagran (serology and virology). Laboratories in the Departments are the responsibility of the General Committee of the Department. Sixteen Departmental laboratories are approved for serology for CSF, eight for CSF (virology) and five for FMD (serology).


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The NRL for bluetongue (serology) is CIRAD-EMVT and AFSSA, Maisons-Alfort (virology). In addition, 57 laboratories are approved for routine virology testing (PCR) and 45 for routine serology testing (ELISA). Approvals are reviewed every five years.

The laboratories of IFREMER undertake analyses of shellfish products on behalf of the DRAM. The NRL is located at La Tremblade.

In addition to the laboratories for official control, other laboratory networks are operated by private bodies for milk and breeding.


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2.2 Control system for food of animal origin

DGAL(RASFF contact point)

SlaughterhousesPrimary production

Processed products-animal originCatering

Distribution and transportEgg production and marketing

Fishery products


SRAL

DDSV

RegistrationApprovalControl

DRAM

DDAM

RegistrationApprovalControl

DGCCRF(RASFF contact

point)

DRCCRF

UDCCRF

DGS

Additives, contactmaterials,

irradiated foods,egg marketing and

traceability

Social catering,general hygiene,

foodborneinfections andwater quality

DRASS

DDASPrefect managescoordination at

Department level

MD

SSA

DGAL Directorate-General for Food RASFF Rapid Alert System for Feed and Food MD Ministry of Defence DGCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression DGS Directorate General for Health SRAL Regional Food Services DRAM Regional Directorate for maritime affairs DRCCRF Regional Directorate for Competition, Consumer Affairs and Fraud Repression DRASS Regional Directorate for Health and Social Affairs DDAM Departmental Directorate for maritime affairs UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression DDASS Departmental Directorate for Health and Social Affairs SSA Health Department of the armed forces


DGAL has exclusive competence as CCA in relation to controls at primary agricultural production and at slaughterhouses and primary shellfish production. DGAL is responsible at central level for: transposition of relevant legislation; co-ordination of supervision of approved establishments; and import and export controls in the veterinary and public health field.

Both DGAL and DGCCRF are responsible for the implementation of Regulation (EC) No. 2295/2003 (marketing standards for eggs).


26

The national surveillance programme for salmonella in poultry flocks is run by DGAL and covers the control and management of Salmonella Enteritidis Hadar, Infantis, Virchow and Typhimurium in breeder flocks Gallus gallus for future laying hens and broilers. It also provides for control Salmonella Enteritidis and Typhimurium in laying hen holdings. Systematic monitoring of all serotypes takes place in these holdings. Turkey production is covered from January 2010.

The following table provides an overview of competences:

DGAL DGCCRF DGS

Primary agricultural production Primary shellfish production Slaughterhouses Egg production and marketing Production and processing –animal origin Storage Transport Distribution and direct sale Catering Contaminants Residues Fishery products and shellfish

Additives Contact materials Irradiated foods Egg marketing Traceability Distribution and direct sale

Canteens in health and social establishments Foodborne infections Water quality

RASFF contact point RASFF contact point

Co-ordination between the CAs is assured through protocols and the MANCP.

Registration and approval of establishments

All food businesses must be registered. Establishments are registered in the SIGAL database (of DGAL) and in the SORA database (of DGCCRF).

The Prefect is the authority for the grant and withdrawal of approvals. Assessment of applications is undertaken by the DDSV or DDAM (to whom authority may be delegated). Requests for approval are made to the SRAL or DDAM. Following assessment and an initial inspection, the establishment may be given conditional approval for a period of up to 3 months. This approval is confirmed following an on-site inspection. All approved establishments are included in SIGAL and published in the official bulletin of MAAP and on the MAAP website:

http://agriculture.gouv.fr/sections/thematiques/alimentation/securite-sanitaire/production-transformation




27

Overview of establishments

Category Number Direct sale of which commercial restaurants canteens

303,300

105,000

91,265Approved establishments Warehouses Slaughterhouses Poultry slaughterhouses Cutting plants Game processing establishments Processing plants Fishery products (+escargots) Shell fish

26,088

3,900319

2,900(of which

1,400 on-farm)

1,72049

8,5003,4005,300

Total 329,388

A new Decree was in preparation to introduce the possibility of a single registration of establishments for all official purposes (including company law, tax and food safety). Official controls and inspection at establishments

Controls are undertaken by DGAL, DGCCRF and DGS.

DGAL

DGAL has exclusive competence in relation to slaughterhouses, primary agricultural production and primary shellfish production. DGAL has primary responsibility for controls in approved establishments for meat and meat products. Permanent controls in slaughterhouses are carried out by 217 official veterinarians and 1,206 veterinary auxiliaries. Audits on these establishments are generally undertaken by the DDSVs.

To ensure harmonised controls, there is a national reference point for slaughterhouses and a network of specialists (attached to the regional SRALs) was established in 2007. These experts assist SRALs and audit establishments.

Two vademecums and checklists for slaughterhouses are in use. For the other sectors, 13 checklists and 12 vademecums are in use and 2 checklists and 3 vademecums were under development.


28

As part of the quality system underway since June 2005, the NERGAL database operates at 10 slaughterhouses and captures information such as identity and results of ante and post mortem checks. The system does not interface with SIGAL. Note de Service N2007-8328 of 28 December 2007 extends this project as a means of improving the effectiveness of controls.

SIGAL is used for planning inspections and monitoring execution of the plan by the DDSVs. A risk analysis tool is in place to define a risk category for each type of approved establishment. This categorisation is to be supplemented by the definition of additional risk criteria applicable to each specific establishment. Both of these risk criteria are defined nationally in a DGAL instruction. The frequency of inspection is determined on a common basis throughout France. The BNEVP has responsibility in cases where cross-Departmental issues arise.

Establishments visited in 2007

Category of establishment Number of establishments visited by SRALs in 2007

Approved establishments 29,732 Commercial restaurants 24,235 Other outlets (including distribution etc)

29,786

Canteens 25,365 Transport 13,147

The control management of food poisoning outbreaks is carried out by DDASS in collaboration with the other agencies.

Salmonella risk in the table egg sector

A baseline study organised by the European Food Safety Authority (EFSA) on the prevalence of Salmonella in laying hen flocks of Gallus gallus showed a relatively low prevalence in France of Salmonella Enteritidis (3.9%) and Typhimurium (4.2%).

France has had a national surveillance programme for Salmonella in poultry flocks since 1991 (adapted in line with Regulation (EC) 2160/2003).

DGCCRF

Controls are undertaken as described in Part 1.

Co-ordination at Department level The prefect may formalise co-ordination between the Departmental services by establishing a "MISSA" (Inter-service mission for food safety), comprising DDSV, DDAM, UDCCRF and DDAS, or, alternatively, may nominate one of the directors of the four Departmental services to co-ordinate activities through a competence centre or an inter-service food safety group.


29

The outline of the national control and surveillance programme is drawn up at central level and is subsequently adapted and implemented in each Department by the responsible authorities. In some Departments, "competence centres" have been created in order to co-ordinate the performance of controls by the services concerned and the generation of their results.

Official controls on identification mark and traceability

Traceability comes within the competence of DDSVs, DDAMs and UDCCRF. DGAL is responsible for the control of health marks.

National control plans involving both DGAL and DGCCRF are in place for beef, fish and eggs. DGCCRF has a national programme to control both traceability and labelling in the meat industry (abattoir, cutting, minced meat, meat preparations establishments, retailer, restaurants, markets, butchers and supermarkets). The frequency and number of visits are fixed at Department level on the basis of minimum requirements set by the central services.

Laboratories

NRLs

The National reference laboratory for monitoring bacteriological and viral contamination of live bivalve molluscs is the IFREMER in Nantes. The NRL for marine biotoxins is the Laboratory for study and research in the quality of food and food products (LERQAP) of AFSSA, in Maisons-Alfort. The AFSSA laboratory in Ploufragan, associated with LERQAP, is NRL for salmonella in poultry farming and campylobacter. AFSSA LERMVD, LERAP, and LERQAP are designated NRLs for certain other analyses.

Two of the units of LERQAP (AFSSA, Ploufragan) deal with issues concerning eggs and egg products. The unit for the quality of poultry and pig products is the NRL for Salmonella in poultry farming and is accredited by COFRAC.

DGAL

The approved laboratory network for microbiological analyses, and in particular for salmonella in food and feedstuffs and on holdings consists mainly of the Departmental laboratories. All approved laboratories carrying out official salmonella analysis are accredited by COFRAC. The laboratories receive samples from the DDSV as well as from third parties.

Private laboratories participating in salmonella analysis for the on farm control programme must be accredited by COFRAC and are authorised by the authorities to undertake analyses for the holdings. They also participate in the same ring tests organised by the NRL for approved laboratories.

Surveillance of shellfish production zones is undertaken by the 11 laboratories of IFREMER are approved by MAAP.

DGCCRF (SCL)

The DGCCRF's network of laboratories merged with the DGDDI's network as the SCL on I January 2007.


30

2.3 Control system for imports of animals and food of animal origin

DGAL DGDDI

BIPs

Inter-RegionalDirectorates

(10)

Protocol on national cooperation

Regional DirectoraTES

(40) Local Protocols on cooperation

Supervision and audit

DDSV

Administrative reporting

Importconsignments

Departmental Analytical Laboratory

DGAL Directorate-General for Food DGDDI Directorate-General for Customs and Indirect Taxation SRAL Regional Food Services BIP Border Inspection Post DDSV Departmental Directorate for Veterinary Services


The CCA for import controls is DGAL of MAAP. Customs (DGDDI) cooperates with DGAL. A protocol on national co-operation between their services is in place. This is complemented by protocols on local cooperation.

Within Customs, the unit for information and planning of controls (CROC) gathers and analyses information in order to target specific controls. These targeted controls may be undertaken by general customs services or by its specialised Regional Investigation Service (SRE).

DGAL supervises and co-ordinates the Border Inspection Posts (BIPs) and liaises with other agencies, primarily Customs. It provides technical support to the BIPs, manages the national database for import documentation "IMPADON", and is responsible for monitoring the TRACES system. It also holds regular meetings with BIP staff including an annual two day meeting jointly with Customs. DGAL also operates an intranet forum for BIP staff. "IMPADON" is also used to disseminate alerts.

In 2008, the BIPs processed 9,810 consignments of live animals and 62,338 consignments of animal origin products (70% fish/shellfish).


31

A total of 100 staff (50 FTE) are assigned to BIPs.They have administrative police powers and may institute criminal proceedings. The BIPs are under the authority of DGAL for the technical aspects of their activities of the DDSV for budgetary and administrative purposes. The individual BIPs come under the responsibility of the relevant Departmental services, (SRAL) in relation to staffing, budgetary and operational management. There is a direct chain of command from the central CCA to the BIPs, via the SRAL.

Import controls

No consignment requiring veterinary control may be assigned a customs destination without having been released by the BIP. Pre-notifications from importers or their agents are accepted via TRACES. Customs verify manifests to ensure that all consignments subject to veterinary check are routed through the BIPs, all of which also have access to the manifests. Inspection fees are collected by Customs.

Declarations are entered using the Customs computerised system DELTA. There is a systematic customs check for the presence of CVED. In DELTA, the relevant CN codes are linked with the requirements for veterinary checks contained in the positive list of Commission Decision 2007/275/EC. The selection of consignments subject to veterinary checks is performed by DELTA which identifies and flags the requirement for veterinary checks on those consignments destined for free release. DELTA is also used to select consignments for physical and documentary checking based on Customs criteria e.g., CN code, origin, value, importer and destination. Customs have responsibility for checks on personal baggage, pets and prevention of illegal imports. Importation without declaration is an offence under both the customs code and the "rural code".

A monitoring plan for imported consignments as required in Annex II to Regulation (EC) No 136/2004 is drawn up annually at central level. The detailed implementation of sampling for residues, hormones and pathogens is determined by the individual BIPs taking into account the guidance from central level. Each BIP has a target to carry out laboratory checks on 3% of the consignments using nationally developed risk factors.

Audit of the BIPs

The office for third country imports undertakes a technical audit on each BIP at least every 2 years. 15 such audits were scheduled in 2009. Audit reports are sent to the BIP and to the SRAL. A vademecum, including standard checklists, is used for the audit of BIP facilities and their procedures.

Listed BIPs

The listing of approved BIPs in France may be found at:

http://ec.europa.eu/food/animal/bips/approved_bips_en.htm

http://ec.europa.eu/food/animal/bips/approved_bips_en.htm


32

Laboratories

The BIPs use the Laboratories approved by MAAP for analyses.


33

2.4 Control system for feedingstuffs and animal nutrition

DGAL DGCCRF

SDSPA

Office for inputsand public health

in animalproduction

DDSVs(100)

SRAL(22)

Sub-Direction foragricultural andfood products

Office for productsof animal origin

UDCCRF(101)

MHS AFSSAMAAP MEIE

Consultation/scientific advice

Farms and establishmentsproducing feedstuffs

InspectionsApproval

Registration

Establishments producingmedicated feedstuffs

Farms producingfeedstuffs and

medicated feedstuffs

ANMV

approval

approval

inspectionsinspections

controls

controls

NRLs andapproved

laboratories

Analyses

Analysis

MAAP Ministry of Agriculture and Fisheries MHS Ministry of Health AFSSA French Agency for Food Safety MEIE Ministry of Economy, Industry and Employment DGAL Directorate-General for Food DGCCRF Directorate General for competition, consumer affairs and fraud repression SDSPA Sub-Directorate for Animal Health and Welfare ANMV French Agency for Veterinary Medicinal Products SRAL Regional Food Services UDCCRF Department Directorate for Competition, Consumer Affairs and Fraud Repression


34


A formal division of responsibilities between DGAL and DGCCRF was established by an inter-service note as follows:

DGAL DGCCRF

Authorisation and registration On-farm production Medicated feeds Use of category 3 material in feed Primary feed producers Salmonella (on farms)

Conformity of composition Labelling Use of prohibited substances (antibiotics, anabolics) Salmonella (in commercial establishments) Absence of animal proteins

The MHS is consulted on legal texts and on guides to good practice drawn up by MAAPand MEIE. A specialist feed committee in AFSSA delivers scientific opinions on legal texts, guides to good practice and specific cases.

According to the protocol for co-operation in the field of hygiene (Note de Service 2007-07), the DGCCRF is responsible for all FBOs not previously covered by Directive 95/69/EC but which fall within the scope of Regulation (EC) No 183/2005, except for primary production and production of feed on farms which are under the responsibility of DGAL. Competence for the transport of feed materials is shared between DGAL and DGCCRF.

MAAP

Within DGAL, the "Office for Inputs and Public Health in Animal Production" of the SDSPA has primary responsibility for feed hygiene, including: registration and approval of establishments; medicated feedstuffs; control plans; management of alerts in association with the "Mission for health emergencies (MUS)" and guides to good practice. Three staff are assigned to this area. The office for third country imports has responsibility for feed imports. In addition, two specialist feed inspectors in the BNEVP carry out investigations.

There are 20 experts on feed controls at regional level who meet with the central level at least twice per year.

MEIE

Within DGCCRF, the office for "products of animal origin" has responsibility for the quality and labelling of feedstuffs and for additives. Three staff are assigned to this area. The UDCCRF undertakes inspections at feed establishments with a view to consumer protection and suppression of fraud. In addition, targeted controls and investigations may be undertaken by DNECCRF.


35

Each SRAL and UDCCRF has appointed a contact person for controls on feed.

Registration and approval of establishments and intermediaries

France produced an estimated 22,560 million tonnes of compound feed in 2008. There were an estimated 404 780 primary producers of feed, 277 registered feed businesses, and 527 approved establishments (2009). No mobile-mixers have been approved.

DDSVs are responsible for the registration and approval of establishments and intermediaries (E/I). The applicant E/I are provisionally approved or registered while their file is being dealt with and are subject to on-the spot inspections before the final approval is granted by the DDSV. E/I seeking registration may also be visited before being registered.

The ANMV authorises establishments manufacturing medicated feedingstuffs, while the DDSVs approve farms producing medicated feed.

Hygiene inspections of feed mills are performed by inspectors of DDSV.

The procedures to be followed for registering and approving FBOs according to Regulation (EC) No 183/2005 are described in a Decree of 23 April 2007 and in Note de Service N2007-8257 of 22 October 2007.

As regards the registration of FBOs, those that were under the scope of Regulation (EC) No 183/2005, are required to submit a declaration containing certain information relating to the production process and types of materials used. The procedures are set down in an amended version of the Decree of 28 February 2000, which originally transposed Directive 95/69/EC. A simplified procedure (based on Siret numbers) was envisaged for the registration of other FBOs (primary producers).

The SORA system (DGCCRF) contains registered establishments (not requiring approval). Other categories, including on-farm mixers, are in the SIGAL system (DGAL). Both databases use the "Siret" reference number of establishments (National Institute for Statistics and Economic Studies -INSEE).) which allows cross-checks.

Official controls

Each year, national plans for inspection and sampling are drawn up separately by the DGAL and the DGCCRF, following inter-service co-ordination. The feed control programmes include imports of feedingstuffs. The co-ordination of the different sampling programmes at central and Departmental levels operates according to the principles laid down in the inter-service note.

For both inspection services, the type of analysis for each sample is determined by the inspector, taking into account the number of samples assigned to the Department and the feed material concerned. After reception of the sample by the laboratory and the evaluation of the sampling report, decisions on further testing on different substances are taken in consultation with the Departmental administration.


36

DGAL carries out controls on farm, in establishment and at import in the following areas:

• Holdings

• Imports

• In establishments using ABP for the manufacture of feed

• Other establishments subject to approval and registration

DGCCRF undertakes controls at production and distribution levels in relation to composition, labelling and undesirable substances. As regards DGCCRF, controls are undertaken on first placing on the market (primary production not included). The SORA system lists some 7,200 establishments each of which has been assigned a risk category for control purposes.

A total of 4,013 inspection visits were carried out in 2007 of which 2,519 by DGAL, and 1,494 by DGCCRF (2,045 at industrial producers and 1,968 on-farm). In addition, a further 1,593 controls on labelling were undertaken by DGCCRF. All farms registered in the SIGAL system are due to receive a risk assessment rating to determine control frequency by DDSVs.

Each SRAL and UDCCRF is responsible for the implementation and co-ordination of the official control in its Department.

Newly registered establishments in accordance with Regulation (EC) No 183/2005 which had not been covered by Directive 95/69/EC are inspected by the DGCCRF to check for prohibited animal proteins.

For 2007, the DGCCRF and DGAl carried out some 10,790 analyses (undesirable substances 3,758, Prohibited substances 4,151, Composition 2,330 and Additives 551).

Each plan (DGAL and DGCCRF) defines the number of samples to be taken in the relevant region. Details of samples taken are registered in the SORA and SIGAL systems (as well as results in cases where the laboratory is connected to SIGAL).

Imports

The CCA has designated 19 entry points, which generally correspond to the Border Inspection Posts (BIPs) for live animals and animal products. The entry points are responsible for performing documentary, identity and physical checks on feed of non-animal origin. Supervision of the process is carried out by a joint committee at central level, and specific protocols on collaboration at the entry points, provide the framework for import controls.

Notification of any import of feedingstuffs has to be made in writing to the SRAL at least 24 hours before arrival. A minimum number of samples to be taken from imported products is defined by the central services when drawing up the annual control programme.

Laboratories

Analyses are undertaken by NRLs and by approved laboratories of DGAL and DGCCRF.


37

In all, 16 laboratories were involved in the 2007 and 2008 programme. The SCL laboratory in Rennes carries out most of the official analyses of feed samples and plays a role similar to a national reference laboratory for this purpose. It is accredited to ISO 17025 and has an advisory role on the analytical procedures in place in the other laboratories working on this area, including those involved in the own-control programmes.

The SIGAL system is used to record the samples to be collected by each department- DDSV and the dates when these were taken and sent to the laboratory. Laboratories qualified to do so, enter the results of the analyses directly into the SIGAL system. For DGCCRF, results are entered in the IRIS system.

In 2007, some 10,790 analyses were carried out. For 2008, the SCL laboratory at Rennes undertook analysis of 2,119 samples (for DGCCRF).


38

2.5 Control system for Transmissible Spongiform Encephalopathy (TSEs)/ Animal By-Products (ABPs)

TSEs

DGAL(SDSPA) DGCCRFAFSSA Scientific advice

SRAL

DDSV

BNESSTDatabase

MSI

ApprovedLaboratories

Samples for analysis

Registration and results

AFSSALyon(NRL)

ConfirmatoryTesting

results

DRCCRF

UDCCRF

Slaughterhouses (including SRM)Cutting Plants (including SRM)

Rendering Plants

Retail (SRM)Beef Labelling/Traceability

Feed (Processed Animal Proteins)

Controls Controls

AFSSA French Agency for Food Safety DGAL Directorate-General for Food SDSPA Sub-Directorate for Animal Health and Welfare DGCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression NRL National Reference Laboratory BNESST National TSE Database SRAL Regional Food Services DRCCRF Regional Directorate for Competition, Consumer Affairs and Fraud Repression UDCCRF Directorate General for Competition, Consumer Affairs and Fraud Repression SRM Specified Risk Material


39


DGAL

At central level, BSE epidemio-surveillance is the responsibility of the Office for Animal Health of SDSPA of DGAL. Two staff are assigned to this area. The office for slaughterhouses and cutting plants in SDSSA ensures implementation of Specified Risk Material (SRM) requirements in slaughterhouses. The office for Inputs and Public Health in Animal Production in SDSPA is responsible for ABP controls. The sub-Directorate for horizontal policies (SDPPST) is responsible for the approval of laboratories and management of the BNESST database (see below).

DGCCRF

In 2007, DGCCRF undertook some 11,200 controls covering-

• prohibition on the marketing of SRM;

• beef labelling (including traceability and indication of origin);

• prohibition on the use of processed animal proteins (PAP) and certain animal fats in animal feed.

Epidemio-surveillance

The national herd includes some 11.5 million bovines over 24 months old. The number of positive bovine BSE cases decreased from 274 in 2001 to 8 in 2008.

Surveillance programmes are implemented by the DDSVs. Samples taken at slaughterhouses and at rendering plants are allocated a unique number and sent to the authorised laboratory. In the case of rendering plants, samples are taken by authorised veterinarians (VS). The sample identifier and the result of the analysis are entered into the national TSE database, BNESST, which also contains data from BDNI, the national identification and registration database. Positive results give rise to confirmatory testing at the NRL and an automatic alert to DGAL. Positive confirmatory tests are also notified to DGAL. In the case of non-negative results to the post mortem rapid test, the carcase is destroyed and the NRL undertakes confirmatory analysis.

The BNESST database is used by veterinary services in the slaughterhouses to obtain the results of testing. It is also used by the DDSVs and by DGAL centrally, to monitor the implementation of the programme.

Updated epidemiological information is available at:

http://agriculture.gouv.fr/sections/thematiques/sante-protection-animaux/maladies-animales/esb/encephalopathie-spongiforme-bovine

Surveillance programmes are also in place for scrapie. In 2008, 74 cases of scrapie in sheep were observed in a sheep population (over six months) of 6,040,000 and 12 cases of scrapie in goats in a population of 880,000 (over 6 months).

Specified Risk Materials (SRM)

DGAL has exclusive competence for controls in slaughterhouses and cutting plants and shares competence with DGCCRF for controls in supermarkets and butchers.




40

Some 1,890 veterinary service agents and 501 contract veterinarians are assigned to slaughterhouses. The training of these agents includes a module on the handling of by-products and TSE.

The Ministry issued instructions in June 2006 (Note de Service N2006-8145) reiterating SRM requirements and launching an audit of all sheep and goat slaughterhouses based on a standard checklist. Results (summarised in Note de Service N2008-8173) indicated a high degree of compliance. AFSSA is due to give an opinion on the outcome.

Total feed ban

Inspections and sampling carried out by both DGAL and the DGCCRF in relation to the feed ban are based on a risk-assessment.

Laboratories

The NRL for TSEs is the Research Laboratory for bovine pathology and meat hygiene of AFSSA based in Lyon (AFSSA LERPBHV). Rapid tests used in the TSEs surveillance programme must be carried out in one of 56 Departmental laboratories authorised for this purpose (of which 43 approved for scrapie). Authorised laboratories must be accredited by the French accreditation body and perform successfully in a ring test carried out by the National Reference Laboratory (NRL). Authorisation is granted by DGAL and must be renewed on an annual basis.

Confirmation tests at the NRL are carried out using the Western blot technique and, if necessary, immunohistochemistry. Tests to distinguish scrapie from BSE are also carried out.

The SCL laboratory at Rennes is the NRL for detection of PAP in animal feed on behalf of DGCCRF.


41

ABP

DGAL

Office forslaughterhouses and

cutting plants

SRALs

DDSVs

MEIE MHSME

IncinerationCo-incineration

Composting

MAAP

DGPRDGCCRF DGS

AFSSA

Scientificadvice

BIPs

Imports

SDASEISDSSA

Establishments

Approval/Controls

DRIRE

Approval and control

Approval/Controls

Livestock office

Controls on the reconciliation of input/output

Office for inputs and publichealth in animal

production

SDSPA

AFSSA French Agency for Food Safety MAAP Ministry of Agriculture and Fisheries MEIE Ministry of Economy, Industry and Employment MEEDDM Ministry for Ecology, Energy, Sustainable Development and the Sea MHS Ministry of Health DGAL Directorate-General for Food DGCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression DGPR Directorate General for the prevention of risk DGS Directorate General for Health SDSSA Sub-Directorate for Food Safety SDSPA Sub-Directorate for Animal Health and Welfare BIP Border Inspection Post SRAL Regional Food Services DRIRE Regional Directorate for Industry, Research and Environment SDASEI Sub-Directorate for European and international health matters


42


At central level, in DGAL, the office for Inputs and Public Health in Animal Production (OIPHAP) in the SDSPA is responsible for the control and supervision of most ABP aspects. Two staff are assigned to this area. An additional staff member of the Sub-Directorate for European and international health matters (SDASEI) is responsible for import controls in the ABP sector. The office for slaughterhouses and cutting plants in SDSSA is responsible for the oversight of implementation of SRM requirements in slaughterhouses. BNEVP undertake targeted controls on ABP.

Four other Ministries have responsibilities as follows:

• MEIE/DGCCRF have joint legislative responsibility with DGAL in relation to animal feed. DGCCRF services carry out controls, in liaison with DGAL, and also deal with ABP issues arising from investigations.

• Customs (DGDDI) undertake a documentary check after the checks by the veterinary services. Physical checks may also be undertaken.

• Ministry for Ecology, Energy, Sustainable Development and the Sea (ME), Directorate for the Prevention of Risks (DGPR), is responsible for some aspects of the ABP Regulation, in particular: agri-food industries and establishments processing ABP considered as "classified premises" for environmental purposes; the authorisation of some establishments (under environmental legislation); and the monitoring of waste products.

• DGS of MHS has joint legislative responsibility with DGAL in relation to animal feed.

Approval of ABP plants and other premises

The DDSVs are responsible for the approval of ABP plants and other premises handling ABP and a centralised list of approved plants is maintained by DGAL. This listing is available on the MAAP website:

http://agriculture.gouv.fr/sections/thematiques/sante-protection-animaux/sous-produits-animaux

Establishments approved and authorised under Regulation (EC) No 1774/2002 are included in the SIGAL system.

The Regional Directorates for Industry, Research and Environment (DRIREs) have a co-responsibility in the approval procedure for incineration, co-incineration plants and composting plants.




43

The following ABP establishments have been approved:

Type of establishment Number approved

Intermediate 160

Storage 63

Category 1 and 2 14

Category 3 51

Pet food 44

Technical 57

Incinerator 6

Composting 11

Users and collection centres 469

Official controls

Most of Category 1 and 2 materials are collected by the private system for rendering (SPE), which deals with: TSE animals; specified risk materials (SRM); fallen animals or groups of fallen animals over 40 kg of all species; and carcasses and parts of carcasses seized for health reasons at slaughterhouse. Material collected when treating waste water from Category 1 processing plants is collected by Category 1 processing plants.

Collection of international catering waste (ICW) is arranged either by the port authorities or the catering companies. The responsibility for checks to ensure proper disposal of kitchen waste from international means of transport, lies with either the Department veterinary service. This task may be delegated to the nearest BIP.

DGAL has produced instructions, inspection guides and checklist for the inspection of ABP establishments for use by the Department and Region services. The Regional Directorates for Industry, Research and Environment (DRIREs) have responsibility for the control of certain incineration, co-incineration plants and certain composting plants.


44

The SIGAL information system includes ABP controls. The frequency of inspection at ABP plants is determined by the individual DDSVs.

SIGAL is used to transmit data on fallen animals and on the flow of category 1 material to DGAL. This facilitates controls on rendering establishments.

Since July 2006, control of the reconciliation of inputs/outputs/traceability by rendering operators handling fallen animals (collection and processing) is undertaken by the “livestock office” in the context of State funding for the establishments. The office must notify SRAL of any discrepancies.

Laboratories

The SCL laboratory at Rennes is the NRL for detection of PAP in animal feed on behalf of DGCCRF.


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2.6 Control system for veterinary medicinal products (VMP) and residues

VMP

AFSSA MHSMAAP

DGAL(SDSPA)

DGS

DRASS(26)

Mixed Wholesaleestablishments

(on behalf of ANMV)

PHISP

RetailPharmacies

ANMV(risk assessment

and management)

MEIE

VMPs and VMPManufacturersWholesalers

Authorisation and control

Farms Veterinarypractitioners

DDSVs

controls

Producer Groups

Approval and control

Production ofmedicated feed

and authorisationof on farmproduction

Controls

Controls

Authorisation

Manufacturers ofmedicated feed


in animalproduction

Producer groups

MAAP Ministry of Agriculture and Fisheries AFSSA French Agency for Food Safety MEIE Ministry of Economy, Industry and Employment MHS Ministry of Health DGAL Directorate-General for Food SDSPA Sub-Directorate for Animal Health and Welfare ANMV French Agency for Veterinary Medicinal Products DGS Directorate General for Health DRASS Regional Directorates for Health and Social Affairs VMP Veterinary Medicinal Products PHISP Public Health Pharmacy Inspectors


The Office for Inputs and Public Health in Animal Production of MAAPand the "Office for medicinal devices and other health products" of the "Practices and health product policy" sub-directorate of DGS (MHS), are responsible for legislation.

The National Agency for Veterinary Medicinal Products (ANMV), of AFSSA is inter alia responsible for the marketing authorisation of veterinary medicinal products (VMP).


46

It participates in the drafting of the regulatory texts on VMP and the management of the pharmacovigilance system, and performs inspection on manufacture, wholesale distribution and imports. MAAPand MHS oversee the role of AFSSA in this sector.

Authorisation of VMP

ANMV is responsible for risk assessment and risk management in the field of VMP from production until the placing on the market, and grants marketing authorisation for VMP following a scientific assessment. It is also responsible for the authorisation of veterinary pharmaceutical establishments. Approximately 3,000 VMP with marketing authorisation are listed on the ANMV website.

Official controls on marketing/use

Wholesalers may supply VMP only to certain classes: pharmacists, veterinary practitioners and producer groupings approved by the region prefect. The only VMP which may be sold outside this circuit are antiparasitic drugs for external use on pets. The distribution and marketing of such products is subject to control by DGCCRF.

Approved agricultural co-operatives are allowed to distribute certain VMP to their members for the purpose of preventing animal diseases. Delivery is under veterinary supervision or by the pharmacy of the co-operative. VMP used by approved groupings are subject to a specific regulation and the purposes of use are limited by law. VMPs for use in food producing animals are available only on prescription by a veterinary practitioner. A veterinarian is designated to oversee the holding programme and is responsible for prescribing medications.

The division of responsibilities for control of VMP between MAAP, MHS and MEIE is defined by a Circular issued in 2003.

There are designated VMP co-ordinators in the SRALs with the following tasks:

• controls on the use of VMP on farms;

• inspection of veterinary practices;

• approval and inspection of producer groups;

• inspection of producers and distributors of medicated feed;

• approval and inspection of medicated feed production on farms;

• inspection of pharmacies (in cooperation with Public Health Pharmacy Inspectorates (PHISPs) in cases of targeted inspections)

Controls on the use of VMP are included as part of cross compliance inspections. At national level, instructions for Good Manufacturing Practice (GMP) are used in the feed mills and by the inspectors.

Good Manufacturing and Distribution practice guidelines for medicated feed were published in February 2007.


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The following table shows the number of establishments in operation in 2007:

Type of establishment Number

Manufacturer 97

Wholesale 207(including 35

VMP only)

Producer of medicated feed and/or Distributor of medicated feed

310

The decentralised services of MHS, have Public Health Pharmacy Inspectorates (PHISP) attached to the DRASS in each of the 26 regions who carry out controls in the VMP sector.

The PHISP carry out inspections in the following areas:

• Wholesalers of veterinary and human medicines ("mixed") which are subject to a minimum inspection period of once every 3 years on behalf of AFSSA/ANMV.

• Retail pharmacy outlets (some 23,000) for which an annual inspection programme is prepared at regional level. These outlets account for less than 8% of total VMP retail sales. Compliance with requirements for VMP are included in the scope of each inspection.

• Producer groups (approved by the Region Prefects) in cooperation with ISPV.

• Veterinary practitioners (in co-operation with the Inspector of Veterinary Public Health ISPV in cases where problems are identified).

In addition, joint inspections may be undertaken with SRALs/UDCCRFs.

The ANMV carries out the following tasks:

• Investigations in view of authorisation of new establishments manufacturing or distributing medicated feed (except on-farm).

• Investigation in view of authorisation of new establishments for manufacturing or wholesale distribution of VMP.

• Inspection of veterinary pharmaceutical establishments and control of Good Manufacturing Practice.

• Inspection of manufacturers and distributors of VMP Good Distribution Practice) inspections every 2-3 years, in which SRALs may participate.

• Control of Good Laboratory Practice.

• Controlling the quality of VMP (inspections concerning GMP analytical controls.

In 2008, ANMV carried out a total of 55 inspections.

In 2008, 15 inspections at "mixed" distributors were carried out by DRASS on behalf of ANMV.


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Residues

AFSSA

MAAP

NRCP

MHS


in animalproduction

INVSInput toNRCPInput to NRCP

DDSVs

Implementing instructionsand Reporting

Food of animal and non animal origin

Sampling

MEIE

DGCCRF

Honey

NRLs (4)

LERQAPLERMVDLABERCA

AFSSA (Sophia-Antipolis)

AuthorisedDepartmentalLaboratories

(26)

Analysis

DDCCRF

Sampling

Input to NRCP

DGAL(SDSPA)

DDSVs Departmental Directorate for Veterinary Services MAAP Ministry of Agriculture and Fisheries MHS Ministry of Health and sport MEIE Ministry of Economy, Industry and Employment DGAL Directorate-General for Food SDSPA Sub-Directorate for Animal Health and Welfare AFSSA French Agency for Food Safety NRCP National Reside Control Plan INVS National Institute for Public Health Surveillance DGCCRF Directorate General for Competition, Consumer Affairs and Fraud Repression NRL National Reference Laboratory LERQAP Research Laboratory for the quality of food and food products LERMVD Research Laboratory for veterinary medicines LEBERCA Laboratory for the study of residues and contaminants in food SRAL Regional Food Services UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression


The three CAs are MHS, MEIE and MAAP.


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Official controls on residues

Preparation of the National Residue Control Plan (NRCP) is a shared responsibility of the MHS, MEIE, and MAAP.

The office for Inputs and Public Health in Animal Production in SDSPA of MAAP, has the lead responsibility in planning and drafting the instructions of the NRCP. In addition, two risk-assessment agencies, AFSSA and the INVS, provide support for the Ministries. Both MEIE and MHS are consulted before the NRCP is finalised. A general instruction is drafted by the DGAL, together with a specific instruction for each commodity. These instructions which are circulated at the beginning of the year, define the number of samples to be taken in each Department and the analyses to be carried out. The DDSV determines where the samples are taken.

The NRCP is entered into SIGAL, along with data on the transmission of samples to the laboratories. Execution of the NRCP is monitored by DGAL. The results of analysis are entered into SIGAL by the laboratories.

The Office for laboratories and coordination of official controls (of MAAP Sub-Directorate for horizontal policies (SDPPST) is responsible for co-ordinating and harmonising instructions relating to the implementation of the NRCP. The BQCC drafts a general instruction containing the general implementation provisions for the NRCP.

The specific instructions for implementation of the NRCP, prepared by the office for Inputs and Public Health in Animal Production, take into account: the Departmental production figures; accreditation of laboratories; and the development of new methods by the National Reference Laboratories (NRLs). The office for Inputs and Public Health in Animal Production assesses the overall implementation of the NRCP annually. Each DDSV is responsible for supervising the implementation of the NRCP in their Department.

The DDSVs are authorised to enforce the relevant regulations in their Department and are informed if a NRCP sample is confirmed non-compliant in order to start the follow-up procedure within their Department.

The SRAL inform the National Brigade of Veterinary and Plant Health Investigations (BNEVP) of the detection of any prohibited substances or in cases of repeated maximum residue limit (MRL) breaches. In case of MRL exceedances, investigations are carried out at producer level by SRAL. As a follow-up, SRAL may carry out targeted controls on the producer. SRAL informs AFSSA if the outcome of its investigation indicates that there may be a problem with the withdrawal period indicated in the authorisation of the VMP.

In addition to sampling by SRALs under the NRCP, the DGCCRF undertakes sampling of honey on the market for the presence of antibiotics (including chloramphenicol for imported honey). Any non-compliances relating to domestic honey are notified to the SRALs who undertake follow-up with the producer.

Laboratories

Decree No. 2006-7 of 4 January 2006 requires, inter alia, that laboratories authorised for the purpose of official controls be accredited. MAAP has authorised 26 Departmental laboratories to undertake analytical work under the NRCP. These laboratories report to the local authorities at Departmental level. A turnaround time of one month is fixed by


50

the central authority for delivering the result of screening analyses. If the screening data indicates a possible non-compliance, an additional one-month turnaround time is allowed for the confirmation analysis. Confirmation of the result is performed in the field laboratory when the necessary equipment and the method are available. Alternatively, the confirmatory test may be carried out in the responsible NRL.

The following laboratories are assigned as NRL:

• The Research laboratory for the quality of food and food products (LERQAP) is the NRL for substance group B2c, B3a, B3b, B3c and B3d;

• Research laboratory for veterinary medicines (AFSSA LERMVD) is the NRL for

substance group A6, B1, B2a, B2b, B2d, B2e, B2f (excluding glucocorticoides), B3f;

• Laboratory for the study of residues and contaminants in food (LABERCA) is the

NRL for substance group A1, A2, A3, A4, A5 and B2f (glucocorticoids), B3f.

While all 29 laboratories are accredited to ISO 17025, the scope of accreditation does not always cover all of the analyses for which the laboratories are approved. Work on accreditation is ongoing.

In addition, the Research laboratory for small ruminants and bees (AFSSA LERPRA) is responsible for pesticides in honey. AFSSA-LERPRA is accredited to ISO 17025 (2005) general requirements. It is not yet accredited for analysis of residues in honey (programme 99) but work towards accreditation was in progress for the first category of analyses under programme 99-3 (acaricides in honey). The COFRAC audit was planned for December 2009.


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2.7 Control system for foodstuffs and food hygiene

DGAL DGCCRF

DDSVs

DRCCRF

UDCCRF

DRAM

DDAM

Foodstuffs of non-animal origin,Additives, contact materials,

irradiated foods, egg marketingand traceability

General consumer safety

DGS

DRASS

DDASSPrefect managescoordination at

Department level

Primary productionContaminantsEgg marketing

Fishery productsProcessing food of animal

originCatering

DistributionTransport


Social catering,general food hygiene,foodborne infections

and water

SSA

Armed services

DGAL Directorate-General for Food DGCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression DGS Directorate General for Health DRAM Regional Directorate for maritime affairs DRCCRF Regional Directorate for Competition, Consumer Affairs and Fraud Repression DRASS Regional Directorate for Health and Social Affairs DDAM Departmental Directorate for maritime affairs UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression DDASS Departmental Directorate for Health and Social Affairs SSA Health Department of the armed forces


There are three CA for foodstuffs and food hygiene:

DGCCRF (sub-directorates for "Consumer Policy and Safety" and "Agricultural and Food Products"); DGAL (sub-directorate for Food Safety (SDSSA); and DGS (Sub-Directorate for the prevention of risks related to the Environment and Food).

In addition, the SSA is the CA for the armed forces. This service has a corps of veterinarians who undertake controls in close cooperation with DGAL. This is covered by an agreement between the two Ministries (2007/1 of 27 April 2007).


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The following table shows the allocation of responsibilities between the three Ministries.

DGAL DGCCRF DGS

Primary agricultural production Primary production of shellfish Egg production and marketing Production and processing of animal origin food Storage Transport Distribution and direct sale Catering Contaminants Residues Fishery products and shellfish

Foodstuffs of non-animal origin (including contaminants and residues) Additives Contact materials Irradiated foods Egg marketing Distribution and direct sale Storage Transport Traceability

Canteens in health and social establishments General food hygiene Foodborne infections Water quality

RASFF contact point RASFF contact point

Licensing and registration of food businesses

A system of single registration ("one stop shop") for all official purposes, including food safety, is being developed by DGAL and DGCCRF.

All food business operators are registered. This registration is based on the obligation for all operators established in France to be registered with the National Institute for Statistics and Economic Studies (INSEE). The list of establishments registered by the INSEE is available to the inspection services.

Within DGAL, the SIGAL information system provides access to registered establishments to all Departments. SORA contains the listing in DGCCRF.

Registered Food establishments

Of a total of 303,300 registered direct sale food establishments (in SIGAL), 105,000 are commercial restaurants and 91,265 canteens.

Official controls of food premises

In 2007, 72 Inter-service missions for food safety (MISSAs) and 20 competence centres had been established. These inter-service groups jointly draw up and execute control plans combining national programmes and local priorities. These groups also provide on food safety aimed at operators and the general public.

Controls by the DDASS may be carried out in collaboration with UDCCRF and DDSV.


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Compulsory training on risk analysis and management of HACCP is provided for all the staff of DGAL/DDSV and for relevant staff of DGCCRF and DGS.

The DGCCRF intranet site (Géci), contains the control plans, service instructions, guides to good hygiene practice and other legal and operational documentation.

DGS

Under the Food Safety programme, the DDASS undertook 9,261 inspections in 2008, including 5,009 commercial outlets (comprising mainly restaurants, bakeries and markets) and 2,636 restaurants and canteens in hospitals, retirement homes and holiday resorts. The number of inspections is determined by each DDASS in the context of the "MISSA". Foodborne illness outbreaks are monitored by the National Institute for Public Health Surveillance (INVS).

Enhanced controls

The DGAL, DGCCRF, DGS, DGDDI and the Ministries of the Interior and Defence carry out targeted controls on foodstuffs during the summer holiday period. In 2007, DGAL undertook 24,634 controls under this programme, 23% of which involved mixed teams. In 2006, the DGCCRF inspected 21,000 food establishments.

DGAL and DGCCRF implement a second annual targeted programme at Christmas and the New Year. For 2007, DGAL targeted game meat and shellfish. In total, 6,953 controls took place inter alia in slaughterhouses, cutting plants, restaurants and shops.

Good Hygiene Practice Guides

Guides are produced by the relevant professional body, evaluated by AFSSA and validated by DGCCRF/DGAL and DGS. Following the AFSSA assessment, the guides are validated by the Agriculture, Consumer and Health Ministers and a notice is published in the French Official Gazette. The guides are presented to the National Consumer Council and the Commission is notified of the validated guides.

Some 35 Good Hygiene Practice Guides have been assessed by AFSSA and published in the French Official Gazette. These apply mainly to the restaurant and social catering sectors, food processing industry, supermarkets and retail sectors. The guides can be ordered from the French official publisher. http://actu-promo.ladocumentationfrancaise.fr/rubrique.php3?id_rubrique=72?xtor=AL-609

In addition to the above controls, DGCCRF undertakes controls regarding contaminants in food of non-animal origin, additives, flavourings, food contact materials and irradiated foodstuffs.

Rapid Alert System for Food and Feed (RASFF)

A protocol on inter-ministerial co-ordination for the management of alerts was signed on 21 December 2007.

The central contact points for the Commission RASFF system are Office C2 of the DGCCRF (Safety and Alert Networks) and the Mission for health emergencies (MUS) of DGAL. Both of these central bodies send relevant alerts to the UDCCRF/SRAL offices

http://actu-promo.ladocumentationfrancaise.fr/rubrique.php3?id_rubrique=72?xtor=AL-609

http://actu-promo.ladocumentationfrancaise.fr/rubrique.php3?id_rubrique=72?xtor=AL-609


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electronically. The alerts are also placed on the DGCCRF intranet site and are accessible by all Departments and the laboratories. The DGS and INVS are kept informed.

Laboratories

NRLs

The SCL laboratory at Bordeaux is the NRL for heavy metals in food of plant origin and for contact materials. The SCL laboratory at Rennes is the NRL for mycotoxins in food of plant origin, additives in feed, and PAP. The SCL laboratory at Montpellier is the NRL for pesticides in fruit and vegetables. The SCL laboratory at Strasbourg is the NRL for GMO. The SCL laboratory at Massy is the NRL for pesticids in cereals.

AFSSA-LERQAP is the NRL for heavy metals in foodstuffs of animal origin. LABERCA is the NRL for dioxins and PCB-DL, PCB-NDL, melamine, PAH. IRSN is NRL for radionuclides.

DGAL

Analysis of products of animal origin and for animal health purposes is carried out by the DGAL in authorised laboratories or at the National reference laboratories.

DGCCRF

In addition to the SCL laboratories designated as NRLs, all SCL laboratories undertake analyses for microbiology, contaminants, additives and contact materials.

No official control laboratory in France is equipped for analysis of irradiated products. The SCL laboratory in Strasbourg contracts out any such analysis to a private laboratory.

MHS (Water quality)

Sampling and analysis of bottled natural mineral waters must be carried out by a laboratory approved by MHS. A national database ‘SISE AGRELAB’ has been set up which contains information on analysis methods relating to all approved laboratories. Detection and quantification limits for each parameter are included.


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GMO

MAP MEIEAFSSA

DGAL DGCCRF DGDDI

SRAL

DDSVs

Animal Feed

Imports

Conventional and organic seedsFoodstuffs

Animal feedOrganic produce

GM Seeds

DRCCRF

UDCCRF

controls

Third Countryseed imports

Controls on food and feedimports

DGCCRFlaboratoryStrasbourg

(NRL)

Analysis

Analysis

NRL forseeds

RegionalDirectorates

Riskassessment

Bio-Geves

MAAP Ministry of Food, Feed, Agriculture and Fisheries AFSSA French Agency for Food Safety MEIE Ministry of Economy, Industry and Employment NRL National Reference Laboratory DGAL Directorate-General for Food DGCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression DGDDI Directorate-General for Customs and Indirect Taxation DRAF Regional Directorate for agriculture and forestry SRAL Regional Food Services DRCCRF Regional Directorate for Competition, Consumer Affairs and Fraud Repression UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression Competent authorities

As regards legislation, DGCCRF and DGAL are the central competent authorities for approvals of GMOs (Regulation 1829/2003 and Directive 2001/18/CE). The DGAL of MAAPis responsible for the registration in the official catalogue of varieties AFSSA is responsible for health risk assessment for GMO food and feed.


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Official controls of GMOs, including at import

The DGCCRF produces annual control plans for food, feed and seeds, except for imports. The DGCCRF may also carry out controls on imported products following their release into free circulation. DGCCRF carries out controls on: conventional seeds; foodstuffs and feedstuffs potentially containing GM products (as regards authorisation, labelling and traceability); and organic production (for presence of GM products and pesticide residues). The DGAL is responsible for controls on seeds at imports.

Food control

In 2007, the UDCCRFs inspected 171 establishments and took 63 samples.

The DGCCRF lays down general guidelines for controls and operations in the UDCCRFs and in consultation with the laboratory, the regional programming group and the UDCCRFs, draws up annual and quarterly monitoring programmes. Standard inspection checklists and reporting forms are used. The UDCCRFs decide which companies should be controlled and carry out additional controls of GM food at their own initiative, as part of other inspections.

Results of the controls carried out are published on the homepage of the DGCCRF. In addition, internal information notes provide a detailed evaluation of the results.

Article R.214-4 of the consumer code defines penalties applicable in the case of infringements of Regulations (EC) No 1829/2003 and No 1830/2003. In the case of proven fraud or adulteration, maximum penalties are imprisonment of 2 years and/or a fine of €37,500. In addition to these penalties, administrative measures may be taken by the CA, such as requiring the company to rectify the labelling, use the product for other purposes or destruction.

Companies placing food on the market for the first time, such as importers, traders and food producers, are specially targeted to evaluate their auto-control systems which are obligatory under French law on first placing on the market (CPMM). Depending on the outcome of a risk assessment, operators are visited annually (high risk), every 2 to 3 years (average risk) or every third year (moderate risk). Additionally, GMO controls are carried out at wholesalers and retailers. DGCCRF plans to carry out controls in organic production for GM products and pesticides.

Feed

A network has been established in each of the two main feed producing regions, South West (Toulouse) and West (Nantes) to ensure co-ordination between the inspection services. In 2007, the UDCCRFs inspected 111 establishments and took 92 samples.

Controls on imports

The DGDDI undertakes documentary checks (health documents) and, as required, physical checks (food and feed) at import.

Based on a health risk analysis by the central authorities, risk assessments are undertaken by Customs guidance cell on controls (CROC). On the basis of observed trade flows into the region, each CROC compiles a database of businesses importing products which


57

potentially contain GMOs. Based on these analyses, Customs define control criteria. The database of importers and control criteria are updated regularly. The IT system for customs declarations, highlights declarations from targeted importers. Imports targeted in this way are subject to a documentary check at the time of declaration. Customs notify any suspicious cases to the DGCCRF. Co-operation between the DGCCRF and the DGDDI is formalised. In 2006, a protocol was signed to reinforce this co-operation and improve the exchange of information.

The SRALs carry out documentary and identity checks of feed. The DRCCRF are responsible for documentary and physical checks on feed and food following its release into free circulation.

The DGAL is responsible for controls on seeds at imports. The controls aim at verification of the labelling of GM seeds and to check the absence of GMO in conventionnal seeds. The annual programmes of controls are established by the DGAL. The inspections are carried out by the SRALs. About 180 samples are taken and analysed every year to check the absence of GMO in conventionnal seeds.

Official controls of GMO in propagating material

The SRALs carry out controls on seeds on third country imports, in co-operation with customs and UDCCRF carry out controls on seeds on the internal market.

In 2007-2008, the UDCCRFs undertook controls on the market in 35 departments and took 132 samples.

Laboratories

The SCL laboratory at Strasbourg is the only designated NRL for GMO testing in feed, food and seed.

The SCL laboratory in Strasbourg, accredited to ISO17025, is responsible for monitoring GMO food, feed and seeds sampled by inspectors of DGCCRF.

The laboratory BioGEVES has been approved by MAAPfor certain GM analysis, in particular on seeds.


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2.8 Control system for imports of food of plant origin

Ministry of thebudget, public

accounts and thepublic service

MEIE

DGDDI

DRDDI

DGCCRF

DRCCRFand

UDCCRFLiason

Products coveredby Decisions2005/402/EC2008/402/EC

Products covered byDecisions

2006/504/EC2008/352/EC2008/352/EC2008/433/EC

Any Product

Documentary checksand

sampling before release

Documentary checksand

sampling before release

Controls and samplingat destination

SCLLaboratory

MEIE Ministry of Economy, Industry and Employment DGDDI Directorate General for Customs and Indirect Taxation DGCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression DRDDI Regional Directorate for Customs and Indirect Taxation UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression SCL Common Laboratory Service


The "Safety and alert networks office" and the "office for products of plant origin" of DGCCRF, are the CA with responsibility for controls on imports of foodstuffs of non-animal origin, as well as for general consumer safety and protection.

Control activities and enforcement actions are predominately discharged at Department level with the regional level playing a co-ordinating role.


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Import controls

A cooperation protocol between the DGCCRF and DGDDI was signed on 8 February 2006. This protocol lays down a cooperation framework and contains annexes detailing procedures for each sector. An Annex dealing with controls in this sector was signed on 23 July 2007.

General procedure

Co-operation between DGDDI and DGCCRF is covered in a protocol of February 2006. Apart from products covered by specific Commission Decisions, there is no systematic control at the point of import. Results of controls by DGCCRF are entered into the IRSIS database.

Specific control programmes on foodstuffs of non-animal origin imported from third countries are devised by DGCCRF on a risk-basis, taking into account data provided by Customs, principal destinations and RASFF alerts. These controls take place on the market. The number of samples to be taken in each Department is defined in the relevant programme.

In 2008, the DGCCRF implemented, inter alia, the following specific control programmes:

monitoring contamination of foodstuffs by mycotoxins (465 samples, including rice, coffee, spices and dried fruits);

contamination of foodstuffs with heavy metals (400 samples);

contamination of foodstuffs by tin (49 samples)

contamination of certain foodstuffs by PAHs (129 samples)

monitoring for foodstuffs treated with ionising radiation.

DGCCRF and AFSSA have annual discussions on mechanisms to better target controls.

Cases where specific Commission Decisions apply

COMMISSION DECISION 2006/504/EC on special conditions governing certain foodstuffs imported from certain third countries due to contamination risks of these products by aflatoxins. There are nine designated import points in France: Marseille; le Havre; Rungis; Lyon; Strasbourg; Lille; Saint-Nazaire Montoir; Agen; and la Réunion.

The UDCCRF, in co-operation with Customs, undertake the required controls:

• systematic documentary checks;

• Identity and physical checks (in accordance with the Decision) before the consignment is released by Customs. Consignments are held in temporary storage under Customs control pending results of analysis.


60

In 2008 3,207 lots were presented at the nine import points. The DGCCRF has established a "dried fruit network" comprising control agents, representatives of the central administration and the laboratories. The network members exchange information and meet annually.

Note de Service N2007-20 sets out procedures for the management of alerts and crises with the aim of co-ordinating all departments involved when a food product poses a serious risk to consumers. If necessary, administrative police powers and/or judicial police powers may be applied.

COMMISSION DECISION 2005/402/EC on emergency measures regarding chilli, chilli products, curcuma and palm oil Customs carry out systematic documentary checks and random sampling on chilli, chilli products, curcuma and palm oil. The DGCCRF undertake controls on products already on the market. In 2008, customs undertook 2,542 documentary checks.

Any lots found to contain Sudan dyes are destroyed. In other cases of non-conformity, the lots may be destroyed, returned to the country of origin, or exported to another third country.

Laboratories

Three official SCL control laboratories in France specialise in mycotoxin analysis. Rennes and Massy undertake analyses for the presence of aflatoxins and for a range of other mycotoxins, and Bordeaux specialises in analysis for Patulin in apple products, particularly cider, and Ochratoxin A in beverages. All of these laboratories are accredited to ISO/EN17025 for these analyses.

Official analysis for aflatoxins (Decision 2006/504/EC) may also be undertaken by approved private laboratories. Most analyses are undertaken by the SCL of Rennes and Massy and by the private laboratory SGS-Multilab in Saint-Etienne du Rouvray.

The SCL laboratories at Massy, Bordeaux and Marseille carry out analysis for the presence of prohibited colorants, including Sudan dyes. While not yet accredited by COFRAC for these analyses, the laboratories operate under quality assurance standards and work was underway on validation.

The majority of SCL laboratories undertake analyses for heavy metals in vegetable products. The laboratory at Pessac is the NRL for heavy metals.


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2.9 Control system for plant protection products (PPP) and residues

PPP

AFSSA DGCCRFDGAL

List of authorisedPPPs

Risk assessment

Authorisation of PPPs

Distribution and users Manufacturers, import, distribution and useLabelling, Packaging and Formulation

SRALs DRCCRF

UDCCRF

Cooperation on controls

SCLLaboratory

controls

Formulation controlSamples

MAP MEIE

MAP approvedlaboratories

MAAP Ministry of Food, Feed, Agriculture and Fisheries MEIE Ministry of Economy, Industry and Employment AFSSA French Agency for Food Safety DGAL Directorate-General for Food DGCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression PPP Plan Protection Product SRAL Regional Food Services DRCCRF Regional Directorate for Competition, Consumer Affairs and Fraud Repression SCL Common Laboratory Service UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression


62


MAAP is the CA for legislation on the marketing and use of Plant Protection Products (PPP) and the authorisation of PPP. The CA for legislation on classification, labelling and packaging of PPP are MAAP, MEEDDM, MEIE, MHS and the ML.

DGCCRF and DGAL are competent authorities for controls of the marketing and use of PPP (including packaging and labelling). DGCCRF also carries out controls of producers and importers of PPP, and on formulation.

The competent authority responsible for overseeing the disposal of non-usable PPPs is the Directorate General for Risk Prevention within the Ministry of Ecology, Energy, Sustainable Development and the Sea (MEEDDM)

Authorisation of PPP

AFSSA is the designated body responsible for risk assessment for PPP and for the assessment of MRLs. Some 3,720 PPPs were authorised for marketing in France as at December 2009 (containing some 537 active ingredients). The number of staff in AFSSA evaluating applications has been increased from 10 to 90 with a temporary increase to 150 until end 2010 to clear a backlog. This is expected to be achieved in 2010.

The formal authority to adopt these decisions rests with MAAP, Sub-Direction for Plant Protection and Quality (SDQPV), Office for the regulation and placing on the market of inputs. A temporary increase in staffing of 4 FTE is in place A list of authorised PPP is available on the web pages of the MAAP (http://e-phy.agriculture.gouv.fr/).

Official controls on marketing/use

Both DGAL and DGCCRF undertake controls. The main focus of DGAL controls is on users (with some controls on distributors), while DGCCRF controls focus on distributors. There are regular contacts between both services, at central and local level. An annual global report on control activities is produced by DGCCRF.

In 2008, the DRAF/SRPV undertook 5,481 inspections on the use of PPP, 627 on distribution and 67 on operators engaging in both activities.

DGAL

Annual control plans are drawn up by the SDQPV (unit for monitoring and control of PPP) within the DGAL. These give instructions for inspections of distributors and users of PPP and pre-harvest sampling for pesticide residue analysis. The SDQPV provides standard reporting forms for the inspections. Each plan specifies the number of inspections are to be carried out, and samples taken, by SRALs. Further instructions are included on the DGAL intranet. Inspectors are required to enter details of inspections into the follow-up module of GEUDI and to co-ordinate controls with other inspection services, including the DGCCRF.

http://e-phy.agriculture.gouv.fr/


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For cross-compliance, 1% of holdings are inspected for the use of PPP, based on risk analysis. In 2008, some 4,274 holdings were visited. In addition, some 1,868 other controls were undertaken, mainly at distributors and professional user sites.

Inspections for marketing and use of PPP and sampling for pre-harvest monitoring are carried out by SRALs covering all regions. In total, some 174 staff undertake controls for marketing and use of PPP.

DGCCRF

Control plans are drawn up annually by the "Safety and alert networks unit" of DGCCRF. These give information on: the legal basis; instructions for inspections of producers, importers, traders and users of PPP; sampling of PPP for formulation analysis; and forms for reporting the results of controls (in SORA).

In 2007, 73 UDCCRFs undertook controls at 965 establishments. Formulation analyses were undertaken on 53 samples.

A network for the implementation of controls on the production, marketing and use of PPP includes representatives of the UDCCRFs from 18 of the 100 Departments, the formulation laboratory, and the "Safety and alert networks Unit" of the DGCCRF.

Laboratories

The laboratory in Paris-Massy of the SCL is the only laboratory responsible for the formulation analysis of PPP. The methods used for formulation analysis of PPP are not accredited, but a quality control plan is applied.


64

PPP residues

AFSSA DGCCRFDGALRisk assessmentand MRLs

SRALDRCCRF

UDCCRF

DepartmentLaboratories

(2)

Laboratories(7)

Food of plantorigin

Pre-market

Food of plantorigin

on the market

Results

Samples

Samples

Samples

AFSSA French Agency for Food Safety DGAL Directorate-General for Food DGCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression DRAF Regional Directorate for agriculture and forestry SRAL Regional Food Services DRCCRF Regional Directorate for Competition, Consumer Affairs and Fraud Repression UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression


AFSSA is designated as the body responsible for setting MRLs. The formal decision is taken by inter-ministerial Order.

Both DGAL (pre-market) and DGCCRF (on the market) are the CA for the control of pesticide residues in and on food of plant origin. DGAL is the competent authority in relation to food of animal origin. Under an agreement, DGCCRF performs controls at market level, and DGAL controls pesticide residues prior to harvesting.

Official controls on residues

An overall report on surveillance and control activity is produced by DGCCRF.


65

DGAL

SDQPV (unit for monitoring and control of PPP), is responsible for residues controls pre-market. The purpose is to detect unauthorised PPP and to verify correct use in accordance with the authorisation. In 2008, 690 analyses were undertaken. In 2009, 806 pre-harvest samples were planned (screening for 266 active ingredients). DGAL is the EU contact point for pesticide MRLs.

DGCCRF

The "Products of plant origin office" of the DGCCRF, draws up an annual “surveillance sampling plan”, which specifies the commodities and number of samples to be taken by each of the regions. It includes all commodities and pesticides specified for sampling within the Community monitoring programme. It also specifies other commodities including baby food and organic produce. The plan requires random sampling as close as possible to production or placing on the market (at farm gate, packing establishments, wholesalers and importers). Under the 2007 programme, 5,412 samples were analysed, of which 3,927 were of fruit and vegetables (including 185 samples taken as part of the monitoring programme for organic production). The results are transmitted to AFSSA for evaluation of the exposure of the population to pesticide residues (http://www.observatoire-pesticides.gouv.fr/.) The DGCCRF reserves the right to return to any location where a sample taken is found to contain residue in excess of the MRL. Any such cases may also be targeted for control in a subsequent control plan. Since 2007, the surveillance programme is supplemented by the "specific surveillance action" which targets specific molecules in fruit and vegetables, as defined by Article 29 of Regulation No 396/2005/EC.

An additional annual control sampling plan is drawn up by the "Products of plant origin office", taking into account the results of previous plans, RASFF notifications and information obtained during controls. There is no specific control plan on pesticide residues in imported products. For fruit and vegetables, the minimum number of samples which must be taken by UDCCRFs (based on the local situation and previous infringements) is 20% of the number of samples taken for surveillance. In 2007, 943 samples were analysed. AFSSA is consulted on the risk implied in case of specific MRL exceedances. A national evaluation tool has been developed for risk assessment.

Laboratories

Seven laboratories of SCL, six of which are accredited to ISO 17025, perform pesticide residues analysis. The pesticide laboratory network is co-ordinated by the laboratory in Rennes.

Two of these laboratories have been designated NRLs: Montpellier (fruit and vegetables); and Paris Massy (cereals). These NRLs were to commission new LC/MS/MS equipment in 2009.

Pesticide residue analysis of pre-harvest samples is carried out by GIRPA Angers which is accredited, and by the seven pesticide residue laboratories of the SCL.

For foodstuffs of animal origin, AFSSA LERQAP (Maisons-Alfort) is the NRL.

http://www.observatoire-pesticides.gouv.fr/


66

Following a call for tender, MAAPhas authorised a network of laboratories (6 for single residue and 8 for multi-residue analyses). For 2009, 7 laboratories had been engaged to undertake the control programme.


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2.10 Control system for animal welfare

DGAL

SRAL

DDSV

FarmsSlaughter

ImportTransport

Police/Gendarmerie

Joint controls

Authorisedtransporters

Authorisation Informationexchange

MD

SSA

DGAL Directorate-General for Food SRAL Regional Food Service SSA Health Department of the armed forces MD Ministry of Defence


The SDSPA "office for animal protection" within DGAL is the CA with responsibility for issuing regulations and instructions, and co-ordinating and supervising the activity of the decentralised offices.

The SSA has responsibility for animals held by the armed forces.

A "Departmental Council for animal health and protection", comprising representatives from the SRALs and other relevant agencies, the police, animal welfare associations, and professional organisations, has been established in each Department.

In general, some 30% of all activity relates to the investigation of complaints from the public.

SIGAL was beginning to be used to guide control activities and for reporting the results of controls. A common inspection guide with model reports was to be included. The system will also provide inspectors with complete information, including historical data, of each holding, as a basis for targeting inspections.


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Official controls on farm

The inspection of animal welfare on farm is due to be accredited to ISO 17020 by 2009. To date 7 (of 9) vademecum have been finalised.

The target frequency for visits by DDSVs to veal, pig and laying hen holdings is 1% for each category in each Department. The selection of farms is made at local level and generally combined with other tasks, including animal health and identification and veterinary medicines.

Official controls during transport

DGAL sends instructions each year to the DDSVs to organise checks on the welfare of animals during transport. Each DDSV is requested to carry out 100 controls on the means of transport.

Standard inspection checklists are being updated to take account of Council Regulation (EC) No 1/2005 and a vademecum to harmonise controls is being prepared. DGAL is working towards planning of transport checks on a regional basis and on ways to improve compliance as regards resting requirements.

DDSVs are responsible for the authorisation of transporters every 5 years. A register of transporters is to be incorporated into SIGAL. The SRALs also verify journey logs.

Checks on imports are carried out by BIP staff who receive special training for this purpose.

Official controls at slaughter

Controls at slaughterhouses include approval of equipment and adequacy of staff training. DGAL was exploring acceptable stunning methods for ritual slaughter and a working group had been established to review the suitability of stunning and slaughter equipment generally. A network of slaughterhouse specialists (comprising seven experts) has been in operation since November 2007. These experts assist DDSVs and audit establishments.


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2.11 Control system for plant health

DGAL

SDQPV

Seed and planthealth section

SRAL

FREDON

Delegation

Imports Exports

Phytopass

Inspection results

Plant passportsystem

Inter-professionalbodies

FranceAgriMerCTIFL

GNIS-SOC

Delegation

Registration ofProducers and

traders

NationalLaboratory

Analyses

DGAL Directorate-General for Food SDQPV Sub-Directorate for Plant Protection and Quality SRAL Regional Plant Protection Services FREDON Regional Federations for the protection against harmful organism FranceAgriMer An interprofessional body GNIS-SOC National inter-professional group for seeds-Official control service


70


The CA is the sub-Directorate for vegetable quality and protection (SDQPV), which is part of DGAL. As regards export to third countries the sub-Directorate for European and International health Affairs is responsible.

The SDQPV consists of 4 offices, one of which, the Seed and plant health section (BSSV), is responsible for policy regarding harmful organisms, including: transposition of legislation; import and export controls; general surveillance; control of producers; and international relations. It issues instructions and guidance for the regional services and is responsible for planning their budget.

The BSSV at central level has 7 FTE on plant health.

There are 22 regional plant protection services within the SRALs in mainland France and four plant protection services in the Overseas Departments which are part of the Regional Directorates (DRAAFs).

The budget for the SRALs is provided by DGAL. The staff salaries are paid directly by MAAP.

A quality management system is in place with a view to ISO 17020 accreditation by COFRAC.

Some 420 agents are employed by the 22 SRALs in the area of plant health. They have a wide range of duties, including: import; intra-Community trade and export certification; and the organisation of surveillance. They have sole responsibility for the implementation of quarantine and other mandatory controls.

FREDON is a regional organisation with delegated responsibility from the SRAL for implementing certain obligatory controls on harmful organisms. The delegation of functions to FREDON is on a regional basis and when the SRAL do not have sufficient staff to carry out the checks. As a result, the proportion of checks carried out by FREDON varies between regions.

Detailed annual work plans are established by all of the responsible official bodies. The SRAL draws up the work plan for the inspectors of FREDON covering the number of premises to be visited, the frequency and duration of visits, and the duties to be performed. Based on this plan the annual agreement between the SRALs and FREDON is prepared.

Each responsible official body has its own database for recording inspections. In the case of the SRALs, this is done on the Phytopass database which contains data on: imports; exports; plant passport inspections; surveillance; and outbreaks.

In all cases, the SRAL is informed if a harmful organism is found. The responsible official bodies prepare an annual report on their activities, which is sent to the SDQPV.

Plant passport system and internal market checks

All growers, traders and distributors of plants and plant material, with the general exception of those sold for non-professional use must be registered with the SRAL. A visit is not required prior to registration. A unique registration number is allocated by the


71

SRAL. The registration is renewed each year, unless there is a reason to withdraw it. Some 78,000 traders are included on the register. The frequency of visits is determined by each SRAL.

The plant passport system is implemented by the SRALs, with, in certain cases, formal delegation to FREDON and three inter-professional bodies: FranceAgriMer for vitis plants; the Inter-professional technical centre for fruit and vegetables (CTIFL) for certified fruit plants; and the National inter-professional group for seeds-official control service (GNIS-SOC) for potato plants). Formal delegation of duties to the three inter-professional bodies is provided for in the "rural code". Conventions have been concluded between MAAP and each of the inter-professional bodies providing for an annual meeting to establish tasks to be performed and to review progress. The SRAL is solely responsible for quarantine issues, including corrective measures such as the withdrawal of passports. Each responsible official body has its own database for recording inspections. In the case of the SRAL, this is done on PHYTOPASS.

In all cases, the SRAL is informed if a harmful organism is found. The responsible official bodies prepare an annual report on their activities, which is sent to the SDQPV.

The delegated bodies also register relevant producers. To avoid confusion, the producer is given a ‘certification’ number by the inter-professional body. The two registration numbers are linked in the SRAL data-base so that the producer can be traced by the SRAL if necessary.

Import controls

All importers of plants and plant products are registered by the SRAL.

Regulated plant material may be imported only through approved entry points. The SDQPV lists 33 of these (including the DOMs), seven of which handle 75% of all such imports.

Consignments of regulated plant material imported from third countries are inspected at the point of entry by the SRAL. Inspections are completed either fully, prior to Customs clearance, or partially (at least documentary check), prior to approval for the use of Community transit procedures. SRALs issue a plant health transport document for regulated material, authorising the movement under transit from the point of entry to authorised place of destination. The remaining checks are carried out at the place of destination. In certain cases, samples may be taken at the point of entry and held at an approved point of destination pending results.

Customs identify consignments of regulated material, based on information in the single administrative document (SAD), and details of relevant material (TARIC code and country of origin) which is usually obtained from "DELT@" (computerised customs clearance system). Customs will not clear such consignments or authorise the use of Community transit procedures until permission is given by the SRAL.

The SRAL may request Customs to establish profiles in their computer system to enable specific consignments to be targeted using data contained in the SAD. These profiles commonly include the TARIC code and country of origin.


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Laboratories

The National Laboratory for Plant Protection (LNPV) comprises 7 units (main site at Angers with 6 stations) and provides diagnostic services and specialist advice and, for certain topics, training for the relevant inspectors of SRAL. In addition, the certification bodies also have their own laboratories. Inspectors may carry out routine checks (usually entomological identification) at points of entry. However, samples are always sent for confirmation to the relevant national or regional laboratory for plant protection.

A call for tender was launched in June 2008 to establish a network of approved laboratories, in line with a Ministerial Order of 19 December 2007. In May 2009, a network of 19 approved laboratories became operational. The LNPV is responsible for validating methods and for overall technical direction of the network.


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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 French authorities in its inspection reports2.

At the time of the general review mission to France in June 2009 a total of 284 recommendations had been made in the 32 finalised inspection reports for France in the period 2004-2008. Prior to the 2009 general review mission, the Commission had closed 186 of these recommendations either on the basis of action taken 3 by the Competent Authorities or because they were no longer relevant.

The remaining 98 recommendations, together with one further recommendation which remained open since 2003, giving 99 in total, were followed up during the 2009 general review mission in June 20094. These consisted of 55 recommendations classified in the 2008 country profile as either “In progress” or “Action still required” and 44 recommendations requiring follow-up from inspection mission reports which had reached the closeout stage since the previous general review mission in 2008. In the case of these more recent recommendations, the response of the competent authority was considered unsatisfactory in 14 cases and verification of promised action by the Competent Authority was considered necessary in 30 cases.

2 Those in respect of which the technical assessment by the FVO had been finalised (“closeout”) at the

time of the general review mission 3 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.

4 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.


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The position is summarised in the following table:

Pre-General Review Mission 2009

Post- General Review Mission 2009

Action taken / No longer relevant 186 221 Outstanding / Action still required Of which carried over from 2003

42 1

15 -

For verification / In progress Of which carried over from 2003

57

49 1

Total number of recommendations

Of which carried over from 2003

285

1

285

1

This assessment is based on information and documentation received and reviewed during meetings with the Central Competent Authorities in the course of the 2009 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 France and the assessment in relation to the recommendations identified for further follow-up during the 2009 general review mission. The findings in relation to the individual recommendations are presented in a separate chapter for each control system.


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Overview of FVO inspections to France 1999-2003 and 2004-2008

Control system Total number of finalised inspections 1999-2003

Total number of finalised inspections 2004-2008

Recommendations

2004-2008

Total Closed Action still required

In progress

Animal Health

10

6 59+ 1 carried

over from 2003

40 3 16+ 1 carried over from

2003

Food of animal origin 11 5 36 23 5 8

Import controls 5 4 66 53 3 10

Feedingstuffs and animal nutrition 2

1 5 5 0 0

TSE/ABP 5 5 39 33 0 6

Veterinary medicinal products and Residues 2

1 14 13 1 0

Foodstuffs and Food hygiene 6

3 11 7 0 4

Imports of food of plant origin 1

1 11 8 1 2

Plant Protection Products and residues 1

1 10 8 1 1

Animal welfare 3 4 25 23 1 1

Plant health 4 1 8 8 0 0

Total

50

32 284 + 1 carried

over from 2003

221 15 48+ 1 carried over from

2003

General Review Missions 0

2 - - -


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Planned inspections to France 2009 post general review mission

Ref No. Subject of Inspection

8231/2009 Public health - food hygiene

8097/2009 Evaluate feed ban controls and compliance with requirements for organic fertilisers and soil improvers

Follow up of FVO missions

This section lists all recommendations requiring follow up during the general review mission in June 2009. Recommendations requiring follow up are shown by control system and are classified as follows:

• Recommendations carried over from the country profile of 2008;

• Recommendations in reports which have reached closeout note stage since the general review mission in 2008 and which were reviewed in the general review mission of June 2009.


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3.1 Animal health

Since 2004 the FVO has carried out 6 inspections in France in relation to animal health. Out of a total of 59 recommendations contained in the reports of these inspections, 24 were identified for follow-up during the general review mission, all of which were carried over from the country profile of 2008.

Recommendations carried over from the country profile of 2008

Inspection 9291/2003 of 24/11/2003 on Disease surveillance network

Reference no. and Recommendation

Findings Assessment

(15205) The other deficiencies found by the inspection team should be correct.

See also Recommendations 25581, 25582, 25587, 25588, 25589 and 1 in MR 7948/2007

Transposition issue

A Decree and Arrete on the '' procedures for approval of assembly centers under Article L.233.3 of the Rural Code'' on the ''conditions for approval of assembly centres'' originally planned for early 2007, were still in preparation.

During the general review mission the Competent Authorities confirmed that these amendments to current legislation will cover the training requirements for staff working in the assembly centres (amending Arrete du 9 Juin 1994, Art 9 and Annex I, Point 3.3). The new legislation will cover all centres except livestock holdings and exhibits, places of cultural or sporting events and slaughterhouses.

The instructions for implementation of the Decree and Arrete will be prepared in parallel with the adoption process and will be transmitted by a Vademecum and Note de Service.

Decree, Arrete and all relevant adjustments to vademecum and note de service were expected to be published during the first quarter of 2010.

Moreover, a new Decree and Arrete concerning ''the conditions of accreditation of veterinarians with a mandate health veterinarian certifying'' as provided for in Article L.221-13 of the Rural Code, now being finalised, expected to be published in the first quarter of 2010 (implementing instructions being prepared in parallel). Provisions for the charging of fees were included in the Law on Finances 2010.

Training of candidate certifying veterinarians was to commence in the first half of 2010.

See also Recommendations 25581, 25582, 25587, 25588, 25589 and 13 in MR 7948/2007

In progress

Inspection 7136/2004 of 11/10/2004 on EU requirements regarding animal health conditions applicable to intra-Community trade in semen and embryos of domestic animals of the bovine species


Findings Assessment

(19420) To provide appropriate

During the general review mission the Competent Authorities indicated that they were in the process of implementation of ISO 17020

In progress


78

Inspection 7136/2004 of 11/10/2004 on EU requirements regarding animal health conditions applicable to intra-Community trade in semen and embryos of domestic animals of the bovine species


Findings Assessment

training for the official supervision of SCCs and Semen Storage Centres (SSCs) to the Ovs responsible.

accreditation.

The French authorities described that in this process DDSV's are preparing to establish procedures for:

- systematic verification on taking up duty,

continual recording of competence checking of the inspectors,

- identification of needs and feedback,

- tutoring programme.

Also, they indicated they were preparing a Training Catalogue for 2010 - FORMCO training of inspectors for the inspection of EC centers for breeding animal quarantine station, the semen collection center, center storage and seed embryo transplant team.

However, these records or procedures are not transmitted to the DGAL.

Inspection 8152/2006 of 30/01/2006 on the implementation of EU animal health requirements for intra-Community trade in live animals


Findings Assessment

(25581) To amend the instructions for tuberculosis testing in order to completely and correctly comply with Points 2.2.5.1 and 2.2.5.3.2 of Annex B to Council Directive 64/432/EEC and to transpose the relevant EU requirements regarding the duties of an official veterinarian at assembly centre (Article 5 (3) of Council Directive 64/432/EEC and Article 9 (3) of Council Directive 91/68/EEC and

Tuberculosis testing

This has been a longstanding issue since the general review mission in 2006. During the general review mission in 2009, the French authorities indicated that the new Note de Service would be issued to inter alia require tuberculosis tests to be read on the basis of an objective measurement of the skin fold (using vernier callipers), rather than just being evaluated manually. This would be implemented early 2010.

The duties of the official veterinarian at assembly centres

During the general review mission the Competent Authorities indicated that the duties of official veterinarian at assembly centre are to be addressed in new draft legislation (modifying Arrete of 9 June 1994) - comprising a Decree (amending article R 221-29 of Rural Code) and an Arrete (see Chapter II, article 7) concerning ''the conditions of accreditation of veterinarians with a mandate health veterinarian certifying as provided for in Article L.221-13 of the Rural Code''.

The instructions for implementation of the Decree and Arrete were being prepared in parallel with the adoption process and will be

In progress


79



Findings Assessment

Article 11 (1) (c) of Council Directive 64/432/EEC and Article 8a (1) (c) of Council Directive 91/68/EEC) into French legislation.

See also recommendation 25595 below for tuberculosis testing

See also Recommendations 15205, 25582, 25587, 25588, 25589 and 13 in MR 7948/2007 for the duties of the official veterinarian at assembly centres

transmitted by means of a Vademecum and Note de Service.

The new Decree and Arrete concerning ''the conditions of accreditation of certifying veterinarians under Article L.221-13 of the Rural Code, were being finalised and were expected to be published in the first quarter of 2010 (implementing instructions being prepared in parallel). Provisions for the charging of fees were included in the Law on Finances 2010.


See also Recommendations 15205, 25582, 25587, 25588, 25589 and 13 in MR 7948/2007 for the duties of the official veterinarian at assembly centres

(25582) To ensure that the staff of the Direction Départemental des Services Vétérinaire are trained in accordance with Article 6 (a) and (b) of Regulation (EC) No 882/2004 and that the Vétérinaires Sanitaires receive, for their area of competence at assembly centres, appropriate training (Article 6 (a) and (b) of Regulation (EC) No 882/2004),

See also Recommendations 15205,

The French Authorities indicated that the ''Information and Training for the staff of the Direction Départemental des Services Vétérinaire'' for their area of competence is to be addressed in the new draft legislation (modifying Arrete of 9 June 1994).

The Competent Authorities indicated that the amendments of article R 221-30 of Rural Code (draft Decree) and the Arrete draft (see Chapter II, art 7 to art.10) concerning ''the conditions of accreditation of veterinarians with a mandate health veterinarian certifying as provided for in Article L.221-13 of the Rural Code'' will address this recommendation.

New Decrees (under Code Rural L 221-13) and Orders, now being finalised, expected to be operational by beginning 2010 (implementing instructions being prepared in parallel).

See also Recommendations 15205, 25581

25587, 25588, 25589 and 13 in MR 7948/2007

In progress


80



Findings Assessment

25581, 25587, 25588, 25589 and 13 in MR 7948/2007

(25586) To ensure that the TRACES list of approved assembly centres is regularly updated (Article 11 (3) of Council Directive 64/432/EEC and Article 8a (3) of Council Directive 91/68/EEC).

During the general review mission, the French authorities indicated that the work was ongoing between TRACES and DGAL and the DGAL may forward regularly the list of assembly centres after they receipt the documents of TRACES computer charges from the Commission.

The mission team pointed out that the competent authority must transmit the assembly centres list to INFORVET (CIRCA) database.

The French authorities indicated that were not aware of this procedure.

The French authorities undertook to:

(a) send the list assemble centres directly to the Commission for updating of list in TRACES by Commission

or to:

(b) send the list through the Circa database.

See also Recommendation 12 of MR 7948/2007

In progress

(25587) To put the approved assembly centres under the control of an official veterinarian in order to ensure that all EU requirements at assembly centres are met, in particular that all necessary checks are carried out on arriving animals (Article 5 (3) of Council Directive

The French authorities indicated that the new draft legislation would place responsibility for the approved assembly centres under the control of an official veterinarian in order to ensure compliance with EU requirements for assembly centres :

Decree and Arrete on the '' procedures for approval of assembly centers under Article L.233.3 of the Rural Code'' and on the ''conditions for approval of assembly centres'' (Article R 233-5 and Article R 233-6 of the Decree and Annex II Operating Conditions - of the Arrete),

The new Decree and Arrete concerning ''the conditions of accreditation of certifying veterinarians under Article L.221-13 of the Rural Code, were being finalised and were expected to be published in the first quarter of 2010 (implementing instructions

In progress


81



Findings Assessment

64/432/EEC and Article 9 (3) of Council Directive 91/68/EEC) and cleansing and disinfection of the facilities before use is carried out (Article 11 (1) (c) of Council Directive 64/432/EEC and Article 8a (1) (c) of Council Directive 91/68/EEC).


25581, 25582, 25588, 25589 and 13 in MR 7948/2007

being prepared in parallel). Provisions for the charging of fees were included in the Law on Finances 2010.



25581, 25582, 25588, 25589 and 13 in MR 7948/2007

(25588) To ensure that the competent authority carry out regular inspections of dealers in order to ascertain that the requirements of Article 13 (4) of Council Directive 64/432/EEC and Article 8b (4) of Council Directive 91/68/EEC are fulfilled.


25581, 25582, 25587, 25589 and 13 in MR 7948/2007

The current French authority programming inspections define different tasks to be performed by official veterinarian in the ''National programme of Inspections''.

Inspections of dealers are covered by Note de Service DGAL/SDSPA/N2008-8232.This requires that 20 % of dealers (with physical premises) are to be inspected annually.

Note de Service DGAL/SDSPA/N2008-8232 refers in particular to the system of identification and registration of cattle, sheep and goats and traceability of sheep and goats and to ensure compliance with the requirements of the Regulations (EC) 1082/2003 and (EC) 1015/2006 laying down detailed rules for implementation of Regulations (EC) 1760/2000 and (EC) 21/2004, required to each member state to control a minimum percentage of holdings holding cattle, sheep and goats, but not to the requirements of Article 13 (4) of Council Directive 64/432/EEC and Article 8b (4) of Council Directive 91/68/EEC.

The French authorities indicated that the legislation (see 25587) would be the new legal frame which will address this specific recommendation and that the implementing instructions were being prepared in parallel.


In progress


82



Findings Assessment

25581, 25582, 25589 and 13 in MR 7948/2007

(25589) To ensure that the facilities of approved assembly centres are dedicated exclusively for this purpose when used as an assembly centre (Article 11 (1) (d) first indent of Council Directive 64/432/EEC and Article 8a (1) (d) first indent of Council Directive 91/68/EEC).


25581, 25582, 25587, 25588 and 13 in MR 7948/2007

Transposition issue

The Competent Authorities indicated that the amendments of article R 233-7 of Rural Code (draft Decree) and the draft Arrete concerning the ''conditions for approval of assembly centres'' will address this recommendation.

The instructions for implementation the Decree and Arrete will be prepared in parallel with the adoption process and will be transmitted by the instrumentality of Vademecum and Note de Service.

The new Decree and Arrete concerning ''the conditions of accreditation of certifying veterinarians under Article L.221-13 of the Rural Code, were being finalised and were expected to be published in the first quarter of 2010 (implementing instructions being prepared in parallel).



25581, 25582, 25587, 25588 and 13 in MR 7948/2007

In progress

(25594) To urgently provide guarantees that an official veterinarian carries out the ante-mortem inspection at the slaughterhouse visited as required by Annex I, Section I, Chapter II, B 1 (a) to Regulation (EC)

The French authorities confirmed that some Departments decide that ante-mortem examinations and permanence be undertaken by Agricultural and Environment engineers and Technicians (collectively '' official auxiliaries'') in cases where there are insufficient official veterinarian resources. MAAP has not issued any instructions to provide for such arrangements.

The French authorities indicated that the extended period of operation of slaughterhouses in the pig sector made it impossible to have permanent presence of an official veterinarian (the French authorities indicated that ante-mortem inspection in bovine sector is

Action still required5

5 In their comments on the draft country profile, the French authorities indicated that a Note de service 2009-8290 dated 22 October 2009 introduced new checklists and procedures on animal welfare at slaughterhouses.


83



Findings Assessment

No 854/2004 and that an official veterinarian is present in the slaughterhouse throughout the ante-mortem inspection as required by Annex I, Section III, Chapter II (1) (a) to Regulation (EC) No 854/2004 and to make sure that is done properly at other slaughterhouses

See also recommendation 7 in MR 7330-2007 (Chapter 3.10: Animal welfare) and MR 2008-7827

largely compliant). There are +/- 450 veterinarians cover some 200 pig slaughterhouses and 100 bovine slaughterhouses. In the poultry sector, there are currently 20 FTE veterinarians for 420 establishments.

In order to address the FVO recommendations, the French authorities produced training material on slaughterhouses controls, including ante-mortem inspection, and this was delivered in an intensive training programme to official auxiliaries in the period February 2008 to mid -2009. Some 2,000 auxiliaries were to be trained.

This training was supported by a Note de Service N2008-8290 dated November 2008 ''List of danger and priority inspection points in slaughterhouses (red meat), checklists and reporting forms''.

New instructions (Note de Service) are being prepared which will formalise and improve the existing situation but will not bring arrangements into line with Annex 1, Section III, Chapter II(1) (a) of Regulation (EC) No 854/2004. These new instructions would specify cases where the official veterinarian should be called upon following screening by auxiliaries. A copy of these instructions will be provided to the Commission on completion (after September 2009).

The French authorities also drew attention to the seminar on modernisation of sanitary inspection in slaughterhouses (Lyon 7-11 July 2008) and to the conclusions of the CVO's meeting in Strasbourg 12 to 15 October 2008 (14438/08).

The mission team drew attention to DG SANCO (E2) letter of 22 December 2008 D(2008) 520925 ( following MR 2008-7827 on poultry) which requested guarantees that non conformities, including those relating with ante-mortem inspections, would be corrected and indicated that the Commission reserved the right to take necessary measures applied only to poultry. The mission team indicated that the reference was to ante-mortem inspections generally.

See also recommendation 7 in MR 7330-2007 (Chapter 3.10: Animal welfare) and recommendation 2 in MR 2008-7827

(25595) To ensure that raw milk

A draft Order amending Article 23 of Order of 15 September 2003 laying down technical and administrative measures on the

In progress6

6 In their comments on the draft country profile, the French authorities indicated that the Order of 15

September 2003 was amended in line with this recommendation by an Order dated 19 August 2009


84



Findings Assessment

delivered to dairies fulfils the requirements in relation to bovine tuberculosis (Annex III, Section IX, Chapter I.I, (2) (b), (3) (a) and (4) to Regulation (EC) No 853/2004).

See also recommendation 25581 above

collective prevention of and health policy on bovine and caprine tuberculosis was expected to be adopted before the end of September 2009. This is intended to bring national provisions fully into line with Regulation (CE) 853/2004, by the last quarter of 2009.

See also recommendation 25581 above

Inspection 8218/2006 of 16/10/2006 on the operation of the ovine and caprine identification system


Findings Assessment

(28451) 2. To ensure that registers are kept in holdings, markets and assembly centres and that they are in compliance with Article 5 of Regulation (EC) 21/2004 and, for assembly centres, also with Article 8(a) (2) of Council Directive 91/68/EEC.

To communicate to the Commission and to the other MS the model of the holding register used, as required by Article 5.6 of Regulation (EC) 21/2004.

The French authorities indicated that are intending to retain current arrangements.

The mission team invited France to formally notify the Commission of the current arrangements7.

The competent authorities indicated that the current situation would be reviewed in early 2010, taking into consideration that, the EC Regulation provides for changes in the content of this register from, the date of implementation of individual traceability.

Action still required

7 In their comments on the draft country profile, the French authorities confirmed that a notification had

been sent to the Commission in December 2009.


85

Inspection 7948/2007 of 11/12/2007 on bluetongue


Findings Assessment

1. Animals from ZR should not be certified for intra-Community trade under the conditions laid down in paragraphs 3 and 4 of Point A of Annex III of Regulation (EC) No. 1266/2007, where there are indications of a possible inadequate protection against vectors;

The French authorities confirmed that, in line with Arrete dated April 2008, laying down technical measures regarding bluetongue (including vaccination) and Note de Service 00986 dated 19 May 2009 and Note de ServiceDGAL/SDSPA/N2008-8305 (implementation instructions for virusological surveillance of BT throughout the national territory and vaccination), all animal certified for ICT are compulsory vaccinated, therefore this recommendation is not longer applicable.

This recommendation was overtaken by the current epidemiological status of France, the implementation of a mass vaccination campaign and because the competent authority confirmed that they were no longer bound by the conditions laid down in paragraphs 3 and 4 of Point A of Annex III of Regulation (EC) No. 1266/2007)

Action taken

2. Restore the ban on movement from farms where cases of Bluetongue are suspected or confirmed, in accordance with Article 4, 2, d), i) of Directive 2000/75/EC, until the presence the FCO is removed;

The French authorities indicated that according to Note de Service DGAL/SDSPA/N2009-8123 and Note de Service DGAL/SDSPA/ N2009-8085, the current epidemiological situation and mass vaccination campaign, they ban only the movement of animals from farms where animals are not vaccinated, in both situations of any suspected or confirmed cases.

Action taken

3. Implement and monitor the implementation of other measures under Article 4 of Directive 2000/75/EC, including the epidemiological investigation described in Article 7 of the Directive, including a review of movements from the holding in question;

The French authorities considered that the Directive is not adapted to the serotype 8 (exotic strain) and point out that a determination, in accordance with Article 7(1) (a), of the duration of the period during which bluetongue may have been present on the holding cannot be made using available tests (due to the persistence of a positive PCR beyond the period of viremia).

The French authorities also point out that the information required by Article 4(2) (b) (i) of the Directive are available from existing sources.

During the general review mission the French authorities referred to Commission working document on Bluetongue SANCO/4656/2009, to support their view.

Additional information received from France on 28 September 2009

The French authorities are anticipating a possible modification to the



86



Findings Assessment

Directive.

4. Apply a serological monitoring by using sentinel animals in protection zones and surveillance zones, in accordance with Annex I, 1.1 of Regulation (EC) No. 1266/2007, for which a rapid confirmation of cases in accordance with Article 2, a, ii) of the regulation is established and documented; ensure proper implementation of this serological monitoring;

The French authorities indicated that an updated protocol had been introduced in a new Note de Service 00986 dated 19 May 2009 which replaced Note de Service 8238 dated 15 September 2008.

The competent authorities pointed out that because of the vaccination programme for 2009 the monitoring programme is based only on virology and genotyping analysis (prevalence detection 2% with a confidence interval of 95%, the basic unit is the department, 150 samples monthly/ department).

In progress

5. Establish a vector surveillance in accordance with Annex I, 1.2 of Regulation (EC) No. 1266/2007, and define the seasonal vector-free period accordance with the criteria of Annex V of the said Regulation;

CIRAD annual activity report 2008, defines the seasonal vector-free period for France, from 5 January to 11 March 2009.

The competent authorities confirmed that the vector surveillance programme (see ‘’Programme national de surveillance de ‘activite des Culicoides, vecteurs de la fievre catarrale ovine’’- dispositif 2009) and the definition of a seasonal vector free period are based on a technical and scientific cooperation (convention) between the French Authorities and CIRAD, which defines the threshold (see CIRAD annual activity report 2008).

These documents do not make references to the requirement in Annex I, 1.2 of Regulation (EC) No. 1266/2007, for traps to be equipped with UV light and do not comply with the criteria established in Annex I, 1.2 of Regulation (EC) No. 1266/2007, regarding the operation rate of the traps, throughout the night .

Also, the documents do not make references to the requirement in Annex V of Regulation (EC) No. 1266/2007, in relation with species identification.

In progress

6. In the light of experience and risk assessment, consider the re-establishment of a surveillance zone extending beyond the limits of the protection zone, in which the

The entire national territory is protected area in view of the implementation of vaccination. Accordingly, this item is no longer relevant.

This recommendation is overtaken by the implementation of a mass

Action taken


87



Findings Assessment

provisions of Article 10 of the Directive are implemented (including monitoring groups of sentinel cattle and populations of vectors, and also an exit ban from the zone unless there are derogations and prohibition of vaccination) and implement the measures laid down in Article 7, 2 of Regulation (EC) No 1266/2007 for the movement of animals in the protection zone to the surveillance zone;

vaccination campaign.

7. Ensure that the protocols used routinely are validated by participation in the tests provided for in Appendix I, B, C) of Council Directive 2000/75/EC, and conform with procedures validated by virtue of under Annex II , B, 1, d) of the said Directive;

The French authorities confirmed that all laboratories listed in Annex I of Note de Service DGAL/SDPPST/N2009 – 8138 are approved for PCR for BT 1, and in the process of approval for the genotyping of the virus serotype BT 8.

The Departmental Veterinarian Laboratories (60), the National Control Laboratory for Breeding (LNCR) and AFFSA Laboratories of Sophia Antipolis (LERPRA - 06) participated in the interlaboratory test organised by AFFSA.

According to ''Rapport d'essai interlaboratoires d'aptitude RT-qPCR fièvre catarrhale ovine 2008'' dated 16 March 2008, in the first step, the laboratories were evaluated for their ability to detect the viral genome by RT-PCR in real time (RT-qPCR) and give a qualitative result (positive or negative).

In the second step, the laboratories were evaluated for their ability to identify by RT-qPCR the genotype 1 of BTV.

Also, AFFSA recommended to candidates laboratories to realize in parallel on the samples, an RT-qPCR type 8, in the eventuality of a future approval for the genotyping of the BT virus, serotype 8.

In progress

8. Inform the Commission and

The French authorities confirmed that the national territory is fully regulated under the serotype 8 of the bluetongue and the channeling

Action taken8

8 In their comments on the draft country profile, France confirmed that the whole territory of continental

France is now a single restricted zone for both serotypes 1 and 8. There is free movement provided that national vaccination requirements are met. The only restrictions under Annex III of Regulation (EC)


88



Findings Assessment

other Member States of the conditions for derogation from the exit ban from ZR established under Article 8, 1, b) of Regulation (EC) No. 1266/2007, and establish a routing procedure in accordance with Article 8, 3) of the Regulations to prevent any subsequent movement of these animals to another member state;

procedure is only applied for animals from zone 1-8. (see Note de Service 2009-8085 dated 12 March 2009).

A reminder of this procedure is contained in Note de Service 2009-8085 dated 12 March 2009, where it is specified that for these animals, the owner should provide a proof of compliance with conditions of release ZR1-8 (results of laboratory analysis, certificate of disinsection, vaccination – animal passport, containment - local level) for certification to intra community trade or any other trade. Without these elements, these animals will not be eligible for any trade.

Moreover, the French authorities indicated that the channeling procedure consists of surveillance of movements of animal ( DDSV level), throw the following IT systems: SIGAL – national establishment's identification, BDNI - national animal identification system TRACES - movements of the animals– for certification.

9. Establish effective control procedures to ensure that all the prescribed control measures to protect animals against vector attack in accordance with the requirements of Annex III, A of Regulation (EC) No. 1266/2007 are correctly applied;

The Commission wrote to the French authorities on 14 March 2008 requesting that France fully comply with the requirements of Regulation (EC) No 1266/2007 and to properly guarantee that the animals fulfil all the requirements of this Regulation before they are moved from a restricted zone and in particular to ensure that the animals are effectively protected from vectors attacks.

The French authorities were invited to describe arrangements in place to ensure that animals are protected against attacks by the vector Culicoides during transportation to the place of destination following the most recent amendment to Regulation (EC) No 1266/2007 as regards protection against attacks by vectors and minimum requirements for bluetongue monitoring and surveillance programmes

In progress

10. Ensure that the official control carried out in cattle assembly centres raising of guarantees, in accordance with the provisions of Article 11, 1) of Council Directive 64/432/EEC, that cattle reared and fattened for intraCommunity trade do not come

The French authorities indicated that Note de Service DGAL/SDSPA/2009-8085 dated 12 March 2009 precludes the possibility of animals crossing.

Also, they indicated that the animals are vaccinated (second line of protection).

Moreover, the ''new draft legislation'' which will place the responsibility for the approved assembly centres under the control of an official veterinarian in order to ensure compliance with EU requirements for assembly centres it is due to be adopted by the end

In progress

No 1266/2007 apply to animals from outbreak holdings or those not complying with vaccination requirements. As regards ICT, usual conditions apply.


89



Findings Assessment

into contact with other animals of species susceptible to Bluetongue which do not conform to Article 8, 1, a) of Regulation (EC) No. 1266/2007;


25581, 25582, 25587, 25588, 25589 and 13 in MR 7948/2007

of 2009(see also 25587).

The implementing measures for official control carried out in assembly centres being prepared in parallel with the ''new draft legislation''.


25581, 25582, 25588, 25589 and 13 in MR 7948/2007

11. Ensure that the certification of animals for intra Community trade is always in accordance with Article 3, 3) of Council Directive 96/93/EC, and that information relating to the certificates are transmitted to the competent authority of the place destination in accordance with Article 4, Article 2 of Directive 90/425/EEC;

See also recommendation No 25071 in MR 8179 / 2006

Two working groups on certification (live animals and products) completed their work at the end of 2008. New Decrees and implementing measures were being finalised:

Decree and Arrete on the '' conditions of accreditation of veterinarians with a health mandate as certifying veterinarians as provided for in Article L.221-13 of the Rural Code'' (in Chapter 2, article 7)

A Note de Service was also in preparation as well a vademecum for export certification ( due by 27 June). Copies of this could not be provided to the mission team as were not sufficiently mature. However, France undertook to provide copies when completed.

France confirmed that these instructions would be in full compliance with Article 3, 3) of Council Directive 96/93/EC and that a unique signature would be required.

The Decree and two Arrete are due to be adopted by the end of 2009. This involves the creation of a new category of '' Certifying veterinarians'' (CVs), a status similar to civil servant. Completion of specific training is a prerequisite to apply for this position. The call for tenders would be announced in Autumn 2009. Some 400-800 CVs are to be appointed. They will be paid by the State funded by a new tax and operators (negotiations with the trade were ongoing). The new arrangements are expected to be in operation from the beginning of 2010.

In progress


90



Findings Assessment

12. Transmit to the Commission, in accordance with the model established by the Decision 2007/846/CE, the list of assembly centres approved in accordance with Article 11 of Directive 64/432/EEC, and ensure that it is updated;

See recommendation 25586 In progress

13. Ensure the implementation of the proposed actions in response to the recommendations in the mission report DG (SANCO) 8152/2206 and indicated in this report, in particular to ensure an adequate control and supervision of approved assembly centres, and of the system of certification;


25581, 25582,25586, 25587, 25588, 25589


25581, 25582,25586, 25587, 25588, 25589

The new Decree and Arrete concerning ''the conditions of accreditation of certifying veterinarians under Article L.221-13 of the Rural Code, were being finalised and were expected to be published in the first quarter of 2010 (implementing instructions being prepared in parallel). Provisions for the charging of fees were included in the Law on Finances 2010.


In progress


91

3.2 Food of animal origin

Since 2004 the FVO has carried out 5 inspections in France in relation to food of animal origin. Out of a total of 36 recommendations contained in the reports of these inspections, 9 were identified for follow-up during the general review mission, 5 of which were carried over from the country profile of 2008 and 15 of which were contained in reports that had reached closeout stage since the 2008 general review mission.



92

Inspection 7023/2004 of 3/05/2004 on Live Bivalve Mollusc production and Fishery Products


Findings Assessment

(20596) Bivalve molluscs

The CA should bring its biotoxins monitoring system to compliance with the requirements of the LBM Directive by doing a more representative monitoring of biotoxins in LBM

This recommendation is outdated because 854/2004 now in force does not apply systematic surveillance except for toxic algae. Annual monitoring programme for toxins is published by IFREMER.

For 2009, IFREMER has identified 10 reference points along the coast, where it tests both the water and the shellfish once per month throughout the year. In addition, such parallel testing is carried out on a weekly basis in risk periods.

Bio-assays are systematic and all positive and suspect cases resulting from the bio-assay are subject to hemical analysis.

Action taken

(20598) Bivalve molluscs

Differences in the transposition of Community legislation to national legislation, reported in point 2.2.2.2., should be corrected

No further discussion was had with CRL. The revision of zones was requested at the start of 2009 on the basis that a 10% tolerance would apply only in the case of Class B areas.

A circular (reference CI/08/434111 was sent to prefects on 19 January 2009 followed by a Note de Service N2009-8132 on 6 May specifying that , in accordance with Regulation (EC) No 854/2004 (Annex II, Chapter 2, Part A, point 4) a 10% tolerance is applied to Class B areas.

Action taken

(20604)

A harmonised procedure should be introduced by the central CA to help the local CAs in starting the organisation and performance of the required checks on fishing vessels to ensure their compliance with the requirements of Council Directive 92/48/EEC,

Vade-mecum was being validated.

Action taken9

9 In their comments on the draft country profile, the French authorities confirmed that the document was

issued with reference number 7023-2004-20604 and was distributed to control staff in September 2009


93

Inspection 8179/2006 of 24/04/2006 on food safety (meat and milk)


Findings Assessment

(25071) To correct the deficiencies identified in the process of official certification;

See also recommendation 11 in MR 7948/2007 on bluetongue

Two working groups on certification (live animals and products) completed their work at the end of 2008. New Decrees and implementing measures were being finalised: Decree and Arrete on ''the conditions of accreditation of veterinarians with a health mandate as certifying veterinarian as provided for in Article L.221-13 of the Rural Code'' (in Chapter 2, article 7)".

A Note de Service was also in preparation as well as a vademecum for export certification (due by 27 June). Copies of these could not be provided to the mission team as they were not sufficiently mature. However, FR undertook to provide copies when completed. France confirmed that these instructions would be in full compliance with Article 3, 3) of Council Directive 96/93/EC and that a unique signature would be required.

The Decree and two Arrete are due to be adopted by the end of 2009. This involves the creation of a new category of “Certifying veterinarians” (CVs) a status similar to civil servants. Completion of specific training is a prerequisite to apply for this position. The call for tenders would be announced in Autumn 2009. Some 400-800 CVs are to be appointed. They will be paid by the State funded by a new tax on operators (negotiations with the trade were ongoing). The new arrangements are expected to be in operation from the beginning of 2010.


A Note de Service (DGAL/SDASEI/N2009-8200) was issued on 15 July 2009. Physical checks are to be carried out on the basis of risk analysis. A Working Group had been established to consider the parameters of the functions of the certifying veterinarian.


(25073) To reinforce the actions undertaken in establishments which do not satisfy community standards, particularly those in the meat sector.

See also

The number of “category IV” establishments has been reduced to 9 (from 18 in 2008). Inspections to these slaughterhouses are undertaken by a network of experts and designation as Category IV results in a high risk rating for frequency of controls. The Ministry set a deadline of end 2008 for the closure or reclassification of these establishments. It emerged that, in some cases, recommendations for closures by the veterinary services were not acted upon by Departmental prefects.

In cases where the prefect fails to act, the matter may be pursued politically via the Minister's office. The focus of activity of the


The Commission has initiated specific follow-up measures in the case of this recommendation

10 In their comments on the draft country profile, the French authorities confirmed that as at end December

2009, the number of establishments in category IV was one (down from 9 at the time of the mission). The deadline for elimination of category III was extended to 31.12.2010


94

Inspection 8179/2006 of 24/04/2006 on food safety (meat and milk)


Findings Assessment

recommendation 2008-7827-5

specialist network is now on category III establishments (currently 112 from 110 in 2008) where the deadline for closure/reclassification is 31 October 2010. This issue was pursued by FVO mission 8231/2009 which took place in France from 15 to 26 June 2009.

Recommendations reaching closeout note stage since the 2008 general review mission

Inspection 2007-7143 of 18-Nov-2007 in order to EVALUATE OFFICIAL CONTROLS OVER THE PRODUCTION AND PLACING ON THE MARKET OF INFANT FORMULAE, FOLLOW-ON FORMULAE AND BABY FOODS, INCLUDING THE SUPPLY CHAIN


Findings Assessment

2007-7143-1 To ensure that official controls are organised so that standards for potable water in establishments under the unique supervision of DGCCRF are subject to regular and risk based official controls as set out in Art. 3 of Regulation (EC) No 882/2004.

Controls are currently subject of DGS/SD7A/2005/334. A new Joint circular from DGAL and DGCCRF was planned but not drafted yet as the CCAs were reflecting on wider framework for water controls. DGCCRF undertook to include specific controls on water in TNs from 3rd or 4th quarter of 2009 and continue with this in 2010.

Action taken

2007-7143-2 To ensure the efficient and effective coordination between the CAs at local level in accordance with Art. 4(3) of Regulation (EC) No 882/2004.

Poles of competence and MISSA structures have been overtaken by the reform of CA structures at local level.

Action taken.

2007-7143-3 To take into account the criteria set out in Art. 3 of Regulation (EC) No 882/2004 and Art. 4(9) of

Note de Service N2008-0487 of 2 June 2008 sets out the criteria for risk based controls. Note de Service N-2008-8078 of 2 April 2008 defines how inspections are to be followed up.

Action taken


95

Inspection 2007-7143 of 18-Nov-2007 in order to EVALUATE OFFICIAL CONTROLS OVER THE PRODUCTION AND PLACING ON THE MARKET OF INFANT FORMULAE, FOLLOW-ON FORMULAE AND BABY FOODS, INCLUDING THE SUPPLY CHAIN


Findings Assessment

Regulation (EC) No 854/2004 in the organisation of the SRAL official control programmes and to fully implement these programmes.

2007-7143-4 To develop documented procedures in accordance with Art. 8(1) of Regulation (EC) No 882/2004 for official controls in the evaluated sector.

Instruction DGAL/MAPP/L2009-9002 recalls that, in the context of the DGAL quality system, the use of standardised inspection methods and checklists is compulsory. The input of results into the database (SIGAL or SIPV) is also obligatory. The process of preparing new joint inspection checklists with DGCCRF had been suspended pending the reform of services at local level.

In progress

Inspection 2008-7827 of 17-Nov-2008 in order to evaluate the control systems in place governing the production and placing on the market of poultry meat


Findings Assessment

2008-7827-1 L'ACC devrait assurer qu'il y a assez de personnel qualifié disponible pour l'exécution de toutes les tâches de contrôles officielles au niveau des établissements selon des exigences de l'article 4 du Règlement (CE) n° 882/2004 et de l'article 5, paragraphe 5 a et b du Règlement (CE) n° 854/2004.

An additional 75 FTE official veterinarians (in addition to existing 20-30 FTE) to be recruited and training to be provided.

The French authorities were invited to provide an update on the Action Plan to be provided to Commission demonstrating whether the additional staff are sufficient to cover the ante- and post-mortem inspections in about 439 EU approved abattoirs and in about 825 EU approved slaughter rooms in small premises (salles d'abattages).

In progress

2008-7827-2 L'ACC devrait assurer qu'une formation spécifique sur le bien être des animaux dans le cadre de l'inspection ante mortem soit donné aux agents

DGAL had undertaken to produce new checklist by June 2009 and provide training on animal welfare. See recommendation 25594



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Findings Assessment

officiels selon les exigences de l'annexe I, section I, partie B, point 2 (a) du Règlement (CE) n° 854/2004.

2008-7827-3 L'ACC devrait assurer que les points de prélèvement dans les établissements soient inclus lors de l'échantillonnage officiel et que la fréquence d'échantillonnage pour les analyses officielles pour l'eau dans les établissements consommant plus que 100 m³ d'eau par jour soit conforme à la directive 98/83/CE du Conseil.

DGAL sent a note to the DRAAFs and SRALs on 13 March 2009 (DGAL L2009-0214) informing them of the deficiencies identified by the FVO mission and requesting that these be rectified.

Action taken

2008-7827-4 L'ACC devrait assurer que les inspecteurs vérifient les résultats d'analyse de laboratoires dans le cadre des autocontrôles disponibles dans les établissements et qu'ils assurent immédiatement un suivie si ces analyses montrent des résultats qui indiquent un risque immédiat par le consommateur selon les exigences de l'article 4, point 8 du Règlement (CE) n° 854/2004.

DGAL was to issue instruction to SRALs in February 2009.

In progress

2008-7827-5 L'ACC devrait assurer que seulement les établissements qui sont en conformité

See recommendation 25073.

As of 1 January 2009, there were 5 poultry establishments in category IV (0.1% of production). The objective is to have 100% of

In progress


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Findings Assessment

selon les exigences de l'article 31 du Règlement (CE) n° 882/2004 détiennent un agrément communautaire.

slaughterhouses in categories I or II by 30 June 2011.

2008-7827-6 L'ACC devrait assurer que la fréquence de leurs visites d'inspection correspond à la fréquence déterminée par leurs propres services d'inspection.

DRAFFS were to review inspection frequencies for each department in their region to establish a national overview.

In progress

2008-7827-7 L'ACC devrait assurer que les non-conformités détectées par les inspecteurs soient corrigées dans des délais adaptés par les opérateurs selon les exigences de l'article 9 du Règlement (CE) n° 854/2004.

Local inspection services had been requested to ensure that deficiencies identified by FVO had been corrected.

In progress

2008-7827-8 L'ACC devrait assurer que la FICA soit introduit et utilisé sur tout le territoire français comme prévu par le Règlement (CE) n° 853/2004, annexe II, section III.

The main points of the Action plan were:

The use of a "health fiche" as defined in Order of 8 September 2000 is regarded by France as meeting the objectives of this section. An Order to require use of harmonised model was in preparation. CCA also undertook to reinforce controls on documentary checks in slaughterhouses.

In progress

2008-7827-9 L'ACC devrait assurer que les IAM soient réalisées selon les exigences de l'annexe I, section I, chapitre II du Règlement (CE) n°

See also recommendation 2008-7827-1.and 25594

DGAL planned to have visits to all poultry holdings in the first half of 2009.

The Action Plan did not address ante-mortem inspection in small


11 In their comments on the draft country profile, the French authorities indicated that a meeting on this

topic was being arranged with the Commission


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Findings Assessment

854/2004. slaughterhouses.

Formal notification to the Commission of pilot project Ante mortem (Article 17 of Regulation 854/2004) was expected to be done in July 2009


France submitted a pilot project to the Commission on 25 September 2009. 35 FTE official veterinarians had been allocated to control the sector, including ante mortem. Work was underway on possible organisation in certain cases of ante mortem checks at the holding by approved veterinarians.

2008-7827-10 L'ACC devrait assurer que lors de l'IAM le bien-être des volailles est inspecté selon les exigences de l'annexe I, section I, chapitre II, du Règlement (CE) n° 854/2004.

Existing arrangements are described in Note de Service N2008-8056. A new checklist was being drawn up. This was expected by June 2009.

In progress

2008-7827-11 L'ACC devrait assurer que les IPM sont réalisées selon les exigences de l'annexe I, section I, chapitre II du Règlement (CE) n° 854/2004 et l'annexe I, section III, chapitre III du Règlement (CE) n° 854/2004.

See recommendation 2008-7827-1. Note de Service N2008-0487 of 2 June 2008 sets out the criteria for risk based controls but the issue of post-mortem inspection in small slaughterhouses was not addressed.


The criteria for the evaluation of slaughterhouse personnel are set out in Note de Service 2009/8030 of 21 January 2009. The circumstances in which personnel must notify the veterinary services are set out in Note de Service 2009/8066 of 18 February 2009. Both of these Notes were included in the notification referred to at recommendation 2008-7827-9.



99

3.3 Imports of animals and food of animal origin

Since 2004 the FVO has carried out 4 inspections in France in relation to imports of animals and food of animal origin. Out of a total of 66 recommendations contained in the reports of these inspections, 22 were identified for follow-up during the general review mission, 2 of which were carried over from the country profile of 2008 and 20 of which were contained in reports that had reached closeout stage since the 2008 general review mission.

Recommendation carried over from the country profile of June 2008

Inspection 7522/2005 of 17/03/2005 on Import controls and border inspection posts


Findings Assessment

(22774) To rectify the major deficiencies noted for facilities in Orly, Le Havre, Dunkerque, and for the product Ics in Marseille-Port. In the meantime an interim solution must be developed and implemented to rectify the major short comings.

For the Orly airport BIP, plans to upgrade it were sent to the Commission on 18 May 2009.

For Le Havre, a completely new BIP has been built.

For the Dunkerque BIP, plans to upgrade it have been sent to the Commission for approval.

For Marseilles, the French authorities confirmed that the remaining shortcomings related to equidae had been satisfactorily addressed.

In progress

Inspection 8055/2006 of 23/01/2006 on import controls and border inspection posts


Findings Assessment

(24447) To ensure that the veterinary supervision of destruction of rejected consignments and the disposal of kitchen waste is applied in line with the provisions of Directive 97/78/EC and related Decisions and Regulation (EC) No 1774/2002 and of Directive 1999/31/EC.

The destruction of rejected consignments and the disposal of kitchen waste are addressed in Chapter 9 of the inspection guide for import controls (Version 1, dated 1 March 2009).

Action taken


100

Inspection 2008-7757 of 07-Apr-2008 in order to evaluate import / transit controls and border inspections posts


Findings Assessment

2008-7757-1 To complete transposition of Art. 6 and 24 of Directive 97/78/EC and Directive 2004/68/EC.

Transposition of Article 6(1)(a) of Directive 97/78/EC: The French authorities are of the opinion that the provisions of Article 6(1)(a) of Directive 97/78/EC have been correctly transposed and are applicable in the national territory. They consider that Commission decisions listing border inspection posts are directly applicable in national law and do not require transposition. In addition, they consider that since the list of border inspection posts is established by a joint decree of the Minister responsible for agriculture and the Minister responsible for the customs service, it meets the full requirements of Article 6 of Directive 97/78/EC. The Commission maintains that Article 6(1)(a) of Directive 97/78/EC, which requires a border inspection post to be located in an area which is designated by the customs authorities, has not been transposed into French law. (Action still required) Transposition of Article 24 of Directive 97/78/EC: The Commission agrees with the French authorities that the rule requiring the next 10 consignments to be subjected to more stringent checks, according to Directive 97/78/EC, must be applied at Community level rather than at national level. DG SANCO is at present preparing a guidance document for the application of the 10-consignment rule. (Closed) Transposition of Directive 2004/68/EC: The draft amendment to the Administrative Order of 19 July 2002 (establishing hygiene conditions for import into and transit through the metropolitan territory or overseas departments of live animals and certain animal products), which was originally expected to be published by 1 July 2009, is now expected to be published before 1 September 2009. (In progress)

In progress

2008-7757-2 To review relevant instructions and manuals in order to provide clear guidance, as required by Art. 8.1 of Regulation (EC) No 882/2004, in order to facilitate and ensure correct implementation of veterinary checks – including, in particular, documentary checks for live animals and POAO, correct veterinary decision and completion of CVED and follow up

Inspection guide and vademecum: As envisaged, the inspection guide for import controls (Version 1, dated 1 March 2009), and Vademecum for import controls on products of animal origin (Version 1, dated 1 June 2008) have been distributed to BIPs. They address the different procedures applied at BIPs, including those relating to reduced physical checks, reinforced checks, re-import, transit, transhipment and rejection of consignments. The guide also includes a chapter on channelled consignments covered by Article 8 of Directive 97/78/EC. The Vademecum has already been validated for controls on products of animal origin, and is in the course of being validated for controls on live animals. Reinforced checks: The central authority issued a national instruction on 29 May 2008 concerning the procedure for reinforced checks.

Action taken


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Findings Assessment

for consignments needed monitoring by the BIP.

To apply the correct procedures concerning reduced checks, reinforced checks, re-import, rejected, re-dispatched and channeling procedure.

2008-7757-3 To put in place administrative measures to ensure the proper application at all entry points of Regulations (EC) No 998/2003 [pet animals] and (EC) No 745/2004 [products for personal consumption] and Decision 2007/25/EC [pet birds] and clarify the responsibilities of the different services also for supervision of customs warehouses and disposal of kitchen waste.

To take measures to ensure the correct application regarding the checks, provision of information to travellers and officials at all entry points and in the collection of information regarding seizures in order to fully implement the provisions of Artt. 3,

Procedure for checking pet animals and birds (Regulation (EC) No 998/2003) and 2007/25/EC: In relation to the list of points of entry and frequency of controls to be carried out on pet animals under Articles 13 and 12 respectively of Regulation (EC) no 998/2003, the French authorities indicated in a letter dated 26 May 2008 that Article L.236-4 of the Code Rural stated that for pet animals accompanying travellers, the control may be carried out in any port, airport, bus or railway station. In addition, the French authorities consider that the Regulation allows a policy of risk analysis to be applied in identifying the pet animals to be checked.

A risk-based approach may only be applied in relation to the geographical distribution and the number of entry points where pet animals may pass, but all pet animals at these entry points must be checked in accordance with Article 12. It is necessary, however, to carry out a documentary and identity check on each pet animal. (Action still required) Additional information received from France on 28 September 2009

The French authorities indicate that controls are carried out in line with the Rural Code (Article L.236-4). The French authorities were invited to confirm whether a documentary and identity check would be carried out on each pet animal. Procedure for checking travellers’ luggage (Regulation (EC) No 745/2004): Instructions on imports of products of animal origin intended for travellers’ own consumption were clearly reiterated in the restricted administrative order No 08-S-011 dated 14 March 2008.

Article 4 of Regulation (EC) No 745/2004 requires the customs services to organise controls to detect the presence of illegal consignments of meat and meat products and milk and milk products. These controls are organised according to an approach



102



Findings Assessment

4 and 5 of Regulation (EC) No 745/2004 including their destruction in accordance with Annex II of Regulation (EC) No 1774/2002.

To ensure that for each consignment of non-commercial pets a documentary and an identity check is carried out in accordance with Art. 12 of Regulation (EC) No 998/2003 and provide for that aim microchip readers in all points of entry including updated instructions.

based on risk analysis, as prescribed by the Community legislation.

Major international points of entry such as Roissy airport have scanning equipment for efficient detection of such products in large volumes of luggage.

DGDDI stated that an instruction concerning checks on food of animal origin carried in travellers’ luggage would be distributed to the relevant services as soon as Regulation (EC) No 745/2004 laying down measures with regard to imports of products of animal origin for personal consumption is repealed.

As regards more specifically the procedures for the destruction of seized foodstuffs, instructions have already been given to the services and are applied by every regional directorate. (In progress) Information to travellers: Responsibilities for the provision of information to travellers in accordance with Regulation (EC) No 998/2003 and Regulation (EC) No 745/2004 are not yet clear. (Action still required) Additional information received from France on 28 September 2009

The additional information did not address the issue of responsibility for the provision of information. Collection of data on seizures: The regional customs directorates submit monthly details of their activities in application of Regulation (EC) No 745/2004 (seizures from travellers) via the SPHINX system. The information includes where the travellers concerned came from, the number of checks carried out, and the number of finds. Statistics are thus forwarded in accordance with the requirements of Annex IV to Regulation (EC) No 745/2004. Goods abandoned voluntarily in the airport area before the customs checkpoint cannot be included in the figures reported. Only seizures and goods given up voluntarily when passing through Customs are counted. (Action taken) Destruction of seized goods: The customs service confiscates any non-compliant foodstuffs, or invites the traveller to give them up voluntarily. Goods seized by Customs are destroyed in accordance with Annex II to Regulation (EC) No 1774/2004. Measures to monitor the collection, transport, use and disposal of animal by-products and processed products have been introduced at local level taking account of the specific nature of the flows of goods identified within the customs directorate concerned. (Action taken)

Monitoring of kitchen waste: See recommendation 7 below (In progress). Micro-chip readers: DGDDI reported that a budget had been provided to regional


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Findings Assessment

services to purchase micro-chip readers, and that the Regional Directorates had recently been requested to report on whether the micro-chip readers had been purchased and were being used

The authorities confirmed that upon receiving the up-to-date situation from all Regional Directorates, they would if necessary issue an instruction to them to purchase the readers within a defined timeframe. (In progress)

2008-7757-4 To complete the lists with all the relevant points of entry for

-personal luggage checks,

-non-commercial pets, birds and

-CITES consignments

in order to apply properly

-Art. 4 of Regulation (EC) No 745/2004 [products of animal origin for personal consumption],

-Art. 13 of Regulation (EC) no 998/2003 [movement of pet animals],

-Art. 2 of Decision 2007/25/EC [pet birds],

-Art. 4 of Directive 91/496/EEC and

-Art. 3 of Directive 97/78/EC.

List of international points of entry for luggage: As far as the French authorities are aware, there is no statutory obligation to draw up an official list of international points of entry. Furthermore, although it did request lists of ‘CITES' or ‘pet animals’ entry points, the Commission has never asked for such a list for ‘luggage’. (Closed) List of international points of entry for non-commercial pets: In relation to the list of points of entry and frequency of controls to be carried out on pet animals under Articles 13 and 12 respectively of Regulation (EC) No 998/2003, the French authorities indicated in a letter dated 26 May 2008 that Article L.236-4 of the Code Rural stated that for pet animals accompanying travellers, the control may be carried out in any port, airport, bus or railway station. (Closed) Lists for CITES consignments: The French authorities provided a satisfactory response. (Closed)

Action taken

2008-7757-5 To take appropriate measures and instructions in order to improve the system of supervision in customs warehouses and ship suppliers, including clarification of responsibilities, in order to apply

Division of responsibilities for monitoring customs warehouses and ship suppliers: DGAL stated that all customs warehouses and ship suppliers come under the jurisdiction of customs. Clear instructions on this subject are found in official customs bulletin No 08-019 of 17 March 2008.

France does not have any free or customs warehouses approved for the storage of non-compliant consignments within the meaning of Article 12 of Directive 97/78/EC.

The veterinary services monitor only establishments which have been granted approval within the meaning of Directive 97/78/EC, i.e. only approved ship suppliers in France’s case. (Closed)



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Findings Assessment

correctly the EU requirements in accordance with Art. 12 and 13 of Directive 97/78/EC and Art. 4 of Regulation (EC) No 136/2004 and records of regular checks in customs warehouses and ship suppliers to be kept at the BIPs in accordance with paragraph 5(4) of Decision 2001/812/EC.

Also to ensure that registration, notification of CA of destination, sealing, exit checks and system for cleaning/disinfection of means of transport for non-EU complying consignments are applied.

To ensure that a system to monitor transhipments is in place in all the relevant BIPs.

Records of regular checks in customs warehouses and ship suppliers: Paragraph 5.4 of the Annex to Commission Decision 2001/812/EC states: "Regular checks must be made at the… [ship] suppliers concerned , and a record to demonstrate this must be kept in the office of the BIP". In section 5.2.4 of the mission report, there was a finding that: "No records of regular checks in customs warehouses and ship suppliers were kept in the office of the border inspection post." It remains unclear whether the French authorities have adopted measures to ensure that records of regular checks on ship suppliers are kept in the BIP offices. (In progress) Customs checks at customs warehouses and ship suppliers DGDDI confirmed that clear instructions on this subject had been distributed to all customs services through administrative order No 08-019 of 14 March 2008, and that the measures implemented were compatible with Community legislation. They stated that a consignment requiring a CVED may not be placed on the market or in a customs warehouse without first being inspected by the competent veterinary services. The French authorities provided details of how checks may be carried out at any one of the following warehouse stages: before placing in a customs warehouse; within the warehouse; and on leaving the warehouse. In relation to veterinary checks at ship suppliers, the French authorities informed the Commission that they do not have the resources to ensure the presence of a veterinarian at ship suppliers every time a consignment arrives or departs. They also informed the Commission that they would like the Community legislation on this subject to be amended, since they consider this surveillance to be unnecessary, based on the fact that consignments enter the Community territory accompanied by a health certificate providing animal health guarantees. (Action still required)

Veterinary checks at customs warehouses:

DGAL stated that Article 12 of Directive 97/78/EC on the approval and supervision of warehouses had been transposed by the Decree of 5 May 2000, and that a legal basis was thus in place. France does not have any free or customs warehouses approved for the storage of consignments which are non-compliant within the meaning of Article 12 of Directive 97/78/EC. (Closed) Transhipments: The French authorities stated that this matter is covered in the inspection guide distributed to BIPs at the beginning of 2009. (Action taken)

2008-7757-6 To ensure that all necessary

Channelling procedure as per Article 8 of Directive 97/78/EC (checks on products): See recommendation 2 above, relating to the inspection guide which

In progress


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Findings Assessment

documentation such as list of channeled establishments, approved bodies, are provided to the BIPs together with the relevant instructions how to use these lists for channeled consignments in accordance with Art. 8 of Directive 97/78/EC and controlled destinations in accordance with Art. 4 of Regulation (EC) No 282/2004.

To ensure that updated IATA rules are in place and RASFF messages are entered immediately in Impadon or the BIPs receive directly all RASFF messages.

was distributed to BIPs at the beginning of 2009. It includes a chapter on channelled consignments covered by Article 8 of Directive 97/78/EC.

The central authority has always provided BIPs with an up-to-date list of establishments approved in accordance with Regulation (EC) No 1774/2004, the most recent update having been forwarded by instruction No 08-136 of 11 March 2008.

However the list of approved ABP establishments http://agriculture.gouv.fr/IMG/pdf/liste_etablissementagrees.pdf does not identify those establishments which have been approved under Article 8 of Directive 97/78/EC12. (In progress)

Approved bodies in accordance with Article 4 of Regulation (EC) No 282/2004 (checks on animals): The provisions of Directive 92/65/EC (on imports into the Community of animals, semen, ova and embryos not subject to animal health requirements laid down in specific Community rules referred to in Annex A (I) to Directive 90/425/EEC) on officially approved bodies and centres are in the process of being transposed into French law, therefore a list is not available at the moment.

A draft national administrative order is currently at the internal consultation stage, and a first list should appear by the end of the year. (In progress)

Use of RASFF messages: A study has been carried out of the time lags between notification of an RASFF message to the Member States and the introduction of reinforced checks. Since the beginning of 2008, the average time-lag observed is three working days, which seems satisfactory given the time needed for forwarding information and for the necessary hierarchical validations. (Closed) IATA rules: The obligation to carry out the checks according to the IATA rules pursuant to Regulation (EC) No 1/2005 is included in the inspection guide distributed to BIPs at the beginning of 2009. (Action taken)

2008-7757-7 To ensure that the requirements for collection, transport and records for destruction of kitchen waste from international means of transport are implemented as laid down in Annex II to

The provisions applicable to the destruction of kitchen waste are included in the inspection guide distributed to BIPs at the beginning of 2009.

A national instruction on the processing of waste collected at international entry points was expected to be updated and sent to the regional services before 1 July 2009.

In progress

12 In their comments on the draft country profile, the French authorities indicated that a column concerning

channelling would be added to the list of approved establishments

http://agriculture.gouv.fr/IMG/pdf/liste_etablissementagrees.pdf


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Findings Assessment

Regulation (EC) No 1774/2002, including detailed instructions and clarification of responsibilities.

2008-7757-8 To update the registration systems in place to ensure that all the information required under paragraph 4 of the Annex to Commission Decision 2001/812/EC is maintained.

To ensure that the system of supervision and monitoring for entry transit consignments has no gaps in particular in relation to their exit from the EU territory in accordance with Art. 11 of Directive 97/78/EC.

Registers required by the Annex to Decision 2001/812/EC: Decision 2001/812/EC has been amended by Decision 2006/590/EC to take account of the use of the TRACES application. Point 4 of the Annex reads: "The following alternative records shall be kept in electronic or paper form where the data are not entered in TRACES at the border inspection post…" The French authorities maintain the legislator’s intention was primarily to avoid duplication of effort, and consider that, since the French BIPs use the TRACES application, the registers referred to in section 4 of the Annex to Decision 2001/812/EC are no longer required.

Since the following information is not included in TRACES, compliance with Commission Decision 2001/812/EC requires such records to be kept in electronic or paper form at the BIP:

• all information required by Decision 97/152/EC, on re-dispatched consignments

• the requirement in paragraph 4.3 of the Annex for the register to record all instances where there is a deadline for action or response by the official veterinarianin the case of goods rejected, sent in transit, or channelled, and where follow-up action is required13. (In progress)

In relation to records on waste (in accordance with paragraph 5.3 of the Annex of the same Decision) the French authorities referred to recommendations 3 and 7. In this regard, it remains to be clarified whether the national instruction on the processing of waste collected at international entry points (expected to be issued before 1 July 2009) requires records to be kept of checks on the disposal of waste made under the official veterinarian's responsibility. (In progress)

Land transit procedure: This point is covered in the inspection guide distributed to BIPs at the beginning of 2009. See also recommendation 2. (Action taken)

In progress

2008-7757-9 To rectify all major shortcomings noted for facilities, equipment and hygiene for the BIPs Roissy CDG,

Action plan for Roissy (CDG) BIP: An order restricting the scope of the BIP was adopted on 18 May 2009, and notified to the EU Commission on 2 June 2009. The French authorities confirmed that they had been in discussions with the airport authority since the FVO mission; the airport authority was required to submit a satisfactory action plan to upgrade the BIP before 31 December 2009. This plan was then expected to be submitted to the EU Commission. (In progress)

In progress

13 In their comments on the draft country profile, the French authorities referred to an exchange of

correspondence with the Commission. Based on a communication from the Commission dated 23 October 2009, the position is regularised.


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Findings Assessment

Concarneau-Douarnenez, Brest and Lyon-Saint-Exupery in order to implement the provisions of Art. 6 and Annex A to Directive 91/496/EEC and Annex II to Directive 97/78/EC and Decision 2001/812/EC.

Action plan for Brest BIP A plan for new installations was forwarded to the Commission for validation by letter dated 6 February 2009. They indicated that they would give an instruction to commence works as soon as a favourable reply was received. (In progress) Action plan for Concarneau-Douarnenez BIP Withdrawal of approval was asked by the CCA to the Commission on 15.04.2009. (Action taken) Action plan for Lyon BIP The French authorities confirmed that they had sent a letter to the EU Commission on 7 April 2009. They indicated that they would give an instruction to commence works as soon as a favourable reply was received. (In progress)

2008-7757-10 To rectify all minor shortcomings for facilities, equipment and hygiene in all BIPs in accordance with the provisions of Decision 2001/812/EC.

The French authorities provided a satisfactory response for the BIPs Vatry and Marseille Fos-sur-Mer. (Action taken)

The French authorities confirmed that they would request action plans for correction of minor shortcomings for facilities, equipment and hygiene for the BIPs Roissy CDG, Brest and Lyon.

In progress

2008-7757-11 To take further measures to ensure that veterinary checks, including the application of a sampling monitoring plan as foreseen in the Annex II to Regulation (EC) No 136/2004 are implemented fully in line with the requirements of Directives 97/78/EC, 91/496/EEC and Decision 97/794/EC.

In particular to ensure that all BIPs participate in the sampling programme and all the necessary tests prescribed for specific consignments in EU legislation are

Monitoring plan in Annex II to Regulation (EC) No 136/2004 A special budget for the monitoring plan has been allocated directly to the BIPs. Appropriations are distributed by comparing import flow forecasts and the central authority’s monitoring requirements. The initial appropriation allocations may be adjusted during the year in accordance with the government’s political choices. Concerning products of animal origin, clear instructions have been distributed in a service memo which is updated regularly, most recently by letter (ref. 2008-196) of 23 April 2008.

The inspection guide and vademecum were sent to BIPs at the beginning of 2009. They include all the information needed for the application of EU legislation. Section D 7 of the Vademecum incorporates points 1-3 of Annex II to Regulation (EC) No 136/2004. In order to address the shortcomings identified in Part 6.3.4 of the mission report, the French authorities issued an instruction on 2 June 2008 to BIP staff to carry out sampling of each imported consignment of fishmeal for use in animal feed. (Closed) Compliance with Decision 97/794/EC Annex II to Decision 97/794/EC requires 3% of the consignments to be subject to serological sampling on a monthly basis, and at least 10 % of the animals of the consignment to be sampled. The French authorities stated that concerning live animals, the



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carried out. provisions of Annex II to Decision 97/794/EC were not being applied for equidae. In view of the commercial value of registered equidae presented at BIPs, the French authorities consider that they cannot take the risks associated with medical intervention. In view of the fact that 95 % of equidae presented at the BIPs are of high value, and are accompanied by documentation, the French authorities consider that the sampling requirements are met by the accompanying documentation. (Action still required) Sampling meat from equidae from Mexico: In relation to sampling meat from equidae from Mexico, as covered by Commission Decision 2006/27/EC, the French authorities confirmed that they had issued an instruction to their authorities in December 2006 to address this issue. It is not clear whether the French authorities have taken measures to retain consignments of equine horse meat pending the results of analyses. (In progress)

2008-7757-12 To further develop the use of TRACES and ensure that correct and complete information is entered into it and is in accordance with Regulations (EC) No 136/2004, (EC) No 282/2004 and Decision 2004/292/EC.

During the mission the French authorities demonstrated to the inspection team that the non-compliances found were attributable to the performance of the TRACES application: slowness and malfunctions; missing or inappropriate functions (e.g. transhipping, ship supply consignments); inappropriate error messages; and the need to resort to paper CVEDs.

The French authorities provided an extract from an audit report to show that the entry of information into TRACES was being assessed by their own audits of BIPs.

Action taken

2008-7757-13 To further develop the training programme for BIP staff for 2008, in particular for the procedures, in order to apply properly the provisions of Art 6 of Regulation (EC) No 882/2004.

The French authorities described their training arrangements in the pre-mission questionnaire and during the mission. The following information was provided in connection with missions DG(SANCO)/2006-8055 and DG (SANCO)/2008-7757:

• ‘The officials from the BIPs are subject to a system of continuing training. This system is based on the constant flow of information between the BIPs and the central authority, accompanied by occasional on-site visits by the BIPT carried out jointly with the DDSVs, particularly when problems are reported to it.

• All officials who are newly appointed to a BIP are systematically sent on a training course, lasting at least one week, at a larger BIP involved in similar work. As a general rule, trainees at BIPs at ports are sent to Le Havre while trainees at BIPs at airports go to Roissy Charles de Gaulle Airport.

• National training and information meetings lasting two days are organised for all BIP veterinarians on a half-

In progress


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Findings Assessment

yearly basis.’

• ‘Since 2004 a training course for BIP and customs officials has been held each year at the ‘Ecole nationale des services vétérinaires’ in Lyon. The one-week course covers the basics of veterinary checks in connection with import and transit, the main regulatory references, and the procedures applied at the border. The next course will be on 17–20 March 2008.’

This means that around 20 people attend a national training course each year. Technical staff accounted for eight out of 20 trainees in 2008 and 11 out of 17 trainees in 2007.

As there are around 100 staff in the country, training needs will be covered in a five-year cycle. The French authorities consider that if this interval were shortened, training would become too repetitive. They consider that current arrangements are satisfactory, as ad hoc needs (new recruits) can be met by practical training at other BIPs and by an on-site mentoring system.

It remains unclear whether the 2008 or 2009 training programmes have been adapted to address the shortcomings identified in this mission, in particular those identified in Section 6.3 (point 3).

2008-7757-14 To take measures so that to ensure that the number of staff in Roissy CDG is increased in order to be in accordance with Annex of Directive 97/78/EC and paragraph 2 of Annex to Decision 2001/812/EC.

The Roissy BIP has recruited one additional veterinarian, bringing the number of full-time posts to 16.

Action taken

2008-7757-15 To take the measures necessary for co-operation and coordination with customs and other authorities and operators to ensure that the exchange of information and access to databases as required in Artt. 6 and 7 of Regulation (EC) No 136/2004 and Artt. 5 and 6 of Regulation (EC) No 282/2004 is put in place.

Information exchange with Customs is regulated by a protocol on cooperation dated 4 May 2001. BIP staff may obtain certain data from the Customs database "DELTA@" on request.

Customs check manifests to verify that all merchandise which should be subject to veterinary inspection is in fact chanelled to the BIPs. In accordance with Articles 6 and 7 of Reg 136/2004 the veterinary services have full access to these documents via the ADEMAR system in Le Havre and Marseille.

The project to have inter-connectivity between TRACES and "DELTA@" is now operational. It is expected to be tested in summer 2009 under real conditions in the BIPs at Le Havre port and Roissy CDG airport. After testing, inter-connectivity between the two systems is expected to be applied throughout all French territory at the beginning of 2010.

In progress


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Findings Assessment

To ensure that prenotification is correctly applied in all BIPs, all manifests are received in time and meaningful cross checks with prenotifications are carried out in accordance with the EU provisions.

To improve cooperation with other authorities concerning correction of shortcomings for facilities, disposal of kitchen waste and information to travellers for illegal imports.

To ensure that consignments are presented upon introduction at the EU territory to the BIPs prior to their storage.

2008-7757-16 To ensure that a system is put in place in order to link the positive list of Decision 2007/275/EC with consignments in transit.

Transit surveillance, NSTI: Where goods covered by Decision 2007/275/EC are placed in customs transit, the operator must enter code 853 under ‘type of document’ and ‘document reference’, corresponding to the obligation to hold a veterinary control certificate or CVED. The designation and CVED references appear in box 44 of the accompanying document (DocAcc).

This means there is a computer link between the positive list under Decision 2007/275/EC and the NSTI computerised customs procedure.

Action taken

2008-7757-17 To further develop the deterrent measures such as penalties and liability for the cost of destruction of illegal imports to apply to all travellers in accordance with Art. 4 of Regulation

Article 4 of Regulation (EC) No 745/2004 states that the competent authority of the Member State may, at its discretion, require the person responsible for a personal consignment to meet the costs or pay penalties. In France, fines may be imposed on travellers responsible for illegal imports.

The measures applied by France are thus compatible with the recommendations in Article 4 of Regulation (EC) No 745/2004.

DGDDI indicated that fine thresholds are fixed by each regional directorate, and that there were no plans for changes to the tariffs applied.

Action taken


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Findings Assessment

(EC) No 745/2004.

2008-7757-18 To further develop the system for supervising the BIPs, in order to ensure that corrective actions for deficiencies are carried out in the deadlines laid down in Decision 2001/812/EC and start the auditing of BIPs in accordance with Art. 4(6) of Regulation (EC) No 882/2004.

In a letter of 24 July 2008 (ref. 080718), the DGAL forwarded to the Commission a memo on its internal audit system. It now considers that inspections carried out at BIPs by the BIPT correspond to internal audits within the meaning of Regulation (EC) No 882/2004.

Accordingly, service memo 07-640 of 22 January 2008 is soon expected to be amended in order to replace the term ‘contrôle technique internal (internal technical check)’ by ‘audit interne (internal audit)’.

They indicated that the audit system would address the completion within specified time frames of action plans implementing corrective actions for deficiencies in BIPs, as described in recommendations 9 and 10.

In progress

2008-7757-19 To ensure that veterinary fees are collected at the minimum EU level in accordance with Art. 27 of Regulation (EC) No 882/2004.

(Recommendation 24444 of Inspection 8055/2006 also addresses this issue)

Veterinary fees for imports according to the amended order of 12 July 2000 are currently lower than the rates stipulated in Annex V to Regulation (EC) No 882/2004. The French authorities regard this situation as legitimate.

In citing the provisions of Articles 27.3 and 27.4 of Regulation (EC) No 882/2004, the French authorities are of the opinion that where the actual cost of checks is less than the minimum fees laid down in Annex V, the competent authority has both the right and the obligation to adapt its fees to the actual cost.

Each year, the French authorities calculate the costs of the previous year’s import checks with a view to ensuring that they correspond overall to the fees actually collected during the year. The French authorities provided a list of costs taken into account at each BIP. This information was sent to the Commission in a letter of 28 February 2008.

The Commission is currently carrying out a survey on fees in Member States. The French authorities have described the above situation in their response to the Commission survey. The French authorities' position will be reviewed in light of the outcome of the Commission survey. Additional information received from France on 28 September 2009

Following correspondence with the Commission (DG SANCO letter D(2009) 550080 dated 20 April 2009) and in view of the ongoing review of fees by the Commission, this recommendation is closed.

Closed

2008-7757-20 To ensure that non-harmonised fishery products are restricted to the

This recommendation was closed as the legal requirement had been repealed.

Closed


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Findings Assessment

domestic market in accordance with Art.17 of Regulation (EC) No 2076/2005.


113

3.4 Feedingstuffs and animal nutrition

Since 2004 the FVO has carried out 1 inspection in France in relation to feedingstuffs and animal nutrition. Out of a total of 5 recommendations contained in the reports of these inspections, 1 was identified for follow-up during the general review mission, which was carried over from the country profile of 2008.

Recommendation carried over from the country profile of June 2008

Inspection 7263/2007 of 19/06/2007 on official controls on feed and compliance with requirements for feed hygiene


Findings Assessment

5. To identify and register FBOs as required by Art. 9 of Regulation (EC) No 183/2005 and to put in place a system of official controls to check their compliance with the relevant feed hygiene requirements.

DGAL is responsible for registering FBOs that carry out on-farm production of mixtures of feedingstuffs. To this end, an identification system was put in place in the livestock sectors at the end of 2007:

Measures have been put into place to identify all Poultry and cattle farms carrying out on-farm production and whether they are subject to Annex I or Annex II to Regulation (EC) No 183/2005. Similar measures were being prepared for pig holdings.

The issue of adapting these systems to other species (horses, sheep/goats, etc.) was being considered.

Some 404,780 establishments had been registered in SIGAL (based on Siret number).

Farms are being registered in DGAL’s database (SIGAL), which will be made public. All farms registered in SIGAL will receive a risk assessment rating to determine control frequency by SRALs. This process is based on the sanitary visits carried out by the VS (bovine farms 2008 and pig/poultry farms during the second half of 2009.

As regards DGCCRF, controls are undertaken on first placing on the market (primary production is not included). SORA lists some 7,200 establishments. These have already been assigned a risk category for control purposes.

The SORA database uses the "Siret" reference number of establishments (National Institute for Statistics and Economic Studies -INSEE) which allows cross-checks with DGAL (SIGAL).

Action taken


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3.5 TSEs/ABP

Since 2004 the FVO has carried out 5 inspections in France in relation to TSEs/ABPs. Out of a total of 39 recommendations contained in the reports of these inspections, 12 were identified for follow-up during the general review mission, 3 of which were carried over from the country profile of 2008 and 9 were contained in a report that had reached closeout stage since the 2008 general review mission.

Recommendations carried over from the country profile of June 2008

Inspection 7700/2005 of 14/11/2005 on control of TSEs in small ruminants


Findings Assessment

(23439) To ensure that in goat herds subject to the experimental protocol, milk produced by goats (which should have been slaughtered according to Annex VII of Regulation (EC) No 999/2001) is not sent for human consumption.

Following opinions from AFSSA in July 2004 and February 2005, an experimental protocol was established by the competent authorities applicable to goat herds infected with a single case of scrapie, subject to specified conditions and controls. At the time of the general review mission, this protocol was being applied to three herds which continue to produce and to market milk. A further opinion was received from AFSSA in April 2009.

The French authorities undertook to formally notify the Commission before 15 July 2009 of the experimental protocol in line with point 10 of Annex VII to Regulation (EC) No 999/2001. The AFSSA opinion of April 2009 will serve as a basis for their submission.

This would enable the Commission to take a position on the use of the derogation provided for in point 9 of Annex VII to Regulation (EC) No 999/2001 in the case of goat herds.

In progress14

14 In their comments on the draft country profile, the French authorities confirmed that the notification was

transmitted to the Commission on 16 July 2009


115

Inspection 7279/2004 of 13/09/04 on ABP / unfit food


Findings Assessment

(25550) To ensure that all ABP are disposed of as required in Art. 4-6 of the ABP Regulation.

The Ministry of Food, Feed, Agriculture and Fisheriesissued instructions on 18 July 2006 on arrangements for the collection and transportation of ABP from butchers' establishments.

Management of ABP is included on the checklist for food establishments.

The Commission has considered the information on the channels of use and disposal of former foodstuffs in FR in the context of proposals for revision of the Regulation.

The French authorities stated that they would adopt a new service note.

The French authorities were invited to provide to the Commission a copy of the new Note de Service showing provisions covering the disposal of Category 3 material by retailers.

In progress

(25553) To ensure that provisions for the approval of composting plants in line with Art. 15 of the ABP Regulation are produced.

Note de Service N2007-8018 of 16 January 2007 formerly set out the conditions for the approval of plants using alternative methods of composting.

An AFFSA opinion received in July 2008, was issued as a basis for new Note de Service (replacing N2007-8018) N2009-8166 of 15 June 2009 on risk evaluation and management. This new Note de Service was to be used as a basis for definitive approvals of the 36 plants which had provisional approvals at the time of the general review mission. Definitive approvals were expected by end 2009.

Action taken

Recommendations reaching closeout note stage since the 2008 general review mission

Inspection 2008-7730 of 25-May-2008 in order to evaluate control measures on Bovine Spongiform Encephalopathy (BSE)


Findings Assessment

2008-7730-2 To ensure that animals fitting into the sub-population "found sick at ante-mortem inspection" over 24 months of age are tested for BSE as required by Annex III (Chapter A, point 2.1 to Regulation (EC) No

A Note de Service was in the course of being signed at the time of the general review mission.

The national database collecting BSE tests results (BNESST) is expected to be modified by the end of September 2009 to register the results of the analysis performed on this sub-population.

In the meantime, a standard report sheet will be used, which is contained in the new Note de Service referred to above.

In progress


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Inspection 2008-7730 of 25-May-2008 in order to evaluate control measures on Bovine Spongiform Encephalopathy (BSE)


Findings Assessment

999/2001.

2008-7730-3 To target controls of the feed ban at farm level to ensure that those where there is a higher risk of breeches of the feed ban are checked - particularly farms receiving OF/SI.

See the response to recommendation 4 of FVO mission number DG(SANCO)/2008-7741.

Action taken

2008-7730-6 To ensure that controls are in place to avoid contamination of head meat with SRM in accordance with Annex V to Regulation (EC) No 999/2001.

The French authorities stated that they were co-operating with ADIV (the Meat Industry Association), with a view to preparing a new Note de Service and a monitoring plan to address this recommendation. Further contacts were expected with ADIV before the end of June 2009, and the new Note de Service and monitoring plan were expected to be in place in September 2009.

In progress

2008-7730-7 To increase inspections in butchers shops to ensure that removal and disposal of SRM is carried out in accordance with the requirements of Annex V to Regulation (EC) No 999/2001.

A new Order had been drafted, which addresses this recommendation through its Annex V. This Order was expected to be adopted soon after the new Decree on the hygiene package, which had recently received the assent of the Conseil d'Etat, has been adopted. A draft Note de Service is at an advanced stage on controls to address this recommendation.

In progress

Inspection 2008-7741 of 18-May-2008 in order to evaluate the implementation of health rules on certain animal by-products


Findings Assessment

2008-7741-1 To take steps to put in place an effective system of coordination as required by Art. 4

DGAL asked SRALs, through a Note de Service N2008-8255 of 30 September 2008, to carry out a special investigation during the second half of 2008 on the traceability of PAP and on its use in farms. The objective was to update the relationship between establishments in the database SIGAL for the end of 2008.

Action taken


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Findings Assessment

of Regulation (EC) No 882/2004, to improve the flow of information concerning the dispatch of PAP from one department to another, in order to facilitate the targeting of controls to check compliance with the requirements of Regulation (EC) No 181/2006, particularly at farm level.

A Lettre-Ordre de service was sent on 12 February 2009 to the regional and departmental directors of DGAL, requesting that controls take place on the conditions of storage and use of PAP in relevant Departements.

The controls on these farms and information on shortcomings, are followed up using the SIGAL database. A SIGAL printout was provided showing that in April 2009, there were 188 farms using PAP as a fertiliser. The French authorities stated that the survey of farms using PAP would be updated in 2010.

In addition, these same farms are targeted for feedban controls in the context of the 2009 animal feed control plan, as described in Note de Service N2008/8311 of 15 December 2008.

2008-7741-2 To ensure that all staff responsible for performing official controls to check compliance with the requirements of Regulations (EC) No 92/2005 and (EC) No 181/2006 receive adequate training and guidance to enable them to undertake their tasks competently and consistently as laid down by Art. 6 of Regulation (EC) No 882/2004.

The next ABP course organised at the national level took place in November 2008 and dealt in particular with the problems of PAP used as fertilizer and the burning of animal fats. It was attended by 11 inspectors, from various departments.

The French authorities stated that in relation to cascading training received at national level to Department level staff, there were between 10 and 15 contact points/reference persons for ABP. Inspectors identified as contact points may cascade training received at National level to Departmental level.

They expected that the new Regional structures resulting from the Reform of State Administration (RGPP) would enhance the cascading of training to staff.

Action taken

2008-7741-4 To take the measures necessary as required by Art. 9 of Regulation (EC) No 181/2006 to ensure compliance with the requirements of that Regulation and in particular that animals cannot have access to PAP which is used

See the response to recommendation 1 of this mission. Action taken


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Findings Assessment

directly as OF/SI.

2008-7741-5 To ensure that the risks posed by the transport, storage and use of PAP on farms are taken into account in practice when implementing controls for the total feed ban, as required by Art. 3 of Regulation (EC) No 882/2004.

National legislation has been amended to reflect the risk of cross contamination between PAP used as fertilizer and animal feed :

• Transport: In the new note de service N2008-8137 of 16 June 2008, PAP must be transported in dedicated vehicles.

• Storage and use on farms as fertilizers: Article 7 of the arrêté of 18 July 2006 and the note de service N2008-8137 of 16 June 2008 require dedicated facilities for storage of fertilizers containing ABP.

Specific provisions on records have been introduced in the draft Order on the register of farms, whose publication, originally planned for early 2009, is now expected by the end of 2009.

The documents (checklist and guidance) used for inspections made by the veterinarians in cattle farms already take the conditions of storage into account.

Inspection guidelines for the implementation of hygiene inspections on pig and poultry farms are being discussed with professional bodies. Work is expected to start soon on the preparation of inspection checklists to be used by SRAL inspectors on cattle, pig and poultry farms. These new inspection guidelines, and checklists, originally expected by early 2009, are now expected to be finalised by the end of 2009.

In progress

2008-7741-6 To approve all plants and establishments which use Category 1 fat in thermal boilers as required by Art. 3 of Regulation (EC) No 92/2005 and to include them on a national list, in accordance with Art. 26 of Regulation (EC) No 1774/2002.

The French authorities provided an extract from SIGAL of the 9 establishments approved for the burning of animal fats.

Action taken


119

3.6 Veterinary medicines and residues

Since 2004 the FVO has carried out 1 inspection in France in relation to veterinary medicines and residues. Out of a total of 14 recommendations contained in the reports of these inspections, 2 were identified for follow-up during the general review mission, both of which were carried over from the country profile of 2008.


Inspection 7506/2005 of 21/06/2005 on control of residues and contaminants in live animals and animal products, including controls on veterinary medicinal products


Findings Assessment

(22245) To ensure, without delay, that all residues laboratories are accredited to ISO 17025.

Decree no 2006-7 of 4 January 2006 requires that all laboratories approved for the purpose of official controls must, inter alia, be accredited.

Three laboratories are designated as NRLs for specified substance groups (LERQAP, LERMVD and LABERCA). 26 Departmental laboratories undertake analytical work under the NRCP. All of these 29 laboratories are accredited to ISO 17025.

Accreditation has to be completed for only two laboratories:

• Lab 06 (COFRAC audit end 2009)

• Lab 37 (Mid 2010: This laboratory is already accredited for chemical analysis of water)

The objective is to use only accredited and approved laboratories or those laboratories undergoing accreditation with provisional approval for official controls.


(22246) To ensure that all analytical methods used are appropriately validated in each laboratory in accordance with the requirements in relevant Community legislation.

The general review mission in 2006 was informed that the process of validation at approved laboratory level comprises the following 6 or 7 parameters:

• Recovery • Repeatability • Within-laboratory reproducibility • Decision limit (CC a) • Detection capability (CC b) • Calibration curves And, in the event of major changes,

• Ruggedness.

The remaining parameters are validated for the method at the relevant NRL: Specificity; Trueness; Ruggedness (major and minor changes);

Action taken

15 In their comments on the draft country profile, the French authorities underline that all laboratories are

accredited to ISO 17025 and as Cofrac confirms competence to the level of individual matrices, it is not correct to ascribe a non-compliance in this area.


120

Inspection 7506/2005 of 21/06/2005 on control of residues and contaminants in live animals and animal products, including controls on veterinary medicinal products


Findings Assessment

and Reproducibility.

The CCA confirmed that the validation of methods would be completed in the only remaining labs (13 and 35) by end June 2009.

3.7 Foodstuffs and food hygiene Since 2004 the FVO has carried out 3 inspections in France in relation to foodstuffs and food hygiene. Out of a total of 11 recommendations contained in the reports of these inspections, 7 were identified for follow-up during the general review mission, all of which were carried over from the country profile of 2008.


Inspection 8086/2006 of 15/05/2006 on controls on feed and food containing, consisting of or produced from genetically modified organisms


Findings Assessment

(26673) Take account of control measures as required by Article 9.1 of Regulation (EC) No 1830/2003 to ensure all seed lots placed on the market comply with Community legislation.

Article 21(2) of Directive 2001/18/EC on the deliberate release into the environment of genetically modified organisms (GMOs) stipulates that, for products where adventitious traces of authorised GMOs cannot be excluded, a minimum threshold may be established below which these products do not need to be labelled.

So far, with regard to products which fall within the scope of the Directive, the value of the threshold is known only for GMOs which are to be processed directly: the value of 0.9%, in line with foodstuffs and animal feed, has been selected. However, the establishment of thresholds for seeds has been under discussion since 2001.

Pending a resolution of this issue at EU level, the DGAL and the DGCCRF applies a threshold value of 0.1% equivalent to the limit of quantification, based on the methods validated by the CRL.

In progress


121

Inspection 7187/2007 of 12 /02/2007 on official control systems in place for food additives and for food contact materials


Findings Assessment

(5) To continue expanding the range of validated and accredited methods in the areas of plastic FCM and also FA in line with Article 12 of Regulation 882/2004. FA laboratories availing of the derogation foreseen in Article 18 of Commission Regulation (EC) No 2076/2005 should provide satisfactory guarantees that quality control schemes are in place for all analyses they conduct for official controls.

Within the SCL, the NRL for FCM is Bordeaux-Pessac. Lyon-Oullins also carries out analyses. Both have ISO 17025 accreditation for each method from the national accreditation body (COFRAC) and carry out official analyses on plastics, silicon elastomers, coatings, ceramics and paper materials.

Work was in progress on accreditation of methods for Aromatic amines, BADGES and Phtalates. Regarding FA, 8 out of the 11 SCL laboratories undertake official analyses. They are in Marseille, Bordeaux-Pessac, Montpellier, Rennes, Lille, Lyon-Oullins, Strasbourg and Paris-Massy. They all have ISO 17025 accreditation from COFRAC for each method. There is no national reference laboratory in this field.

Validation of methods was underway for sulfites and preservatives.

The French authorities were invited to provide an overview table showing the state of accreditation and validation.

In progress

(6) To ensure that all non-compliant samples which pose a direct or indirect risk to human health are notified to the Commission RASFF network, as required by Article 50 of Regulation (EC) No 178/2002.

Note de Service 2007-20 sets out in detail the procedures to manage alerts and notifications to the Commission.

Action taken

Inspection 7223/2007 of 10/12/2007 on food hygiene (within the meaning of Regulation (EC) No 852/2004), traceability and labelling


Findings Assessment

(2) To ensure that the delegation of official control tasks to private laboratories fulfils the requirements of Article 5 of Regulation (EC) No 882/2004

The organisation of health checks on bottled natural mineral waters is based on checks on water for human consumption. Articles R. 1322-44-2 and R. 1322-44-3 of the Public Health Code, updated by the Decree of 11 January 2007, require sampling and analysis to be carried out by a laboratory approved by the Health Ministry

A national database ‘SISE AGRELAB’ has been set up which contains information on analysis methods relating to all approved laboratories. Detection and quantification limits for each parameter are included.

In progress


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Findings Assessment

Ministry of Health Order of 9 July lists the approved laboratories. This Order was in the process of being revised. Accreditation by Cofrac is a pre-requisite for approval.

Two further Administrative Orders have been delayed (now expected by mid 2010) on

• procedures for the organisation of health checks on bottled waters; and

• establishing the administrative and technical conditions for the approval of laboratories for parameters specific to bottled waters

LERH will be designated NRL.

Once these have been adopted, an updated list of approved laboratories, replacing that attached to the administrative order of 14 October 1937, will be forwarded to the Commission.

Meanwhile specific orders had been given the public health control services (DDASS/DRASS) by a ministerial circular on 31st January 2008 (cf. page 58).

(3) To ensure that food business operators are inspected regularly and with appropriate frequency, as required by Article 3.1 of Regulation (EC) No 882/2004

An investigation method for the stage of ‘first placing on the market on national territory’ is implemented by the DGCCRF.

Checks of this type are planned on the basis of a prior risk analysis comprising two stages: Stage 1: The central administration prepares a scoresheet for types of establishment, based on their theoretical risk level.

Stage 2: The decentralised services undertake a risk analysis for each establishment individually. This analysis takes account of how the establishment complies with regulations and the scale of placing on the market.

The frequency of checks is fixed on the basis of three specified risk levels: low, medium and high:

• high-risk establishments: inspection every year; • medium-risk establishments: inspection every three years; • low-risk establishments: inspection every five years.

For the stages other than ‘first placing on the market’, the frequency of checks is fixed at local level on the basis of elements in the risk analysis, such as:

• the establishment’s activity; • previous history; • area coverage.

The TN instructions prescribe both targeting and coverage criteria. The information system IRSI allows the CA to monitor compliance

Action taken


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Findings Assessment

with Article 3.1 of Regulation (EC) No 882/2004.

As regards DGAL, instructions were issued on 2 June 2008 (DGAL/SDSSA/N2008/N° 0487) as regards risk-based controls on establishments requiring approval and social catering. The implementation is managed in SIGAL (in the module "GOS" – management of instructions).

(4)To ensure that the preservation of the collected samples and the time interval between the dates of sampling and test results comply with Chapter 3.1 of Annex I to Regulation (EC) No 2073/2005

The joint laboratory service had completed a study at the eight laboratories concerned with a view to reorganising the way in which samples are collected and preserved before analysis. The objective is to reorganise both sample collection by the departmental directorates and sample storage at all stages up to analysis in the laboratory.

New procedures were introduced for refrigerated transport.

Action taken

(5) To ensure that the decrees establishing the sanctions applicable to infringements of Regulation (EC) No 882/2004 and Regulation (EC) No 852/2004 are issued, as required by Article 55 of Regulation (EC) No 882/2004

The French authorities confirmed that they already have the necessary legal basis for applying administrative police powers. Infringements of the hygiene package continue to be sanctionable under the existing provisions of the Code Rural (Articles 237-1, 237-2 and 237-4). The legal basis for controls and sanctions which apply pending adoption of the new Decrees are set out in Note de Service N2006-8026 dated 6 January 2006. In addition, Note de Service N2005-8205 of 17 August 2005 sets out arrangements as regards traceability.

Draft Decrees modifying the code rural and the code de la consommation were adopted by the Conselil d'Etat on 12 May 2009 and 2 June 2009 respectively. Both these Decrees may now be adopted by the Prime Minister and will enter into force following publication in the official journal.

Work is advanced on sectoral implementing orders and on a Decree on sanctions. This work is being undertaken by a working group involving DGAL, DGCCRF and the Legal Service (SAJ). The first meeting of the group was held on 18 February 2009. The planned Decree will list infringements under the hygiene package and simplify and diversify the range of administrative and penal sanctions which may be imposed.

In progress


124

3.8 Imports of food of plant origin

Since 2004 the FVO has carried out 1 inspection in France in relation to imports of food of plant origin. Out of a total of 11 recommendations contained in the report of these inspections, 4 were identified for follow-up during the general review mission, all of which were carried over from the 2008 country profile.


Inspection 7185/2007 of 26/03/2007 on import controls on food and feed of non-animal origin


Findings Assessment

(4) Ensure that official controls are organised in the light of potential risks in line with Article 15(1) of Regulation (EC) No 882/2004 and not only concentrating on foodstuffs affected by Commission Decisions 2006/504/EC and 2005/402/EC.

For 2009, plans are in place for mycotoxins, heavy metals, alumnium/chinese noodle, nicotine in mushrooms, Guar gum, aflatoxins, PCP:

TN 316 BB (mycotoxins)

TN 316 BA (heavy metals)

TN316 BG (alumnium/chinese noodles)

TN 316 nicotine in mushrooms

TN 316BH PCP

TN 316BE aflatoxins

Note de Service 2008-25: Guar gum

Action taken

(5) Ensure that official controls referred to in Article 15(1) include at least a systematic documentary check, a random identity check and, as appropriate, a physical check, in accordance with Article 16(1) of Regulation (EC) No 882/2004

Article 15 (1) of Regulation (EC) 882/2004: There are no systems in place to carry out regular official controls on feed and food of non-animal origin not included in the scope of Directive 97/78/EC.

The French position is that where there is no compulsory document required, there is no standard document which could be checked.


The implementation of Commission Regulation (EC) No 669/2009 from 2010 will significantly increase controls in this area.

A Note de service No 2009-43 was issued by DGCCRF on 22 December 2009 to take account of Commission Regulation (EC) No 1152/2009 and of Commission Regulation (EC) No 669/2009. A DNO (TN 31 CF) was issued by DGCCRF on the application of Regulation 669/2009 during the first quarter of 2010.

In progress

(7) Ensure that split consignments are accompanied by a copy of the health certificate in accordance with Article 6 of Commission

Article 6 of Commission Decision 2006/504/EC and point II.26.1 of the GUIDANCE DOCUMENT FOR COMPETENT AUTHORITIES FOR THE CONTROL OF COMPLIANCE WITH EU LEGISLATION ON AFLATOXINS, March 2009 requires that "If a consignment is split, copies of the report and health certificate and the accompanying document shall accompany each part of the split consignment. These copies must be certified by the competent authority of the Member State on whose territory the splitting has

In progress


125

Inspection 7185/2007 of 26/03/2007 on import controls on food and feed of non-animal origin


Findings Assessment

Decision 2006/504/EC.

taken place. These certified copies must accompany the split consignment up to and including the wholesale stage. No developments".

The French authorities consider that practical difficulties make this requirement impossible to implement and that the existing Community requirements may be subject to change.


Commission Regulation (EC) No 1152/2009 repealed Commission Decision 2006/504/EC.

See also recommendation 7185-2007-5

(11) Ensure that all laboratories undertaking official control analysis for Sudan dyes make the necessary arrangements to extend the scope of their accreditation, in line with Article 12 of Regulation (EC) No 882/2004 and Article 18 of Regulation (EC) No 2076/2005

The CCA indicated that COFRAC is unwilling to perform accreditation in the absence of a standard Community method.


A file for validation is now in preparation. For practical reasons a conclusion is not expected before 2010 or 2011.



126

3.9 Plant protection products

Since 2004 the FVO has carried out 1 inspection in France in relation to pesticides. Out of a total of 10 recommendations contained in the reports of these inspections, 2 were identified for follow-up during the general review mission, both of which were contained in reports carried over from the 2008 country profile.

Recommendations carried over from the country profile of June 2008

Inspection 8113/2006 of 29/05/2006 on controls of pesticide residues in food of plant origin


Findings Assessment

(26297) The competent authority should continue the process of laboratory accreditation, and make every effort to implement the quality control procedures for pesticide residue analysis provided for in Guidance Document SANCO/10232/2006, as required by Article 4 of Regulation (EC) No 645/2000.

DGCCRF

The seven SCL laboratories carrying out analysis on behalf of DGCCRF are accredited. Bordeaux and Massy have obtained flexible accreditation.

Montpellier, Bordeaux, Strasbourg and Massy have been accredited for GC/MS multi-residue analysis. Rennes was to have an audit in Autumn 2008 for this accreditation. This approach will be extended to other laboratories so that all official analyses are covered by accreditation. Accreditation for Reunion was planned for 2009.

Each laboratory is applying, fully or partially, quality control procedures for pesticide residue analysis provided for in Guidance Document SANCO/2007/3131.

DGAL

Note de Service N2008-8132 of May 2008 launched a tender for laboratory services for the 2009 programme. Accreditation and implementation of Guidance Document SANCO/2007/3131 were among the requirements for tenders. The other requirements concern time limits for analysis, analytical capacity and responsiveness to ring test results.


Updated Table (SCL) showing status for each laboratory as regards accreditation and SANCO quality implementation was provided on 28 September 2009. This showed that the laboratory in La Reunion had not achieved progress towards accreditation although this had been planned for 2009.


(26299) The competent authorities should ensure a reduction of excessive time-lapses between sampling for pesticide residues analysis and reporting of results in order to allow

The average turnaround time for the first half of 2008 was 30 days (ranging from below 5 to 75 days, with 52% below 30 days). The target fixed by SCL for 2009 was 30 days.

Improved capacity should lead to shorter turnaround times. The NRLs (Montpellier and Paris Massy) were to commission LC/MS/MS in 2009.

General discussions were taking place between DGCCRF and SCL on monitoring arrangements for turnaround time by SCL: Performance contract was being developed including indicators on

In progress


127

Inspection 8113/2006 of 29/05/2006 on controls of pesticide residues in food of plant origin


Findings Assessment

adequate enforcement, follow-up actions, and emergency measures, as necessary

inter alia this criterion.


128

3.10 Animal welfare

Since 2004 the FVO has carried out 4 inspections in France in relation to animal welfare. Out of a total of 25 recommendations contained in the reports of these inspections, 4 were identified for follow-up during the general review mission, all of which were carried over from the 2008 country profile.

Recommendations carried over from the 2008 country profile

Inspection 7330/2007 of 12/02/2007 on animal welfare at slaughter


Findings Assessment

2) (To ensure) that the intensity and duration of the current used in stunning by bath water for poultry, is determined by the competent authority, as required by Annex C, II (3) B (1) of Directive 93/119/EC;

Pending adoption of new Community provisions replacing Directive 93/119, the CCA is considering the possibility of designating OIE guidelines as the standard to apply in France.

In progress

5) (To ensure) that risks linked with animal welfare at slaughter are identified and that inspections are organised to meet the requirements of Article 3, paragraphs 1, 2 and 3 of Regulation (EC) No. 882/2004;

Draft inspection checklists and instructions were being tested. This was expected to be finalised by September 2009.

Action taken

7) (To ensure) that the ante-mortem inspection of all animals before slaughter is carried out by an official veterinarian, in accordance with the

See recommendation 25594 Action still required16

16 In their comments on the draft country profile, the French authorities indicated that a Note de service 2009-8290 dated 22 October 2009 introduced new checklists and procedures on animal welfare at slaughterhouses.


129

Inspection 7330/2007 of 12/02/2007 on animal welfare at slaughter


Findings Assessment

requirements of Annex I, Section I, Chapter II, (B)1(a) of Regulation (EC) No. 854/2004;

See also recommendation 25594 in MR 8152/2006 (Chapter 3.1: Animal Health) and MR 2008-7827

10) (To ensure) for the killing in the case of outbreaks of disease, the methods used are compatible with the requirements of Article 3 of Directive 93/119/EC; that electrocution of pigs is made so that the electrodes surround the brain and, when CO2 is used, that the duration of exposure is defined in accordance with the requirements of Annex C, III 3) of Directive 93/119/EC.

The electrocution of pigs in a mobile electrocution unit was not considered to be in compliance with Article 3 of Directive 93/119/EC which requires that the electrodes span the brain. The animals enter the corridor head first and electronarcosis and electrocution occur simultaneously, based on the voltages and amperages (1000 V, 15A) used. The whole body of an animal is in contact with the electrified lines. The death of the animal is checked by a veterinarian, leaving at the end of the conveyor belt. In the event of technical problems, euthanasia is performed using a euthanasia injection.

The method used is not listed in the OIE standards.

The CCA confirmed that this method had not been used in France since 2001 and would not be used in cases where alternative methods were available. Note de Service N2006-8105 of 2 May 2006 will be updated to highlight that this method should be used only in cases of force majeure in emergency situations and only with the prior approval of DGAL.

Action taken17

17 In their comments on the draft country profile, the French authorities indicated that a new Note de

Service N2009-8301 was issued on 4 November 2009. A letter had also been sent to the manufacturer of the unit requesting that a modification be studied in order to render it compliant.


130

3.11 Plant health

Since 2004 the FVO has carried out 1 inspection in France in relation to plant health. Out of a total of 8 recommendations contained in the reports of these inspections, 1 was identified for follow-up during the general review mission, which was carried over from the country profile of 2008.

Recommendations carried over from the 2008 country profile

Inspection 7545/2005 of 28/02/2005 on the implementation of the plant passport system


Findings Assessment

(21135) The BSV has adequate staff to enable up-to-date guideline instructions to be issued to registered producers, as required by Article 2(2)(d) of Commission Directive 92/90/EEC.

A convention with the professional bodies was being finalised. State co-financing and technical support was made available to produce guides. There was no longer any issue as regards staff levels in the CA.

Action taken


131

3.12 Overview of more recent inspections

In addition to the 32 finalised inspection reports and recommendations arising from these reports which are dealt with in chapters 3.1 - 3.11 above, 2 further inspections which had not reached the "closeout" stage at the time of the general review mission in June 2009 had been carried out. The recommendations contained in these reports will be followed up and assessed in the next update of the country profile.

The following tables give a brief summary of state of play on these inspections as of June 2009.

MR 8309/2008 of 24/11/2008: Evaluate the emergency vaccination against bluetongue

The report concluded that the current surveillance systems do not adequately take account of the risk of spread of BTV1 outside the restricted zone and that it was likely that BTV1 is present in France outside the BTV1+8 restricted zone. During the general review mission, the French authorities indicated that an Action plan being finalized. France was requested to give emphasis to recommendations 1 (verification of effectiveness of vaccination) and 4 (data flows). The French authorities were also requested to notify the Commission of Future strategy (following discussions with professional organisations and AFSSA (and pharmaceutical companies) on two issues: technical/political decision on whether to continue compulsory vaccination (timescale 2-3 weeks) and the development of strategy to cope with potential new serotypes. An Action Plan and additional information were provided by France on 18 June 2009. The French CAs have taken appropriate action to address the majority of the recommendations made in the report.

MR 8245/2009 of 20/04/2009: Evaluate the implementation of rules on the protection of animals during transport

The report concludes that the Competent Authority have put in place a system for the implementation of the rules on the protection of animals during transport which is being integrated with the requirements for official controls laid down in Regulation (EC) No 882/2004. However, the procedures for the authorisation of transporters are incomplete and means of transport for long journeys have been approved without verification of all the requirements laid down in Regulation (EC) No 1/2005. When deficiencies were detected during checks on transport, the remedial actions taken were not always sufficient. Additionally, certain problems identified in previous FVO missions have not been addressed by the competent authority, such as the transport of unfit animals toslaughterhouses and the inadequate checks of journey logs. The French authorities had been requested to provide an Action Plan following receipt of the translated report.


132

ANNEX I – ACRONYMS, ABBREVIATIONS AND SPECIAL TERMS

ACRONYM DESCRIPTION ABP Animal by-products as defined in Regulation

1774/2002

AFNOR Standards Association of France AFSSA French Agency for Food Safety

Agence française de sécurité sanitaire des aliments http://www.afssa.fr/

AH Animal Health ANMV French Agency for Veterinary Medicinal Products

Agence Nationale du Médicament Vétérinaire http://www.anmv.afssa.fr/

ARS Regional Health Agency

BDNI National database for identification and movement data

BICMA Office for animal identification and movement control Bureau de l'identification et du contrôle des mouvements des animaux (pour l´identification et les échanges intracommunautaires)

BIP Border Inspection Post BNESST National TSE Database BNEVP National Brigade for Veterinary and Plant Health

Investigations Brigade nationale d'enquêtes vétérinaires et phytosanitaires

BLACCO Office of laboratories and Co-ordination of Controls (in DGAL) Bureau des laboratoires et de la qualité et de la co-ordination des contrôles (DGAL)

BSE Bovine Spongiform Encephalopathy BSSV Seed and Plant health section

Bureau des semences et de la Santé des Végétaux

CA Competent Authority CAI Internal Audit Committee

Comité d’Audit Interne

CCA Central Competent Authority CTIFL Inter-professional technical centre for fruit and

vegetables Centre Technique Interprofessionnel des Fruits et Légumes

COFRAC French accreditation body / Comité Français d'Accréditation

CP Contingency plan CPMM Controls at the point of first placing on the market

Contrôle de la Premiere Mise sur le Marché (DGCCRF)

CROC Unit for information and planning controls (customs) Cellule du renseignement et d’orientation de contrôles

CSF Classical Swine Fever CVO Chief Veterinary Officer DDAF Departmental Directorates for Agriculture and

http://www.afssa.fr/

http://www.anmv.afssa.fr/


133

ACRONYM DESCRIPTION Forestry Direction départementale de l’agriculture et de la forêt

DDAM Departmental Directorate for maritime affairs Direction départementale des affaires maritimes

DDASS Departmental Directorates for Health and Social Affairs Direction Départementale des Affaires Sanitaires et Sociales

DDCSPP Departmental Directorate for social cohesion and protection of the population

DDPP Departmental Directorate for the protection of the population

DDSV Departmental Directorate for Veterinary Services Direction Départementale des Service Vétérinaires

DELT@ Customs information system Système de dédouanement dématérialisé

DGAL Directorate-General for Food Direction Générale de l´Alimentation

http://www.agriculture.gouv.fr/

DGCCRF Directorate General for Competition, Consumer Affairs and Fraud Repression Direction Générale de la Concurrence, de la Consommation et de la Répression des fraudes

DGDDI Directorate General for Customs and Indirect Taxation Direction générale des douanes et droits indirects

http://www.douane.gouv.fr/

DGPAAT Directorate General for Agricultural policy, agri-food and territories (MAAP) Direction générale des politiques agricole agroalimentaire et des territoires

DGPR Directorate General for the prevention of pollution and risks (in ME) Direction générale de la prévention des pollutions et des risques (ME)

http://www.developpement-durable.gouv.fr/

DGS Directorate General for Health Direction générale de la santé

http://www.sante.gouv.fr

DIRECCTE Regional Directorate for Enterprise, Competition, Consumers and Employment

DNECCRF National Directorate for enquiries on competition, consumer affairs and repression of fraud Direction nationale des enquêtes de concurrence, de consommation et de répression des fraudes

DPMA Directorate for sea fisheries and aquaculture Direction des Pêches maritimes et de l’Aquaculture


DRAAF Regional Directorates of food and feed, agriculture and forestry Direction régionale de l’alimentation, de l’agriculture et de la forêt

DRAM Regional Directorate for maritime affairs Direction régionale des affaires maritimes

DRASS Regional Directorates for Health and Social Affairs


http://www.douane.gouv.fr/



http://www.sante.gouv.fr/ministere/organig/dgs/index_org.htm

http://www.sante.gouv.fr/



134

ACRONYM DESCRIPTION Direction Régionale des Affaires Sanitaires et Sociales

DRCCRF Regional Directorate for Competition, Consumer Affairs and Fraud Repression Direction Régionale de la Concurrence, de la Consommation et de la Répression des Fraudes

DRDDI Regional Directorate for Customs and Indirect Taxation

DRIRE Regional Directorates for Industry, Research and Environment Directions régionales de l’industrie, de la recherché et de l’environnement

DRSSA Regional Directorate of the Health Service of the armed forces

DUS Department responsible for emergency situations located within DGS Département des Urgences Sanitaires

EDE Departmental livestock body Etablissement Départemental d'Elevages

EU European Union FMD Foot and Mouth Disease FREDON Regional federations for the protection against

harmful organisms Fédérations Régionales de Défense contre les Organismes Nuisibles

FVO Food and Veterinary Office GALATEE Database for regulatory texts and operational

instructions

GEUDI Information management system for phytosanitary inputs

GDP Good Distribution Practice GDS Departmental animal health defence co-operatives GLP Good Laboratory Practice GMO Genetically modified organism GMP Good Manufacturing Practice GNIS-SOC National inter-professional group for seeds-Official

control service Groupement National Interpro Semences Serv Off Contrôle

HACCP Hazard Analysis Critical Control Point IAE Agricultural and environment engineers

Ingénieurs de l’agriculture et de l’environnement

ICT Intra-Community trade of live animals of the bovine, ovine, caprine, equine and porcine species

ICW International catering waste IFREMER National Institute for Sea Fishing Research

Institut Français de Recherche pour l’Exploitation de la Mer

IGIR Inter-Regional General Engineers


135

ACRONYM DESCRIPTION Ingénieurs Généraux Inter régionaux

IGS Internal general inspectorate of services IGVIR Inter-Regional General Veterinary Inspectors

Inspecteurs Généraux Vétérinaires Inter Régionaux

IMPADON National database for import documentation INVS National Institute for Public Health Surveillance

l’Institut national de veille sanitaire

ISPV Inspector of Veterinary Public Health Inspecteur de santé publique vétérinaire

LABERCA Laboratory for the study of residues and contaminants in food LABoratoire d'Etude des Résidus et Contaminants dans les Aliments

LDCC Local Disease Control Centre LDA Authorised Departmental Laboratory

Laboratoire départementale agréé

LERMVD Research laboratory for veterinary medicines Laboratoire d’études et de recherches sur les médicaments vétérinaires et les désinfectants (AFSSA-Fougéres)

LERPRA Research laboratory for small ruminants and bees Laboratoire d’Etudes et de Recherches sur les Petits Ruminants et les Abeilles (AFSSA-Sophia-Antipolis)

LERQAP Research laboratory for the quality of food and food products Laboratoire d'Etudes et de Recherches sur la Qualité des Aliments et sur les Procédés Agroalimentaires-LERQAP (AFSSA-Maisons-Alfort)

LNPV National Laboratory for Plant Protection (Orléans) Laboratoire national de la protection des végétaux (Orléans)

MAAP Ministry of Agriculture and Fisheries Ministère de l'agriculture et de la pêche


MANCP Multi-annual National Control Plan MBM Meat and bone meal MD Ministry of Defence Ministère de la Défense MEEDDM Ministry for Ecology, Energy, Sustainable

Development and the Sea http://www.developpement-durable.gouv.fr/

MEIE Ministry of Economy, Industry and Employment Ministère de l’Economie, de l’Industrie et de l’Emploi.

http://www.minefi.gouv.fr

MHS Ministry of Health and Sport http://www.sante-jeunesse-sports.gouv.fr/

MISSA Inter-service mission for food safety ML Ministry of Labour

Ministère du Travail, des Relations sociales, de la Famille et de la Solidarité

http://www.cohesionsociale.gouv.fr/




http://www.minefi.gouv.fr/themes/protection_conso/alimentation/index.htm

http://www.sante-jeunesse-sports.gouv.fr/

http://www.sante-jeunesse-sports.gouv.fr/




136

ACRONYM DESCRIPTION MS Member State MUS Mission for health emergencies NDCC National Disease Control Centre NRCP National Residue Control Plan NRL National Reference Laboratory OIPHAP Office for Inputs and Public Health in Animal

Production of MAAP

OV Official Veterinarian PAH Polycyclic aromatic hydrocarbons PAP Processed animal Protein PCB Polychlorinated biphenyls PCF Permanent Command Centre PCO Operational Command Centre PCR Polymerase chain reaction PHISP Public Health Pharmacy Inspectors

Pharmacien inspecteur de santé publique

PPP Plant Protection Product RASFF Rapid Alert System for Feed and Food RESAQ Quality Assurance Network

Réseau Assurance Qualité

RGPP General review of public policies Revue générale des politiques publiques

SAD Single Administrative Document SCL Common Laboratory Service

Service commun des laboratoires

SDASEI Sub-Directorate for European and international health matters (DGAL) Sous direction des affaires sanitaires européennes et internationales Mission de coordination sanitaire internationale (DGAL)

SDPPST Sub-Directorate for horizontal policies (DGAL) SDQA Sub-Directorate for food quality

Sous-direction de la qualité de l’alimentation (DGAL)

SDQPV Sub-Direction for Plant Protection and Quality Sous-Direction de la Qualité et de la Protection des Végétaux (DGAL)

SDSPA Sub-Directorate for Animal Health and Welfare (in DGAL) Sous direction de la santé et de la protection animales (DGAL)

SDSSA Sub-Directorate for Food Safety (in DGAL) Sous Direction de la sécurité sanitaire des aliments (DGAL)

SGAR Secretariat General for Regional Affairs SIGAL Information system of the Directorate-General for

Food Système d´Information de la Direction Générale de l’Alimentation

SORA Information system of the DGCCRF


137

ACRONYM DESCRIPTION SPE Public system for rendering

Service public de l’equarrisage

SDPPST Sub-Directorate for horizontal policies (DGAL) SRAL Regional Food Services

Service Régional de l’Alimentation (partie de la DRRAF)

SRE Regional Investigation service / Service régional d’enquête

SRM Specified Risk Material SSA Health Department of the armed forces TB Tuberculosis TOSCA Database for registration of operational instructions,

mail and alerts

TRACES The TRACES system is a risk management tool for animal health and public health, allowing the integration within a central server of all the veterinary information relating to trade in animals and products of animal origin, whether within the Community or originating in third countries. It also provides the veterinary authorities of the Member States and third countries with assistance in dealing with the animal health certification required, by making available and keeping up-to-date all the regulatory bases which apply (Commission Decision 2004/292/EC)

TSE Transmissable Spongiform Encephalopathy UAS Health Audit Unit

Unité d’Audit Sanitaire

UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression Direction Départementale de la Concurrence, de la Consommation et de la Répression des Fraudes

http://www.bercy.gouv.fr/directions_services/dgccrf/

VCR Regional Veterinary Inspector VI Veterinary Inspector VINHIFLOR National inter-professional office for fruit, wine and

horticulture l'Office national interprofessionnel des fruits, des légumes, des vins et de l'horticulture

VPHI Veterinary public health inspector VIV Contract veterinary inspector VMP Veterinary medicinal products VS Approved Veterinarians

Vétérinaire Sanitaire




138

ANNEX II - PRODUCTION, CONSUMPTION AND TRADE OVERVIEW

This Annex presents summary data on France's production, consumption and trade of food, animals and plants. It gives the economic context for the control systems described in Parts 1 to 3 of the profile. The data are taken from Eurostat's database on "Food: From Farm to Fork Statistics" which can be found on the following web site: Food Chain Statistics

Actors in the Food Chain

Holding rearing animals (Number) 2007 % EU-27 Trend (Absolute figures)

All holdings rearing equidae 55340 3.82% 2003 2007

All holdings rearing cattle 219960 6.10% 2003 2007

All holdings rearing sheep 66060 5.19% 2003 2007

All holdings rearing goats 19590 2.75% 2003 2007

All holdings rearing pigs 35290 1.00% 2003 2007

All holdings rearing poultry 134580 2.29% 2003 2007

All holdings rearing other livestock 420 0.03% 2003 2007

http://epp.eurostat.ec.europa.eu/portal/page/portal/product_details/publication?p_product_code=KS-30-08-339


139

Food production enterprises (Number) 2006 % EU-27 Trend (Absolute figures)

Production, processing, preserving of meat, meat products 10675 24.39% 2000 2006

Processing and preserving of fish and fish products 495 12.29% 2000 2006

Processing and preserving of fruit and vegetables 1452 13.21% 2000 2006

Manufacture of vegetable and animal oils and fats 225 2.17% 2000 2006

Manufacture of dairy products 1436 11.39% 2000 2006

Manufacture of grain mill products, starches and starch products 603 7.45% 2000 2006

Manufacture of other food products 48661 24.77% 2000 2006

Manufacture of beverages 3260 15.60% 2000 2006

Food retail enterprises (Number) 2006 % EU-27 Trend (Absolute figures)

Retail sale in non-specialized stores with food beverages or tobacco predominating 30942 6.39% 2000 2006

Retail sale of food,beverages,tobacco in specialized stores 47519 8.93% 2000 2006

Retail sale of fruit and vegetables 5645 7.28% 2000 2006

Retail sale of meat and meat products 16942 13.30% 2000 2006

Retail sale of fish, crustaceans and molluscs 2676 7.44% 2000 2006

Retail sale of bread, cakes, flour confectionery and sugar confectionery 3882 5.50% 2000 2006

Retail sale of alcoholic and other beverages 5237 12.11% 2000 2006

Restaurants; bars; canteens and catering 180462 12.73% 2000 2006

Fishing vessels (Number) 2008 % EU-27 Trend (Absolute figures)

Number of fishing vessels 7941 8.56% 2001 2008


140

Feedingstuffs and pesticides enterprises (Number) 2006 % EU-27 Trend (Absolute figures)

Manufacture of prepared feeds for farm animals 446 11.10% 2000 2006

Manufacture of pesticides and other agro-chemical products 118 20.87% 2000 2006

Production

Livestock (1000 heads) - rounded 2008 * % EU-27 Trend (Absolute figures)

Total of cattle population 19366 21.28% 2002 2008

Total of the pig population 14796 9.46% 2002 2008

Sheep total 7781 8.90% 2002 2008

Total of the goat population 1265 9.36% 2002 2008

Total of equidae 394 10.23% 2003 2007

Poultry total 275780 18.72% 2003 2007

* or most recent available data

Slaughtering (1000 heads) - rounded 2008 % EU-27 Trend (Absolute figures)

Bovines 5083 17.95% 2002 2008

Pigs 25735 10.31% 2002 2008

Sheep 5944 9.24% 2002 2008

Goats 877 11.07% 2002 2008

Poultry 924395 21.03% 2002 2008

Equidae 16 8.11% 2002 2008


141

Milk and eggs production (1000 t) - rounded 2008 % EU-27 Trend (Absolute figures)

Milk collected by dairies 24259 17.65% 2002 2008

Eggs 947 14.00% 2002 2008

Fishery production (tons) 2007 % EU-27 Trend (Absolute figures)

Catches 556216 10.89% 2001 2007

Landings 301797 8.45% 2001 2007

Aquaculture 237451 18.70% 2001 2007

Crop production (1000 t) - rounded 2008 * % EU-27 Trend (Absolute figures)

Cereals, incl. rice 70481.9 22.36% 2001 2008

Root crops 38458 28.61% 2001 2006

Industrial crops (total) 6500 36.58% 2001 2006

Fresh vegetables, melons, strawberries 5654 9.98% 2001 2006

Fruit (excl. citrus fruit, grapes, olives) 3339 14.45% 2001 2006

Citrus fruit 31 0.25% 2001 2006

Grapes 6685 25.07% 2001 2006



142

Food production turnover (Mio Euro) - rounded 2006 * % EU-27 Trend (Absolute figures)

Production, processing, preserving of meat, meat products 35232 19.99% 2001 2006

Processing and preserving of fish and fish products 3621 16.15% 2002 2006

Processing and preserving of fruit and vegetables 7265 13.83% 2001 2006

Manufacture of vegetable and animal oils and fats 1567 6.68% 2001 2003

Manufacture of dairy products 24074 21.22% 2001 2006

Manufacture of grain mill products, starches and starch products 5447 16.00% 2001 2006

Manufacture of other food products 38718 16.91% 2001 2006

Manufacture of beverages 21533 16.42% 2001 2006


Feedingstuff production (1000 t) - rounded 2006 * % EU-27 Trend (Absolute figures)

Premixtures for farm animal feeds 160 1.64% 2005 2006

Preparations used for farm animal feeds (excl. premixtures) 22398 18.38% : 2001


Consumption


143

Gross apparent human consumption Degree of self-sufficiency of main food items - 2008 (1) of main food items (%) -2008 (2)

Total kg/head %Cereals (excluding rice) (1000 t) 7468.00 117.14 Cereals (excluding rice) 173.22Wheat - Total (1000 t) 7066.00 110.84 Wheat - Total 177.37Barley (1000 t) 22.00 0.35 Barley 236.44Maize (1000 t) 332.00 5.21 Maize 165.95Dried pulses (1000 t) 19.00 0.30 Dried pulses 166.86Rice - total (1000 t) 406.61 6.42 Rice - Total (equivalent milled rice) 13.65

Meat - Total (1000 t) 6496.00 102.00 Meat - Total 106.00Meat : Cattle (1000 t) 1664.00 26.00 Meat : Cattle 105.00Meat : Pigs (1000 t) 2207.00 35.00 Meat : Pigs 106.00Meat : Sheep and goats (1000 t) 250.00 4.00 Meat : Sheep and goats 51.00Meat : Poultry (1000 t) 1566.00 25.00 Meat : Poultry 119.00Meat : Equidae (1000 t) 22.00 0.00 Meat : Equidae 40.00

Drinking milk (1000 t) 4250.24 67.06 Drinking milk :Whole milk (raw mat) : : Whole milk (raw mat) :Cheese (1000 t) 1499.65 23.66 Cheese :Eggs (1000 t) 953.00 : Eggs :Butter (1000 t) 500.69 7.90 Butter :

Vegetable fats and oils (1000 t) 767.00 12.03 Vegetable fats and oils :Oil seeds and oleaginous fruit - Total : : Oil seeds and oleaginous fruit - Total 127.98

Apples (1000 t) 1534.00 24.06 Apples (1000 t) :Pears (1000 t) 322.00 5.08 Pears (1000 t) :Fresh peaches (1000 t) 391.00 6.17 Fresh peaches (1000 t) :Grapes (1000 t) 257.00 4.03 Grapes (1000 t) :Citrus fruit (1000 t) : : Citrus fruit :Oranges (1000 t) 7824.00 122.73 Oranges (1000 t) :Nuts (1000 t) : : Nuts :Dried fruit (1000 t) : : Dried fruit :Cauliflowers (1000 t) 278.00 4.36 Cauliflowers (1000 t) :Fresh tomatoes (1000 t) 851.00 13.35 Fresh tomatoes (1000 t) :Potatoes (1000 t) 3194.21 50.11 Potatoes 112.98Vegetables (excluding potatoes) : : Vegetables (excluding potatoes) :

Sugar (equivalent white sugar) (1000 t) 1981.00 31.07 Sugar (equiv white sugar) 179.66Honey (1000 t) 36.00 0.57 Honey :

Total lt/headWine (1000 hl) 29733.00 46.64 Wine - Total 125.73

(1) Eggs 2005, Meat, Rice, Drinking milk, Cheese, Butter, Pears, Fresh peaches 2007

(2) Meat, Rice 2007


144

Trade

Extra-EU Trade (2008)

TARICCODE COMMODITY Imports

(Mio €)%

EU-27Imports (1000t)

% EU-27

Exports (Mio €)

% EU-27

Exports (1000t)

% EU-27

01 Live animals 50.00 14.55% 1.23 12.01% 99.12 8.96% 9.33 4.23%

02 Meat and edible meat offal 198.11 5.50% 48.34 4.99% 694.53 13.67% 516.42 15.21%

03 Fish and crustaceans, molluscs and other aquatic invertebrates 1125.04 8.70% 282.08 6.94% 259.85 11.21% 135.92 9.94%

04 Dairy produce; birds' eggs; natural honey; edible products of animal origin (not elsewhere included) 78.88 8.26% 90.39 21.89% 1067.23 16.29% 409.50 16.83%

05 Products of animal origin (not elsewhere included) 72.90 6.79% 51.34 8.76% 53.12 9.15% 45.86 12.42%

06 Live trees and other plants; bulbs, roots and the like, cut flowers and ornamental foliage 24.02 1.56% 5.47 1.18% 36.65 2.08% 8.92 1.36%

07 Edible vegetables and certain roots and tubers 667.88 19.03% 791.40 17.55% 247.98 11.86% 458.95 13.03%

08 Edible fruit and nuts; peel of citrus fruit or melons 1064.02 8.14% 913.48 6.89% 217.94 8.78% 214.67 8.04%

09 Coffee, tea, mate and spices 555.81 8.27% 191.02 5.80% 60.76 5.31% 10.19 3.45%

10 Cereals 276.91 4.88% 694.25 3.09% 2343.92 42.60% 10151.40 42.55%

11 Products of the milling industry; malt; starches; inulin; wheat gluten 22.26 19.27% 32.65 20.18% 402.93 20.05% 990.17 23.47%

12 Oil seeds and oleaginous fruits; miscellaneous grains, seeds and fruit; industrial or medicinal plants, straw and fodder 456.31 5.41% 868.72 4.57% 209.48 11.49% 164.17 8.95%

13 Lac; gums; resins and other vegetable saps and extracts 107.25 18.32% 43.54 24.25% 86.95 13.58% 20.11 23.85%

14 Vegetable plaiting materials; vegetable products (not elsewhere included) 11.76 8.87% 15.70 4.17% 2.55 6.90% 1.54 10.20%

15 Animal or vegetable fats and oils and their cleavage products; prepared edible fats; animal or vegetable waxes 959.12 11.94% 1080.76 11.47% 114.28 3.59% 72.64 3.77%

16 Preparations of meat, of fish or of crustaceans, molluscs or other aquatic invertebrates 454.43 9.43% 133.14 9.09% 131.04 11.41% 43.47 10.64%

17 Sugars and sugar confectionary 124.56 5.88% 447.26 7.06% 212.45 14.73% 413.40 20.33%

18 Cocoa and cocoa preparations 637.71 16.03% 248.65 12.42% 256.19 9.85% 66.82 8.49%

19 Preparations of cereals, flour, starch or milk; pastrycooks' products 134.15 14.05% 66.65 12.80% 537.19 10.82% 194.67 8.91%

20 Preparations of vegetables, fruit, nuts or other parts of plants 366.61 8.80% 289.77 6.75% 241.73 7.87% 115.12 4.45%

21 Miscellaneous edible preparations 208.42 10.19% 67.60 8.01% 710.57 14.27% 227.80 15.82%

22 Beverages, spirits and vinegar 264.00 5.24% 1068.53 16.95% 4885.83 28.86% 1662.26 17.88%

23 Residues and waste from the food industries; prepared animal fodder 1143.60 13.12% 3830.41 12.26% 344.48 14.91% 336.72 10.59%


145

Intra-EU Trade (2008)

TARICCODE COMMODITY Imports

(Mio €)%

EU-27Imports (1000t)

% EU-27

Exports (Mio €)

% EU-27

Exports (1000t)

% EU-27

01 Live animals 244.85 4.19% 1.09 0.08% 1482.19 23.88% 0.76 0.06%

02 Meat and edible meat offal 3608.05 13.15% 1251.62 11.79% 2554.14 8.82% 954.59 8.43%

03 Fish and crustaceans, molluscs and other aquatic invertebrates 1907.72 17.72% 476.31 15.75% 836.82 7.41% 173.99 5.47%

04 Dairy product; birds' eggs; natural honey; edible products of animal origin (not elsewhere included) 2446.40 9.31% 1366.44 7.61% 4176.31 15.58% 2524.52 13.49%

05 Products of animal origin (not elsewhere included) 177.85 13.24% 170.46 9.48% 97.12 7.10% 94.51 6.61%

06 Live trees and other plants; bulbs, roots and the like, cut flowers and ornamental foliage 1137.57 15.22% 277.46 11.54% 132.99 1.45% 71.79 2.78%

07 Edible vegetables and certain roots and tubers 1573.62 10.54% 2125.58 10.45% 1461.21 10.03% 3070.49 15.74%

08 Edible fruit and nuts; peel of citrus fruits or melons 2270.58 13.18% 2251.34 13.90% 1252.36 7.38% 1140.43 7.00%

09 Coffee, tea, mate and spices 607.36 16.84% 179.56 17.60% 203.30 4.95% 28.60 2.45%

10 Cereals 502.98 4.37% 1028.20 2.38% 4186.37 36.44% 17629.41 38.81%

11 Products of the milling industry; malt; starches; inulin; wheat gluten 348.24 9.90% 610.85 8.55% 704.21 21.24% 1582.70 23.32%

12 Oil seeds and oleaginous fruits; miscellaneous grains, seeds and fruit; industrial or medicinal plants, straw and fodder 447.62 6.35% 593.95 4.72% 1317.59 19.49% 2677.44 21.68%

13 Lac; gums; resins and other vegetable saps and extracts 108.94 12.20% 18.38 12.38% 158.82 17.65% 24.72 21.77%

14 Vegetable plaiting materials; vegetable product (not elsewhere included) 17.14 18.62% 51.70 20.29% 6.74 7.81% 35.19 13.74%

15 Animal or vegetable fats and oils and their cleavage products; prepared edible fats; animal or vegetable waxes 1631.16 11.94% 1344.06 11.07% 1085.28 7.92% 1259.39 9.86%

16 Preparations of meat, or fish or of crustaceans, molluscs or other aquatic invertebrates 1012.50 11.85% 245.47 10.76% 643.51 6.80% 136.13 5.45%

17 Sugars and sugar confectionary 699.81 9.73% 903.19 9.43% 1617.26 22.59% 3008.07 32.31%

18 Cocoa and cocoa preparations 1383.53 14.54% 502.29 16.98% 1106.31 11.15% 364.02 12.03%

19 Preparations of cereals, flour, starch or milk; pastrycooks' products 2262.18 14.49% 1170.78 15.27% 2005.25 12.59% 968.99 12.72%

20 Preparations of vegetables, fruit, nuts or other parts of plants 2413.04 17.32% 2517.09 18.99% 1062.80 7.28% 856.65 6.18%

21 Miscellaneous edible preparations 1349.26 9.89% 657.71 12.98% 1243.98 9.98% 400.37 8.57%

22 Beverages, spirits and vinegar 2432.21 9.87% 6064.42 15.57% 6657.71 26.17% 1910.74 6.26%

23 Residues and waste from the food industries; prepared animal fodder 1205.66 10.56% 3023.47 10.83% 1586.29 12.81% 3234.85 10.37%


146

ANNEX III - OVERVIEW OF STAFF RESOURCES

Organisation Number of Staff Full time equivalent

National Level

MAAP Ministry of Agriculture and Fishery

DGAL Directorate-General for Food

SDQPV Sub-Direction for Plant Protection and Quality

227

MEIE Ministry of Economy, Industry and Employment

DGCCRF Directorate-General for Competition, Consumer Affairs and Fraud Repression

26 +55 on pesticides/residues

(all levels)

MHS

Ministry of Health, Youth, Sport and Social life

-

DGS Directorate-General for Health 5 Ministry of Defence

SSA Health Department of the armed forces

113 (78 veterinarians + 35 technicians)

ME Ministry for Ecology, Energy, Sustainable Development and Spatial Planning

DGPR Directorate General for the prevention of pollution and risks -

AFSSA French Food Safety Agency 1,000 ANMV French Agency for veterinary

medicinal products 80


Regional level

SRAL Regional Food Services

480

DRASS Regional Directorate for Health and Social Affairs

540

DRCCRF Regional Directorate for Competition, Consumer Affairs and Fraud Repression

Included in UDCCRF


Departmental level SRAL Regional Food Service 4,580 + 12,500 mandated

veterinary (part time)

DDAM Departmental Directorate for maritime affairs 61


147


DDASS Departmental Directorate for Hygiene and Social Action

28 (food) 500 (water) including 250

working on analysis

DDAF Departmental Directorates for agriculture and forestry

UDCCRF Departmental Directorate for Competition, Consumer Affairs and Fraud Repression

426+ 138 in laboratories

Total 8,246 FTE + 12,500 part-time

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