final report of an audit carried out in the netherlands
Transcription
final report of an audit carried out in the netherlands
Ref. Ares(2013)2633331 - 10/07/2013 EUROPEAN COMMISSION HEALTH AND CONSUMERS DIRECTORATE-GENERAL Directorate F - Food and Veterinary Office DG(SANCO) 2012-6315 - MR FINAL FINAL REPORT OF AN AUDIT CARRIED OUT IN THE NETHERLANDS FROM 08 TO 12 OCTOBER 2012 IN ORDER TO EVALUATE THE PLANT HEALTH CONTROLS IN THE POTATO SECTOR In response to information provided by the Competent Authority, any factual error noted in the draft report has been corrected; any clarification appears in the form of a footnote. Executive Summary This report describes the outcome of a audit carried out by the Food and Veterinary Office (FVO) in the Netherlands from 8 to 12 October 2012. The objective of the audit was to evaluate the official control system in place against the harmful organisms Clavibacter michiganensis spp. sepedonicus, (causing potato ring rot), Ralstonia solanacearum (causing potato brown rot) and potato cyst nematodes (PCN, Globodera spp). Phytosanitary controls of the Dutch potato sector are well organised and carried out efficiently by well-equipped organisations and well educated staff. Most aspects of the Directives for the control of ring rot and Ralstonia solanacearum are implemented correctly and well. Intensive surveys are carried out for both organisms and outbreaks are followed up by appropriate tracing back and forward and designation of contaminated and probably contaminated material. Eradication measures, including proper disposal of contaminated or probably contaminated potatoes are in place and supervised by inspectors. However, production of seed potatoes is allowed in the place of production in the first year after a ring rot outbreak, which is not in line with EU requirements. The implementation of Directive 2007/33/EC for the control of potato cyst nematodes (PCN) is also to a large extent compliant and has improved the Dutch controls against the organism somewhat, although these do not appear to be aimed at maximising the assurances against the spread of PCN. Official investigations of seed potato fields are done in line with the requirements of the Directive. However, the high incidence of PCN findings, the systematic use of the derogation facility for reduced sampling rates, the minimalistic demarcation of PCN infested plots and the fact that some of the official control measures applied before re-sampling/de-scheduling of demarcated plots are not reliable, mean that the level of assurance against PCN in seed could be compromised. Testing for PCN resistance is carried out by qualified laboratories of private companies and lists of varieties are submitted to the EU and other Member States as required. However, some of the laboratories belong to potato breeding companies, who have a direct interest in the outcome of the tests and EU requirements for independence are in these cases therefore not met. The Netherlands apply the official control programme referred to in Article 9(2) of Directive 2007/33/EC for the suppression of PCN in ware potatoes. However, this programme does not take sufficiently into account the required use of potato varieties of the highest levels of resistance available. The vast majority of the findings in ware potatoes are, in line with the same Directive, not subject to the official suppression programme. In this regard it has to be noted that farmers in the Netherlands have sophisticated tools at their disposal to prevent PCN from causing losses in their production and they are likely to implement measures on their own that – even if not resulting in much suppression – will match the official suppression programme in terms of effectiveness. The authorities have identified the need for establishing phytosanitary procedures for disposal of waste from all potato processing and packing facilities and are working on some proposals, however, so far the requirements in Article 10(1)(b) of this Directive have in most cases not been met. Recommendations are made in the report to address the shortcomings identified by the FVO audit. I Table of Contents 1 INTRODUCTION........................................................................................................................1 2 OBJECTIVES............................................................................................................................1 3 LEGAL BASIS..........................................................................................................................1 3.1 RELEVANT LEGISLATION..................................................................................................................1 3.2 RELEVANT STANDARDS...................................................................................................................1 4 BACKGROUND..........................................................................................................................2 4.1 PREVIOUS RELEVANT AUDITS............................................................................................................2 4.2 PRODUCTION OF POTATOES..............................................................................................................2 4.3 POTATO TRADE..............................................................................................................................2 5 FINDINGS AND CONCLUSIONS...................................................................................................3 5.1 ORGANISATION AND LEGISLATION ON OFFICIAL PLANT HEALTH CONTROLS............................................3 5.1.1 DESIGNATION OF COMPETENT AUTHORITIES................................................................................3 5.1.2 STAFFING PROVISIONS..............................................................................................................4 5.1.3 TRAINING AND WORKING INSTRUCTIONS........................................................................................4 5.1.4 LEGAL POWERS OF INSPECTORS..................................................................................................5 5.1.5 WORK PLANNING AND RECORD KEEPING......................................................................................5 5.1.6 COOPERATION AND COMMUNICATION WITH STAKEHOLDERS...............................................................5 5.1.7 LABORATORIES.......................................................................................................................5 5.1.8 RELEVANT NATIONAL LEGISLATION AND RULES...............................................................................6 5.1.9 REGISTRATION/APPROVAL OF ESTABLISHMENTS...............................................................................6 5.2 POTATO CONTROLS........................................................................................................................7 5.2.1 CLAVIBACTER MICHIGANENSIS SSP. SEPEDONICUS SURVEILLANCE STRATEGY AND RESULTS.........................7 5.2.2 HANDLING OF SUSPECTED AND CONFIRMED RING ROT OUTBREAKS.....................................................9 5.2.3 RALSTONIA SOLANACEARUM SURVEILLANCE STRATEGY AND RESULTS..................................................12 5.2.4 HANDLING OF SUSPECTED AND CONFIRMED BROWN ROT OUTBREAKS................................................13 5.2.5 SPECIFIC RING ROT AND BROWN ROT CONTROL PROGRAMMES..........................................................14 5.2.6 GLOBODERA PALLIDA AND G. ROSTOCHIENSIS SURVEILLANCE STRATEGY AND RESULTS..........................15 5.2.7 HANDLING OF POTATO CYST NEMATODES IN WARE POTATO PRODUCTION............................................22 6 OVERALL CONCLUSIONS.........................................................................................................24 7 CLOSING MEETING................................................................................................................25 8 RECOMMENDATIONS...............................................................................................................25 ANNEX 1 - LEGAL REFERENCES.................................................................................................26 ANNEX 2 – STANDARDS QUOTED IN THE REPORT...........................................................................27 II ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT Abbreviation Explanation Brown rot Disease caused by the bacterium Ralstonia solanacearum (Smith) Yabuuchi et al. CA Competent Authority EC European Community ELI Ministerie van Economische Zaken, Landbouw en Innovatie Ministry of Economic Affairs, Agriculture and Innovation EPPO European and Mediterranean Plant Protection Organisation EU European Union FVO Food and Veterinary Office NAK Nederlandse Algemene Keuringsdiest, the Dutch General Inspection Service for Agricultural Seed and Seed Potatoes NPPO National Plant Protection Organisation NVWA Nederlandse Voedsel - en Warenautoriteit, Netherlands Food and Consumer Safety Authority PCN Potato cyst nematode PCR Polymerase chain reaction PDA Personal digital assistant PRISMA A laboratory information management system of the NVWA Ring rot Disease caused by the bacterium Clavibacter michiganensis (Smith) Davis et al. ssp. sepedonicus (Spieckermann et Kotthoff) Davis et al. III 1 INTRODUCTION The audit took place in the Netherlands from 8 to 12 October 2012. The Food and Veterinary Office (FVO) team, which comprised three officials from the FVO and one national expert from a Member State, was accompanied throughout the audit by a representative from the Netherlands Food and Consumer Safety Authority – Nederlandse Voedsel - en Warenautoriteit (NVWA). An opening meeting was held on 8 October 2012 at the local office of NVWA, during which the objectives, itinerary, and the standard reporting and follow-up procedures were confirmed, and additional information required for the satisfactory completion of the audit was requested. 2 OBJECTIVES The objective of the audit was to evaluate the official control system in place against the harmful organisms Clavibacter michiganensis spp. sepedonicus, Ralstonia solanacearum and potato cyst nematodes (PCN, Globodera spp.). In pursuit of this objective, the following competent authorities were contacted and the following plant health control sites were visited: Competent authorities Single Authority Local office NVWA (Wageningen) Official Inspection Body Central office NAK (Emmeloord) Laboratory visits Official laboratories 1 NAK (Emmeloord) Private laboratories 1 (Bant) Plant health control sites Seed and ware potato producers 6 (Dirksland, Klaaswaal, Westmaas, Dronten, Biddinghuizen) Potato processing facility 1 (Baarle Nassau) 3 LEGAL BASIS The audit was carried out under the general provisions of EU legislation, and in particular Art. 21 and 27a of Council Directive 2000/29/EC. 3.1 RELEVANT LEGISLATION All EU legislation relevant for this audit is listed in Annex 1. Legal acts quoted refer, where applicable, to the last amended version. 3.2 RELEVANT STANDARDS International Standards for Phytosanitary Measures (ISPMs) are issued by the International Plant Protection Convention (IPPC) of which the EU Member States are members. Those of relevance for this audit are listed in Annex 2. 1 4 BACKGROUND 4.1 PREVIOUS RELEVANT AUDITS So far, the FVO has carried out six missions to the Netherlands with relevance to potatoes. Four missions were carried out in five years (1995-1999) focusing solely on brown rot and the implementation of the relevant Community legislation. During these missions, the Netherlands was generally found to be complying with the requirements. Two more missions to evaluate the plant health controls in the potato sector (DG(SANCO)20001175 and DG(SANCO)2005-7681), resulted in a number of recommendations for improvements that were generally satisfactorily addressed by the Dutch authorities. A more recent audit (DG(SANCO)2011-8977) in the Netherlands took place on import controls. The reports are available on http://ec.europa.eu/food/fvo/ir_search_en.cfm as are the Single Authority’s comments on the reports and its response to the recommendations. Unless otherwise stated, statistical data in this and the following chapters were provided by the Dutch authorities. 4.2 PRODUCTION OF POTATOES Netherlands has retained its position as the largest producer of seed potatoes and one of the largest producers of other potatoes within the EU. Over the last three years, the annual production of certified seed potatoes was approx. 957,000 t from an area of 38,000 ha (extracted from annual survey reports), with an average yield of 35-40 t/ha. Over the last three years, about 120,000 ha (as above) per year were planted with starch and ware potatoes. Yields are generally high; in 2011, a total of 6.02 million t was produced, with an average yield of 50.9 t/ha for ware and 41.7 t/ha for starch potato. In 2011, there were 9,165 potato growers with average production area of 17.3 ha. Figures 1-3 below provide an overview of main potato growing areas in the Netherlands. Figures 1-3: main potato growing areas in the Netherlands Seed Potato 4.3 Ware Potato Starch Potato POTATO TRADE Seed potatoes The Netherlands is the world’s largest exporter of seed potatoes. The trade is concentrated: 10% of traders export 90% of the volume. From 2009 to 2011, on average 370,000 t per year were traded to the rest of the EU and 360,000 t per year to third countries. In 2012 the Netherlands imported around 1,100 t of seed potatoes for seed potato production from the EU Member States (mainly from UK (Scotland), Belgium, Denmark, Germany and France). 2 Other potatoes In the 2010-2011 marketing season, the Netherlands traded 634,200 t of potatoes other than seed to other EU countries and 422,700 t to third countries. The Netherlands is also an importer of potatoes for processing and for starch production. In the 2010-2011 marketing season, more than 1.1 million t were imported, of which around three quarters were for direct consumption and for processing and one quarter for starch production. 5 5.1 FINDINGS AND CONCLUSIONS ORGANISATION AND LEGISLATION ON OFFICIAL PLANT HEALTH CONTROLS Legal requirements Article 1(4) of Directive 2000/29/EC provides that Members States shall ensure a close, rapid, immediate and effective cooperation between themselves and the Commission in relation to matters covered by this Directive and that, to this end, each Member State shall establish or designate a single authority, which shall be responsible, at least, for the coordination and contact in relation to such matters. Article 2(1)(g) of the same Directive requires that the responsible official bodies in a Member State shall either be the official plant protection organisation (Single Authority-SA) set up under the IPPC, or any other State authority established at national level or within the terms established in that Article, at regional level; a close cooperation between SA and the responsible official bodies shall be ensured. The same article allows responsible official bodies in a Member State to delegate their tasks. Laboratory testing may only be delegated if the responsible official body ensures throughout the time of the delegation that the legal person to which it delegates laboratory testing can assure impartiality, quality and protection of confidential information, and that no conflict of interest exists between the exercise of the tasks delegated to it and its other activities. Article 2(1)(i) of Directive 2000/29/EC requires Member States to ensure that their public servants and qualified agents have the qualifications necessary for the proper application of the Directive. Article 12(2) of the same Directive establishes that inspectors shall have access to plants, plant products or other objects at all stages in the production and marketing chain and that they shall be entitled to make any investigation necessary for the official checks concerned, including those related to the plant passports and the records. Article 291.1 of the Treaty on the Functioning of the EU requires that the Member States adopt all measures of national law necessary to implement legally binding Union acts. Articles 6.5, 6.6 and 13c(1)(b) of Directive 2000/29/EC require that, subject to certain exemptions, producers, collective warehouses, dispatching centres and importers of certain plans and plant products must be included in an official register of a Member State under an official registration number. Directive 92/90/EEC establishes the obligations for producers and importers of certain plants and plant products and the details for their registration. Findings 5.1.1 Designation of Competent Authorities Detailed descriptions of the control system are provided in the country profile for the Netherlands 3 (see: http://ec.europa.eu/food/fvo/controlsystems_en.cfm?co_id=NL ) and in the reports from previous audits listed in 4.1 above. The overall organisation of official plant health controls has also been described in the DG(SANCO) 2011-8977 audit report. Since then, certain changes took place in the organisation of the plant protection service with the establishment on 1 January 2012, of NVWA. NVWA is the Single Authority for plant health matters within the meaning of Article 1(4) of Directive 2000/29/EC and has the overall responsibility and supervision of the activities related to Directive 2000/29/EC. It functions as an agency of the Ministry of Economic Affairs, Agriculture and Innovation – Ministerie van Economische Zaken, Landbouw en Innovatie (ELI). NVWA is comprised of the Office for Risk Assessment and Research and five divisions of which the Division for Agriculture and Nature has the same structure and areas of responsibility as the former Plant Protection Service (PD). The activities related to potato controls are divided between NVWA and the Dutch General Inspection Service for Agricultural Seed and Seed Potatoes – Nederlandse Algemene Keuringsdiest (NAK). Among NVWA competences are the supervision and auditing of official inspection bodies, the development of inspection protocols, the validation of test methods, the organisation of surveys and the handling of outbreaks. Plant health policy, international representation and research funding remain within the competence of ELI. NAK is an official independent public body authorised to carry out inspection of crops and provide certification according to instructions received from the NVWA. It operates on long-term agreement under the financial and technical supervision of ELI and NVWA respectively. Its main activities are the implementation of marketing and plant health directives on agricultural seed and seed potatoes and the provision of routine diagnostic support. Specific plant health tasks assigned to NAK include those of surveying, sampling and laboratory testing for the detection of regulated harmful organisms. 5.1.2 Staffing provisions NVWA employs around 2,100 staff: approximately 145 are in charge of plant health. NAK has around 210 full time staff supported by additional 150 temporary staff, working at the laboratory or sampling potatoes, during peak periods. A large proportion the resources are devoted to the potato sector. During the inspections witnessed by the FVO team, staff resources were not mentioned as a problem or a limiting factor for controls of regulated material. 5.1.3 Training and working instructions Details of inspector specialisation and training have been provided in the DG(SANCO) 2011-8977 audit report. NAK inspectors receive specific training resulting in an official qualification. When necessary, the NVWA organises additional specific training sessions for NAK staff. Inspectors use a personal digital assistant (PDA) and/or a laptop computer providing access to a comprehensive selection of information data. Work instructions including the sampling rates, methods and densities for tubers, soil, surface or waste water have been produced. Operating procedures provide, inter alia, standardised forms with codes and serial numbers of samples to be taken for laboratory analysis. They also provide information on where there is need for increased sampling rates associated with elevated plant health risk. The inspectors met by the FVO team were well informed and prepared for carrying out the tasks as described in their instructions. 4 5.1.4 Legal powers of inspectors Both NVWA and NAK inspectors have the necessary legal power to access the premises of places of production, grading and storage of potatoes and carry out phytosanitary controls. Handling of outbreaks and implementation of specific measures is handed over to the NVWA, which issues a statutory notice to inform the producer and impose appropriate measures. 5.1.5 Work planning and record keeping An ad hoc expert working group organises meetings for the implementation of new legislation. A core group with experts of NVWA and NAK provides technical advice and decides on the management of more serious outbreaks. The selection of inspection and surveillance places is planned at central level. Inspections and sampling are recorded electronically and are signed by the producer / stakeholder via the PDA. Inspection, sampling and testing records are kept by NVWA (ware potatoes) or by NAK (potato seed) in a common database providing daily interchange of inspection data, test results and registration data on certification. 5.1.6 Cooperation and communication with stakeholders NVWA maintains close contacts with professional organisations such as the potato growers' “Dutch arable farming union” and the “Agricultural and horticultural organisation”, the potato traders' “Dutch potato organisation” and the “Organisation of potato processing industry”. Regular meetings taking place between the NVWA and representatives of potato industry aimed at keeping the organisations informed about the latest developments in the legislation and to advise stakeholders on phytosanitary issues. Information manuals for the management of post-outbreak situations of harmful organisms are regularly issued for farmers. 5.1.7 Laboratories The laboratories carrying out official controls in the potato sector have been presented in the DG(SANCO) 7681/2005 mission report. NAK has been accredited according to ISO/IEC 17020 (inspection) and 17025 (testing) standards. The FVO team visited the PCN section of NAK and observed the test line of soil samples. The FVO team noted that testing of samples is carried out following specific detailed test protocols approved by the NVWA. Clear procedures for registration and processing of samples were in place to ensure anonymity. Reporting requirements of test results to the growers and the NVWA are clearly described. Resistance testing of potato varieties is carried out under the supervision of NVWA by the laboratories of three private companies according to a detailed experimental protocol as described in Annex IV of 2007/33/EC. This among others indicates the methodology of counting cysts, the number of replicates to be used and quality assurances to be applied by the laboratories. Apart from the standard PCN populations required by the Directive, the laboratories assess the variety resistance towards the “local” populations representing the virulence group Ro2/Ro3 and pathotype Pa2. The practical organisation of the testing is handled by NAK and the system is subject to regular blind tests. Potato varieties for resistance testing are sent by the breeders to NAK, which verifies the identity of the varieties and re-distributes them to the laboratories together with differential cultivars in anonymous form. Two of the three companies performing resistance testing are involved in potato breeding and they test only their own material. A separate protocol is in place for handling test results including checks of raw data and supervision of statistical analysis. NVWA organises audits to check if relevant requirements are fulfilled and compiles the lists with the scores of resistance of different potato varieties. 5 The FVO team visited one of the resistance testing laboratories. It is owned by a private company representing a cooperative of seed potato producers and breeders. The company develops new potato varieties adapted for cultivation in various European and international destinations. An authorisation has been given to the company to carry out the PCN resistance testing of their own potato varieties according to an approved laboratory protocol. All data of the official tests described in Directive 2007/33/EC are sent to the NAK and from there to NVWA for analysis according to the protocol. On average, four new varieties are assessed for PCN resistance by this company every year. Since there is a two year testing period, on average eight varieties are checked annually. Overall, the degree of variety resistance to PCN is assessed against five or six PCN populations present in the area as the introduction of other PCN populations had not been permitted. The results of the tests carried out by the company are considered as official and are included in the official list of registered potato varieties indicating the degree of resistance to PCN (see also section 5.2.7.3). 5.1.8 Relevant national legislation and rules Both Directives on the control of potato ring rot and on the control of Ralstonia solanacearum have been transposed in the Netherlands. Council Directive 2007/33/EC of 11 June 2007 on the control of potato cyst nematodes was transposed by royal decree No.243 and by ministerial regulation No. 126660 published on 29 June 2010 and applied from 1 July 2010. NVWA has also adopted a protocol on PCN for official inspection bodies. This protocol includes requirements for the NAK procedures, exchange of data and reporting. 5.1.9 Registration/approval of establishments The registration of producers and traders has been presented in detail in the DG(SANCO)7681/2005 mission report. All producers of seed potatoes and traders, packers, processors and wholesalers of seed and ware potatoes are registered. NAK is responsible for the registration of seed potato producers who are obliged to submit annually an application accompanied by the certification labels of the seed used. Companies involved exclusively with wholesale potato trade and packaging and/or processing are registered by the Commodity Board for Agricultural Wholesale. As from 2012, seed producing companies and breeders have the option to submit their applications for both certification and field testing of PCN, via a web application system operated by NAK. The NAK laboratory system is interlinked with PRISMA, a laboratory information management system of the NVWA allowing for the registration of ring rot and brown rot outbreaks. PRISMA is also used for registration of PCN findings in affected plots and of the measures taken. It also allows for the production of official letters to be sent to producers and the registration of inspections carried out to check the control measures applied. The coordinates of the field where potatoes are grown and additional information such as the class and the origin of the seed used, as well as the number of rows where a specific variety is grown, have to be declared by the producer. A registration/certification fee is directly payable to NAK. Overall, 1,872 seed potato producers and 418 wholesalers were registered in 2012. Individual ware potato producers are not officially registered but their data can be made available through the seed trading companies and ware potato wholesalers. Seed potato producers registered with NAK are not permitted to use in parallel farm-saved seed. Of the approx. 6,000 ware potato producers, 2-3% use farm-saved seed produced under the official system for approval and control of such. Conclusions There is a good general organisation of controls in the potato sector in the Netherlands and a clear structure and division of responsibilities in line with EU legislation. There is good cooperation and communication with the key stakeholders for implementing controls in the potato sector. Inspectors have appropriate legal powers to act and are supported by efficient laboratory checks. Potato 6 producers and traders are registered as required in EU legislation. Laboratory analysis for PCN detection and identification is supported through clear reporting lines. However, the CA has authorised private breeders to carry out the official tests of their own potato varieties to assess the level of PCN resistance. This is not in line with Article 2.1(g) of Directive 2000/29/EC, requiring that if official testing is delegated to a private body, there shall be no conflict of interest between the exercise of the tasks delegated to it and its other activities. 5.2 POTATO CONTROLS 5.2.1 Clavibacter michiganensis ssp. sepedonicus surveillance strategy and results Legal requirements Article 2 of Directive 93/85/EEC requires Member States to conduct systematic official surveys for Clavibacter michiganensis ssp. sepedonicus in their territory and establishes the requirements to be met. Findings Surveillance covers all stages of potato production and trade as well as potatoes intended for export to third countries or other EU Member States and imported potatoes. NVWA in collaboration with NAK developed an integrated survey protocol for ring rot and brown rot. All samples taken are tested simultaneously for Clavibacter michiganensis ssp. sepedonicus and Ralstonia solanacearum. The official controls for seed potatoes consist of visual checks and sampling for laboratory analyses both during the vegetation period and post-harvest. Controls follow a systematic approach of testing one sample (200 tubers) per lot (deriving from max. 6ha of land). Seed potato producers with confirmed outbreaks or having clonal/contact links with outbreaks which occurred in previous growing periods are scheduled as having a “high risk profile”. In this case the sampling rate is increased to one sample (200 tubers) per 25 t during the three years after the finding. The same sampling rate applies if producers are caught employing high risk cultivation practices such as cutting of seed potatoes or irrigation with surface water. The official controls for ware potatoes consist of random sampling of produced lots, which is carried out in ware potato packing stations, collective warehouses, storage facilities and potato starch producing factories. Sampling is targeted in cases of outbreak follow up and “high risk profile” sampling of ware potato producers applies at a rate of one sample (200 tubers) per 150 t. There is a legal basis for inspections carried out on farm-saved seed; these focus on the random field inspections and test 10% of produced lots. Legally produced farm-saved seed is used exclusively at the same place of production, to produce ware potatoes or potatoes for industrial processing. During 2011, 122 lots of seed from other Member States and 72 lots of ware potatoes originating from Member States and third countries were subject to laboratory testing for both bacteria. No positive ring rot or brown rot cases were identified. The FVO team visited a farm where it observed sampling of seed potatoes for ring rot and brown rot and noted that the inspector had access through his PDA to the central NAK database providing information on the number of samples to be taken according to a specific sampling protocol. Sampling was carried out within the framework of the annual surveys undertaken by NAK after a notification that harvest had been completed for a field registered for the production of potato seed. A request had been submitted to NAK by the seed potato trading company for additional sampling to be carried out. Representative tuber samples were taken using appropriate procedures and equipment to avoid cross contamination and false positives. Samples were registered and labelled to safeguard anonymity. 7 Table 1 below shows the results of surveys for ring rot in the 2011 potato harvest. A substantial part of the seed potato samples tested in the EU is of the Dutch seed potato crop. On average, 22,125 samples per annum were analysed during the last three growing periods. The average sampling density of potato seed in 2011 was 1.6 ha/sample while that of other potatoes was 47.4 ha/sample. For seed, the average density of sampling applied by those EU Member States where ring rot is known to occur, was 1.5 ha/sample and for other potatoes 55.2ha/sample. Of the annual samples examined in 2011, approx. 5% were taken for the obligatory follow-up of outbreaks. In 2012, 1,150 samples of ware potatoes and potatoes for the production of starch were taken from processing factories and 500 samples from growers with clonal/contact links with previous ring rot outbreaks. Table 1. Results for the annual survey for ring rot in seed and ware potatoes harvested in 2011 Category of potatoes Total Laboratory testing cropping No. of No. of lots Size of lots Sample area (ha) samples period Breeding material 219 Pre-basic, basic and certified seed 36,682 22,258 Seed - other (Targeted survey) 200 Farm saved seed for starch 61 28,872 61 No. of positive lots Various Aug-Nov 0 1.3 ha Aug-Nov 1 Various Aug-Apr 0 1.0 ha Aug-Nov 0 Ware 72,000 497 Various Aug-Apr 2 Industrial for starch production 49,168 1,026 Various Aug-Apr 0 971 Various Aug-Apr 14 Ware - other (Targeted survey) Table 2 below provides details of ring rot incidence calculated as number of positive lots compared to total number of samples taken between 2007 and 2011. This is based on the analysis of data provided by the NVWA in the annual survey reports that have been submitted to the Commission for the harvests of 2007-2011. Table 2. Incidence of ring rot, 2007-2011 Type Ring rot incidence (No. Contaminated lots / Total number of samples x 100%) 2007 harvest 2008 harvest 2009 harvest 2010 harvest 2011 harvest Seed potatoes 0.005 0.005 0.000 0.030 0.004 Other potatoes 0.029 0.026 0.189 0.130 0.626 The data indicate that there is very little, ring rot infestation in potato seed produced in the Netherlands. However, during the last growing period there has been an increase in the overall level of ring rot incidence mainly due to the increased numbers of findings which occurred in ware potato production. The handling of outbreaks is covered in section 5.2.3.2 below. Conclusions There is a well organised system of surveillance for ring rot in the seed and ware potato production in the Netherlands. Ring rot surveys are compliant with EU requirements. Density of both seed and ware potato sampling is close to the average of Member States affected by ring rot. The total number of samples taken is the highest in the EU. The overall incidence of ring rot in potato production remains very low. 8 5.2.2 Handling of suspected and confirmed ring rot outbreaks Legal requirements Article 4 of Directive 93/85/EEC stipulates the actions to be taken by a Member State in case of suspected outbreak of Clavibacter michiganensis spp. sepedonicus. Articles 5, 6 and 7 of the same Directive establish provisions that the Member States have to apply when the presence of Clavibacter michiganensis spp. sepedonicus is confirmed. ISPM No. 5 defines as a “place of production” any premises or collection of fields operated as a single production or farming unit. This may include production sites which are separately managed for phytosanitary purposes. Findings For the management and follow up of outbreaks, a technical advisory team has been formed within NVWA with the participation of coordinating inspectors from both NVWA and NAK and scientific experts. The team is assisted by international policy and legal advisers. Trace back and forward of clonally related lots is carried out by inspectors using inter alia the PRISMA application. The team is also responsible for analysing the possible sources and spread of outbreaks, requesting extra sampling and, if necessary, variety checks. Decisions on outbreak handling are taken in collaboration with the manager of the arable crops sector of NVWA. Upon suspicion of an outbreak (i.e. following a positive immunofluorescence test and a positive second screening test) the place of production in question is suspended from trading potatoes through a statutory notice issued to inform the producer. A demarcated zone is designated through a chart of a “clonal tree” with upstream and downstream places of production where lots with sister or parental relation to the suspected lot(s) were produced, handled or stored; the primary source and the extent of the contamination is determined. In parallel, statutory notices to inform producers associated through the chart of the “clonal tree” are issued; as all clonal and contact links are examined, cases of producers exchanging potato material plots of land and agricultural machinery are also investigated. Intensive sampling of potato lots which are still present in warehouses takes place to contribute to the investigation of the origin of the infection and the designation of the demarcated zone with contaminated and probably contaminated material. Where sister lots have been exported the competent authority of the receiving country is informed. Upon confirmation of the contamination, the control measures laid down in Directive 93/85/EEC are implemented on the contaminated and probably contaminated material at the place of production. All measures to be applied are communicated to the producer. Depending on the results of the investigation other associated places of production having clonal or contact links are also included in the demarcated zone and their remaining potato lots, agricultural machinery and storage places are designated as contaminated or probably contaminated. The FVO team visited three places of production where ring rot had been found, all producing certified seed and ware potatoes. All producers involved confirmed that: • Following the first notification for a suspicion of outbreak they had to suspend all commercial activities involving potato trade; samples were taken by NVWA from all potato lots still present in their premises at the sampling rate of one sample per 25t of potatoes; • Upon confirmation of the outbreak and following disposal of the potatoes they were instructed to proceed with disinfection of all potato handling machinery, wooden potato storage crates and warehouses based on detailed guidelines; additional instructions were provided for the control of potato volunteers in contaminated or probably contaminated fields; 9 • Compliance with the disinfection measures and volunteer control was confirmed through complementary checks. Follow up testing of potato lots produced in their premises was carried out at a higher sampling rate of 1 sample/25 t. The outcome of three recent ring rot investigation, presented according to the chronological order of the outbreaks, is described in detail below. Producer 1 runs an arable crop farm producing seed and ware potatoes, onions, sugar beet and cereals. Prior to the ring rot outbreak detected in potatoes stored in the premises, the producer also provided potato storage services to farmers and multiplication of potato seed through cutting. The producer was identified as a result of a trace-back exercise after the detection of ring rot in seed potatoes in 2010. Out of 86 samples taken from the premises of his farm of the remaining 2010 potato lots, 17 were found positive. The quick build-up of ring rot incidents was attributed by NVWA to the high risk practice of cutting potato seed. The producer stated that following the detection of ring rot in 2010: • a four year prohibition was imposed for growing seed potatoes in contaminated fields. Other fields of the farm could be cultivated for ware potatoes the year after the outbreak; • contaminated potatoes were sold for processing; transport to processing factories with approved solid and liquid waste disposal facilities took place in closed trucks. Other potatoes were individually packed in 25kg bags and sold as ware. • seed potato production was also approved to be carried out in the year following that of the designation of the outbreak in rented plots of another farm using the same machinery after disinfection; • high grade certified pre-basic material and new wooden crates were purchased for this purpose. Producer 2 runs a 3-4 year arable crop rotation scheme growing mainly potatoes, sugar beet, wheat, onion and bulbs in an area totalling 400ha. 120-150 ha are used annually for the production of certified potato seed, early ware potatoes and potatoes for industrial processing. In March 2012 investigations were initiated tracing back a notification by another Member State where ring rot was detected in the 2011 harvest of “class A” seed. The planting material used for this crop originated from this producer (his 2010 crop). Sampling and testing of all potato lots remaining within the premises of this place of production revealed ring rot contamination only in clonally related material (35kg) of the same variety. Other potatoes remaining in the premises (765 t) tested negative. Testing of clonally related potatoes of other producers who had received seed from him in 2010 or 2011 revealed several contaminated lots. It also revealed contaminated lots at several producers who had purchased seed potatoes of another variety from the 2010 harvest. The producer stated that all premises of his place of production were designated as contaminated and that the competent authorities provided him with adequate advice on how the situation should be handled. All remaining potato lots and lots delivered to other producers (some 2,800 t) were withdrawn and sent to a fermentation plant for composting between early May and late June 2012. A prohibition for growing seed potatoes at the premises was imposed. During the first year after the finding, the producer was allowed to grow only ware potatoes in non-contaminated fields using newly introduced certified seed; a high risk sampling rate was applied for ring rot testing. The producer also stated that: • soon after the detection of the outbreak, seed potato production was approved to be carried out in plots of a newly bought farm not having previous potato cropping history; 10 • high grade certified pre-basic material and new wooden crates were purchased for this purpose; • disinfected cropping and grading machinery and warehouses of the contaminated place of production were used for producing the crop that was planted in April 2012. Producer 3 was identified as having received potato seed from producer 2. He also runs a 3-4 year arable crop rotation scheme growing mainly potatoes, sugar beet and brussel sprouts on an area totalling ca. 240ha. Starting from higher grades, he grows certified potato seed and ware potatoes in ca. 60-65 ha of land, often exchanging some of his plots with neighbouring farms. The producer stated that by March 2012, 85% of his seed potatoes had already been sold. Out of 81 samples taken in total from potatoes of the 2011 crop remaining in the premises, four samples of ware potatoes and one sample of seed saved for own use, tested positive. After the detection of positive samples, potatoes remaining in his premises had to be destroyed. Only a small amount of newly bought seed still in the original sealed containers was exempted. In total 2,800 t of seed and ware potatoes produced in 2011, were sent for processing at a feed producing company in the period between end-April to end-August 2012. The producer also stated that: • ware potato production was re-introduced in 2012 soon after the detection of ring rot positive samples; for this purpose certified seed was planted in plots other than those that had been designated as contaminated; • potato seed production in 2012 was permitted soon after the detection of ring rot positive samples by using certified seed planted in rented plots of another farm using the same machinery after disinfection; • disinfected cropping and grading machinery and warehouses of the contaminated place of production were used for producing the crop that was planted in April and harvested in September. Seed and ware potatoes had been sampled following the high-risk sampling rate of one sample/25 t; at the time of the audit, results were still pending. An organic waste processing plant producing animal feed was also visited by the FVO team. The raw materials are by-products of potato processing factories, dairies and breweries. The company also provides transport services for material to be transported to its premises and had processed contaminated and probably contaminated material from producer 3. Upon arrival contaminated potatoes were immediately washed out and processed into liquid pig-feed heated to 80oC. Water was re-used in a closed system and soil/mud was stored in a 15 t capacity tank until deeply buried in a nearby landfill. NVWA inspectors were present throughout the removal/burial process. Conclusions Following ring rot outbreaks, control actions for both seed and ware potatoes involve appropriate tracing back and forward of contaminated and probably contaminated material. Measures taken on places of production affected by ring rot outbreaks are also, to a large extent, in line with Annex IV of Directive 93/85/EEC. Monitoring is intensified in producers using clonally related material. Measures are also taken for producers having contact links through shared machinery with contaminated places of production. Ring rot eradication and disinfection measures in place are adequately supervised by inspectors. The waste disposal facility for contaminated and probably contaminated potatoes visited by the audit team met the requirements of Directive 93/85/EEC. Farmers affected by ring rot outbreaks generally grow seed potatoes in rented / bought fields of other farms earlier than the second year after the outbreak. However, even if disinfected machinery is used, newly introduced fields for potato seed production are still considered by the FVO that they 11 belong to the same place of production. In two of the three cases visited, production of the potato seed even started long before the contaminated potatoes had been cleared off the place of production and disinfection completed, which further increases the risk of the eradication failing1. Growing seed potatoes in a contaminated place of production in the growing year following that of the designated contamination is not in compliance with Annex IV point 4.1.(b) of Directive 93/85/EEC. The safety margin envisaged by the Directive generally means that no potatoes for the production of seed can be grown in the place of production in the year of the outbreak or the year after. 5.2.3 Ralstonia solanacearum surveillance strategy and results Legal requirements Article 2 of Directive 98/57/EC requires requires Member States to conduct systematic official surveys for Ralstonia solanacearum in their territory and establishes the requirements to be met. Findings As mentioned previously all samples taken are tested simultaneously for both ring rot and brown rot (see also section 5.2.1). Brown rot surveillance covers all stages of potato production and trade and follows the systematic approach of testing applied in ring rot surveys. A “high risk profile” sampling rate of one sample per 25 t is applied to seed in case of outbreaks or to producers exposed to brown rot through clonal and/or contact links and to producers irrigating potato crops with surface water. For ware potatoes the “high risk profile” sampling rate is one sample per 150 t. The number of samples tested for brown rot and results for the 2011 growing period are detailed in table 3 below. Table 3. Results for the annual survey for Ralstonia solanacearum for the 2011 growing period Category of potatoes Total cropping area (ha) Breeding material Pre-basic, basic and certified seed Laboratory testing No. of samples No. of lots 219 36,682 Farm saved seed for starch Size of lots Sample period No. of positive lots Various Aug-Nov 0 22,258 28,872 1.3 ha Aug-Nov 0 61 61 1.0 ha Aug-Nov 0 Ware 72,000 497 Various Aug-Apr 1 Industrial for starch production 49,168 1,026 Various Aug-Apr 0 103 Various Aug-Apr 3 Ware - other (Targeted survey) L. esculentum 25 S. dulcamara 6 Pelargonium sp. Water No. of visual inspections 47 75 2,139 47 1 In their response to the draft report the Competent Authority noted that: A ring rot finding in spring is not common. The National Plant Protection Organisation (NPPO) recognizes the potential risks that are involved in this period where new production of potatoes was started when there were still infested potatoes in storage. All the activities for potatoes have been carried out under close supervision of the NPPO. Looking at the level of specific processes, the machinery and facilities for starting the new production were separated from those for storage and delivery of infested material. 12 On average, 24,021 samples per annum were analysed during the last three growing periods. The sampling density of potato seed in 2011 was 1.6 ha/sample while that of other potatoes was 71.8 ha/sample; both figures are above the average sampling density applied by Member States affected by the bacterium (1,9ha/sample and 100ha/sample respectively). Of the annual samples examined in 2011, approx. 0.5% were taken for the obligatory follow-up of outbreaks. The same table also indicates the survey activity carried out in the Netherlands in water and R. solanacearum hosts other than potato. Netherlands analyses a very high number of water samples. In 2012 4,000 samples of surface water were taken at random from 1,000 high risk locations. Table 4 below provides details of the percentage of tuber samples found to be contaminated with brown rot in each harvest between 2007 and 2011. This is based on the analysis of data provided by the NVWA in the annual survey reports that have been submitted to the Commission for the harvests of 2007-2011. Table 4. Incidence of brown rot, 2007-2011 Type Brown rot incidence (No. Contaminated lots /Total number of samples x 100%) 2007 harvest 2008 harvest 2009 harvest 2010 harvest 2011 harvest Seed potatoes 0.009 0.005 0.004 0.000 0.000 Other potatoes 0.000 0.000 0.037 0.066 0.237 There is a considerable progress in the Netherlands with very little or no brown rot infestation in seed potatoes produced. This is largely attributed to the general prohibition of irrigating seed potato crops with surface water, introduced in the Netherlands in 2005. However, during the last growing period, there has been an increase in the findings in ware potato production. The handling of outbreaks is covered in section 5.2.4.2 below. Conclusions There is a well organised system of surveillance for brown rot in the seed and ware potato production in the Netherlands. Surveys meet the EU requirements. Density of seed potato sampling is far above the average of Member States affected by brown rot. The total number of samples taken is the highest in the EU. The overall incidence of brown rot in potato production remains very low. A substantial amount of water samples is analysed for R. solanacearum and additional sampling is carried out on other hosts. 5.2.4 Handling of suspected and confirmed brown rot outbreaks Legal requirements Article 4 of Directive 98/57/EC stipulates the actions to be taken by a Member State in case of suspected outbreak of Ralstonia solanacearum. Articles 5 and 6 of the same Directive establish provisions that the Member States have to apply when the presence of Ralstonia solanacearum is confirmed. ISPM No. 5 defines as a “place of production” any premises or collection of fields operated as a single production or farming unit. This may include production sites which are separately managed for phytosanitary purposes. Findings As for ring rot the management and follow up of brown rot outbreaks is carried out by a technical advisory team and a similar methodology to that applied for ring rot. The team takes into consideration additional factors like flooding or irrigation with surface water in prohibited areas. For example, account was taken of a large flood that took place recently in Friesland and affected 13 350 plots of 65 producers. Official maps with the areas where surface water irrigation is prohibited are available on the internet. During the last two growing periods there were no violations of the prohibition on surface water. Trace back and forward of clonally related lots is achieved through PRISMA. The FVO team visited a farm growing ware potatoes, onions and sugar beet following a 3 year crop rotation scheme on an area totalling 50ha located outside the irrigation prohibition area. Irrigation with surface water is not applied. In 2011, brown rot was found in one lot of ware potatoes from this farm, during the annual surveillance exercise. Follow up monitoring carried out at five other producers using clonally related seed showed brown rot contamination at three. Tracing back investigations to the place of production of the certified seed gave negative results. No indication of irrigation with surface water was in place. The affected farm was designated as contaminated while another farm sharing machinery was included in the zone for controls. Contaminated and probably contaminated potatoes were sold for processing in a company having appropriate soil disposal facilities. Conclusions Control actions involve appropriate tracing back and forward of contaminated and probably contaminated material. Measures taken at the place of production visited by the audit team and affected by brown rot are in line with Annex VI of Directive 98/57/EC. Monitoring is intensified at producers using clonally related material. Measures are also taken for producers having contact links through shared machinery with contaminated places of production. 5.2.5 Specific ring rot and brown rot control programmes Legal requirements Article 11 of Directive 93/85/EEC provides that Member States may adopt such additional or stricter measures as may be required to combat Clavibacter michiganensis ssp. sepedonicus or to prevent it from spreading, in so far as they are in compliance with the provisions of Directive 2000/29/EC. Article 10 of Directive 98/57/EC provides that Member States may adopt such additional or stricter measures as may be required to combat Ralstonia solanacearum or to prevent it from spreading, in so far as they are in compliance with the provisions of Directive 2000/29/EC. Findings There is no provision for the compensation of producers by the State in case of financial damages caused by ring rot and brown rot outbreaks in the potato sector. A voluntary insurance mutual fund has been established for this purpose. The insurance scheme provides coverage to approx. 3,500 potato producers and 95,000 ha. To date, about 88% of seed potato producers as well as 73% of starch potato and 38% of ware potato producers are covered. Since 2008 the insurance scheme also provides coverage for outbreaks of Potato spindle tuber viroid. Eligibility of compensation depends on the compliance of the producer with the phytosanitary measures set by NVWA. Netherlands has adopted a hygiene protocol for the prevention of potato bacteria outbreaks agreed with many partners in the potato production chain such as grower associations, handling and grading companies, processors and transporters. In order to minimise the risk of ring rot and brown rot spread, the protocol provides, inter alia, for preventive measures like the regular cleaning/ disinfection of trucks used for transport and of wooden crates used at central grading companies. Exchange of machinery between producers may take place only after intensive cleaning and disinfection. A research project has been launched to examine the effectiveness of disinfection techniques on wooden crates after bacterial contamination. A ban has been imposed for the re-use of disinfected 14 crates in which contaminated lots have been stored. The potato bacteria hygiene protocol provides for the use of jumbo bags for the transport of potato seed. The use of wooden crates is to be restricted within the same place of production. Currently there is no legal basis prohibiting the cutting of potato seed for either ware or seed production. However, producers are discouraged from applying this practice by the implementation of an increased sampling rate of one sample/25 t at harvest to their seed production. NVWA has launched a long term eradication campaign to tackle brown rot and to prevent the spread of the disease through contaminated surface water. Surface water from clearly defined nonprohibited areas can only be used in ware potato production. Detailed maps indicating the surface water prohibition areas are issued annually. As an additional measure, since 2005, a full ban has been imposed for using surface water in seed potato production (see also section 5.2.4). NVWA carries out regular controls for to check for infringements of the irrigation bans within and outside the prohibited areas. Conclusions Netherlands has adopted good additional measures to combat Clavibacter michiganensis ssp. sepedonicus and Ralstonia solanacearum in line with Article 11 of Directive 93/85/EEC and Article 10 of Directive 98/57/EC. 5.2.6 Globodera pallida and G. rostochiensis surveillance strategy and results The NVWA has developed a protocol for the investigation and the management of PCN. The protocol describes the activities to be carried out by NAK under the supervision of NVWA, together with a detailed flowchart of actions to be taken for the production of PCN-free potato seed. The management of PCN is supported by an IT application the “PCN viewer”, linked with the “Geoexplorer” a geographical information system that provides access to maps with plots of land indicating their previous cropping history. The PRISMA database on PCN is also linked with the PCN viewer. Areas which have been registered as infested can be viewed on the laptops of the NAK inspectors (see also section 5.1.9). 5.2.6.1 Definition of a field and demarcation of PCN infestations Legal requirements Article 3 of Directive 2007/33/EC states that responsible official bodies of the Member State shall define what constitutes a field for the purposes of this Directive in order to ensure that phytosanitary conditions within a field are homogeneous as regards the risk of PCN. In doing so, they shall take into account sound scientific and statistical principles, the biology of PCN, the cultivation of the field and the particular production systems of the host plants of PCN. ISPM No. 5 defines as a “field” a plot of land with defined boundaries within a place of production on which a commodity is gown. Unless specifically indicated in the text, when the word field is used, this definition is intended and not the definitions provided below by the CA. Findings In the context of official investigations referred to in Article 4.1 of Directive 2007/33/EC, NVWA has provided three different definitions of a field depending on the development in its PCN infestation status: • • A field for which an official investigation is required under Article 4.1: “A plot of land destined by a grower for the production of a specific commodity of plants for planting as listed in Annex I of the PCN Directive, or for the production of seed potatoes”. A field officially recorded as infested in line with Article 8 of Directive 2007/33/EC: “A plot of land delimited by the Plant Protection Service of the Netherlands as infested with PCN”. 15 • A field officially recorded as free from PCN in line with the sampling and testing methods of Annex II of the Directive: “A plot of land delimited by the Plant Protection Service of the Netherlands as free from PCN based on official investigations as required for the intended use”. The delimitation of PCN infestation found in the official investigation is based on the application of a PCN distribution model according to which the presence of the nematodes retains the form of oval foci in the direction of cultivation with the highest density of nematode cysts observed around the centre of the ellipse. The model is the result of a study that involved very intensive sampling of 37 PCN infested fields and the analysis of 40 foci, in order to indicate the spatial distribution characteristics of cysts. As a follow up, sampling methods for the detection of PCN were developed and evaluated2. On basis of these studies, the PCN management programme NemaDecide was developed in 2005. On request of the NVWA, the Wageningen University and Research has made a statistical analysis on the foci model, using the Monte Carlo method, to be able to demarcate PCN infestations under field conditions. This statistical analysis is explained in detail in a non peerreviewed publication by Schomaker C.H. and Been T.H. in the 2010 OEPP/EPPO Bulletin 40, p. 147-157. During the development of the current PCN control Directive, analyses have been made with NemaDecide to define the required detection probability for PCN infestations. The calculations are based on the assumption that a population of PCN cysts will be dispersed within a field in one large (100 cysts/kg of soil) and three smaller foci (50 cysts/kg of soil) located almost exclusively in the direction of cultivation. The calculations show that the demarcation of PCN infestation in a field should not necessarily involve the demarcation of entire plots according to cropping or cultivation commonality, but it may follow a segmented approach of “PCN contaminated strips or zones within a larger field”. Based on the model it has been calculated that the demarcation of the infested strip or sampling unit along the direction of cultivation, plus two 16m wide zones located on either side of the infested part, up to a total length of 111m (an exemption provided for in case of a very long field) are sufficient to ensure freedom from PCN in the remaining parts of a plot with high statistical confidence levels. Figures 4i and 4ii below indicate the foci model and the demarcation in the direction of cultivation developed with support of the statistical analyses of Schomaker and Been. Figure 4i. Foci model Figure 4ii. PCN demarcation of a field according to NemaDecide PCN management programme As additional safeguard the developed protocol for the implementation of the model also provides for the expansion of the demarcation to a safety zone located between two infested zones which are 2 In their response to the draft report the Competent Authority provided details of the scientific references related to these studies: Schomaker C.H. and Been T.H. (1999): A model for infestation foci of potato cyst nematodes Globodera rostochiensis and G. pallida. Phytopathology 89, 583-590 and Been T.H. and Schomaker C.H. (2000) Development and evaluation of sampling methods for fields with infestation foci of potato cyst nematode (Globodera rostochiensis and G. pallida Phytopathology 90, 647-656 16 then merged into a bigger PCN infested field (including the safety zone). This may take place if the total width of this zone is less than 27m, between two new or a new and an existing infestation. The same 16m demarcation is used in all circumstances. Prior to the date of the implementation of the Directive two 6m wide strips on either side of the infested part were designated as PCN contaminated instead of the two 16m width strips applied today. This led the average size of infested plot to be doubled (now 2.2ha). The model for demarcation is implemented without taking into consideration the actual circumstances in the field at hand, such as cropping history, water movement due to flooding or additional soil movement due to agricultural machinery moving across the direction of cultivation. Likewise, demarcation is applied the same way regardless of the sampling rate used in the field, even though different sampling rates result in different detection probabilities and consequently different estimations of PCN populations. (For the sampling rates applied, see section 5.2.6.2). In the context of official surveys referred to in Article 6 of the Directive, the area which is sampled on a field where ware potatoes are grown is delimited to a maximum of 3 ha (see also section 5.2.6.4). The sampling is carried out in the separated sampling units, as described elsewhere in this report. Where PCN infestation is detected during the official surveys. the infestation is demarcated around the infested sampling unit using the 16 meter approach based on the foci model. Conclusions In the Netherlands, substantial efforts have been made to adopt and demonstrate rules of demarcation which are proportionate to plant health risk associated with the presence of PCN. However, the definition of a field for PCN purposes varies according to circumstances, including whether PCN is present or not and it is aimed at minimising the effect on the grower of a PCN finding. In some cases, the demarcation of infestations covers an entire sampled area or even more. PCN infestation is in most cases demarcated as one or several strips of land often forming unified parts of smaller demarcated “plots” or “zones” within a larger field. This approach is not based on a single definition of a field; this is not fully in line with the “sound scientific and statistical principles” referred to in Article 3 of Directive 2007/33/EC. Nevertheless, this current approach provides a greater degree of assurance than what was implemented previously in the Netherlands. 5.2.6.2 Sampling and testing carried out for official investigation - results Legal requirements Articles 4 and 5 of Directive 2007/33/EC lay down that Member States shall carry out an official investigation for the presence of potato cyst nematodes on the field in which plants listed in Annex I intended for the production of plants for planting, or seed potatoes intended for the production of seed potatoes are to be planted or stored; this investigation shall involve sampling and testing and its details are specified in Annexes II and III to the Directive. Article 7 of the same Directive requires Member States to officially record information on fields where no potato cyst nematodes are found during official investigations. Article 8 of the same Directive lays down that a field found infested with potato cyst nematodes during official investigations or surveys is officially recorded. Findings In general, the sampling and testing season for PCN official investigations starts on the 1st of July. For the submission of applications to NAK for official investigation, two different application forms are used: a “standard” to obtain a “Document of official investigation” for plots which are known to be PCN free and an application for “de-scheduling”, for plots which have been officially recorded as contaminated. Application forms require additional information i.e. the coordinates and a map of the plot under investigation, the crop rotation schemes applied, as well as an indication/request of 17 the time period in which the results have to be delivered. Depending on their specific cropping plans, producers can request the PCN testing results between 5 days to 6 weeks or even later during the next growing period. The validity and eligibility of the application is checked with the help of data stored in the PCN viewer which provides information on previous cropping history and on previous PCN sampling results. Soil sampling is carried out by inspectors of NAK or inspectors of the Flower Bulb Inspection Service, Bloembollen Keurings Dienst (2,000-3,000 ha/year). Farm saved seed grown within officially defined areas for the production of ware potatoes (within 25km from the farm) or potatoes for starch (north east part of the Netherlands), is not subject to official investigation. Compliance with terms and conditions is regularly checked by NAK. Depending on the cropping history of the field two soil sampling rates are in place: (a) a standard rate of 1,500 ml/ha applied in cases of plots where potatoes have been grown within the last six years without prior official PCN testing or in cases of contaminated plots which are sampled for descheduling; (b) a reduced rate of 600 ml/ha minimum (instead of 400ml/ha provided under the derogation of annex II point 3 of Directive 2007/33/EC). Because pre-1/7/2010 results count towards meeting derogation requirements, the “derogation”, which is used to its full extent is already used in the majority of cases (on 76% of seed plots). The rate of 200 ml/ha or any other rate further minimising the sampling density as foreseen in annex II point 4 of the same Directive is not applied in the Netherlands. Two sampling units apply: 0.3ha and 1ha. The width of each sampling unit is determined by the length of the field and may range from 7-12m. The volumes of samples taken from these two sampling units are 500 ml/0.3ha and 600 ml/ha or 200 ml/0.3ha. PCN viewer indicates the plots where the rate of 600 ml/ha can be applied according to the fulfilled criteria of Annex II point 3 of the same Directive. In particular: • no cultivation of potato or other PCN host plants has taken place during the last 6 years, or, • no PCN cysts with living content were found during standard rate sampling that took place in the last two growing periods, or, • no empty PCN cysts were found during standard rate sampling that took place in the last growing period; Positive PCN results are communicated to NVWA through a registered report prepared by NAK. The report indicates the details of sampling (area sampled, sub-sample numbers, width of the sampling unit) and the plot that has been demarcated according to the demarcation rules explained in the previous section. The results are recorded in PRISMA, the infested plot is officially registered and an “Official Declaration of Infestation” is issued. The information is then transferred into digital format by using Geo-explorer and becomes accessible through the PCN viewer. De-scheduling of PCN infested plots is also carried out through PRISMA. The FVO team visited a place of production where a 300ha crop rotation scheme growing potatoes, winter wheat, sugar beet and onions was applied. 25ha were used annually for the production of potato seed and 60ha for ware potatoes including potatoes for processing. The producer stated that soil sampling for PCN, Meloidogyne chitwoodi and M. fallax was carried out regularly after harvesting ware potatoes and seed by a private advising company. The FVO team observed soil sampling carried out for official PCN investigation of a 3ha field located within a 14,5ha larger plot, which had two PCN designated strips. The producer had requested the 3ha field to be sampled and tested for the production of potato seed; the last potato crop in the field had been ware potatoes. The FVO team noted that soil sampling was carried out by a NAK inspector following instructions on the numbers of sub-samples to be taken and the width 18 (7m) of the sampling unit (0.3ha) provided by the sampling protocol and his PDA. The inspector had the appropriate equipment for sampling 3ha (63m x 480m); the rate applied was that of taking 500 ml/0.3ha with 50-60 sub-samples of ca. 10ml for each 7m strip. PCN occurrences were not officially recorded in the Netherlands between 1993 and 2003. Following the FVO audit in 2000, referred to in section 4.1 above, such recording was re-introduced in 2003. Since then the single authority has issued 12,854 official declarations of infestation for contaminated plots of which approximately 6,100 are still valid and mostly recorded in 1,872 registered seed potato farms (see section 5.1.9). G. pallida has been identified in 80% of the cases while 15% concerns G. rostochiensis and 5% mixed populations. Conclusions The high number of contaminated plots compared to the total number of seed farms indicates a real probability of PCN presence on these farms. However, the Netherlands have developed a highly sophisticated and transparent IT support system for the control of PCN and other nematode species. All plots where potato seed is grown are sampled prior to planting as required in EU legislation using 600ml/ha for the majority of the official investigations. This provides a slightly higher PCN detection probability than the minimum 400ml/ha required by the Directive (65,5% instead of 51,6% according to the 1 larger + 3 smaller foci model). The standard rate of 1,500ml/ha, gives a 91,9% probability for the detection of PCN cysts in a contaminated field. 5.2.6.3 De-scheduling of PCN infested plots Legal requirements Article 13 of Directive 2007/33/EC establishes that if after the officially approved measures referred to in Section III(C) of Annex III have been taken, the presence of PCN is not confirmed, any restrictions imposed on the contaminated field shall be revoked. Findings Producers can request re-testing and de-scheduling of demarcated plots after six years if no potatoes or other PCN hosts have been grown in the plot. This period can be reduced to three years if appropriate officially approved control measures have been implemented and verified by NVWA. These measures are: • growing of highly resistant potato varieties with a minimal score of resistance of 8 or 9 or, • chemical treatment (Metam-Sodium) or, • PCN trapping by growing crops that trigger chemical simulation of PCN egg hatching like the highly PCN resistant sticky nightshade Solanum sisymbrifolium or both highly susceptible or susceptible potato varieties. The latter must be destroyed prior to the formation of new cysts. Growers applying one of these measures have to notify in writing NVWA by reporting the measure taken on an infested field. A specific form is used for this purpose and the measures taken or to be taken are registered in PRISMA. NVWA inspectors carry out high intensity random checks and reject the measure in case it is not implemented correctly or if the crop is not developing sufficiently. Officially approved measures for the de-scheduling of PCN contaminated fields include official re-sampling of soil at 1,500ml/ha and additional control measures for the reduction of the waiting time from six to three years. NemaDecide can help producers plan and implement control measures and the appropriate timing for re-test and de-scheduling. By introducing relevant data in the application it calculates the corresponding decrease of a PCN population over time. In one of the places of production visited by the FVO team, S. sisymbrifolium was grown as a PCN trap crop in a PCN demarcated strip. The team noted that the crop had not been successfully 19 established. Because of this the grower had not reported the trap crop to the NVWA. The NVWA inspector in charge stated that, in this particular case, the effectiveness of the measure would not have been accepted in the context of Section III(C) of Annex III to the Directive. NVWA stated that there can be problems with proper establishment of sticky nightshade in the Netherlands under unfavourable weather conditions after sowing. The use of susceptible potato varieties as a PCN trap crop was authorised under the derogations provided in the repealed Directive 69/465/EEC3. However, the reliability of the method for PCN control could be questioned as it largely depends on environmental and biological factors. Effective control may not be achieved if the cropping period of the trap crop is too short to effectively reduce nematode populations. On the other hand, if the trap crop stays too long in the field nematode populations may be able to multiply on the trap crop. For these reasons, trap cropping as a control measure should only be applied if appropriate checks are in place to verify effective PCN control. Conclusions Official measures for the de-scheduling of PCN contaminated fields have been approved as required in section III(C) of Annex III. It appears that the risk factors affecting the success of trap crops are taken into consideration when planning these measures and during the evaluation of their results. However, the FVO team questions the reliability of PCN trap crops and thus whether they are indeed an “appropriate measure” as required by Section III(C) of Annex III to Directive 2007/33/EC. 5.2.6.4 Sampling and testing carried out for official surveillance - results Legal requirements Article 6 of Directive 2007/33/EC requires that Member States carry out official surveys on fields used for production of potatoes other than those intended for the production of seeds, in order to determine the distribution of PCN; these surveys shall involve sampling and testing and their details are specified in Annexes II and III to the Directive. Findings Until 2009 surveillance for the PCN symptoms was carried out by the observation of potato crops using a helicopter. Since 2010 annual surveys are carried out by NAK according to the NVWA protocol with samples of soil taken from fields covering 0.5% of the acreage used for growing only ware potatoes and potatoes for starch production. Fields are randomly selected from the databases of NAK and the Regulations Service (Dienst Regelingen), an agency of ELI, handling inter alia the agricultural subsidies, and the samples taken are analysed by NAK; growers being selected during previous growing periods are excluded from sampling. • The size of the field sampled for PCN surveillance corresponds to an area totalling max. 3ha where the sampling rate applied is 400ml/ha in order to provide comparable results with surveys carried out in other Member States. Table 5 below provides the results of the annual surveillance carried out for the 2010/2011 growing periods. 3 In their response to the draft report the Competent Authority noted that extensive research (Dutch report nr 33.3.10 PPO/AGV; authors; L.P.G. Molendijk & F.G. van Beers: Aardappel als vanggewas, Evaluatie van PAGV onderzoek 1988-1992) showed that potatoes grown as trap crop (full field sown, harvested after 40 days, use of certified seed) can be very effective in reducing PCN populations. Trap crops are used on only a small number of fields. The growers who use the trap crops are aware of the risks. The NPPO has recommended to use resistant varieties. With these varieties, multiplication of the nematodes can not take place in case the crop can not be destroyed after 40 days. The timely destruction of the plants is part of the inspection program on trap crops. Only well developed crops of S. sisymbrifolium are accepted by NPPO as a control measure 20 Table 5. Results for the annual PCN surveys carried out in fields with ware and starch potatoes in 2010/2011 Year Ware Starch Total No. Infested Free of fields fields fields Infested fields % Total No. of samples No. of positive samples No. of free samples No. of infested samples found on infested fields G. rostochiensis G. pallida G. rostochiensis + G. pallida 2010 125 8 117 6.4% 352 24 328 16 2 6 0 2011 153 10 143 6.5% 446 30 416 20 3 7 0 2010 77 32 45 41.5% 220 95 125 63 1 27 3 2011 87 35 52 40.0% 246 102 144 65 0 33 2 The results of official surveillance indicate that in the south-west areas where long crop rotation cycles are applied there are significantly less PCN findings. By contrast, shorter crop rotations applied in the north-east starch producing areas have contributed to the increased numbers of PCN findings. Although direct comparisons cannot be carried out, overall the situation appears to have improved in these areas: in 2011 a 60% PCN area freedom was observed while in 2001 only 10% of potato producing fields had no PCN infestations. Figures 4-5 below provide an overview of PCN survey results in main potato growing areas in the Netherlands. Figures 4 and 5. Overview of PCN survey results in main potato growing areas in the Netherlands Conclusions Official surveys are carried out in line with the Directive 2007/33/EC in fields where ware potatoes or potatoes for industrial processing are grown. 21 5.2.7 Handling of potato cyst nematodes in ware potato production 5.2.7.1 Official control programme for the suppression of PCN Legal requirements Article 9.1 of Directive 2007/33/EC provides that in officially recorded infested fields no potatoes intended for the production of seed potatoes shall be planted and no plants listed in Annex I of the same Directive intended for replanting shall be planted or stored. Article 9.2 provides that officially recorded infested fields to be used for planting potatoes other than those intended for the production of seed potatoes, shall be subject to an official control programme aiming at the suppression of PCN. Findings The Netherlands has set up an official programme for PCN suppression allowing the use of infested fields for growing ware potatoes or potatoes for processing. The programme is based on a combination of crop rotation schemes, which are used complementary with potato varieties showing various degrees of resistance to PCN. Table 6 indicates the minimum levels of resistance susceptibility accepted in the Netherlands for different crop rotation cycles. Table 6. Minimum levels of resistance in the Netherlands Frequency of crop rotation potatoes : total crop years Maximum level of relative susceptibility (%) Minimum Resistance score 1:2 5 7 1:3 10 6 1:4 15 5 1 : 5 or more 25 4 As indicated in the table, the official control programme provides that varieties with relatively low resistance scores can be cultivated in the same field with a few years interval. The aim is to achieve some suppression over a long period i.e. over 10 years or so and in between, populations are allowed to increase. This indicates that in the Netherlands only a very modest goal for suppression has been set. Conclusions The Netherlands has set up an official control programme for the suppression of PCN. However, only a very modest goal for suppression has been set, which does not take sufficiently into account “the use of resistant potato varieties of the highest levels of resistance available”. This is not in line with Article 9(2) of Directive 2007/33/EC. However, the resulting plant health risk is very limited as the suppression programme, in accordance with the same Directive, is applied only to the findings made in the official ware potato surveillance and not to the remaining 99,5% of the ware potato production. Farmers in the Netherlands have sophisticated tools at their disposal to prevent PCN from causing losses in their production and they are likely to implement measures on their own that – even if not resulting in much suppression – in effectiveness will match the official suppression programme. 5.2.7.2 Decontamination of potatoes intended for industrial processing Legal requirements Article 10.1.b of Directive 2007/33/EC provides that contaminated potatoes for industrial 22 processing or grading shall be delivered to a processing or grading plant with appropriate and officially approved waste disposal procedures for which it has been established that there is no risk of PCN spreading. Findings Until recently, environmental legislation banned potato industries from dumping waste soil on fields used for agriculture; soil from starch production factories was placed in landfills. However, in 2011, this ban was lifted creating a substantial potential risk. There is good awareness in the starch industry of the phytosanitary risk from soil and the procedures there are not likely to change. However, this is not the case for other processors, such as crisps and chips factories. Furthermore, already now, most potato sorting and packaging companies bring soil back to agricultural fields. As a consequence of the absence of official control of PCN in the ware potato production, NVWA has recognised, that separation of soil from infested fields cannot be guaranteed in practice and that all adhering soil from ware and starch potatoes poses a risk for spreading PCN. However, phytosanitary procedures for adherent soil have not been put into force. As disinfection of soil is not yet a realistic option, NVWA is examining the options for possible safe destinations with exclusion of its use for agricultural purposes and from areas where bulbs and nursery plants are grown. The use on fields where growing of potatoes and propagating material will be banned for 12 years is also examined. These measures will also have some preventive effect against other soil borne organisms, such as potato wart disease and against the proliferation of different PCN populations. This is not the case for an alternative option under consideration, where fields receiving soil can be used for potatoes following a specific PCN suppression programme. Conclusions Appropriate and officially approved waste disposal procedures for establishments handling PCN contaminated potatoes are not in place. This is not in line with Article 10.1.b of Directive 2007/33/EC. 5.2.7.3 List of potato varieties resistant to PCN and recording of break down of resistance Legal requirements Article 11 of Directive 2007/33/EC provides that the suspected occurrence or confirmed presence of potato cyst nematodes resulting from a breakdown or change in the effectiveness of a resistant potato variety which relates to an exceptional change in the composition of nematode species pathotype or virulence group should be reported to official bodies of the Member States. Article 12 of the same Directive provides that Member States shall notify in writing a list of all new varieties of potatoes which they have found by official testing to be resistant to potato cyst nematodes. Findings Monitoring of virulent populations is carried out through a well established network of scientists, breeders, laboratory experts and policy advisors, meeting twice a year to examine recent PCN developments. The network organises tests every 10 years on the virulence of PCN populations found in the Netherlands. It also investigates cases where signs of unexpected PCN behaviour or breaking of resistance have been reported. A reporting tool is to be developed within the NemaDecide application for the detection and reporting of unexpected sampling results of PCN populations. The widespread use in the Netherlands of varieties having a low PCN resistance (score 4-6), will allow considerable PCN multiplication. Hence, a breakdown of resistance under field conditions 23 may not be observable. NVWA has established a legal obligation to be informed of any potential resistance breakdown or any changes in the effectiveness of resistant potato varieties. The lists with the resistant varieties are regularly communicated to the Commission and the Member States. The most recent was communicated in February 2012. Conclusions In the Netherlands there is a mechanism in place for the notification of new events resulting from a breakdown or change in the effectiveness of a resistant potato variety. The list of resistant varieties is submitted as required in EU legislation. 6 OVERALL CONCLUSIONS Phytosanitary controls of the Dutch potato sector are well organised and carried out efficiently by well-equipped organisations and well educated staff. Most aspects of the Directives for the control of ring rot and Ralstonia solanacearum are implemented correctly and well. Intensive surveys are carried out for both organisms and outbreaks are followed up by appropriate tracing back and forward and designation of contaminated and probably contaminated material. Eradication measures, including proper disposal of contaminated or probably contaminated potatoes are in place and supervised by inspectors. However, production of seed potatoes is allowed in the place of production in the first year after a ring rot outbreak, which is not in line with EU requirements. The implementation of Directive 2007/33/EC for the control of PCN is also to a large extent compliant and has improved the Dutch controls against the organism somewhat, although these do not appear to be aimed at maximising the assurances against the spread of PCN. Official investigations of seed potato fields are done in line with the requirements of the Directive. However, the high incidence of PCN findings, the systematic use of the derogation facility for reduced sampling rates, the minimalistic demarcation of PCN infested plots and the fact that some of the official control measures applied before re-sampling/de-scheduling of demarcated plots are not reliable, mean that the level of assurance against PCN in seed could be compromised. Testing for PCN resistance is carried out by qualified laboratories of private companies and lists of varieties are submitted to the EU and other Member States as required. However, some of the laboratories belong to potato breeding companies, who have a direct interest in the outcome of the tests and EU requirements for independence are in these cases therefore not met. The Netherlands apply the official control programme referred to in Article 9(2) of Directive 2007/33/EC for the suppression of PCN in ware potatoes. However, this programme does not take sufficiently into account the required use of potato varieties of the highest levels of resistance available. The vast majority of the findings in ware potatoes are, in line with the same Directive, not subject to the official suppression programme. In this regard it has to be noted that farmers in the Netherlands have sophisticated tools at their disposal to prevent PCN from causing losses in their production and they are likely to implement measures on their own that – even if not resulting in much suppression – will match the official suppression programme in terms of effectiveness. The authorities have identified the need for establishing phytosanitary procedures for disposal of waste from all potato processing and packing facilities and are working on some proposals, however, so far the requirements in Article 10(1)(b) of this Directive have in most cases not been met. 24 7 CLOSING MEETING A closing meeting was held on 12 October 2012 with the representatives of the Competent Authorities. At this meeting, the audit team presented the main findings and preliminary conclusions of the audit. These were provisionally accepted by the Single Authority. 8 RECOMMENDATIONS The Single Authority in the Netherlands is recommended: N°. Recommendation 1. To ensure that when official PCN resistance testing is delegated to a private body, no conflict of interest exists between the exercise of the tasks delegated to it and its other activities as required by Article 2.1(g) of Directive 2000/29/EC. 2. To ensure that following a ring rot outbreak, production of seed potatoes is not allowed in the place of production in the same or in the following year of the designated contamination, as required by point 4.1.(b) of Annex IV to Directive 93/85/EEC. 3. To ensure that the definition of a field for the purposes of Directive 2007/33/EC fully takes into account sound scientific and statistical principles and the cultivation of the field as required by Article 3 of the same Directive. 4. To ensure that the control measures authorised for reducing the waiting time for retesting of PCN scheduled plots are appropriate as required by point C, Section III of Annex III to Directive 2007/33/EC. 5. To ensure that establishments where PCN contaminated potatoes are delivered for processing and grading will have appropriate and officially approved waste disposal procedures as required by Article 10.1.(b) of Directive 2007/33/EC. The competent authority's response to the recommendations can be found at: http://ec.europa.eu/food/fvo/rep_details_en.cfm?rep_inspection_ref=2012-6315 25 ANNEX 1 - LEGAL REFERENCES Legal Reference Official Journal Title Dir. 2000/29/EC OJ L 169, 10.7.2000, Council Directive 2000/29/EC of 8 May 2000 on p. 1-112 protective measures against the introduction into the Community of organisms harmful to plants or plant products and against their spread within the Community Dir. 93/85/EEC OJ L 259, 18.10.1993, Council Directive 93/85/EEC of 4 October 1993 on p. 1-25 the control of potato ring rot Dir. 98/57/EC OJ L 235, 21.8.1998, Council Directive 98/57/EC of 20 July 1998 on the p. 1-39 control of Ralstonia solanacearum (Smith) Yabuuchi et al. Dir. 2007/33/EC OJ L 156, 16.6.2007, Council Directive 2007/33/EC of 11 June 2007 on p. 12-22 the control of potato cyst nematodes and repealing Directive 69/465/EEC Dir. 92/90/EEC OJ L 344, 26.11.1992, Commission Directive 92/90/EEC of 3 November p. 38-39 1992 establishing obligations to which producers and importers of plants, plant products or other objects are subject and establishing details for their registration 26 ANNEX 2 – STANDARDS QUOTED IN THE REPORT International Standard Title ISPM No. 5 International Standard on Phytosanitary Measures Publication No 5, Glossary of Phytosanitary Terms, Food and Agriculture Organisation, Rome, 2010