CPM 2011/INF/15
March 2011
E
COMMISSION ON PHYTOSANITARY MEASURES
Sixth Session
Rome, 14-18 March 2011
Compiled Member Comments on Draft Revision of ISPM 7:1997
Phytosanitary Certification System (CPM2011/03/Attachment 1)
Agenda Item 9.2.1 of the Provisional Agenda
The Secretariat compiled a total of 55 comments received in advance of CPM-6 on the Revision of
ISPM 7:1997 Phytosanitary Certification System, from the following members:
Argentina
Australia
Brazil
Canada
Chile
COSAVE
EPPO
EU and its 27 Member States
Japan
Kenya
Norway
Russia
South Africa
Uruguay
United States of America
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2 CPM 2011/INF/15
Compiled comments prior to CPM-6 on document CPM/2011/3/Attachment 1
DRAFT REVISION OF ISPM 7:1997
PHYTOSANITARY CERTIFICATION SYSTEM
Comments received 14 days prior to CPM-6 (28 Feb. 2011)
The following are comments received according to guidelines given in the document CPM 2011/03. The Secretariat has compiled the comments, as provided
by members, in the order of the text with editorial and translation comments, if any, at the end of the list. This document is provided for information.
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
1.
Outline of [11] Sustantive Contracting parties shall should make To be consistent with Article ARGENTINA, Brazil,
requirements arrangements for the issuance of V of the text of IPPC CHILE, COSAVE,
phytosanitary certificates. These URUGUAY
phytosanitary certificates are issued for
exported or re-exported consignments to
provide assurance to an NPPO that the
consignments meet its phytosanitary import
requirements.
CPM 2011/INF/15 3
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
2.
Outline of [12] Sentence 2 Substantive The NPPO undertakes the operational It‟s not just about “setting up” AUSTRALIA
requirements responsibilities, including the sampling and the systems, it‟s also about
inspection of plants, the detection and maintaining them.
identification of pests, the surveillance of
crops, the performance of treatments, and
establishing and maintaining setting up a
record-keeping system.
3.
Outline of [15] Last Technical ...import requirements or and non- These are not alternatives EPPO, NORWAY, EU and
requirements sentence compliances.. its 27 Member States
(hereinafter referred to as
'EU'), RUSSIA
4 CPM 2011/INF/15
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
4. Article V.1 of IPPC Convention provides:
REQUIREMENTS [17] paragraph substantial New changes make the Kenya
Each contracting party shall make paragrapgh clear
arrangements for phytosanitary certification,
with the objective of ensuring that exported
plants, plant products and other regulated
articles and consignments thereof are in
conformity with the certifying statement
“This to certify that the plants, plant products
or other regulated articles described herein
have been inspected and/or tested according
to appropriate official procedures and are
considered to be free from the quarantine
pests specified by the importing contracting
party and to conform with the current
phytosanitary requirements of the importing
contracting party, including those for
regulated non-quarantine pests. They are
deemed to be practically free from other
pests”
5.
REQUIREMENTS [18] Sustantive Therefore, contracting parties shall should To be consistent with Article ARGENTINA, Brazil,
develop and maintain a phytosanitary V of the text of IPPC CHILE, COSAVE,
certification system for certifying compliance URUGUAY
of plants, plant products and other regulated
articles with the phytosanitary import
requirements regulations of importing
CPM 2011/INF/15 5
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
contracting parties as well as their freedom
For consistence throughout
from regulated pests. The system for the
the text.
issuance of phytosanitary certificates includes
the components of authority, responsibilities,
resources, documentation, communication
and review.
6.
REQUIREMENTS [18] First Technical ..and other regulated articles with the Consistent with wording of EPPO, NORWAY, EU,
sentence phytosanitary regulations import para 11 and statement on the RUSSIA
requirements of importing contracting certificates.
parties...
7.
1. Legal Authority [20] Substantive The NPPO shall should have the sole To be consistent with the text ARGENTINA. Brazil,
authority by legislative or administrative of IPPC. CHILE, COSAVE,
means to conduct, develop and maintain a URUGUAY
phytosanitary certification system related to
exports and re-exports, and shall should bear
the legal responsibility for its actions in using
this authority, in accordance with Article
IV.2(a) of the IPPC.
8.
1. Legal Authority [21] Sentence Substantive The NPPO may should have the Consistent with the intent of Australia
responsibility to prevent the export of the Convention
consignments….
9.
2.2 Operational [27] 1st Substantive The NPPO should have the capability to Article V 2 (a) of the AUSTRALIA
responsibilities sentence undertake, or systems in place to allow for convention allows for the
authorised personnel to conduct some NPPO to authorise personal
tasks on their behalf, the following to perform some tasks on
functions: their behalf.
6 CPM 2011/INF/15
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
10. - perform, supervise or audit the required
2.2 Operational [27] Fifth dot Substantive Treatrments may be Australia
phytosanitary treatments
responsibilities point performed by organisations or
personnel other than the
NPPO. These are not always
directly supervised, but may
be undertaken through
arrangements approved by the
NPPO and subject to regular
audit.
11. The NPPO should have the capability to
2.2 Operational [27] ARGENTINA, Brazil,
undertake the following functions:
responsibilities CHILE, COSAVE
- document and maintain the
information regarding the
phytosanitary import requirements
where needed for phytosanitary
certification and provide relevant
information in instructions to
personnel
- perform sampling, inspection and
testing of plants, plant products and
other regulated articles for purposes
related to phytosanitary certification
- detect and identify pests
- identify plants, plant products and
other regulated articles
- perform or supervise the required
phytosanitary treatments
- perform surveys and monitoring and
control activities to confirm the
CPM 2011/INF/15 7
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
phytosanitary status attested in
phytosanitary certificates
- complete and issue phytosanitary
certificates
- verify that appropriate phytosanitary
procedures have been established and
correctly applied
- investigate and take corrective actions
(if appropriate) on any notification of
non-compliance
- produce operational instructions to
ensure that phytosanitary import
requirements are met satisfied
- archive copies of issued phytosanitary
certificates and other relevant
documents
- review the effectiveness of
phytosanitary certification systems
- implement, to the extent possible,
safeguards against potential problems
such as conflicts of interest and
fraudulent issuance and use of
phytosanitary certificates
- conduct training for personnel
To clarify
- verify the competency of authorized
personnel
- ensure through appropriate procedures
the phytosanitary security of
consignments after phytosanitary
8 CPM 2011/INF/15
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
certification, prior to export.
Editorial
To clarify
Editorial
To be consistent with Article
IV.2(g) of the text of IPPC.
Substantive
12.
2.2 Operational [27] 16th Technical
- ensure through appropriate procedures
Addition in conformity with EPPO, NORWAY, EU,
the phytosanitary security of
responsibilities indent Article IV 2(g) of the IPPC. RUSSIA
consignments after certification prior
to export.
CPM 2011/INF/15 9
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
13. - ensure through appropriate procedures To be consistent with Article
[27] 16º Indent Substantive URUGUAY
the phytosanitary security of IV.2(g) of the text of
consignments after phytosanitary IPPC.
certification, prior to export.
14.
3.1 Personnel [32] Last substantive To ensure independence in their exercise of 3rd parties have a financial Australia
sentence official functions, they should be subject to interest in any inspection they
restrictions and obligations equivalent to carry out as they arepaid for
those for government officials and have no these inspection. Use of
financial interest in the outcome conflict of „conflict of interest‟ (a
interest, financial or otherwise, that may situation in which someone‟s
affect the in the outcome. private interests could
conflict with their
obligations) overcomes this
and aligns the concept and
working with that for
government officials given in
para 31.
15.
3.1 Personnel [32] Last Substantive To ensure independence in their exercise of This is a new concept. Canada
sentence official functions, they should be subject to Canada does not agree with
restrictions and obligations equivalent to its addition and requests it be
those for government officials and have no deleted.
financial or any other personal interest in the
outcome.
It could be difficult to assess
the „personal interest‟ of non-
government officials in the
outcome. The evaluation of
their personal interest in the
10 CPM 2011/INF/15
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
outcome would be very
subjective and hard to prove
in some instances.
Canada strongly believes that
the risk of personal interest is
mitigated by a strong
oversight by the NPPO,
including a thorough audit
component.
16.
3.1 Personnel [32] 3rd Substantive To ensure independence in their exercise of This last obligation goes over USA
sentence their official functions, they should be and above the Convention.
and editorial
subject to restrictions and obligations Current certification practices
equivalent to those for government officials. may use the industry in the
and have no financial or any other personal process. NPPOs would train
interest in the outcome. personnel, oversee their work,
audit the work, and take full
responsibility for the
phytosanitary certification.
Nevertheless, it would be
rather difficult to agree with
this last statement. Suggest
deletion.
17.
3.2 Information on [34] Substantive Phytosanitary certification should be based ARGENTINA, Brazil,
phytosanitary import on official information from the importing CHILE, COSAVE
requirements country. The NPPO of the exporting country
should, to the extent possible, have available
official current information concerning the
phytosanitary import requirements of relevant
CPM 2011/INF/15 11
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
importing countries. Such information shall
should be made available in accordance with
Article VII.2(b), VII.2(d) and VII.2(i) of the
Convention and ISPM 20:2004, section
5.1.9.2.
To consistence with Articles
mentioned in this para.
18.
3.2 Information on [34] Substantive Phytosanitary certification should be based To be consistent with IPPC URUGUAY
phytosanitary import on official information from the importing Articles mentioned in this
requirements country. The NPPO of the exporting country paragraph.
should, to the extent possible, have available
official current information concerning the
phytosanitary import requirements of relevant
importing countries. Such information shall
should be made available in accordance with
Article VII.2(b), VII.2(d) and VII.2(i) of the
Convention and ISPM 20:2004, section
5.1.9.2.
[2] 19. 4.2 Documentation of
[44] Indent 1 Editorial - specific activities…..including inspection, Describe phytosanitary EU
procedures
sampling, inspection, testing, treatment and procedures in right order.
Technical
verifying the identity and integrity of
Unclear what is meant by
consignments
“verifying consignments”.
The proposed wording is an
attempt to clarify according
to our understanding, and to
keep compliance with
Section 2.2 of ISPM 23.
20.
4.2 Documentation of [45] Whole Technical In addition NPPOs may have documented Clarification concerning EPPO, NORWAY, EU,
procedures sentence procedures in place related to phytosanitary cooperation with stakeholders RUSSIA
12 CPM 2011/INF/15
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
certification for the cooperation with
stakeholders (i.e. producers, brokers, traders).
21. Copies of phytosanitary certificates should
4.3 Record-keeping [47] 2nd Technical Add text to be in line with EPPO, NORWAY, EU,
also be kept by the NPPO for the purposes of
sentence para 49, copies of PC should RUSSIA,
validation and trace-back for an appropriate
be kept by the NPPO
period of time (at least one year).
22.
4.3 Record-keeping [49] 1st Technical Records should be kept for an appropriate We note that the Standards AUSTRALIA
sentence period of time (at least one year) and the Committee will discuss the
NPPO should be able to retrieve these issue of the length of time
records. that records must be kept as
contained in ISPMs. There
should be some consistency
between the length of time
with adopted ISPMs have
record keeping periods
suggested between 1 and 3
years.
23.
5.2 Communication [55] Substantive NPPOs shall should, in accordance with their To be consistent with the text ARGENTINA, Brazil,
between NPPOs obligations in the Convention, designate an of IPPC. CHILE, COSAVE,
IPPC contact point (IPPC, Article VIII.2). URUGUAY
Official communications should be sent to
that contact point. However, for specific
information or activities (e.g. notification of
non-compliance) an NPPO may designate
alternative points for contact on such matters.
24.
5.2 Communication [55] Sentence 2 Substantive Official communications should be sent to To indicate a two-way South Africa
between NPPOs that contact point communication flow through
CPM 2011/INF/15 13
1. Section 2. 3. 4. Type of 5. Proposed rewording 6. Explanation 7. Country
Para. Sentence comment
No. /row/inde
nt, etc.
the NPPO Contact Point.
Official communications should be sent to
and from that contact point.
EDITORIAL COMMENTS
25.
GENERAL Througho Editorial Convention IPPC Throughout the text the EPPO, NORWAY,
COMMENTS ut the text Convention is referred to as
EU and its 27 Member States
“the IPPC” - see para [7],
(hereinafter referred to as
[17], [20], [42], [55] and [56].
'EU') RUSSIA
Please check in the all
document for consistency for
example [34], [42], [55]
26.
Scope [6] Last row Editorial Requirements and guidelines for the The reference to ISPM 12 EPPO, NORWAY, EU,
preparation and issuance of phytosanitary may require a later RUSSIA
certificates1 (phytosanitary certificates for amendment.
export and phytosanitary certificates for re-
export) are described in ISPM 12:
2001[amend as appropriate to
ISPM 12:201-].
27.
Scope [6] footnote editorial The IPPC refers to two models: a For consistent wording with JAPAN
“phytosanitary certificate” for export the draft revision of ISPM
purpose and a “phytosanitary certificate for No.12
re-export” for re-export purposes.
28.
Outline of [11] 2nd Editorial These phytosanitary certificates are issued Use of the word “its” seems EPPO, NORWAY, RUSSIA
requirements sentence for exported or re-exported consignments to inappropriate since it is not
provide assurance to an NPPO that the the importing requirements of
14 CPM 2011/INF/15
consignments meet its the phytosanitary the NPPO but of the
import requirements. contracting party.
29.
Outline of [12] Sentence editorial The NPPO undertakes or approves the “The NPPO undertakes the Australia
requirements 2 operational responsibilities arrangements operational responsibilities
to implement these requirements, …” does not allow for other
including… accredited organisations or
personnel to perform the
listed activities in the
remainder of the sentence and
is inconsistent with other
elements of the Standard,
especially paragraph 13.
30.
Outline of [12] 2nd Editorial The NPPO undertakes the operational The responsibilities are EPPO, NORWAY, EU,
requirements sentence responsibilities, including the sampling and referred to very generally, so RUSSIA
inspection of plants, the detection and definite articles don‟t seem to
identification of pests, the surveillance of be proper.
crops, the performance of treatments, and
setting up a record-keeping system.
31.
Outline of [12] 2nd editorial The NPPO undertakes the operational For consistency. Same USA
requirements sentence, responsibilities, including the sampling and wording used in the
4th row inspection of plants, plant products, and Convention and rest of the
other regulated articles, the detection and standard.
identification of pests, the surveillance of
crops, the performance of treatments, and
setting up a record-keeping system.
32.
Outline of [13] Sentence Editorial Authorized non-government personnel, More precise. Consistency EPPO, NORWAY, RUSSIA
requirements 2 when qualified and skilled and responsible with the wording used in para.
to the NPPO, may carry out specific No. [32].
CPM 2011/INF/15 15
specified certification functions.
33.
Outline of [13] Sentence Editorial Authorized non-government personnel, Better English. EU
requirements 2 when qualified and skilled and responsible
to the NPPO, may carry out specific
specified certification functions., provided More precise. Consistency
they are qualified and skilled and with the wording used in para
responsible to the NPPO. [32].
34.
Outline of [13] 1st editorial In undertaking these functions, the NPPO of USA
requirements sentence, the exporting country should have personnel
2nd row with the required skills and technical
qualifications.
35.
REQUIREMENTS [18] Last editorial The system for the issuance of phytosanitary Wording consistent with the USA
sentence certificates includes the componentes of rest of the text.
legal authority, administrative and
operational responsibilities, resources and
infrastructure, documentation,
communication and system review.
36. - document and maintain the information
2.2 Operational [27] 1st dash editorial Section 4.2 of the draft refers Australia
regarding the phytosanitary import
responsibilities point to work instructions –
requirements where needed for
consistency of terms here
phytosanitary certification and provide
appropriate work instructions relevant
information in instructions to personnel
37. - implement, to the extent possible,
2.2 Operational [27] 13th Editorial Term used everywhere else in Australia
safeguards against potential problems such
responsibilities indent this section may as well stay
as conflicts of interest and fraudulent
consistent.
issuance and use of phytosanitary
certificates
38.
2.2 Operational [27] 2nd Editorial . ..including inspection, sampling, describe phytosanitary EPPO, NORWAY, EU,
responsibilities indent inspection…. procedures in right order RUSSIA
16 CPM 2011/INF/15
39.
2.2 Operational [27] 13th editorial implement, to the extent possible, For consistent wording JAPAN
responsibilities indent safeguards against potential problems such
as conflicts of interest and fraudulent
issuance and use of phytosanitary
certificates
40.
2.2 Operational [27] 10º Editorial
- produce operational instructions to
To clarify URUGUAY
ensure that phytosanitary import
responsibilities Indent
requirements are met satisfied
41.
2.2 Operational [27] 13º Editorial
- implement, to the extent possible,
To clarify URUGUAY
safeguards against potential problems such
responsibilities Indent
as conflicts of interest and fraudulent
issuance and use of phytosanitary
certificates
42. - Perform or supervise the required
2.2 Operational [27] 5th indent Editorial USA
phytosanitary treatments
responsibilities
- Perform surveys, and monitoring
and control activities to confirm the
6th indent Editorial phytosanitary status attested in
phytosanitary certificates
- Implement, to the extent posible,
safeguards against potential problems such
as conflicts fo interest and fraudulent
13 indent editorial issuance and use of phytosanitary Not necessary
certificates
43. remove the brackets around this sentence
3.1 Personnel [31] Last Editorial RUSSIA
sentence
CPM 2011/INF/15 17
44.
3.1 Personnel [32] 1st Editorial
- Except for the issuance of
consistency AUSTRALIA
phytosanitary certificates non-
sentence
governmental personnel may be authorized
by the NPPO to perform carry out
specified certification functions.
45.
3.2 Information on [34] 1st Editorials
- Phytosanitary certification should be
2 edits: Remove space at AUSTRALIA
based on official information from the
phytosanitary import sentence beginning of paragraph ie
importing country. The NPPO of the
requirements align text
exporting country should, to the extent
possible, have available current official
current information concerning the
move “current”.
phytosanitary import requirements of
relevant importing countries.
46. - the biology, surveillance, detection and
3.3 Technical [36] Indent 2 Editorial More precise as it is EPPO, NORWAY, RUSSIA
identification of these pests
information on concerning “regulated pests”
regulated pests and not all pests.
47. - the means to control such pests, including
3.3 Technical [36] 3rd indent editorial USA
treatment where appropriate
information on
regulated pests
48. The system should allow the traceability of
4. Documentation [40] Sentence Editorial As “phytosanitary EPPO, NORWAY, EU,
phytosanitary certificates and the related
2 certificates” is a plural, the RUSSIA
consignments and its their parts.
“related consignements”
should be a plural.
49. The NPPO should have a system for
4. Documentation [40] 1st editorial USA
documenting the relevant procedures
sentence,
applied, and maintain records kept
1st row
(including documentation storage and
retrieval).
50. ..including inspection, sampling,
4.2 Documentation of [44] Indent 1 Editorial Describe phytosanitary EPPO, NORWAY, RUSSIA
inspection….
procedures procedures in right order
18 CPM 2011/INF/15
51. - Specific activities relating to phytosanitary
4.2 Documentation of [44] 1st indent editorial USA
certificates, as described in ISPM 12:2001,
procedures
including sampling, inspection, testing,
treatment and verifying verification of
consignments
52.
4.3 Record-keeping [47] 2nd editorial Copies of phytosanitary certificates should USA
sentence also be kept for the purposes of validation
and traceability -back
53.
4.3 Record-keeping [49] paragraph editorial Records should be kept for an appropriate Paragragh more clear with Kenya
period of time (at least one year) and the revisión suggested
NPPO should be able to retrieve these
records. The use of secure electronic
storage and retrieval system is
recommended for standardized
documentation of records.
54.
5.2 Communication [57] 1st row editorial Where necessary, the NPPO of the exporting USA
between NPPOs country should liaise communicate with
the IPPC contact point of the importing
country to clarify and confirm the
phytosanitary import requirements.
55. 5.2 Communication [58] Editorial If after phytosanitary certification the NPPO To clarify ARGENTINA, Brazil,
between NPPOs of the exporting country becomes aware CHILE, COSAVE,
that an exported consignment may not have URUGUAY
complied with phytosanitary import
requirements, the IPPC contact point or
designated alternative point of contact in
the importing country should be informed
as soon as possible. In cases where non-
compliance has been identified at import,
ISPM 13:2001 applies.