CPM 2011/INF/15 by HC111208013634

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									                                                                                                          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.

								
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