REPORT OF A MISSION CARRIED OUT IN THE CZECH REPUBLIC FROM 4 TO 8 SEPTEMBER 2000

Transcription

1 EUROPEAN COMMISSION HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL Directorate F - Food and Veterinary Office DG(SANCO)/1236/2000 MR Final REPORT OF A MISSION CARRIED OUT IN THE CZECH REPUBLIC FROM 4 TO 8 SEPTEMBER 2000 IN ORDER TO EVALUATE THE OPERATION OF CONTROLS OVER THE PRODUCTION OF FRESH PIG MEAT Comments from the Czech Authorities regarding factual errors have been included in the main text in bold and italic. Clarifying comments have been incorporated in footnotes also in bold and italic. 24/11/

2 TABLE OF CONTENTS 1. INTRODUCTION OBJECTIVES OF THE MISSION LEGAL BASIS FOR THE MISSION BACKGROUND General information Summary of previous mission results Production and trade information Animal Health information EC-approved establishments MAIN FINDINGS Competent authority Veterinary supervision Health Certificates Animal registration and identification Establishments CONCLUSIONS Competent authority Veterinary supervision Health Certificates Establishments OVERALL ASSESSMENT CLOSING MEETING RECOMMENDATIONS To the competent authorities of the Czech Republic To the Commission Services...20 ADDDENDUM

3 ABBREVIATIONS & SPECIAL TERMS USED IN THE REPORT AM BIP CA CCA CSF EC EU FVO OVS PM SVS VHS Ante Mortem Border Inspection Post Competent Authority Central Competent Authority Classical Swine Fever European Communities European Union Food and Veterinary Office Okresní Veterinarní Správa District Veterinary Administration Post Mortem Statna Veterinarna Správa Ceské Republiký The National Veterinary Administration of the Czech Republic (Central Competent Authority) Veterinární Hygienické Stredisko Local veterinary office at the plant (slaughterhouse), carrying out direct supervision CZECH LEGAL ACTS AND INSTRUCTIONS MENTIONED IN THE REPORT Zákon c.166/1999 ze dne o veterinární péci a o zmene nekterých souvisejících zákonu (veterinární zákon) Act of 13 July 1999 concerning veterinary care and amending some related laws (the Veterinary Act). Vyhláška c.287/1999 Ministerstva zemedelstvi ze dne o veterinárních požadavcích na živocišné produkty - the Decree no 287/1999 of 2 December 1999 relative to the veterinary requirements for the products of animal origin. Zákon c.154/2000 ze dne 17. kvetna 2000 o šlechtení, plemenitbe a evidenci hospodárských zvírat a o zmene nekterých souvisejících zákonu (plemenárský zákon) Act of 17 May 2000 concerning breeding and registration of domestic animals (Animal Breeeding Act) 3

4 Metodický návod c.12/ Zarazení a vyrazeni / zrušeni schváleni/ ze seznamu schválených závodu (dále jen seznam) pro export do clenských státu EU a pozastavení schválení takového závodu Methodical instruction nr 12/2000 of the State Veterinary Administration concerning granting and withdrawal of approval for export to the EU countries and suspension of such approval of 12 July Metodický návod SVS CR cislo 2000/11/HYGI ze dne Závazný postup pri prohlidce masa a orgánu po porážce jatecných zvírat Methodical instruction of the SVS CR number 2000/12/ Proceeding for meat and offal inspection of slaughter animals Metodický návod c.14/ Vyšetrení na svalovce Methodical instruction nr 14/2000 of the State Veterinary Administration concerning examination for trichinae of 28 August Smernice Státní veterinární správy CSR c. ze dne 21. zárí 1989, jimž se upravuje prohlídka jatecných zvírat a masa Priloha c. 3 Vyšetrení na svalovce Directive of the State Veterinary Administration of the Czechoslovak Republic of the 21 September 1989 concerning inspection of slaughter animals and meat annex 3 Examination for trichinae [Repealed by the letter of the CVO dated 8 August 2000 from the 1 September 2000] 4

5 1. INTRODUCTION The mission took place in the Czech Republic (CR) from 4 to 8 September The mission team comprised 2 inspectors from the Food and Veterinary Office (FVO). The mission was undertaken as part of the FVO's planned mission programme. The inspection team was accompanied during the whole mission by representatives from the central competent authority (CCA), the National Veterinary Administration of the Czech Republic (Statna Veterinarna Správa Ceské Republiký, SVS). An opening meeting was held on 4 September 2000 with the SVS. At this meeting, the objectives of, and itinerary for, the mission were confirmed by the inspection team, and additional information required for the satisfactory completion of the mission requested. 2. OBJECTIVES OF THE MISSION The objective of the mission was to evaluate the performance of the competent authority s controls over the production of fresh pig meat, in the framework of: Council Directive 72/462/EEC (upon importation of fresh meat from third countries) and of Council Directive 77/96/EEC (trichinae controls). This mission formed part of a wider series of missions to all Member States and certain Third Countries evaluating control systems and operational standards in this sector. In pursuit of this objective, the following sites were visited: COMPETENT AUTHORITY VISITS Comments Central 1 There are no regions in the veterinary Competent Regional organisation authority District 3 Local 3 LIVE ANIMAL CONTROL SITES Comments Farms (pigs) - visit planned but not performed due to the lack of time. The visit was planned for the same day as a visit to a slaughterhouse. The visit at this plant finished at due to the problems found there. FOOD PROCESSING ESTABLISHMENTS Slaughterhouses 3 Cutting plants 3 Cold stores 3 Comments TRICHINAE LABORATORIES 3 5

6 3. LEGAL BASIS FOR THE MISSION The mission was carried out under the general provisions of Community legislation and, in particular: Council Directive 72/462/EEC of 12 December 1972 on health and veterinary inspection problems upon importation of bovine, ovine and caprine animals and swine, fresh meat or meat products from third countries. 1 Council Directive 77/96/EEC of 21 December 1976 on the examination for trichinae (trichinella spiralis) upon importation from third countries of fresh meat derived from domestic swine. 2 Commission Decision 98/140/EC of 4 February 1998 laying down certain detailed rules concerning on-the-spot checks carried out in the veterinary field by Commission experts in third countries. 3 The application of the following Community legislation was assessed: Council Directive 96/93/EC of 17 December 1996 on the certification of animals and animal products BACKGROUND 4.1. General information The Czech Republic is an EU associated member country as a result of the Europe Agreement of It is also an EU candidate country belonging to the Luxembourg group (i.e. the group of first six EU candidate countries, together with Poland, Hungary, Estonia, Slovenia and Cyprus). In relation to veterinary and phytosanitary matters the Czech Republic has a particular status. As part of the Europe Agreement, a veterinary and phytosanitary protocol concerning sanitary, phytosanitary and animal welfare measures applies to trade between the EU and the Czech Republic (hereinafter referred to as the Equivalency Agreement ). The equivalence agreement was adopted by Council Decision 98/250/EC 6. More details about the Equivalency Agreement are available in the Mission Report 1080/ Summary of previous mission results A number of veterinary missions to Czech Republic were carried out in the past. The last five missions took place during : Milk products (SANCO 1082/2000) 5-9 June Meat of Wild and Farmed Game (SANCO 1080/2000) May 2000, Fishery products (XXIV/1089/99) 3-7 May 1999 Residue monitoring (XXIV/1008/99) March 1999, 6

7 Meat products (XXIV/1315/98) March 1998, The reports of the year missions are available on the DG (Health and Consumer Protection) Internet site at The reports of the previous missions made a number of recommendations in respect of the action required of the CA in the Czech Republic. One of these recommendations relevant for the current mission was, pending the transposition of the EC legislation, to urgently provide and operate clear written guidelines describing the specific conditions, and providing equivalent guarantees relating to the requirements of Council Directive 77/96/EEC, as regards examination for trichinae by the digestion method. Another recommendation was to implement clear written guidelines describing the procedures for approval, suspending (with time limits) and withdrawing approval for EC listed establishments, and ensure that the European Commission is kept informed of changes to lists of approved establishments. Some action with regard to these recommendations has been taken by the Czech authorities Production and trade information The Czech Republic is a traditional supplier of meat to the EU. In 1998, the EU Member States imported: 1,144.5 tons of fresh ( red ) meat, 1,371.5 tons of poultry meat and 1,970.3 tons of other meat 7. The last category consists mainly of wild game and rabbit meat Animal Health information Under Commission Decision 97/217/EC 8, the Member States are authorised to import fresh meat (bovine, porcine, ovine, goat and soliped) from the whole territory of the Czech Republic. Is to be noted, that some restrictions are still in force concerning imports of meat of wild swine regionalisation applies as laid down in Commission Decision 98/371/EC 9 as amended by Commission Decision 1999/538/EC 10, i.e. due to the current CSF situation imports are not authorised from the provinces of Kromeríž, Vyškov, Hodonín, Uherské Hradište, Zlin and Vsetín. The most recent finding (positive CSF virus isolation) in wild boar took place in November 1999, in domestic pigs in June EC-approved establishments There are currently 8 fresh meat establishments listed for export to the EU (Modification of the Annex to Commission Decision 93/543/EC as last amended by telefax No SANCO/7988 of 26/06/2000). These comprise four integrated slaughterhouses, cutting plants and cold stores (pig and bovine meat), one cutting plant and three independent cold stores. Before the announcement of this mission, the CCA informed the Commission of the suspension of one integrated slaughterhouse-cutting plant and meat products plant, and one independent cold store. The reason for the suspension of the first one was cross- flows in the 7

8 production process and unsatisfactory condition of the thermometers and manometers. Later, the CCA informed the Commission of the suspension of another cold store. As a consequence, at the time of the mission, only three integrated slaughterhouses / cutting plants / cold stores were currently authorised to export pork and bovine meat to the Community. All three were visited during the mission. 5. MAIN FINDINGS 5.1. Competent authority Structure of the competent authority The details of the Czech veterinary structure and its functioning are given in the Mission Report SANCO 1080/2000. No organisational changes took place in the interim. A new administrative structure will enter into force in the Czech Republic the 1 January The districts will be grouped into 13 regions + 1 (Prague). These new regions will be different to, and smaller than, the old regions under the Czechoslovak administration. However, the CCA intends to retain staff at local level as local veterinary inspectorates. Territorially, the local inspectorates will correspond to municipalities. In response to the recommendation in Mission Report SANCO 1080/2000 to reinforce the control and co-ordination by the CCA (SVS) of the districts units (OVS) in order to assure a uniform approach the Czech Authorities informed the Commission that a Manual concerning control and uniform approach had been issued by the SVS: the mission team, however, were unable to confirm the existence of this manual on-the-spot. The CCA did not report staff shortages. A more detailed description of the CA and the Czech veterinary system is given in a review prepared by the Office for Technical Assistance and Information Exchange (TAIEX), reference AACCVO/BP/20. TAIEX can be contacted on the Internet site at Legislation in force The Veterinary Act of 13 July lays down the organisation of the veterinary services and their functions in relation to animal health and public health activities. Provisions governing the public health conditions for foodstuffs, food establishments and food export are laid down in Decree No. 287/1999 of 2 December 1999 relative to the veterinary requirements for products of animal 8

9 origin 12. This document of general character covers the production and inspection of fresh meat and other products of animal origin (meat of wild and farmed game, poultry meat, meat products, fishery products and molluscs) In this decree, the lay down the rules for the inspection and evaluation of fresh meat. These include: Identification and certification of animals intended for slaughter, Rules for ante-mortem inspection, Rules for post-mortem inspection, Meat evaluation, Health marking rules. The details of veterinary post mortem inspection are laid down in 65 (large slaughter animals, including pigs). The above mentioned rules are similar to, or in a number of cases identical with those laid down in Directive 64/433/EEC point 2 says that the post mortem inspection of meat of pigs, horses, donkeys and their crosses includes the trichinae examination. The provisions of the Czech legislation related to trichinae examination seem to be limited to this single reference. A number of important topics are not covered in this legislation. e.g. emergency/sick and suspect animal slaughter is not clearly defined, a control of health mark labels by the veterinary service is not mentioned, the special conditions for cutting are not mentioned, b potable water standards are not specified. the conditions under which oval stamps may be applied are not specified Instructions In order to complete this somewhat limited legislation, the Czech authorities have issued a number of instructions (Metodické návodý SVS CR) following the EC legislation in different areas. Three instructions were seen by the mission team: PM inspection of slaughter animals (no 11HYGI/2000), a b In their response to the draft report, the Czech authorities noted that the Veterinary Act No. 166/1999 Coll contains definitions for these issues. In their response to the draft report, the Czech authorities noted that general cutting conditions are laid down in Section 6, Procedural Decree No. 287/

10 trichinae examination (nr 14/2000) and granting/withdrawal of approval for plants exporting to the EC (no 12/2000). In 2000, 14 instructions (concerning different fields of veterinary activity) were issued. The mission team was told that these instructions are available on the State Veterinary Administration s computerised network. However, this system is not universally available to the official veterinarians at establishment level. In all locations visited (including CCA headquarters) there were difficulties with system availability/connectivity. It appears that only the District Veterinary Offices (OVS) have access to the system (the system was seen in operation in one such office). The official veterinarians in the establishments are expected to have instructions as paper copies. However, no more that three of the instructions mentioned above could be presented to the mission team at the establishments. Some of the instructions are direct translations of EC legislation. In a number of instances, the instructions do not contain clear information as to the circumstances in which they apply Veterinary supervision Approval procedure In the Veterinary Act 48 it states that the SVS has the competence to approve establishments. Withdrawal of approvals is not mentioned. c The approval procedure, as explained to the mission team, is the following: The owner/company applies for approval to the OVS; The OVS evaluates the dossier and carries out an inspection on the spot; When the plant is considered to be in compliance with the Czech and EC requirements, the OVS recommends it for approval to the SVS; A second inspection is carried out by the OVS, with the presence of a representative from the SVS; The company is required to rectify within 30 days the deficiencies found during the second inspection; A third inspection by the OVS is carried out. If the deficiencies have been rectified, the OVS recommends the plant for approval by the SVS; A fourth inspection is carried out by the OVS, with the presence of a representative from the SVS; c In their response to the draft report the Czech authorities noted that this approval procedure was contained in guideline No. 12/2000. Since the establishments visited had been approved before this guideline came into effect, it was not possible to demonstrate the operation of this new system. 10

11 The approval is granted by the SVS. During on-the-spot-visits at the plants it was found that the approval files were not complete. In two of three plants visited, there were no approval letters by the CCA available. In one case, the mission team was told that the complete file was available in the District Veterinary Office (OVS). In two cases, only letters from the CCA, informing that Brussels has approved the plant, and referring to a Commission list of approved establishments, were found. One of the recommendations of the SANCO/1080/2000 mission was to implement clear written guidelines describing the procedures for approval, suspending and withdrawing approval for EC listed establishments. Further to this recommendation, the CCA has issued an instruction (no 12/2000) with the rules for suspension and withdrawal of approval. This instruction describes in detail the suspension of approval; however, it does not prescribe the approval process as outlined above Supervision at central and district level The routine supervision of the export approved plants is carried out by the District Veterinary Offices (OVS). Their District Public Health Inspectors (Vrchní inspektor pro hygienu) supervise the activities of the Local Veterinary Offices (VHS) which are located directly at the plants. The districts are also responsible for the implementation of the residue monitoring plan and allocate samples to the plants. Data concerning residue monitoring and AM and PM inspection are registered on computers and collected monthly from the VHS and send to Headquarters. The District inspectors visit the export approved plants at least once a month. During these visits, a report according to a standardised model (Protokol o kontrolním zjišteni) is made. When deficiencies are found, a verbal process (Spravni rizeni 14 ) is commenced. The management is requested to correct the deficiencies within clearly defined deadlines; they can appeal this decision to the CCA within 15 days. After the expiry of the deadline a repeat inspection is carried out to check compliance. Depending on the result of this inspection, fines may be imposed on the management or the plant may be suspended or delisted. The representatives from the CCA carry out on-the-spot inspections at least once a year, together with District staff. The reports of these inspections are always made by the District staff, due to the possibility of appeal by the management of the plants. 11

12 During the visits on the spot, the mission team saw detailed extensive records from these inspections, showing how problems were identified and followed up Controls in the establishments Trichinae examination One of the recommendations of the SANCO/1080/2000 mission was to implement clear written guidelines describing the specific conditions and providing the equivalent guarantees relating to the requirements Council Directive 77/96/EEC as regards examination for trichinae by the digestion method. The SVA has issued a Methodical instruction no 14/2000, dated 28 August 2000, which is a Czech translation of Annex I, II and III of Directive 77/96/EEC as amended. In the slaughterhouses, method VI (the magnetic stirrer method for pooled sample digestion) is used. The requirements of Directive 92/45/EEC, art. 3.3 (trichinoscopic examinations in wild boar, in relation to which deficiencies were found during the previous mission SANCO/1080/2000), were not taken into account in this instruction During on-the-spot visits the mission team made the following observations: The method prescribed was not followed. In fact it had been countermanded almost immediately after issue. This appears to have been due to the realisation that the pepsin available was of a different concentration to that specified in the instruction. Whilst the instruction was altered by the districts, this was done on advice from the CCA. The source and quality of pepsin was unreliable: The pepsin unit was not specified on the containers (an analysis certificate stating that the concentration was 10,000 units BP had recently been obtained the method used requires 12,500 units BP). Containers bearing the same batch number but different expiry dates were seen. Equipment was not in conformity with requirements and inexpert attempts had been made to alter its calibration. Moreover, the mission team was told that until the 1 September 2000, the day when it was officially repealed, a Czechoslovak directive of 1989 for trichinae examination (see p. 4) was used. The method prescribed by this directive does not correspond to any of the methods specified in Annex I of Council Directive 77/96/EEC ). However, this method was in use for many years, during which time the pig meat was certified for export to the EU. The mission team was not immediately informed about the above mentioned facts. 12

13 The mission team required immediate action from the Czech authorities and received, before the end of the mission, satisfactory guarantees concerning trichinae examination Veterinary documentation and record keeping In general, there was little written evidence of veterinary supervision at plant level. The existing records (AM inspection journal, trichinae inspection journal, etc.) were kept in a haphazard manner (pages not numbered, signatures not legible). In a number of cases, there were no records for the day-to-day supervisory activities. In one plant the records of local supervision were clearly insufficient. AM inspection records No official instructions have been issued at central level for the performance of ante mortem inspection. In one establishment visited the official veterinarian in the establishment had written instructions based on the Czech legislation. All incoming animals were accompanied by certification issued in their district of origin. In all establishments visited, the veterinarian, after performing ante mortem examination, stamped these certificates as passed and transmitted them to the veterinarian in charge of post mortem inspection. In cases where a number of animals were withheld at ante-mortem inspection, this was noted on the certificate. Details of incoming consignments were recorded. However, in all cases there was no defined format for these records. In one establishment, animals which were deemed not to have passed antemortem inspection were sent to a separate slaughter facility within the establishment. No record of the ante-mortem findings was passed to the veterinarian in charge of post mortem inspection.. The numbers of animals rejected at normal ante-mortem inspection were recorded on the SVS computer system. Post-mortem inspection records Post-mortem inspection was carried out in a satisfactory manner. There was no structured method for recording of the findings of post-mortem examination on the slaughter floor. All records were entered into the SVS computer system. Correlation of post mortem findings with the sources of live animals was only possible through consultation of establishment records. 13

14 Transfer of meat between establishments Concerning transport of meat between the plants, it should be noted that, according to the Veterinary Act 166/1999 art. 27, a veterinary transport document (Veterinární osvedcení pro prepravu potravin a surovin živocišného puvodu) is only required for certain categories of meat, but not for fresh meat. Own checks supervision There were no instructions available to the official veterinarians for the supervision of establishment own check systems. In most cases, records of checks carried out by the establishments were initialled by the official veterinarian. In one case, a report of an inspection carried out by the OVS was seen where deficiencies in the own check system were identified and improvements required Special emergency slaughter In the Czech Republic there are a number of slaughterhouses for special emergency slaughter and for slaughter of sick and suspect animals (sanitary slaughter). These slaughterhouses are not mentioned in the current Czech veterinary legislation (Veterinary Act 166/1999, Decree 287/1999) and the CCA representatives could not explain to the mission team their legal status and the difference between these two categories. In one plant it was noted, that no records were kept of the reasons for sending animals for emergency slaughter, which is carried out in a separate slaughter facility within the plant. This facility met the standard required for a small capacity slaughterhouse, but is not approved as such. However, an animal slaughtered in this slaughterhouse may be approved and receive oval health mark and, as such, enter the EU export chain Health marking The Czech legislation prescribes that fresh meat fit for human consumption is marked with a round stamp (Decree 287/1999, 74). Use of the oval mark is also authorised, but the Decree does not indicate the circumstances in which such a mark may be used (Decree 287/1999, 78 p. 2). During the mission it was found that another plant, which is not approved for EU, uses an oval health mark. In relation to health marked labels, it was noted that the small marks applied to the wrapping, were not under veterinary supervision at all. The supervision of the large marks was not satisfactory in that the records of issue and use were not accurate and no correlating checks with production records were 14

15 performed. In one plant, a system based on correlation with the production records, but which was not yet operational, was shown to the mission team Many labels currently used were of poor quality and easy to remove/replace or damage Import control The mission team detected fresh meat, which had been imported into the Czech Republic from several Member States, which did not fulfil the requirements of EC legislation (not packaged, not properly health marked) Health Certificates Since 1 January 2000 the model certificates for export to the EU have been available on the CCA computerised network and they are printed out and numbered in the district offices (OVS). Each certificate is signed twice: by the veterinarian on the spot, supervising the unloading of the consignment, and by the public health inspector of the OVS. In each OVS there is a list of persons eligible to sign the certificates. The copies of certificates seen by the mission team were in principle correct, and only minor deficiencies were noted. The public health certificate for fresh meat (Council Directive 72/462/EEC, Annex A), however, could not be presented to the mission team. The mission team noted that in addition to the certificates prescribed by the EC legislation (Commission Decision 98/371/EEC as amended) some additional, supplementary certificates were issued, which are not foreseen by the EC legislation. The CCA explained that a number of additional certificates were required by certain Member States, in particular Austria and Germany 15. This requirement, however, was never officially passed by the competent authorities of the relevant MS to the Czech CCA; instead, the information was passed via the trade channels (importer to exporter) Animal registration and identification According to the Animal Breeding Act (154/2000) owners of domestic animals and farmed game are responsible for the individual identification of their animals ( 22), with the exception of bees, fish and poultry. Owners of 1 pig or 3 sheep /goats are also exempted. Owners are obliged to keep registers of their animals ( 23) and inform the authorities about births, origin, species, population, identification numbers and transfer of animals. The mission team was shown computerised animal registers, which are kept for each district and for the following animal species: bovine animals, pigs, sheep, goats, horses, poultry and farmed game. The registers are updated on a monthly basis. A planned visit to a pig farm was cancelled because of lack of time. 15

16 5.5. Establishments Three integrated slaughterhouses, cutting plants and cold stores were visited. The plants visited were generally in good condition. In one plant, however, serious deficiencies due mainly to lack of maintenance of the chilling facilities, were found. These deficiencies were so severe that the plant did not fulfil the requirements of the EC legislation. It was recognised that the District Veterinary Office had identified these problems and had initiated corrective action. However, suspension of certification of meat to the EU was not included in the action taken. Satisfactory guarantees were received by the mission team during the final meeting. These guarantees included: suspension of certification during the refurbishment of the chilling facilities, and suspension of the plants itself, if the refurbishment will not be completed within the deadline set by the District Veterinary Office Hygiene of operation Few problems in relation to hygiene of operation were noted. In two cases, the temperature of meat in cutting room in was close to 7 C. A number of sterilisers were operating under 82 C. One steriliser at bleeding was found empty. These deficiencies were corrected on the spot. In many cases, suspended hoses were seen, used for washing aprons directly at the working place in close proximity to exposed meat with consequent risk of splash contamination Structure and layout In relation to structure and layout, it was noted, that many doors were not pest proof. In one case, hatches for dispatch of trays of meat, leading to the exterior, were not completely covered. In one plant, the same dispatch was used for packaged meat, and for imported (unpacked) carcasses. There were no inspection facilities for incoming meat Maintenance and cleanliness In relation to maintenance and cleanliness, and in addition to the establishment described at the beginning of this section, rusty equipment was found in a number of places. Dripping water condensation was also seen in a number of establishments Equipment In relation to equipment, the following was noted. In two cases, there were no sterilisers for splitting saws (the management argued that the saws had an integrated sterilisation system; however, this was found not to be efficient by the mission team). In two cases, there were no isolation pens in the lairages, or, where such pens existed, they did not provide effective isolation. In some cases, there were no watering facilities in the pens. Stunning equipment was generally working well, but there were neither voltmeters nor ammeters, or, 16

17 where these existed, they were not visible to the operator. There were in general no cabinets for washing aprons. In one case, a scalder of particular construction produced excessive amounts of steam Own checks Own check systems and documentation were generally found to be in place in the establishments visited. Records of the results of visual checks of cleaning and disinfection were not extensive. Instead there was a heavy reliance on the results of bacteriological testing. In all establishments visited, the bacteriological testing associated with the own checks systems was carried out by external, officially recognised laboratories. Testing was restricted to certain pathogenic organisms no total counts etc. were performed (a direct agar swab one blood agar and one Endo agar for E. coli were used, plus Salmonella plus Staphylococcus). No parameters for determining whether a sample is positive were available. While the laboratories categorised the results as satisfactory or unsatisfactory, the criteria applied were not known to the establishment. In many cases, particularly in relation to water quality, no corrective action (or inadequate corrective action) was specified. 6. CONCLUSIONS 6.1. Competent authority The national legal basis related to fresh meat production and trichinae control in the Czech Republic is very limited. The legislation recently adopted (The Veterinary Act 166/1999 and Decree 287/1999) does not take the EC legislation fully into account, and it does not provide equivalent health guarantees to those provided by EC legislation. Negligible progress has been made in the process of speeding up the implementation of EC legislation in order to comply with the Acquis Communautaire as recommended in the previous report (SANCO/1080/2000). The relevant Community legislation is available to the official veterinarians, properly updated and translated into the Czech language. The CCA has issued a number of instructions describing specific production and control conditions equivalent to those laid down in EC legislation. This represents a positive response to the previous mission s recommendations. However, these instructions are not comprehensive and in some cases their field of application is not clear. They are not yet fully implemented, and are not fully available to the official veterinarians supervising the plants. In one 17

18 case, the CAA issued an instruction about Trichinae examination and immediately, unofficially, altered it. There is a vertical line of command. However, the current organisation of the CA (SVS, the headquarters and 73 veterinary districts, the OVS) makes it somewhat difficult to supervise and co-ordinate the work of the districts. The Czech Authorities informed the Commission that a Manual concerning control and uniform approach had been issued by the SVS: the mission team, however, were unable to confirm the existence of this manual on-the-spot Veterinary supervision The guidelines concerning principles of pre-listing (Council Decision 95/408/EEC), especially in relation to suspending and de-listing the plants, have been provided and appear to be implemented. The rules for approval are still missing. The CA has sufficient veterinary staff to perform the control tasks. The staff appear to be professional and motivated. In relation to the supervision at the local level, the records of activities were insufficient, even though it appears that the official veterinarians carried out their work properly. However, the supervision at the district level was found to be effective, and comprehensive records were kept. Among the deficiencies in the veterinary system, the trichinae control was found to be unreliable, and immediate action to correct the situation was required by the mission team. Appropriate guarantees in this matter were received from the Chief Veterinary Officer. The use of an oval health mark by non-eu approved establishments as well as lack of clear conditions for use of such a mark in the Czech legislation can easily cause confusion and exposes the system to fraud. In relation to animal welfare, stunning was generally satisfactory; however, the positioning of monitoring devices was not in accordance with the EC legislation. In some cases, facilities for watering animals in the stables were missing Health Certificates Veterinary health certificates were generally completed in an acceptable way. It was noted that some Member States had unofficially required additional assurances to those foreseen by EC legislation Establishments For most aspects the plants were found to be satisfactory and the deficiencies found can easily be corrected. However, in one case, serious deficiencies due mainly to lack of maintenance of the chilling facilities, were found. These deficiencies were so severe that the plant did not fulfil the requirements of EC 18

19 legislation. It was recognised that the District Veterinary Office had identified the problems and had initiated corrective action. Satisfactory guarantees were received by the mission team during the final meeting. In relation to own checks, it was found that results of microbiological tests were not carried out in most productive manner (see point third indent) Corrective actions, in particular in case of unsatisfactory results of water examination, in many cases were not specified. 7. OVERALL ASSESSMENT While a number of aspects of the veterinary supervision system in the Czech Republic give cause for concern (notably trichina testing, the incomplete nature of the legislation and the lack of comprehensive instructions for the official veterinarians), the overall organisation and performance of the service can be considered generally reliable and effective. It was noted that efforts had been made to address some of the problems identified in the previous FVO mission (SANCO/1080/2000). However, as indicated above, further work in certain areas is still outstanding. 8. CLOSING MEETING Due the unavoidable absence of the CVO from the final meeting, an informal meeting took place on the eve of the official final meeting. At both meetings the main findings, conclusions and recommendations of the mission team were outlined and discussed. All findings, conclusions and recommendations were, in essence, accepted and agreed. Official assurances were received in relation to trichina testing and to standards in one establishment. 9. RECOMMENDATIONS 9.1. To the competent authorities of the Czech Republic With regard to the target date of accession, to speed up the process of implementation of EC legislation related to fresh meat production and trichinae examination, in order to comply with the Acquis Communautaire Pending the transposition of EC legislation, urgently to provide and operate clear written guidelines describing the specific conditions and providing the equivalent guarantees relating to the requirements of Council Directive 64/433/EEC as regards fresh meat and Council Directive 77/96/EEC as regards examination for trichinae. 19

20 To take steps to improve the local supervision and record keeping by the Local Veterinary Offices (VHS) To ensure that pig meat exported to the EU has received and passed the antemortem inspection laid down in the EC legislation To rectify the deficiencies found in the establishments visited and ensure that all other approved establishments are also checked. A report indicating the actions taken or to be taken, including a timetable for the actions recommended in points should be submitted to the Commission within two months of receiving the final report To the Commission Services To consider further action in respect of imports of pig meat from the Czech Republic unless the guarantees given by the Czech competent authorities in relation to the recommendations within the deadline mentioned above are found to be satisfactory To take steps to ensure that Member States do not require certification and/or health conditions in excess of those laid down in the relevant Community legislation; ADDENDUM TO MISSION REPORT DG(SANCO)/1236/2000 Competent Authority response to the recommendations in the report In a letter (ref. no. 4841/2000-SM, dated 7 November 2000) the Czech authorities commented on the draft report and offered their initial reaction to its recommendations. They indicated the action already taken, or planned, to respond to each of the above recommendations, including deadlines for its completion. 20

21 1 2 3 OJ No L 302, OJ No L 26, OJ No. L 138, OJ No L13, Europe Agreement establishing an association between the European Communities and their Member States, of the one part, and the Czech Republic, on the other part, of 4 October 1993 (hereinafter referred to as the Europe Agreement ) Council Decision 98/250/EC of 20 October 1997 on the conclusion of a Protocol concerning sanitary and animal welfare measures in relation to trade to the Europe Agreement between the European Communities and their Member States, on the one part, and the Czech Republic, on the other part (OJ No L 106, , p. 1) Source: Données statistiques sur les importations de denrées alimentaires d origine animale des pays tiers vers l Union Européenne pour l année 1998, rapport de l Office Alimentaire et Vétérinaire du 27 septembre 1999 Commission Decision 97/217/EC of 28 February 1997 establishing groups of third countries which are able to utilise the veterinary certificates for imports of wild game meat, farmed game meat and rabbit meat from third countries, OJ No L 088, , p. 20, as amended by Decision 98/648/EC, OJ No L 308, , p. 42 Commission Decision 98/371/EC of 29 May 1998 concerning the health conditions and veterinary certification for imports of fresh meat from certain European countries, OJ No L 170, , p. 16 Commission Decision 1999/538/EC of 26 July 1999 amending Decision 98/371/EC concerning the animal health conditions and veterinary certifications for imports of fresh meat from certain European countries to take into account some aspects in relation with Bulgaria and the Czech Republic, OJ No L 207, , p. 21 Zákon c.166/1999 ze dne o veterinární péci a o zmene nekterých souvisejících zákonu (veterinární zákon). Vyhláška c.287/1999 Ministerstva zemedelstvi ze dne o veterinárních požadavcích na živocišné produkty. OJ No. L 121, , p Council Directive 64/433/EEC of 21 December 1976 on health conditions for the production and marketing of fresh meat Zákon c. 71/1967 Sb. O správnim rizeni e.g. Veterinärbehördliches Zeugnis für die Einfuhr von Wurst- und Fleischwaren, Fleischerzeugnissen, fleischenthaltenden Zubereitungen und Konserven für Ausstellungen, Vorführungen oder Messen nach Österreich. 24/11/