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From: TSS (216-119-144-9.ipset24.wt.net)
Subject: REPORT OF A MISSION CARRIED OUT IN GREECE FROM 15 TO 19 MARCH 2004 CONCERNING THE DISPOSAL OF CERTAIN ANIMAL BY-PRODUCTS
Date: August 17, 2004 at 8:05 am PST

-------- Original Message --------
Subject: REPORT OF A MISSION CARRIED OUT IN GREECE FROM 15 TO 19 MARCH 2004 CONCERNING THE DISPOSAL OF CERTAIN ANIMAL BY-PRODUCTS
Date: Tue, 17 Aug 2004 10:06:45 -0500
From: "Terry S. Singeltary Sr."
To: Bovine Spongiform Encephalopathy


REPORT OF A MISSION CARRIED OUT IN GREECE FROM 15 TO 19 MARCH 2004
CONCERNING THE DISPOSAL OF CERTAIN ANIMAL BY-PRODUCTS

EXECUTIVE SUMMARY
This report describes the outcome of a mission carried out by the Food
and Veterinary
Office (FVO) in Greece, from 15 to 19March 2004.
The objective of the mission was to evaluate the system in place
concerning the safe
disposal and destruction of animal by-products to give effect to EC
rules on animal byproducts
not intended for human consumption (ABP), as laid down in Regulation (EC) No
1774/2002.
In terms of scope, the mission focused on the capability of the
competent authorities to
ensure the correct handling and storage of ABP from slaughterhouses and
cutting plants
until their safe rendering/disposal
Overall, the report concludes that there are delays regarding the
implementation of
Regulation (EC) No 1774/2002 and substantial shortcomings in the safe
disposal of certain
animal by-products and in the collection of fallen stock.
The report makes a number of recommendations addressed to the Greek
competent
authorities, aimed at rectifying the identified shortcomings and/or
further enhancing the
implementing and control measures in place.

snip...

2. FINDINGS AND OBSERVATIONS
2.1. COMPETENT AUTHORITIES
The organisation of the veterinary services is described in report
8635/2002.
The CCA responsible for the control of animal waste from the slaughterhouses
until safe disposal and the approval and operation of rendering plants,
collection
centres, incinerators, co-incinerators and intermediate plants is the
Ministry of
Agriculture, Development and Food and aside to this, other Ministries have
competencies as well.
Within the Ministry of Agriculture, Development and Food, two new
offices have
been established in order to handle all issues related to ABP: the
"Office for
Animal Waste" under the Directorate of Public Health and a new
Directorate of
Inspections and Controls.
Responsible bodies for approved landfill sites are the Ministry of
Development,
Ministry for the Environment Physical Planning and Public Works and
Ministry of
DG (SANCO)/7015/2004 - MR - Final
6
Health and Welfare and the Ministry of the Interior Affairs, Public
Services and
Decentralisation.
There are 54 Prefectures in Greece, provided with a Veterinary Service
holding the
responsibility to carry out a wide range of veterinary issues including
health
schemes, supervision and control, eradication measures etc. with
assistance from
the Veterinary Field Stations (VFS).
Observations
The Office for Animal Waste is responsible for supervision, instructions and
guidance for the correct handling of ABP including correct separation of the
categories (4).
The Directorate for Inspections and Controls is responsible for auditing the
ABP control by on spot slaughterhouse inspections and co-ordination between
different Ministries involved in ABP. The Directorate is not
sufficiently staffed
yet, and has not started its work.
The general shortage of staff on Prefecture level hampers their ability
to carry
out all tasks required, including the supervision of the safe handling and
disposal of ABP.
The responsibility of other Ministries and the mode of co-operation was not
clearly defined.
2.2. COLLECTION, PROCESSING AND DISPOSAL OF ANIMAL BY-PRODUCTS
2.2.1. Legal and administrative provisions
The Presidential Decree 243 of 1993 and the implementing circular letter
381384
of August 2000 transposed Council Directive 90/667/EEC(5) and Council
Decision
1999/534/EC(6), which are still applicable in Greece. In November 2002,
the CCA
sent a circular letter to Prefectures to inform them about the change in the
Community legal framework for the disposal of animal waste and the
possibility to
download Regulation (EC) No 1774/2002. The Prefectural Veterinary Services
(PVS) were responsible for the communication of the given information to
local
inspectors and operators.
In June 2003, the CCA requested the processing plants to specify what
category of
ABP they intend to process. In December 2003, the CCA sent a circular letter
concerning the guidance on the classification into categories and
clarification on
the disposal of ABP pursuant to Regulation (EC) No 1774/2002 inter alia to
prefectures, universities and industry. In March 2004, training inter
alia in ABP
requirements was provided to veterinarians and to industry.
(4) In their response to the draft report the Greek competent
authorities stated that on spot-spot checks
are carried out in cooperation with the Office for the Management of
Animal Waste or the
Slaughterhouse Department, depending on the circumstances, both in
respect of the activities of the
Prefectural Veterinary Services and the premises, establishments, means
of transport, staff,
documents and data subject to surveillance on the part of these services
(5) Council Directive 90/667/EEC of 27 November 1990 laying down the
veterinary rules for the disposal
and processing of animal waste, for its placing on the market and or the
prevention of pathogens in
feedingstuffs of animal or fish origin and amending Directive
90/425/EEC. OJ L 363, 27.12.1990, p.
51
(6) Council Decision of 19 July 1999 on measures applying to the
processing of certain animal waste to
protect against transmissible encephalopathies and amending Commission
Decision 97/735/EC. OJ L
204. 4.8.1999. p. 37
DG (SANCO)/7015/2004 - MR - Final
7
Observations
Regulation (EC) No 1774/2002 was not applied from 1 May 2003, as required.
The CCA confirmed that a multi-ministerial decision on the disposal of
animal
waste in accordance with Regulation (EC) No 1774/2002 is being drafted, and
its completion is expected by the end of September 2004. The CCA explained
the delayed adoption was partly due to re-organisation of the central
service,
and the forthcoming elections in early 2004.
Few rendering plants have so far responded to the enquiry on which
category of
ABP they intend to process. The CCA stated that no further action was
planned,
but will be taken after the multi-ministerial decision on ABP has been
issued.
Although the guidance already given to various stakeholders provides a good
tool to categorise animal waste, no guidance on transportation and
storage or
official controls and approval conditions for processing plants in line with
Regulation (EC) No 1774/2002 was issued. The CCA stated that this will be
part of the forthcoming multi-ministerial decision.
2.2.2. Application and supervision in practice
2.2.2.1. Collection, transport, processing and disposal of ABP from
slaughterhouses and cutting plants
Guidelines regarding the categorisation and disposal of ABP received
from the
CCA were communicated to the slaughterhouses by the VFS.
Observations
SRM removed at slaughter is recorded by date, weight and specified type,
signed and stamped by the official veterinarian.
The recorded amounts of SRM did, at the on spot check, correlate with the
estimated expected amount of SRM.
The CCA stated that ashes from slaughterhouse incineration are buried at
approved sanitary landfill sites.
No evidence could be provided that all category 1 material other than
SRM was
incinerated. According to the CCA, all category 1 material referred to as
"buried" in Table 1 consisted of dead companion animals.
The figures provided by the CCA regarding the production and disposal of
animal waste suggest that 99,8% of Category 1 material is incinerated
(including all SRM). The percentage of category 2 and 3 material for burial
without pre-processing at landfill sites is, according to the same
figures, 69%
and 45%, respectively.
Substantial amounts of category 2 material from slaughterhouses are buried
without pre-processing at municipal landfill sites, and without evidence of
supervision of the veterinary or environmental authorities. In this
context, the
CCA confirmed the insufficient rendering capacity of the country.
Category 3 material other than hides for export or raw material for pet food
production is buried without pre-processing at municipal landfill sites,
without
evidence of supervision of the veterinary or environmental authorities.
There is no collection and disposal of fallen stock. According to the
CCA, the
practice to bury fallen stock on site will be changed by a new Ministerial
DG (SANCO)/7015/2004 - MR - Final
8
decision which provides for compensation to be paid to farmers bringing in
dead animals for disposal.
2.2.2.2. Official control and supervision along different stages until
disposal
of ABP
At Prefecture level, it is the responsibility of the PVS to ensure the
correct handling
of ABP and to carry out controls regarding the disposal of animal waste and
documentary checks at slaughterhouses and rendering plants.
The physical inspection at slaughter and control of consignments
dispatched from
the slaughterhouses or rendering plants is the responsibility of the
VFS, under the
supervision of the PVS.
Observations
Official supervision of slaughterhouses and rendering plants is carried
out on a
monthly basis by the PVS; documentary checks were done at random.
No evidence could be provided of supervision or documentation of unprocessed
category 2 and 3 material disposed at municipal landfill sites.
The commercial documents accompanying consignments of waste from
slaughterhouses and rendering plants held incomplete details about the
category
of material due to lack of guidance from the CCA regarding transports of
ABP.
The CCA stated that the forthcoming multi-ministrial decision would rectify
this
The traceability of the dispatched category 3 material could not be
fully ensured
since no reference was made to category, batch number or animal origin. The
CCA stated that the forthcoming multi-ministrial decision would rectify
this.
In cases of non-compliance it is the responsibility of the PVS to
propose and
follow up actions. If appropriate actions have not been taken as
proposed the
PVS could close the establishment, impose financial sanctions or take legal
actions. It was not uncommon that establishments were closed by the PVS and
in some cases sanctions had also been imposed.
The CCA has, in order to address the apparent shortfall in the rendering
capacity of the country and the possible numbers of new rendering plants
needed, commissioned a study on "The management of waste solids and liquids
from Greek slaughterhouses". A first report was foreseen at the end of
March.
3. CONCLUSIONS
3.1. COMPETENT AUTHORITIES
The establishment of two new offices at central level should enhance the
CCA's
ability to carry out APB controls. However, inspections, controls and
supervision
of the handling of ABP, apart from SRM, at slaughterhouses, rendering
plants and
cutting plants, in accordance with Regulation (EC) No 1774/2002, has not
commenced due to shortage of staff at central and local level.
3.2. COLLECTION, PROCESSING AND DISPOSAL OF ANIMAL BY-PRODUCTS
1. The current legal framework is based on repealed Community rules for the
disposal of animal waste. Regulation (EC) No 1774/2002 is not yet
sufficiently
applied but national provisions are in the process of being set up.
DG (SANCO)/7015/2004 - MR - Final
9
2. The incineration of slaughterhouse SRM and the disposal of ashes at
approved
sanitary landfill sites appear satisfactory.
3. Due to serious shortcomings in the rendering capacity of the country,
substantial
amounts of category 2 and 3 material from slaughterhouses are being disposed
of unprocessed at municipal landfill sites not authorised for this purpose.
4. Fallen stock is at present routinely buried on site, and unsupervised
since there
is no system in place for collection and disposal.
5. Official controls of SRM at slaughterhouses and general controls at
rendering
plants are carried out by the local veterinary authority in each
Prefecture, but
due to shortage of staff the supervision of all stages in the flow of
disposal of
category 2 and 3 material cannot be sufficiently ensured. As a result
deficiencies
in the application of the relevant EU requirements may go unnoticed and
timely
corrections are not assured.
3.3. OVERALL CONCLUSION
The current legal and administrative framework do not allow for proper
application
of the EU rules on ABP, and the situation is exacerbated by serious
shortfalls in the
rendering capacity in the country. In addition, staff shortages do not
allow adequate
controls to ensure EU-conform disposal of ABP. As a result, safe disposal of
animal by-products not intended for human consumption is currently not
ensured.
4. CLOSING MEETING
A closing meeting was held on 19 March 2004 with the representatives of the
CCA, during which the mission team presented its initial findings and
conclusions.
The CCA reserved its position until the draft report is made available.
5. RECOMMENDATIONS
TO THE COMPETENT AUTHORITIES OF GREECE
The competent authorities are invited to provide details of the actions
taken and
planned, including deadlines for their completion within 20 working days
following the receipt of the translated final version.
1. Ensure without delay full implementation of Regulation (EC) No 1774/2002.
2. Review staffing in order to enable the control and supervision of the
correct
categorisation, handling and disposal of ABP.
3. To develop actions aimed at increasing the countrys rendering
capacity, taking
into account the outcome of the ongoing study.
4. To develop systems for the collection of all fallen stock for their
disposal in
line with Regulation (EC) No 1774/2002.
DG (SANCO)/7015/2004 - MR - Final
10
Addendum
Response of the competent authorities to the recommendations
Comments from the Greek CCA on the draft report were received on 10 July
2004, and
included the actions planned and /or undertaken to address the
recommendations
contained in this report. These may be summarised as follows:
As regards 5.1, the preliminary draft of the multi-ministerial decree
from January 2004,
setting out licensing requirements and conditions within the remit of
Regulation (EC) No
1774/2002 is currently for legal examination and will most likely be
brought forward to
the competent ministers for signature in July 2004.
As regards 5.2, a planned recruitment of 51 staff was to be launched by
the Supreme
Council for Personnel Selection in the Greek Gazette in June or July
2004. In addition to
this, the recruitment of 79 veterinarians at Prefecture level will be
done by
implementation of Invitation 27/23k/2003. Furthermore the Deputy
Minister for Rural
Development and Food has sent a letter to the Minister of Public
services and
Decentralisation calling for recruitment by way of exception7 of
veterinary personnel.
As regards 5.3, the initial phase of the study to analyse the rendering
situation of the
country is now completed and a report on the production of animal waste
with a
breakdown per Prefecture has been delivered. The second part including
proposals
concerning the type and number of processing plants required in the
entire country to
ensure the proper disposal of ABP is under way. On the basis of the
envisaged report a
central plan will be prepared for the disposal of ABP in accordance with
Regulation (EC)
No 1774/2002.
As regards 5.4, due to the large number of islands and the mountainous
nature of the
country  with a large number of small settlements located in mountain
and remote
regions which have a very small animal population and are distant from
the processing
plants and the plants for the destruction of fallen animals  there is a
large risk of
spreading diseases during transport; besides, it is also very difficult
to operate such a
system smoothly. The Ministry of Rural Development and Food, in its
endeavour to
monitor the collection and destruction of fallen animals, has issued
Joint Ministerial
Decision No 577/2004 together with the Ministry of Finance (enclosed).
This decision
provides for the compensation of producers who submit fallen animals for
destruction.
Besides, the decision implementing Regulation (EC) No 1774/2002 imposes
severe
penalties on owners of fallen animals who infringe the disposal
requirements.
7 This was highlighted by the Competent Authority in their response to
the draft mission report.

http://europa.eu.int/comm/food/fs/inspections/vi/reports/greece/vi_rep_gree_7015-2004_en.pdf

TSS





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