EUROPEAN COMMISSIONHEALTH AND CONSUMERS DIRECTORATE-GENERAL

Directorate F - Food and Veterinary Office

FINAL REPORT OF AN AUDIT

CARRIED OUT IN

INDIA

FROM 24 JANUARY TO 02 FEBRUARY 2012

IN ORDER TO EVALUATE THE PLANT HEALTH CONTROLS IN THE POTATO SECTOR IN VIEW OF INDIA'S REQUEST TO EXPORT POTATOES FROM THE REGION OF PUNJAB

DG(SANCO) 2012-6311 - MR FINAL

Ref. Ares(2012)695894 - 11/06/2012

Executive Summary

This report describes the outcome of a audit carried out by the Food and Veterinary Office (FVO) in the State of Punjab in India from 24 January to 2 February 2012.The objectives of the audit were to evaluate the phytosanitary situation of potato production and to assess the performance of the various bodies involved in the national plant health system with reference to the potato sector. An additional objective was to assess the methodology and results of the surveys that are carried out to establish freedom from the relevant harmful organisms, in particular Clavibacter michiganensis ssp. sepedonicus and Ralstonia solanacearum and the plant health measures applied to potato production to meet the requirements of the relevant EU legislation in view of a possible derogation from the prohibition on ware potato imports into the EU as laid down in Annex III to Council Directive 2000/29/EC.A well-structured phytosanitary organisation system operates in Punjab. Tasks and responsibilities in the plant protection service are well defined between the central and the regional services. There are no staffing problems and a good technical communication between the services is achieved with adequate work planning and regular meetings. There are well documented work procedures for sampling and testing for the production of potato seed as well as for inspections to be carried out prior to export. However, brown rot is not handled as a quarantine harmful organism and staff are not familiar with potato crop symptoms to look out for, during visual inspections.For the establishment of a brown rot free area emphasis was given to a large programme of soil testing, which is not appropriate for detection purposes. The main laboratory which was involved in this project is not equipped with necessary analytic and containment facilities and the protocol followed for the detection of brown rot could not be verified. The number of tuber samples taken for the establishment of the pest free area was very small of which the majority were inspected without cutting. Analysis of tuber samples for the detection of brown rot took place only occasionally and according to a non verified laboratory protocol. No surveys were carried out of surface water or wild hosts for the bacterium. No laboratory testing has been conducted to verify the absence of Clavibacter michiganensis ssp. sepedonicus.The vast majority of marketed seed is not subject to official control as producers and traders are not registered and the current labelling system does not allow for tracing back and forward actions to take place. Although legislation in place regulates movement of seed potatoes into Punjab from other regions, no controls regarding the effectiveness of the measure are implemented in practice; ware potato movement from other States of India where brown rot is present is not controlled. Composted solid waste from potato processing plants handling non-Punjab potatoes is used by farmers without being treated and untreated waste water is used for irrigation.Organisation of selected farmers for potato export to the EU has been initiated to ensure that only potatoes under the required official control are exported.Overall, Punjab currently cannot provide adequate guarantees for safe export of ware potatoes to the EU. There are structures in place for rectifying actions to be taken and the authorities expressed determination to meet requirements. Uncertainty regarding a number of exotic potato organisms occurring in India remains. The phytosanitary risk of these harmful organisms for the EU and the risk of them being introduced and spread by potato trade still need to be evaluated. The report makes a number of recommendations addressed to the competent authorities, aimed at rectifying the shortcomings identified and further enhancing the implementing and control measures in place.

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Table of Contents 1 INTRODUCTION ........................................................................................................................1 2 OBJECTIVES ............................................................................................................................1 3 LEGAL BASIS ..........................................................................................................................2

3.1 RELEVANT EU LEGISLATION ...........................................................................................................2 3.2 INTERNATIONAL STANDARDS ...........................................................................................................2

4 BACKGROUND ..........................................................................................................................2 5 FINDINGS AND CONCLUSIONS ...................................................................................................2

5.1 ORGANISATIONAL ASPECTS ............................................................................................................2 5.1.1 STRUCTURE OF THE NATIONAL PLANT PROTECTION ORGANISATION AND RESPONSIBILITIES ....................3 5.1.2 NATIONAL LEGISLATION ..........................................................................................................4 5.1.3 DELEGATION OF OFFICIAL CONTROLS .........................................................................................4 5.1.4 LABORATORIES AND DIAGNOSTICS ..............................................................................................5 5.1.5 GUIDELINES AND TRAINING ......................................................................................................7 5.1.6 WORK PLANNING AND EVALUATION ............................................................................................7 5.1.7 FINANCIAL RESOURCES AND CONTINGENCY FUNDING ......................................................................8 5.1.8 COMMUNICATION AND CONSULTATION WITH STAKEHOLDERS ............................................................8

5.2 POTATO PRODUCTION AND TRADE ....................................................................................................9 5.2.1 POTATO PRODUCTION SYSTEM ...................................................................................................9 5.2.2 IMPORTS AND HOLDING OF SOLANUM GENETIC MATERIAL .............................................................10 5.2.3 SEED MULTIPLICATION AND CERTIFICATION ................................................................................11 5.2.4 PRODUCTION METHODS OF WARE POTATOES ...............................................................................13

5.3 REGISTRATION OF STAKEHOLDERS AND TRACEABILITY OF CONSIGNMENTS ..............................................14 5.4 PHYTOSANITARY STATUS OF POTATO HARMFUL ORGANISMS IN INDIA AND THE STATE OF PUNJAB ...............15

5.4.1 ESTABLISHMENT AND MAINTENANCE OF PUNJAB AS A PFA FOR RING ROT AND BROWN ROT ..................18 5.4.2 OTHER HARMFUL ORGANISMS OF POTATOES ...............................................................................20

5.5 PROCESSORS, PACKERS AND CONTROL OF WASTE ...............................................................................21 5.6 CONTROLS OF POTATO IMPORTS AND INTERNAL MOVEMENT ................................................................22 5.7 CONTROLS FOR POTATO EXPORTS AND ISSUANCE OF PHYTOSANITARY CERTIFICATES .................................22

6 OVERALL CONCLUSIONS .........................................................................................................24 7 CLOSING MEETING ................................................................................................................25 8 RECOMMENDATIONS ...............................................................................................................25ANNEX 1 - LEGAL REFERENCES .................................................................................................27ANNEX 2 – STANDARDS QUOTED IN THE REPORT ..........................................................................28

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ABBREVIATIONS AND DEFINITIONS USED IN THIS REPORT

Abbreviation Explanation

APEDA Agricultural and Processed Food Products Export Development Authority

BLO Bacteria like organism

CPRI Central Potato Research Institute

DAC Department of Agriculture and Cooperation

DPPQS Directorate of Plant Protection Quarantine and Storage

EC European Commission

ELISA Enzyme Linked Immuno Sorbent Assay

EPPO-PQR European Plant Protection Organisation Plant Quarantine Data Retrieval System

EU European Union

FVO Food and Veterinary Office

GAP Good Agricultural Practice

ICAR Indian Council of Agricultural Research

IPPC International Plant Protection Convention

ISPM International Standards for Phytosanitary Measures

MARKFED Punjab State Supply Cooperative and Marketing Federation

NPPO National Plant Protection Organisation

PAU Punjab Agricultural University

PCR Polymerase chain reaction

PFA Pest Free Area

PSDA Punjab State Department of Agriculture

PSSCA Punjab State Seed Certification Authority

SMSA Selective medium for isolation of bacteria used as primary screen

TLS Truthfully Labelled Seed

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1 INTRODUCTION

The audit took place in India from 24 January to 2 February 2012 as part of the Food and Veterinary Office's (FVO) planned programme.

The FVO team, which consisted of two auditors and a national expert from a Member State, was accompanied throughout the audit by representatives of the Department of Agriculture and Cooperation of the Ministry of Agriculture, Government of India and the Department of Agriculture of the State of Punjab. A questionnaire was sent to the Indian Authorities in advance of the audit, which was completed and returned to the FVO.

An opening meeting was held on 24 January in Chandigarh during which the objectives and itinerary for the audit were confirmed. A closing meeting was held in Chandigarh on 2 February 2012.

2 OBJECTIVES

The objectives of the audit were to evaluate the phytosanitary situation of potato production in the State of Punjab and to assess:

(1) the performance of the various bodies involved in the national plant health system with reference to the potato sector;

(2) the methodology and results of the surveys that are carried out to establish freedom from the relevant harmful organisms;

(3) the phytosanitary situation as regards harmful organisms in potatoes of quarantine relevance for the EU, in particular Clavibacter michiganensis ssp. sepedonicus and Ralstonia solanacearum;

(4) the plant health measures applied to potato production in the State of Punjab to meet the requirements of the relevant EU legislation in view of a possible derogation from the prohibition on ware potato imports into the EU as laid down in Annex III to Council Directive 2000/29/EC.

In pursuit of these objectives the following sites were visited:

Competent authority visits Comments

Competent authority Central office Agriculture Service / State Government of Punjab Chandigarh

Regional offices Pre-export plant health inspection Amritsar

Central office Punjab State Seed Certification Authority Chandigarh

Laboratory visits

Official laboratories Punjab Agricultural University, Plant Pathology and Bacteriology Ludhiana

Central Potato Reserch Institute and Potato Gene Bank Shimla

Seed Testing Laboratory Station Jalandhar

Plant health control sites

Private potato seed production farm / packing, storage and dispatch station Jalandhar

Private ware potato production farm Patiala

Government potato seed production farm Kartarpur

Potato processing plant and private refuse dump receiving potato waste Sangrur

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3 LEGAL BASIS

The audit was carried out under the general provisions of Community Legislation, in particular Articles 21 and 27a of Council Directive 2000/29/EC and in agreement with DPPQS.

3.1 RELEVANT EU LEGISLATION

All EU legislation referred to in this report is listed in Annex I to this report. References to legislation are to the latest amended version, where applicable.

3.2 INTERNATIONAL STANDARDS

International Standards for Phytosanitary Measures (ISPMs) are issued by the International Plant Protection Convention (IPPC). The full text of the IPPC and all adopted ISPMs is available on the International Phytosanitary Portal (www.ippc.int) of the IPPC. Of these standards, which are recognised international benchmarks for phytosanitary control, those of particular relevance to this audit are listed in Annex II to this report.

4 BACKGROUND

This was the first audit carried out to evaluate the phytosanitary situation of potato production in the State of Punjab. The FVO had previously carried out one mission to India DG(SANCO)2010-8707 to evaluate the export certification system of plants and plant products.

The import into the EU of tubers of species of Solanum L. is prohibited under point 12 of Part A of Annex III to Council Directive 2000/29/EC. However, derogation from this prohibition is possible, in line with Article 15 of the same Directive, following a formal evaluation of the plant health risks for the EU. In 2008 the Department of Agriculture and Cooperation (DAC) requested such a derogation by the submission of a technical information dossier to the EU indicating that the agri-export zone of the State of Punjab is an area free from potato brown rot caused by Ralstonia solanacearum and potato ring rot caused by Clavibacter michiganensis ssp. sepedonicus (i.e. Pest Free Area, PFA). This information was discussed by the Standing Committee on Plant Health in November 2011, which recommended that the FVO carry out an audit in order to assess the situation on the spot.

Unless stated otherwise, all data in this report has been provided by the Indian National Plant Protection Organisation (NPPO).

5 FINDINGS AND CONCLUSIONS

5.1 ORGANISATIONAL ASPECTS

Legal requirementsArticle 2(1)(i) of Council Directive 2000/29/EC establishes the requirements for a measure or statement, to be considered as 'official'. In particular, '…if it is made by representatives of the official NPPO of a third country, or, under their responsibility, by other public officers who are technically qualified and duly authorised…'

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ISPM 7 describes the basic elements of the phytosanitary certification process and the requirements for a certification system to fulfil these functions. Sections 1 (Legal Authority), 2 (Management responsibility), 3 (Resources), 4.3 (Procedures), 5 (Communication) and 6 (Review mechanism) are of particular relevance.

ISPM 23 describes the objectives and requirements for inspections. Of particular relevance here, are sections 1.3 (Responsibility for inspection) and 1.4 (Requirements for inspectors).

5.1.1 Structure of the National Plant Protection Organisation and responsibilities

FindingsThe Directorate of Plant Protection Quarantine and Storage (DPPQS) of DAC of the Ministry of Agriculture fulfils the role of the NPPO. Since the last FVO mission to India, there were no significant changes in the structure and responsibilities of DPPQS which is the central authority responsible for coordinating all activities relating to imports and exports of commodities of plant origin. The DPPQS also determines the status of the country with regard to the presence or the absence of regulated harmful organisms.

At regional level the following authorities are also involved in plant health controls:

• The Directorates of Horticulture and Agriculture operating within the State of Punjab Department of Agriculture (PSDA) are responsible for potato crop production and crop protection.

• The Punjab State Seed Certification Authority (PSSCA) is responsible for providing certification of potato seed. Its main objective is to maintain, provide and make available to the public high quality seeds of notified varieties and ensure genetic identity.

• The Regional Service of Plant Protection Quarantine and Storage of the State of Punjab located in Amritsar is in charge of import controls and plant health export certification.

• The Department of Plant Pathology of the Punjab Agricultural University (PAU) Ludhiana, has been given overall responsibility for the monitoring and maintenance of the PFA status and for the future certification of lots for export.

PSDA has regional offices covering twenty districts and approximately 150 staff whose duties include inspection (Directorate of Horticulture) as well as extension and verification services (Directorate of Agriculture). The minimum educational requirement is Bachelor degree in agriculture or a related discipline.

The mission team noted that:

• The division of responsibilities amongst the authorities involved in plant health is clear;

• There is good cooperation and communication between the authorities involved in plant health inspections and export certification systems;

• There is adequate staff for the current control system and for carrying out the necessary field inspections.

Conclusions

There is a well established NPPO in India and a well structured regional plant protection service.

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Tasks and responsibilities are clearly defined between central and regional services in line with the relevant standards. The staff of the plant health services involved in plant health checks and official controls for exports are technically qualified.

5.1.2 National legislation

FindingsThe “Destructive Insects and Pests Act, 1914” (Act 2 of 1914) is the primary legislation for plant health issues. Its purpose is to prevent the introduction into India of harmful organisms as well as the movement of such organisms from one State to another. The Act is implemented by DPPQS through the Plant Quarantine Order of 2003 which is the main regulation covering import into India of plants and plant products. Pest Risk Analysis of agricultural commodities for import is mandatory to safeguard Indian agriculture from exotic pests. The “Seeds Act 1966” (Act No. 54 of 1966) and complementary legislation on seed and propagating material provide the terms and conditions for the import and movement of seeds and gives legal powers to inspectors to carry out field inspections and take samples.Following a study carried out by the PAU, the PSDA declared that all of Punjab is a PFA for ring rot and brown rot (Order No. 4/22/07-agri 4 (4)/7103 of 4 August 2008). The PSDA has also assigned roles and responsibilities for the maintenance of the designated PFA to the Directorate of Horticulture, the PAU and the State Supply Cooperative and Marketing Federation (MARKFED), which is the main stakeholders organisation in Punjab. The FVO team received a copy of the PSDA Order and noted that the legislation:• Gives the Directorate of Horticulture and the PAU legal powers to perform their duties for the maintenance of the PFA status;• Specifies registration and training requirements to be met by potato growers who would like to join the project;• Specifies the obligations to be met by MARKFED for the promotion of ware potato exports to the EU.ConclusionsThere is general and specific legislation in India, particularly for potatoes, which gives the plant health services the legal basis to carry out their tasks, in line with Section 2 of ISPM 7.

5.1.3 Delegation of official controls

Findings

A significant proportion of potato controls and monitoring surveillance for the establishment and maintenance of the designated PFA has been assigned to the Department of Plant Pathology of the PAU. In particular the PAU is responsible for the inspection of potato crops as well as for sampling and laboratory analysis of soil and domestically produced potato material. For this purpose the PAU is also requested to provide training to field staff of PSDA and MARKFED as well as to potato growers. Laboratory examinations of imported seed potato material have been assigned to the Central Potato Research Institute (CPRI).

The FVO team visited the PAU and met the management team of the Department of Plant Pathology where it was noted that:

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• PSDA has assigned PAU the responsibility for organising pre-harvest and post-harvest inspections and laboratory testing and tracing back cases where brown rot or ring rot are detected or intercepted;

• The Head of the Plant Pathology Department of PAU has been authorised by the Ministry of Agriculture to inspect export consignments and issue phytosanitary certificates in order to facilitate farmers to export their produce.

Funding of PAU activities for the establishment of the PFA is provided directly by MARKFED (see also chapter 5.1.7). However, PAU staff are effectively public servants and measures are in place to ensure that its staff are free from potential conflicts of interest.

Conclusions

Responsibility for carrying out checks before and during potatoes' growth, as well as laboratory analysis for the presence of brown rot has been delegated the Department of Plant Pathology of the PAU. This delegation is in line with ISPM 7 (Section 3, Resources), ISPM 23 (Section 1.4 Requirements for inspectors) and Article 2(1)(i) of Directive 2000/29/EC.

5.1.4 Laboratories and diagnostics

Findings

Punjab Agricultural University

The Plant Pathology Department of the PAU in Ludhiana, is the main unit which provides diagnostic support to plant health inspectors in the potato sector. Staff with levels of experience ranging from senior scientists to graduate and post-graduate students were taken from across the this department in order to work in brown rot surveillance. Although analysis of various types of material, mainly soil, plants and tubers is carried out for the establishment and the maintenance of the designated PFA, current bacteriological research focuses on Xanthomonas oryzae pv. oryzae and screening for the Citrus greening (BLO).

The FVO team visited the laboratory of the Plant Pathology Department and noted that improved testing methodology has been adopted in line with screening methods used in EU laboratories like isolation on selective SMSA medium as primary screen, with a polymerase chain reaction (PCR) test as secondary screen to identify any suspect isolates. However some discrepancies were observed in the procedures for sample preparation from potato tubers as provided in written protocols and discussions / demonstrations with laboratory staff. Standard operating procedures describing the whole testing process from potato tuber sampling to laboratory screening and laboratory confirmation of positive screening tests were not available. No internal quality procedures such as ring tests, blind samples and audits were in operation in the laboratory.

In addition the FVO team also noted that:

• The laboratory is equipped for PCR and isolation procedures but is not set up with sufficient containment to safely work with liquid waste, solid laboratory refuse or with live cultures of bacteria regarded as non-indigenous such as potato brown rot and potato ring rot;

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• For selective isolation tests and PCR methods, brown rot testing procedures have been adapted from published methods. A number of reagent sources have been changed from the published selective media. DNA extraction methods and PCR primers differ from the validated procedures used in EU laboratories. Moreover the methods adapted at PAU have not been validated before use, as there are no containment facilities to enable the use of infected plant materials or viable reference cultures for use as positive controls;

• A room which is used for incubation and storage of soil and tuber samples had not been specifically designed for this purpose and had not been equipped with measurement devices to allow for constant monitoring of the incubation parameters (i.e. the temperature and the humidity). At the time of the audit no tubers were incubated / stored awaiting analysis.

Central Potato Research Institute

The Central Potato Research Institute (CPRI) at Shimla, State of Himachal Pradesh together with its Central Potato Research Station at Jalandhar is the main source of pre-basic/basic material for production of certified seed in Punjab. CPRI participates in annual meetings with counterparts in universities and research institutes throughout India to monitor the current status of pests and pathogens. Annual diagnostic activities of the CRRI focus mostly on screening of all grown varieties grown for resistance on races of late blight.

The FVO team visited the laboratory facilities of the CPRI where it was noted that:

• CPRI has excellent facilities and competently trained staff. A well characterised reference collection of R. solanacearum isolates was set up in 2009 and is available for use as positive controls in the diagnostic tests. No such collection is yet available for C. michiganensis ssp. sepedonicus;

• Detailed standard operating procedures are available for the detection of brown rot and ring rot bacteria, which differ from those employed at PAU. A collection of relevant, commercially available antibodies and positive control materials is available for use in Enzyme Linked Immuno Sorbent Assay (ELISA) detection of all target pathogens.

Tests involve initial screening by ELISA followed by confirmation of positive screening using PCR. Similar tests are also available for all other potato quarantine pathogens for India.

The FVO team was also informed that:

• Although CPRI participates in EU and other international research projects on potato brown rot, no specific training has been provided to staff of PAU on detection methods for potato bacteria;

• The collaboration with the PAU for the establishment of the PFA in Punjab, was limited to providing general training to 2 PAU staff during the initial stages of the project. CPRI had an advisory role and no testing of samples for brown rot detection was carried out in its laboratory during the study for the PFA establishment.

Conclusions

There is only basic diagnostic support in the Plant Pathology Department of the PAU in Ludhiana

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with regard to analysis for the presence of potato brown rot and potato ring rot. The methods adopted for the detection of brown rot lack reliability as they have not been validated in line with internationally accepted sound scientific protocols. The procedures followed remain unclear and negative results obtained during screening tests may therefore be unreliable. Although CPRI could provide state-of-the-art diagnostic support and sound scientific knowledge for monitoring the status of pests and pathogens, its role in the establishment of the PFA was limited.

5.1.5 Guidelines and training

FindingsPlant health inspectors involved in import controls and export certification, attend training courses on the methodology of crop inspection and the detection of harmful organisms. These courses are organised regularly by the National Institute of Plant Health Management of DAC in Hyderabad. Special attention is paid to quarantine pests. Three months induction training is delivered to newly assigned officers, while training courses are also conducted for more experienced plant health inspectors. Specialised training courses for the identification of potato harmful organisms are organised by the PAU for the personnel of PSDA and PSSCA.

Inspectors have been issued with specific guidelines and technical instructions, helping them to carry out controls in the potato sector. A detailed presentation of potato diseases and insect pests including quarantine ones has been included in leaflets prepared by CPRI. MARKFED issued technical instruction leaflets describing methods and techniques of potato production addressed at growers. These contain additional information on a variety of harmful organisms affecting potatoes with detailed descriptions of symptoms including pictures.

During its visits the mission team noted that:

• Plant health inspectors met by the FVO team appeared to be competent and motivated in carrying out their tasks. They were well aware of the main insect pests and diseases of the potato crop and how to conduct on-the-spot examinations. However, staff were not familiar with the typical visual symptoms of potato brown rot;

• The method followed for the examination of tuber samples during the brown rot surveillance is restricted to an external visual examination. Sufficient numbers of tubers are not inspected and basic techniques like cutting are not employed. When surveying during grading and storage, out-graded potatoes are not included in sampling for the detection of brown rot.

Conclusions

Sufficient training on visual has been provided to staff for the recognition of specific signs and symptoms of the most important harmful organisms in Punjab. However it appears that staff are not adequately trained to look for and recognise suspicious visual symptoms of bacterial diseases like brown rot.

5.1.6 Work planning and evaluation

FindingsTo organise and plan the work a monthly meeting is organised in each of Punjab's 20 geographical regions. These meetings address crop protection issues and emerging plant health threats for all crops, including potato. A monthly meeting is also held at State level with the participation of district plant health officers, experts from research institutes and the PAU and representatives from PSSCA.

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During its visits the FVO team noted that:

• Working procedures and internal communication were well organised within the PSDA and all the relevant units;

• The local inspectors met during the mission had instructions and manuals to hand;

• There are good procedures for recording and reporting the controls carried out by inspectors at various levels of potato seed production;

• There is no auditing system in place and, apart from occasional documentary checks, the performance of the inspectors is neither evaluated nor verified.

ConclusionsThere is good technical communication between services and the relevant specialists. Work is planned during regular meetings. Plant health controls are well planned, executed and documented. However, the work of phytosanitary inspectors is not subject to regular internal and external evaluation, as required by Section 6 (Review mechanism) of ISPM 7.

5.1.7 Financial resources and contingency funding

FindingsThe financial resources of the PSDA are provided by the State budget. MARKFED provides funding, either directly or through the PSDA, to the Department of Plant Pathology of the PAU for the surveillance monitoring and maintenance of the PFA. Inspection fees are charged by PSSCA to seed potato growers for the inspection and certification of the crop. Fees are also paid by producers for inspection and issuance of phytosanitary certificates. Officials met by the FVO team stated that financial resources are sufficient to carry out any tasks related to controls of production and export.

ConclusionsThere is a clear system of financing of plant health services in Punjab. This is in line with Section 3 (Resources) of ISPM 7 and Article 2(1)(i) of Directive 2000/29/EC. Financial resources are not a major limiting factor for official controls in the potato sector.

5.1.8 Communication and consultation with stakeholders

Findings

Both DPPQS and PSDA cooperate with the Agricultural and Processed Food Products Export Development Authority (APEDA) which represents the interests of producers, traders and exporters and plays an important role in safeguarding traceability of crop produce from production field to export. The latter is also reinforced through private Good Agricultural Practice (GAP) certification schemes introduced by MARKFED (see also section 5.3).

Various means are used to inform stakeholders about crop protection in the potato sector. PSDA and MARKFED cooperate in providing information to potato producers and traders by means of booklets, leaflets and posters with a description of the symptoms of plant diseases and pests. In collaboration with the PSDA and PAU, there is direct consultation with representatives of stakeholders through regular meetings and forums which are organised for various cooperatives of potato seed producing farms and companies as well as agricultural export associations. Corrective

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actions to be taken are communicated to the major potato growers and stakeholders either directly through horticulture extension staff or mass media and IT communication systems.

Conclusions

There is good communication and consultation between PSDA and representatives of producers, stakeholders, exporting agencies and cooperatives involved in the potato sector. This is in line with Section 5 (Communication) of ISPM 7. Major producers and exporters of ware potatoes are well organised.

5.2 POTATO PRODUCTION AND TRADE

5.2.1 Potato production system

Findings

India is the third largest potato-producing nation and ranks fourth in the world for area cultivated with potatoes (1.83 million ha) totalling approximately 34.4 million tonnes with an average of 18.8 tonnes/ha. Statistical data on the leading potato growing States of India are indicated in Table 1 below. Agro-climate conditions favour winter potato production in most districts of the State of Punjab due to mild winter temperatures. Most of the area under potato is confined to Punjab plains and in particular to Jalandhar (19,000 ha), Hoshiarpur (16,400 ha), Kapurthala (7,000 ha), Bhatinda (6,000 ha), Moga (5,500 ha), Ludhiana (5,300 ha) and Amritsar (5,000 ha). Depending on the region and the variety, potatoes can be planted as early as mid-September to first fortnight of October. Harvest can take place from the end of January until mid-February, completing a growing period of 70-90 days in total.

Table 3 Leading potato growing States of India (data 2008-2009)

State Area(thousand ha)

Production (thousand tonnes)

Productivity (tonnes/ha)

Uttar Pradesh 527 10,810 20.5

West Bengal 383 4,090 10.7

Punjab 81 2,001 24.7

Gujarat 57 1,449 25.4

Bijar 310 5,034 16.2

Madhaya Pradesh 66 883 13.4

Assam 80 669 8.4

Karnataka 72 606 8.4

Haryana 23 490 21.3

In Punjab potato is cultivated in approximately 83,500 ha producing about 2 million tonnes of potato every year with an average productivity of 24.7 t/ha. Of the total potato production 60% is used as seed which covers its entire requirement for seed potato (about 0.3 million tonnes) and supplies other States in India (about 1.1 million tonnes) representing 20% of the national potato seed requirements. The rest is either consumed as ware (about 0.3 million tonnes) or is a surplus for trade and exports (about 0.4 million tonnes). There are approximately 490 cold storage facilities for potatoes. Owners receive government subsidies for their warehouses which can store some 1.6

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million tonnes of potato. The areas of production as well as the potato quantities produced are summarised in the Table 2 below.

Table 2 Areas (ha) and quantities in tonnes of potato crop in the State of Punjab

Year Seed (ha) Ware (ha) Total (ha) Fi&Fii (t) Certified (t) Total (t) TLS* (t) Ware (t) Total (t)

2009/10 48,208 34,909 83,117 1,672 2,348 4,020 1,223,562 888,938 2,116,520

2010/11 48,472 35,101 83,573 2,085 3,353 5,438 1,205,810 877,111 2,088,359

2011/12 48,720 35,280 84,000 2,094 4,168 6,262 1,211,348 881,718 2,099,328*Truthfully labelled seed (see also section 5.2.3)

Potato growers generally follow annual rotation schemes which include rice or maize, potato and sunflower or cucurbits. The PSDA does not provide compensation to seed or ware potato producers for losses resulting from adverse weather conditions or phytosanitary measures. The water used for irrigation is 95% “tube well” underground water the remaining 5% is surface water from canals. All potato crops are irrigated 6-7 times per growing period mainly by flood irrigation. Most potato varieties cultivated have been selected for their adaptability to the prevailing weather conditions in Punjab from September to January and their tolerance to late blight.

Seed is regularly renewed by the annual introduction of certified or Truthfully labelled seed (TLS, see also section 5.2.3). Harvest takes place manually as the potato production in Punjab is not highly mechanised. Tractor operating capacity ranges between 35-75hp; potatoes are frequently graded manually and packed in the field. The PSDA stated that agricultural contractors do not have major role in the potato production sector. All operations are carried out under the direct supervision of the farmers. Producers met by the audit team stated that there is no sharing of equipment between them. GAP - accredited producers met by the FVO team appeared to be well aware of plant health matters.

Conclusions

There is a well organised potato production system in Punjab. Agricultural practices implemented in Punjab like regular renewal of seed contribute to the maintenance of plant health status of potato crops. The irrigation predominantly with ground water presents little risk of introducing brown rot. However, flooding of the fields with water increases the potential for the spread of the bacterium, if it were introduced.

5.2.2 Imports and holding of Solanum genetic material

Findings

CPRI is the major potato breeder in India and responsible for the maintenance of a gene bank where approximately 3,900 genotypes and wild potato species are stored on behalf of the National Bureau of Plant Genetic Resources, New Delhi. With a total of 497 staff, CPRI carries out research for the development of new potato varieties and has participated in the project for cracking the genome sequence of potato. In addition, through its seven regional potato research stations and in collaboration with national and international partners, it provides training and extension services. Since 1958 CPRI has developed 48 potato varieties of which the most popular in Punjab are Kufri Chandramukhi, Kufri Pukhraj, Kufri Lauvkar, Kufri Jyoti, Kufri Bahar, Kufri Badshah, Kufri Pushkar, Kufri Sutlej Kufri Sindhuri and Kufri Chipsona.

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Export of Solanum material from the gene bank is only allowed only for research purposes and requires the signing of a Material Transfer Agreement approved by Indian Council of Agricultural Research (ICAR). Solanum material sourced outside India, requires permission from Department of Agricultural Research and Education. For in-vitro material a six months quarantine period involving testing for viruses, diseases and other harmful organisms in the premises of CPRI is required. The range of harmful organisms tested for corresponds to a large extent to those tested for when similar material is imported into the EU. The relevant quarantine period required for potato tubers is two years but recently such imports are limited due to increased costs for storage under quarantine conditions. The same restrictions apply to private companies importing potato germplasm for trial or scientific purposes. Accreditation of the laboratory and quarantine facilities of these companies should be carried out by the DPPQS/DAC and the Department of Biotechnology (DBT).

Conclusions

The conditions for holding and release of Solanum genetic material are in line with international standards and quarantine periods are imposed to material imported into India for scientific purposes.

5.2.3 Seed multiplication and certification

Findings

CPRI and its regional potato research stations play a major role in the development of new varieties and the multiplication of pre-basic material. The end product is fully traceable breeders grade potato seed with approximately 3000 tonnes produced p.a. Of the multiplication methods used seed production through micro propagation and tissue culture techniques constitutes 10-15% of the produced pre-basic material, the rest is produced by traditional clonal selection. CPRI has also developed minituber and aeroponic techniques, as well as new methods of micro-propagation.

Production of certified seed

In Punjab domestic certified seed is used in only 1% of the areas cultivated for the production of ware potatoes. The remaining 99% is covered by using TLS produced exclusively by private seed producers or by farm saved seed. Production of certified seed involves the multiplication of breeder seed at Government potato seed farms or at farms of registered producers. In principle, breeder seed accompanied with a certificate and an appropriate tag is purchased from authorised seed producing institutions such as research farms of the ICAR, Agricultural Universities, Government Potato Seed Farms, National Seed Corporations or private growers and multiplied to the foundation (i.e. Fi and Fii) and certified stages. The area of production and the number of certified seed, TLS and ware potato producers are summarised in the Table 3 below.

The “Seed plot technique” used for seed production is based on the treatment of the seed with boric acid prior to sowing in high density (15x50 cm) rows and intense roguing of symptomatic/infested plants, plants showing undesirable varietal characteristics and volunteer plants. In principle cutting of potato haulms takes place during the winter prior to the increase of aphid populations which is estimated according to historic data and field observations (scouting). Depending on the place of production, potato seed in Punjab is also classified as “hill seed” (altitude of 2,500m or more) and “plain seed” (areas where aphid populations remain low in a “window” during the winter crop growing season).

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Table 3 Number and size of potato production units in the State of Punjab

Areaplanted (ha)

Certified seed (Govt. farms)

Total area(ha)

Certified seed(Private farms)

Total area(ha)

Non-certified TLS & ware

Total area(ha)

< 1 0 0 43 49 1,000 604

1 - 5 2 20 52 101 25,000 50,000

5 - 20 6 40 3 51 2,000 30,140

20 - 50 2 120 3 75 300 2,000

> 50 0 0 0 0 15 1,000

Total 10 180 101 256 28,315 83,564

The PSSCA is one of 20 seed certification agencies operating in India which regulate seed quality. In compliance with the “Indian minimum seed certification standards for potato”, PSSCA carries out inspections of propagating material prior to planting and at different stages during crop growth. During these inspections documentary, identity and plant health checks are carried out prior to harvest. The issuance of a potato seed certificate is accompanied by certification tags to be enclosed in or attached to the packaging material. PSSCA also has an advisory and extension role and makes suggestions for corrective action to be taken by farmers on a case-by-case basis.

The FVO team visited the premises of the PSSCA in Chandigarh and noted that fully documented procedures are in place for checks to be carried out before, during and after planting. These involve documentary, identity and plant health checks of the seed to be planted. Four inspections of the crop take place: 45 and 60 days after planting, during haulm cutting and 10 days after haulm cutting, in order to verify that certain crop standards have been respected and cultivation / crop protection measures have been applied. In all cases an inspection report document is issued along with a number of tags. A sample of 400 tubers per lot is taken from the Fi and Fii stages for post-harvest virus testing.

The FVO team examined relevant documentation including certificates issued after field inspections where it was noted that:

• The “Indian minimum seed certification standards for potato” which are also implemented in Punjab provide for zero tolerance for brown rot in foundation generations (i.e. Fi and Fii). However for the production of certified seed in areas known to be infested with brown rot, seed can still be eligible for certification with a brown rot occurrence of 3 plants/ha; in case of brown rot suspicion, neighbouring plants and their tubers have to be rogued out;

• Legislation in place regulates the movement of seed potatoes into Punjab from other States. However no controls regarding the effectiveness of this measure are implemented;

• No sampling programme for brown rot testing is implemented at any stage in the seed multiplication chain for certified seed; the visual inspection carried out during seed certification does not involve cutting sufficient quantities of tubers for the purpose of verifying freedom from brown rot.

Production of truthfully labelled seed

TLS originates from stocks of certified seed which have been grown using the seed plot technique

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for up to four growing periods and stored for 6-7 months during the warm season under refrigerated conditions. An internal inspection system similar to that applied for the production of certified seed is expected to be in place to check that varietal characteristics and appropriate hygiene conditions of the produced TLS are kept. However, there is no official or other external verification of the TLS production.

The FVO team visited the warehouses and a farm of a company producing TLS and ware potatoes under the GAP certification scheme. Of the 1000 ha grown in total, 10-12 ha were used each year to produce certified seed. The company also had its own micro propagation facility. Advanced grading and packing machinery was used. An internal marking system was also in place allowing some tracing back and forward at farm level. Cutting of oversized tubers for the production of TLS is not applied as this is not in compliance with working protocols. The owner confirmed that PSSCA regularly carries out all the necessary inspections for the production of certified seed, from the foundation Fi and Fii generations to the final product. At the end of each production cycle of foundation stages sampling is carried out by the PSSCA for post-harvest virus testing.

• However the FVO team during its visit also noted that the source of the seed used for the production of TLS and ware potatoes is not adequately documented. Documentation presented during the visits would not allow for easy tracing back and forward following a potential occurrence of a brown rot incident.

Conclusions

The potato seed production system in Punjab is based on a relatively small amount of officially certified seed which is then multiplied and marketed as TLS. The shortcomings observed relate to the existence of a tolerance for the presence of brown rot and the lack of traceability involving TLS stages and grades. The latter is not subject to any official control or laboratory testing for monitoring and verification purposes.

5.2.4 Production methods of ware potatoes

Findings

Figures of ware potato production data are provided in sections 5.2.1 and 5.2.3. As already mentioned the vast majority of the ware potato production area is planted with TLS which is used for 3 to 4 growing periods whereas only 1% is planted with certified seed.

The FVO team visited a farmer producing ware potatoes of the variety Kufri Pukhraj for sale in the local market. From the 12 ha cultivated in total, approximately two were set aside for the production of farm saved seed to be cold stored in rented storage and used in the next growing period. The need for potato seed was covered either by certified “Government grade” seed or by TLS purchased from producers assuring that they were sourcing certified seed of “Government grade” quality. The farmer was using his own machinery and “tube-well” water. Farmyard manure was applied every 3-4 years to improve soil structure and quality. The potato crop had been recently severely damaged due to heavy rainfall which resulted in increased rotting of tubers probably caused by late blight.

• The FVO team noted that non-registered ware potato producing farms are not visited by the PSDA for inspection or advice. Extension services are usually provided by commercial agents of plant protection products.

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Conclusions

A large proportion of the ware potatoes in Punjab is produced by numerous small farmers who are not regularly visited by Government control or advisory bodies.

5.3 REGISTRATION OF STAKEHOLDERS AND TRACEABILITY OF CONSIGNMENTS

Legal requirements

Section 4.5 of ISPM 7 establishes that consignments and their certification should be traceable as appropriate through all stages of production, handling and transport to the point of exit.

Findings

Registration of certified seed potato growers and the fields of certified seed production is carried out through the PSSCA provided that specific rules are respected and conditions for the production of certified seed are fulfilled (see also section 5.3.4 production of seed potatoes). For registration producers need to complete an application form indicating the grade of seed to be produced and provide complementary documents and certificates, e.g. invoices of seed purchase, monitoring reports and labelling tags, indicating the source, the lot, and the grade of the seed to be used. The growers are checked for compliance with the guidelines of PSSCA regarding potato seed production. Registration and follow up inspection fees have to be paid. Potato producers are also required to be registered under Agricultural Produce Market Committee Act in order to get reasonable prices for their produce.

The intention of the authorities is to link any future potato export to the EU with the GAP certification scheme. As no potato exports are allowed to the EU there are few farmers participating in the GAP certification scheme so far. MARKFED has registered 242 potato producers and has enabled them to obtain GAP certification, ensuring quality production and traceability and provided them with a GAP certification code number. In compliance with a national coding system developed by APEDA, a 15-digit identification code is provided to farmers as well as labelling of the final product. Guidelines for the potato growers and guidelines for internal inspection and auditing are in place. A checklist of control points and compliance criteria for potato production has been elaborated. This includes record keeping, health and safety of workers, waste and pollution management, safe use of fertilisers and plant protection products, integrated pest management and sustainable use of water resources, final product traceability. Currently there is no obligation by the GAP certification scheme to indicate the source/origin of potato seed used for plant health traceability purposes.

During its visits the FVO team noted that:

• There is no legal obligation for farmers producing exclusively TLS to be registered with the PSSCA. Although TLS represents 99% of the marketed seed used for the production of ware potatoes no official control or certification scheme is involved;

• Marketed TLS is accompanied by a commercial label indicating the name of producer or the company trading the seed. However, there is no indication of lot number which could facilitate tracing back and forward to identify the field where the seed was produced;

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• There are no registration requirements for plant health purposes for ware potato producers or traders. Ware potatoes circulated in the domestic market are not labelled. The same applies to ware potatoes which circulate in Punjab from other States in India.

Conclusions

The vast majority of seed and ware potato producers are not registered. Labelling of ware potatoes is not required. Although traceability may be possible using trade documentation, this does not ensure that potatoes can be traced back to the place of production. The absence of control mechanisms for the movements of material from other regions does not exclude the possibility of introduction of potentially contaminated material into the State of Punjab (see also section 5.6).

5.4 PHYTOSANITARY STATUS OF POTATO HARMFUL ORGANISMS IN INDIA AND THE STATE OF PUNJAB

Legal requirements

Annex I, Part A, to Council Directive 2000/29/EC lists those harmful organisms whose introduction and spread within the Community is banned.

In addition, Annex IV, Part A, Section I, Point 25.1 to 25.3, 25.4.1 and 25.4.2 of Directive 2000/29/EC lays down special requirements that must be met by exporting countries when exporting ware potatoes to the EU. This requirements concern such harmful organisms as: Clavibacter michiganensis ssp. sepedonicus, Meloidogyne chitwoodi, Meloidogyne fallax, Globodera pallida, Globodera rostochiensis, Potato spindle tuber viroid, Potato stolbur mycoplasm, Scrobipalpopsis solanivora and Synchytrium endobioticum.

ISPM 4 details the requirements for the establishment of PFAs. In particular, Section 1.2 includes the three components in establishing and maintaining a PFA: 'systems to establish freedom (surveys and general surveillance), phytosanitary measures to maintain freedom, and checks to verify freedom has been maintained'. Section 2.3 details the requirements for the establishment and maintaining a specific type of the PFAs, which is 'an uninfested part of a country situated within a generally infested area'.

ISPM 6 establishes guidelines for surveillance. In particular Section 2 of ISPM 6 specifies elements which should be considered when establishing the survey plan; these elements include, amongst others, identification of the target pest and timing, indication of statistical basis (such as number of samples; selection and number of sites; frequency of sampling), and description of survey methodology. Section 2.1 specifically relates to pests which are only likely to be present as a result of recent introduction; in such cases the selection of suitable survey sites may relate to points of possible entry, possible pathways of spread, sites where imported commodities are used as planting material, etc. Section 2.3 provides that the survey plan should include random sampling to detect unexpected events.

ISPM 8 describes the use of pest records and other information in the determination of pest status in an area. It also provides that exporting countries need pest status information to comply with import regulations of the importing country.

Findings

Table 4 provides information on the status of harmful organisms relevant to potatoes in India and

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the State of Punjab. The table is based on a compilation of lists provided by CPRI and PAU and where indicated on information from European Plant Protection Organisation Plant Quarantine Data Retrieval System (EPPO-PQR).

Table 4 Status of harmful organisms of potatoes in India and the State of Punjab

Harmful organism Status

India Punjab

Agrotis flammatra E D

Agrotis ipsilon D D

Agrotis segetum D D

Agrotis spinnifera E D

Alebroides nigroscutulatus E A

Alternaria alternata D A

Alternaria solani D D

Amrasca biguttula biguttula E D

Amrasca devastans E D

Andean potato latent virus* + A A

Andean potato mottle virus* + A A

Aphis fabae E D

Aphis gossypii D D

Arracacha virus B, oca strain* + A A

Bacillus megatherium E A

Bacillus polymyxa E A

Bacillus subtilis E A

Bemisia tabaci D D

Brahmina coriacea E A

Brahmina longipennis E A

Cercospora solani E E

Clavibacter michiganensis spp. sepedonicus* + A A

Ditylenchus destructor* + A A

Ditylenchus dipsaci + A A

Empoasca fabae E D

Epilachna ocellata E E

Epilachna vigintioctopunctata E E

Epitrix sp.* + A A

Erwinia carotovora spp. atroseptica E E

Erwinia carotovora spp. carotovora D A

Fusarium acuminatum E A

Fusarium coreruleum E A

Fusarium eumartii E A

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Fusarium oxysporum E E

Fusarium oxysporum f.sp. tuberose E E

Fusarium semitectum E A

Fusarium solani E E

Fusarium solani f.sp. eumartii E A

Globodera pallida* + E A

Globodera rostochiensis* + E A

Helicoverpa armigera E A

Helminthosporium atrovirens E A

Leptinotarsa decemlineata * + A A

Macrophomina phaseolina E E

Marginal flavescence phytoplasma (MF) E A

Meloidogyne chitwoodi* + A A

Meloidogyne fallax* + A A

Meloidogyne incognita E A

Meloidogyne javanica E A

Myzus persicae D D

Nacobbus aberrans* + A A

Phoma andina* + A A

Phoma exigua + E A

Phoma sorghina D A

Phtorimaea operculella D A

Phytophthora erythroseptica E A

Phytophthora infestans D D

Polyphagotarsonemus latus E A

Potato apical leaf curl virus (PALCV) E A

Potato aucuba mosaic virus (PAMV) E A

Potato black ringspot virus* + A A

Potato deforming mosaic virus (PDMV) + A A

Potato leaf roll virus (PLRV) * D D

Potato phyllody (PP) E A

Potato spindle tuber viroid (PSTVd)* + F (1) A

Potato purple-top wilt and stolbur phytoplasma* + A A

Potato virus A (PVA)* D E

Potato virus M (PVM)* D E

Potato virus S (PVS)* D E

Potato virus T (PVT)* + A A

Potato virus V (PVV)* + A A

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Potato virus X (PVX)* D D

Potato virus Y (PVY including Yo, Yn and Yc)* D D

Potato yellow dwarf virus (PYDV) + A A

Potato yellow vein virus (PYVV) + A A

Premnotrypes spp.* + A A

Pseudomonas marginalis E A

Psylloides spp. E A

Purple top roll phytoplasma (PTR) E A

Ralstonia solanacearum * D B

Rhizoctonia solani D D

Rhopalosiphum rufiabdominalis E D

Sclerotium rolfsii E A

Scrobipalpopsis (=Tecia) solanivora* + A A

Septoria lycopersici var. malagutii* + A A

Spilosoma obliqua E A

Spodoptera litura E E

Spongospora subterranea E A

Stem necrosis (Ground nut bud necrosis virus) E A

Streptomyces spp. D D

Synchytrium endobioticum* + E A

Tetranychus urticae E A

Thecaphora solani* + A A

Tobacco ringspot virus (TRSV) * + E (1) A

Tobacco streak virus potato strain (TSVP) + E (1) A

Tomato spotted wilt virus (TSWV) * + E (1) A

Trialeurodes vaporariorum E A

Verticillium alboatrum E A

Witches' broom phytoplasma (WB) E A

Table Key: *= Harmful organism listed in the EU legislation+= Quarantine harmful organism for India(1)= Present in India according to EPPO PQRA = Absent, no reportsB = Absent, confirmed by surveyD = major importanceE = minor importance and incidental report

5.4.1 Establishment and maintenance of Punjab as a PFA for ring rot and brown rot

The Department of Plant Pathology of PAU carried out a study to prove the absence of the bacteria causing potato ring rot and potato brown rot from Punjab and to facilitate the export of potatoes from the designated agri-export potato growing districts of Punjab to the EU. The study was based on carrying out three different types of surveillance in different blocks of the agri-export zone of

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Punjab all selected and sampled at random: (a) a pre-cropping soil examination and laboratory analysis of 10% of the fields used for potato growing (b) a visual inspection of potato plants grown in 20% of the fields and (c) a visual inspection of 30% of tuber lots harvested in blocks of the same agri-export zone. Tubers were mostly visually inspected without being cut; where this was done it was only where oozing symptoms appeared during visual inspection and then samples of 200 tubers were also sent for laboratory analysis. Table 5 indicates the numbers of samples taken from the agri-export zone in Punjab during the two 2005-06 and 2006-07 successive growing periods. No positive ring rot or brown rot samples were detected. Following the results of this study the PSDA established Punjab as PFA for brown rot and ring rot.

Table 5. Number of soil and tuber samples taken from the agri-export zone for brown rot detection

No of farms visited

No of soil samples analysed

Visual inspection Laboratory analysis

No of tuber lots (field)

No of tuber lots (warehouse)

No of tuber lots (field)

No of tuber lots (warehouse)

2005-06 1,556 6,551 1,877 3,108 378 150

2006-07 1,580 6,506 2,343 3,910 336 180

Average 1,568 6,529 2,110 3,509 357 165

The FVO team visited the Plant Pathology Department in PAU and noted that substantial effort has been made to establish the PFA through soil sample analysis during 2005-06 and 2006-07 growing periods in accordance with the ISPM 4. No monitoring took place during the 2007-08 growing period. Further surveillance also took place during the 2008-09, 2009-10 and 2010-11 periods for the maintenance of the PFA based on the same inspection approach and sampling methods, but without the soil sampling. No positive ring rot or brown rot samples were detected. The numbers of samples taken from the agri-export zone in Punjab during these period are indicated in table 6.

Table 6. Number of plant and tuber samples taken from the agri-export zone for brown rot detection

Visual inspection of tuber samples

Laboratory analysis

Plant samples Tuber samples

2008-09 1,227 516 319

2009-10 2,275 204 153

2010-11 405 220 170

Average 1,302 313 214

However the FVO team also noted that:

• No laboratory testing for ring rot has been conducted. To a large extent the studies carried out in the PAU were based to the general assumption that ring rot and brown rot cannot survive under the ecological conditions of Punjab;

• Although considerable effort has been made by analysing soil samples, this method is unreliable for determination of the absence of the brown rot bacterium due to (a) sampling limitations, (b) inhibitory competition effects with common soil-borne bacteria on the isolation medium and (c) the fact that the bacterium is unlikely to survive in the upper 5-10 cm of layer sampled due to the effects of increased soil temperatures during the summer;

• In addition, sample storage conditions observed in the PAU do not safeguard the viability of

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the bacterium in a potentially contaminated soil sample overall leading to a possibly false conclusion that the disease is absent;

• Sampling and testing of potato plants from the growing crop has been conducted to a very limited extent (approximately 310 plants in total);

• The number of potato crops from which tuber samples were collected and tested in each season was relatively low representing an average of 390 ha/sample of the total areas with potato crops. The number of growers visited (approx. 1570) for the establishment of the PFA represents 5.5% of the approximately 28,300 potato growers in Punjab;

• Potato producing farms were randomly selected for sampling in the first year of the studies carried out for the establishment of the PFA. However, subsequent sampling targeted the same farms and only in few cases material from different farms was inspected / analysed;

• There are no records of the types of potato crops sampled in terms of whether they were grown as seed or ware and whether they were produced from certified, truthfully-labelled or farm-saved seed. It is therefore not possible to determine whether any of the potato crops at highest risk from potential brown rot infections had been targeted in the surveillance work;

• Surface water sources or potential weed hosts like Solanum dulcamara or other perennial weeds growing in contact with such water, have not been tested for presence of the brown rot bacterium, despite the fact that in Punjab potato crops are also irrigated from such sources.

ConclusionsSubstantial efforts have been made to establish Punjab as a PFA for brown rot and ring rot. All results are negative for the presence of the bacteria. However, a number of shortcomings were noted in the implementation of the surveillance project. Soil testing and visual inspection of tubers without being cut do not qualify for safe conclusions about the absence of the bacteria; laboratory analysis of plants and tubers took place only occasionally and according to non verified analytic protocols. No surface water or wild Solanaceous hosts were included in the survey carried out for brown rot, which is widespread in other States in India including those neighbouring Punjab. In addition, although potato ring rot has not previously been reported in India, its absence from an area claimed to be “pest free” remains unproven as no laboratory testing has been conducted.

5.4.2 Other harmful organisms of potatoes

The NPPO informed the FVO team that the stated presence of Synchytrium endobioticum is restricted to the Darjeeling District of the State of West Bengal and the State of Sikkim. An official notification of DAC banned the movement of potatoes from Darjeeling to other States or places of India in 1997. Similarly the distribution of Globodera pallida and G. rostochiensis is limited to the States of Kerala and Tamil Nadu; these species are also subject to quarantine measures.

The nematology department of PAU has carried out diagnostic tests for the identification of plant parasitic nematodes found in fields where potatoes are also grown. Analysis of soil samples revealed that the species most commonly found are: Tylenchorhynchus persicus, Meloidogyne incognita, Pratylenchus pratensis, Helicotylenchus dihystera, Hopolaimus indicus, Xiphinema insigne, Basirolaimus sp. and Hirschmanniella oryzae. All Hirschmanniella spp. other than Hirschmanniella gracilis are not known to occur in the EU and are listed in Directive 2000/29/EC. Hirschmanniella oryzae in the EU appears to occur only in Portugal.

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ConclusionsThere are records of harmful organisms listed in Annex I Part A Sections I and II or Annex II Part A Section II to Directive 200/29/EC which have a limited distribution in India or being under official control. In general, these organisms do not appear to be present or have never been recorded in Punjab. However non-European isolates of viruses which are also commonly found in the EU, may still constitute a potential plant health risk. The potential risk of introducing non-EU-listed harmful organisms which are present in India/Punjab still needs to be addressed.

5.5 PROCESSORS, PACKERS AND CONTROL OF WASTE

Legal requirements

Section 2.3 of ISPM 4 provides that for the uninfested part of a country situated within a generally infested area, requirements for the establishment of PFAs should include checks and ongoing monitoring surveys to verify that freedom has been maintained.

Findings

There is no specific plant health legislation on the control of waste from potato processing and no controls or sampling are carried out for plant health purposes in establishments operating in Punjab. Environmental and planning legislation requires that sewage treatment must be included in the planning process of industrial facilities. All processing units have to operate with the consent of the Punjab Pollution Control Board which imposes the conditions for waste handling on a case-by-case basis and carries out monitoring checks for compliance.

The FVO team visited the processing plant and the storage facilities of a company producing potato crisps. The company collaborates on a contract basis with approximately 260 potato growers and provides extension services through a network of agronomists. Depending on availability, potatoes for processing are largely sourced in Punjab (80% December – April) or in Uttar Pradesh and Maharashtra (20% September - November). Prior to storage, potatoes are size-graded and checked for quality and sugar content. Rejected undersized potatoes (8-10%) are returned to farmers or, in case of potatoes coming from other States, sold to the local market for ware consumption.

Raw potato waste such as peelings are composted together with soil sludge (approximately 180 tonnes/month) in a nearby landfill for 90 days prior to being given to farmers for use as compost. Potato slices and fine pieces which are not suitable for processing, are used as fresh feed for fish reared in nearby sweet water fish farms. Used water (approximately 300 m3/day) receive a treatment for compliance with environmental criteria and is then used to irrigate an area where Eucalyptus trees are grown.

During its visit to the processing plant the FVO team noted that:

• There were no measures in place against the introduction of possibly contaminated material from brown rot infested areas into Punjab through potatoes for processing;

• There were no measures in place against the spread of brown rot by treating potato processing waste. Instead this material is spread in nearby farms of the area or in water reservoirs; no samples are taken either from solid or liquid waste after processing for brown rot detection.

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• The waste water treatment is not efficient for eliminating potato brown rot.

Conclusions

A potential risk occurs where processing of ware potatoes imported from other States in India takes place and no controls for testing of solid waste or waste water have ever been carried out. Although the handling of waste is considered as part of the planning process for potato processing facilities, there is no specific legislation in place related to its safe disposal. Uncontrolled use of solid potato residues and waste water for other purposes consist a pathway for the introduction of potato brown rot to an area claimed to be free from brown rot.

5.6 CONTROLS OF POTATO IMPORTS AND INTERNAL MOVEMENT

Legal requirements

Section 2.3 of ISPM 4 provides that for the uninfested part of a country situated within a generally infested area requirements for the establishment of PFAs, should include phytosanitary measures including the regulation of the movement of host material out of the infested area to the uninfested area to prevent the spread of the pest.

Findings

No potatoes, ware or seed, are allowed to be imported into India from South America. Legislation in place regulates the movement of potatoes into India from non-South American countries providing for a two year quarantine period. True seed/microtubers (in vitro) of potato tissue culture are also subject to plant quarantine regulations (see also section 5.2.2.).

The movement of potato seed from other regions of India into Punjab is prohibited except after official certification as disease-free (Order of 4 August 2008). However no controls are carried out to check the effectiveness of this measure in practice. Ware potatoes can also be moved into Punjab from other States of India for processing or for other purposes where local ware potato stocks are not available; such movement is taking place, as described in section 5.5 above.

Conclusions

The import of potatoes into India is regulated. Restrictions are also in place for the movement of potato seed into Punjab from other regions of India and the large amounts of seed produced there suppress such commercial interests, but there are no controls in place to verify that restrictions are respected. There are no movement restrictions or labelling requirements of marketed ware potatoes and these may constitute a pathway for introduction of brown rot and other pests and diseases, either by being planted or by other means such as mentioned in Chapter 5.5.

5.7 CONTROLS FOR POTATO EXPORTS AND ISSUANCE OF PHYTOSANITARY CERTIFICATES

Legal requirements

Annex I, Part A, Sections I and II and Annex II Part A Sections I and II to Council Directive 2000/29/EC list those harmful organisms whose introduction and movement within the EU is banned.

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Points 25.1 to 25.3, 25.4.1 and 25.4.2 of Annex IV, Part A, Section I to Directive 2000/29/EC establish other specific requirements, with respect to other harmful organisms relevant for potatoes, which must be met in order for ware potatoes to be exported to the EU.

Section 4.5 of ISPM 7 establishes that consignments and their certification should be traceable as appropriate through all stages of production, handling and transport to the point of exit.

Section 3.4. of ISPM 7 provides that the NPPO should ensure that adequate equipment and facilities are available to carry out inspection, testing, consignment verification and phytosanitary certification procedures.

ISPM 23 establishes guidelines for inspection.

ISPM 31 establishes methodologies for sampling of consignments.

ISPM 12 establishes requirements for phytosanitary certificates.

Findings

Seed potatoes from India are exported mainly destined to Sri Lanka and Middle East while ware potatoes are exported mainly to Pakistan and Nepal. Table 7 indicates statistic data on seed and ware potato exports from India for the last three growing periods.

Table 7. Indian potato exports (tonnes)

Seed Ware

2008-09 11,299 184,872

2009-10 2,306 94,086

2010-11 8,899 184,195

Average 7,501 154,384

DPPQS has mandated a list of officers of Plant Quarantine Stations across the country and other central/State government agencies as eligible to carry out pre-export inspections and issue phytosanitary certificates. Farmers interested in exporting potatoes should be registered with MARKFED for tracing back purposes and to meet the export standards applied under GAP certification scheme. Each consignment for export must be accompanied by a sales invoice issued by the suppliers along with appropriate labelling and transport documents from the place of production to the point of export. Mixed consignments bear tags with producers' specific ID codes.

The FVO team noted that inspections carried out prior to export are based on standard operating procedures and export certification is facilitated by adequate IT support at the point of exit. In general, upon suspicion and/or detection of pest presence during a pre- export check the consignment is subjected to treatment. If this is not feasible, the infested lot is rejected and no phytosanitary certificate is issued.

However the FVO team also noted that:

• There is no handbook or guidance on the specific requirements of possible recipient countries. Pre-export certification procedures are based on information which is provided by traders / stakeholders and not from official information provided by the competent authorities of importing countries;

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• Phytosanitary certificates are currently issued according to checks which are carried out prior to export at the point of export. There are no provisions covering requirements of plant health inspections that have to be carried out at the place of production. The mechanism ensuring that such requirements are met safeguarding the phytosanitary integrity of the consignment still have to be worked out.

ConclusionsThe NPPO has the sole authority for control and issuance of phytosanitary certificates. It can also prevent the export of consignments which do not meet the requirements of the importing country. In general there are quite clear procedures for export controls. However, the current phytosanitary inspection regime is based on checks carried out exclusively at the points of export and does not provide the necessary means to safeguard the phytosanitary integrity of consignments covered by checks which may have been carried out at the place of production. The details of ensuring official control from the place of production to the point of exit have not yet been finalised.

6 OVERALL CONCLUSIONS

A well-structured phytosanitary organisation system operates in Punjab. Tasks and responsibilities in the plant protection service are well defined between the central and the regional services. There are no staffing problems and a good technical communication between the services is achieved with adequate work planning and regular meetings. There are well documented work procedures for sampling and testing for the production of potato seed as well as for inspections to be carried out prior to export. However, brown rot is not handled as a quarantine harmful organism and staff are not familiar with potato crop symptoms to look out for, during visual inspections.

For the establishment of a brown rot free area emphasis was given to a large programme of soil testing, which is not appropriate for detection purposes. The main laboratory which was involved in this project is not equipped with necessary analytic and containment facilities and the protocol followed for the detection of brown rot could not be verified. The number of tuber samples taken for the establishment of the PFA was very small of which the majority were inspected without cutting. Analysis of tuber samples for the detection of brown rot took place only occasionally and according to a non verified laboratory protocol. No surveys were carried out of surface water or wild hosts for the bacterium. No laboratory testing has been conducted to verify the absence of Clavibacter michiganensis ssp. sepedonicus.

The vast majority of marketed seed is not subject to official control as producers and traders are not registered and the current labelling system does not allow for tracing back and forward actions to take place. Although legislation in place regulates movement of seed potatoes into Punjab from other regions, no controls regarding the effectiveness of the measure are implemented in practice; ware potato movement from other States of India where brown rot is present is not controlled. Composted solid waste from potato processing plants handling non-Punjab potatoes is used by farmers without being treated and untreated waste water is used for irrigation.

Organisation of selected farmers for potato export to the EU has been initiated to ensure that only potatoes under the required official control are exported.

Overall, Punjab currently cannot provide adequate guarantees for safe export of ware potatoes to the EU. There are structures in place for rectifying actions to be taken and the authorities expressed determination to meet requirements. Uncertainty regarding a number of exotic potato organisms occurring in India remains. The phytosanitary risk of these harmful organisms for the EU and the risk of them being introduced and spread by potato trade still need to be evaluated.

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7 CLOSING MEETING

A closing meeting with the representatives of the NPPO and PSDA was held on 3 February 2012 in Chandigarh. At this meeting, main findings and preliminary conclusions of the audit were presented by the audit team. During the meeting, additional information requested by the audit team was provided by the CA. The NPPO provisionally accepted the findings and conclusions and indicated a commitment to make improvements on the potato production and certification system.

8 RECOMMENDATIONS

The Competent Authorities in India are recommended to:

N°. Recommendation

1. Ensure that appropriate guidance and documentation with technical instructions are provided along with sufficient training to plant health inspectors for the recognition of suspicious symptoms of potato bacterial diseases through visual inspection and that work carried out by phytosanitary inspectors is subject to regular internal and external evaluation according to ISPM 7 requirements.

2. Ensure that adequate laboratory facilities will allow for safe conclusions to be drawn with regards to the presence or absence of potato bacteria; in particular that materials and methods adopted are validated in line with internationally accepted sound scientific protocols and the procedures described in Directive 93/85/EEC and Directive 98/57/EEC.

3. Increase substantially the number of tuber samples tested for especially brown rot, but also for ring rot. The sampling should include all segments of the production including certified seed, truthfully labelled seed and small holder ware potato production to ensure adequate delimiting and detection surveys as referred to in point 2.3.1 of ISPM 4.

4. Include in the ongoing brown rot surveys monitoring of surface water bodies in particular those used for irrigation and of wild hosts growing in proximity of these. Checking of waste water from potato processing plants should also be required to verify that freedom from brown rot has been maintained as referred to in point 2.3.3 of ISPM 4.

5. Carry out controls to verify that movement requirements in place for the introduction of seed potatoes from other States of India into Punjab are respected and freedom from brown rot is maintained as referred to in point 2.3.2 of ISPM 4.

6. Address the risk of brown rot introduction by the movement of ware potatoes from other States in India into Punjab and adopt phytosanitary regulations in order to maintain freedom and prevent spread of brown rot, as referred to in point 2.3.2 of

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N°. Recommendation

ISPM 4.

7. Ensure that an effective traceability system will be established through the registration of potato producers and adequate labelling of potatoes in order to allow tracing back and forward actions to take place for potato lots exported from Punjab as referred to in point 4.5 of ISPM 7.

The competent authority's response to the recommendations can be found at:

http://ec.europa.eu/food/fvo/rep_details_en.cfm?rep_inspection_ref=2012-6311

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ANNEX 1 - LEGAL REFERENCES

Legal Reference Official Journal Title

Dir. 2000/29/EC OJ L 169, 10.7.2000, p. 1-112

Council Directive 2000/29/EC of 8 May 2000 on protective measures against the introduction into the Community of organisms harmful to plants or plant products and against their spread within the Community

Dir. 93/85/EEC OJ L 259, 18.10.1993, p. 1-25

Council Directive 93/85/EEC of 4 October 1993 on the control of potato ring rot

Dir. 98/57/EC OJ L 235, 21.8.1998, p. 1-39

Council Directive 98/57/EC of 20 July 1998 on the control of Ralstonia solanacearum (Smith) Yabuuchi et al.

Dir. 93/50/EEC OJ L 205, 17.8.1993, p. 22-23

Commission Directive 93/50/EEC of 24 June 1993 specifying certain plants not listed in Annex V, part A to Council Directive 77/93/EEC, the producers of which, or the warehouses, dispatching centres in the production zones of such plants, shall be listed in an official register

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ANNEX 2 – STANDARDS QUOTED IN THE REPORT

International Standard TitleISPM 4 International Standard on Phytosanitary Measures Publication No 5,

Glossary of phytosanitary terms, Food and Agriculture Organisation,Rome, May 2010 Requirements for the establishment of pest free areas, Food and Agriculture Organisation, Rome, February 1996

ISPM 6 Guidelines for surveillance, Food and Agriculture Organisation, Rome, November 1997

ISPM 7 Export certification system , Food and Agriculture Organisation, Rome, November 1997

ISPM 8 Determination of pest status in an area, Food and Agriculture Organisation, Rome, November 1998

ISPM 12 Guidelines for phytosanitary certificates, Food and Agriculture Organisation, Rome, September 2001

ISPM 23 Guidelines for inspection, Food and Agriculture Organisation, Rome, April 2005

ISPM 31 Methodologies for sampling of consignments, Food and Agriculture Organisation, Rome, April 2008