Finnish comments to the Draft report DG (SANCO) 8596 2002 ON A MISSION  CARRIED OUT IN FINLAND FROM
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Finnish comments to the Draft report DG (SANCO) 8596 2002 ON A MISSION CARRIED OUT IN FINLAND FROM

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Finnish comments to the Draft report DG (SANCO)/8596/2002 ON A MISSION CARRIEDOUT IN FINLAND FROM 15 TO 19 APRIL 2002 IN ORDER TO AUDIT THE PLANTHEALTH SYSTEM IN THE POTATO SECTOR and the Working document providingsupplementary information to that contained in the draft reportGENERAL REMARKSIn general, we are very satisfied with the mission report. It describes accurately the current planthealth system in the potato sector in Finland. There are, however, some points we would like toclarify or correct in the text. To our understanding, the corrections mainly represent slightcommunication difficulties due to use of English both in the pre-mission questionnaire and duringthe mission.The Finnish comments to the draft report and to draft working document are based on the Englishversions. The Finnish language version of the report contains a considerable amount of translationmistakes.SPECIFIC REMARKS on the DRAFT REPORT6.1 Plant health system in FinlandFigure 6.1 should be amended as follows:replace the text in the box ’Seed Testing’ by ’Seed Certification’ and ’Laboratory’ by ’SeedLaboratories’.Reason: “Seed Certification” is the official English name for the unit and several laboratoriesfunction in the Seed Testing Department.6.1.1.1 KTTKst1 paragraph, part of the last line should be deleted:”:it is supplemented by fees for registration and inspection.”Reason: KTTK is not supplemented by fees, it is solely budget funded. Fees collected return to ...

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Finnish comments to the Draft report DG (SANCO)/8596/2002 ON A MISSION CARRIED OUT IN FINLAND FROM 15 TO 19 APRIL 2002 IN ORDER TO AUDIT THE PLANT HEALTH SYSTEM IN THE POTATO SECTORand theWorking documentproviding supplementary information to that contained in the draft report
GENERAL REMARKS
In general, we are very satisfied with the mission report. It describes accurately the current plant health system in the potato sector in Finland. There are, however, some points we would like to clarify or correct in the text. To our understanding, the corrections mainly represent slight communication difficulties due to use of English both in the premission questionnaire and during the mission.
The Finnish comments to the draft report and to draft working document are based on the English versions. The Finnish language version of the report contains a considerable amount of translation mistakes.
SPECIFIC REMARKS on the DRAFT REPORT
6.1 Plant health system in Finland Figure 6.1should beamendedas follows: replace the text in the box ’Seed Testing’ by ’Seed Certification’ and ’Laboratory’ by ’Seed Laboratories’. Reason: “Seed Certification” is the official English name for the unit and several laboratories function in the Seed Testing Department.
6.1.1.1 KTTK st 1 paragraph,part of the last line should bedeleted: ”:it is supplemented by fees for registration and inspection.” Reason: KTTK is not supplemented by fees, it is solely budget funded. Fees collected return to the treasury.
th st 4 paragraph,1 sentenceshould becorrectedas follows: ”The KTTK has a total of nine inspectors based in three Plant Health Units in Helsinki, Turku and Kouvaola.” Reason: the correct name is Kouvola.
6.1.1.2 Employment and Economic Development Centres st rd 1 paragraph,3 sentenceshould becorrectedas follows: “ Staff from the Rural Department assist in the plant health work on the basis of workplans that are agreed during annual meetings between the Plant Protection Service Department...“ Reason: it is the Department, which negotiates with EEDC management.
6.1.2 Human and financial resources st Under the headline Human resources, 1paragraph, first sentence should beamendedas follows: ”The Plant Protection Service employs 32 professional grade staff persons, including consisting of 12 staff holding an academic degree (Senior Inspectors or Administrators), 11 7 laboratory staff technicians, and 9 7 inspectors and 6 secretaries.” Reason: Clarification on PPS staff.
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st Under the headline Human resources,addparagraph as follows:a new paragraph after the 1 The Seed Testing Department employs in the Seed Health Laboratory 1 Senior Inspector and 5 laboratory technicians. In the High Grade Area 2 persons,1 Senior Inspector and 1 inspector, are employed in the phytosanitary field.” Reason: Staff figures for STD from premission questionnaire should be added here.
rd st 3 paragraph,1 sentenceshould becorrectedas follows: “The advisory organisations employ 57 people, of whom 12 are trained and authorised by Plant Protection Service to carry out take samples for plant quarantine purposes and marketing tasks. 12 of their staff are authorised and trained by the Seed Certification Unit.” Reason: Clarification is needed: the advisory organisations employ more than 57 people. Out of the employees 57 are authorised to collect samples for surveys of potato pests. 12 are authorised for certified seed production inspection task.
6.1.3 Work planning and assessment of the institution’s work Under the headline Work planning, in the first sentencecorrectionof a term as follows: “MAF and the KTTK establish an annual “result contract” performance agreement...” Reason: ”performance agreement” is the correct term in this connection.
6.1.4 Transposition and enforcement of legislation st ndrd 1 paragraph,2 and3 sentencesshould beamendedas follows: ”There are three two main types of legislation in the plant health sector, these are Laws which must be adopted by the parliament and Ministerial Decrees and Ministerial Regulations issued by the relevant Minister. ” Reason: Only two types of legislation exist. Previously Ministerial Decrees were issued as st “Decisions”, but after an amendment to the Constitution on 1of March 2000 Ministerial Decrees are issued as “Regulations”.
6.2.3.2 Quarantine pests in the multiplication of seed potatoes st st Subtitle Basic and certified seed: 1paragraph, 1sentence should becorrectedas follows: ”All lots of basic and certified seed are tested for ring rot with one sample of 200 tubers per 25 t ha.” Reason: One sample is taken from each hectare, not per 25 t.
nd nd Subtitle Potato cyst nematodes (G. rostochiensisandG. pallida), 2paragraph 2sentence should bedeleted: ”This is done of free of charge.” Reason: The sampling and testing is in effect not free of charge, because for a grower to obtain a certificate a fee is charged and field testing is a compulsory part of the certification process.
6.3.2.2 Ring rot (C.m.s.) st Subtitle Surveys, 1sentence should beamendedas follows: ”The general surveys in ware potatoes for ring rot as for brown rot are carried out by the Plant Protection Department of the KTTK with the analyses carried out in the Plant Quarantine Laboratory in Helsinki and occasionally also in the Seed Testing Department in Loimaa.” Reason: The Seed Testing Department does analysis when needed.
Table 6.3: Surveys in ware potatoes for ring rotshould becompletedas follows: Deletefootnote “*) figure not collected by the mission team” and replace* in the column “Harvest 2000” by number 11.
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Reason: The information was available for the mission team.
st st Subtitle Handling of outbreaks, 1paragraph, 1sentence should beamendedas follows: “According to a Finnish ministerial decision a sample of domestic production is considered...” Reason:The Ministerial Decision referred to here concerns only potato of Finnish origin.
6.3.2.3 Potato cyst nematodes st nd Subtitle Surveys, 1paragraph,2 sentenceshould beamendedas follows: ”Lately, the emphasis has shifted somewhat away from the southern main production area, where PCNGlobodera rostochiensisis common to the Northwest main production area, which is still largely free fromG. rostochiensisand totally free fromG. pallida.” Reason: The abbreviation PCN refers to the both species G. rostochiensis and G. pallida. In Finland, G. rostochiensis is common but only samples derived from 8 farms have revealed findings of G. pallida so far. Further, all these 8 farms are situated in southern Finland.
Subtitle Surveys, last paragraph, last sentence should beamendedas follows: ”They represent 8 farms and 4 farms for 2001 and 2000 respectively, all in the South of the country.” Reason: The 13 positive G. pallida samples from 2000 and 2001 were collected from 8 farms.
6.3.2.4 Potato wart disease (Synchytrium endobioticum) st st Subtitle Outbreaks, 1paragraph, 1sentence should becorrectedas follows: ”After entry into force of the new Plant Protection Act i In 1981 when the previous Plant Protection Act came into force the premises in the old records of potato wart disease were investigated again.” Reason: The Act referred to here has been repealed by the current Act (1203/1994).
6.5 Laboratories th 4 paragraphshould becorrectedas follows: ”The mission team visited the Plant Quarantine Laboratory of the Plant Protection Department and a two representatives from the Seed Testing Department met the team in Helsinki.” Reason: Both the Director and a Senior Inspector (Head of the Unit of Seed Health Laboratory) were met.
7.2 Seed potatoes rd st 3 paragraph,1 sentenceshould becorrectedas follows: ”The surveys for ring rot in seed potatoes are carried out systematically at a very high density, including all seed lots with a sample for laboratory analysis per 25 t ha.” Reason: One sample is taken from each hectare, not per 25 t.
7.4 Laboratory analyses th 4 paragraphshould bedeleted ”The laboratories involved with plant quarantine do not have a fully developed quality system yet.” Reason: The quality system for plant quarantine laboratories is not required in the EU legislation. Therefore, delete this remark form chapter 7. Conclusions.
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