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Organization de los controles de condicionalidad en irlanda Organisation of Controls in Ireland Dr Al Grogan Head of Int

Organization de los controles de condicionalidad en irlanda Organisation of Controls in Ireland Dr Al Grogan Head of Integrated Controls Division. Overview. Irish Administrative Control System Implementation of Cross Compliance Risk Analysis Organisation of Inspections

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Organization de los controles de condicionalidad en irlanda Organisation of Controls in Ireland Dr Al Grogan Head of Int

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  1. Organization de los controles de condicionalidad en irlandaOrganisation of Controls in IrelandDr Al GroganHead of Integrated Controls Division

  2. Overview • Irish Administrative Control System • Implementation of Cross Compliance • Risk Analysis • Organisation of Inspections • Inspection Report Forms / Checklists • Selection of sample • Organisation of Controls • Coordination of Inspections • Training of Inspection Staff • Determining the Control Result • Cross Reporting of breaches outside selected sample • Informing the Farmer

  3. Irish Administrative Structure Department of Agriculture Paying Agency Inspections Payments DAS GAEC SMR 13-15 ELIG Other Divisions in DAFF SMR 11 SMR 16 - 18 SMR 6 SMR 10 SMR 7 SMR 9 SMR 8A SMR 12 ENV Pillar 2 LFA Pillar 2 SMR 8 SMR 1 SMR 3 SMR 4 Nitrates SMR 2 SMR 5 Department of the Environment

  4. Paying Agency Structure Minister For Agriculture Legal Services Support Secretary General Administration 3Division Heads 3Units dealing with all aspects of SPS + LFA+ Inspection 350 Staff Assistant Secretary Specialised control Bodies Cross Reporting COMPUTER SUPPORT Inspections Unit Eligibility LFA Cross Compliance 190 Staff

  5. Administration Unit

  6. Inspections Unit

  7. Cross Compliance .. Ongoing Implementation Cross Compliance Coordination Group • Coordinates implementation • Composed of Administrative and Inspection Staff • Interpretation of the Cross Compliance regulations (Attend Cion. Man. Meetings) • Inspection report checklist design • Design, agree software specifications and sign off the Cross Compliance SPS software • Monitor the progress of the Cross Compliance inspections RETURN

  8. Cross Compliance .. Ongoing Implementation • Review and implement improvements • Ensure all Farmers fully informed of requirements • Monitor the implementation of the Farm Advisory Service (FAS) • Both State and Private • Risk Analysis and Sample Selection • Coordinate ongoing Inspector Training

  9. Risk Analysis Becomes complicated for Cross Compliance where the Paying Agency as in Ireland must control for many SMR’s and GAEC Commission advise is to use a weighted risk analysis… But how should we determine the weights for such a sampling process Generally agreed that as more measures apply to applicants and as the risks triggered increase, the selection process tends to approach a random selection

  10. Selecting the Control Sample Being responsible for a number of SMR’s we must under the legislation control for all on each selected farm Risks associated with a number of SMR’s and GAEC are selected for in conjunction with each other Individual farmers may trigger one or more risk category within an SMR and one or more SMR’s WEIGHTING FACTORS

  11. What to consider in determining the Weighting Values Look at simple statistics on the power of the each risk to identify breaches (simple means) How to avoid double counting.. Which risk is actually identifying the breach Regression analysis tools also useful to help in this process (stepwise etc)

  12. Risk Analysis

  13. Risk Analysis S12 has low breach level but high significance… why A Check on correlations with other predictors shows:

  14. Weights Matrix

  15. The Sample Statistics for Ireland 127,000 applications for single payment of €1.3 billion 5% (6,500) farmers selected for eligibility (land declared) inspections 1% (1,300 farmers) selected from within the 6,500 for cross-compliance checks. (5% cattle and 3% sheep) Integrated inspections where possible resulting in a total of 7578 inspections nationally

  16. Sample selection process SHEEP GAEC G WATER SMR 9-18 From 2006-7 Environmental Pillar 2 SLUDGE Least Favoured Area Pillar 2 BIRDS BOVINES Selected from within Eligibility with some outside HABITATS NITRATES 127,000 APPLICANTS ELIGIBILITY SAMPLE SELECTED FIRST PIGS

  17. Inspection Report Forms/ChecklistsDesign Principles Records Breaches using ‘weighting’ concept Must facilitate immediate computation of the Sanction Must also accommodate the determination of repetition if applicable Converts weighting to sanction Report Forms Mirror the Data Capture Screen All IRF’s results summarised into a single summary report (SAIRS) which farmer invited to sign With the exception of 2 IRF’s (SMR4 and SMR9) farmer provided with provisional result on the day as required by farmer charter agreement

  18. Inspection Cycle Risk analysis run Remote sensing sites selected (60% remote and 40% ground) Cross Compliance files selected from the 5% land eligibility sample and only select from the remainder of the population (the 95%) where necessary to make up the full bovine 5% Database of inspection details for each farm compiled (CCR) Dossier for each farm assembled in advance at Central Office Inspections scheduled and the CCR then generated providing the inspector with all of the farm details and the latest bovine profile Physical Location of file always tracked (AFIT system)

  19. Notification Procedures No Notice given for Feed, Food Hygiene and Welfare checks Up to 48 hours notice for animal identification once control not jeopardised For others up to 14 days once control not jeopardised. (but few requests for a 14 day notice period) Majority of inspections are completed on the day • Nitrates (SMR4) and Pesticides (SMR9) however a two phase process and not finalised until later in the office RETURN

  20. Inspection Report Form Design and use of the Weighting Approach

  21. Cross Compliance ..The weighting System Article 48 condition i.e. ‘Where provisions relating to the requirement or standard in question leave a margin not to further pursue the non-compliance found, the report shall make a corresponding indication’ In addition whereas 57 states that : ‘Reductions and exclusions should be established having regard to the principle of proportionality’ So we consider‘Inadvertent and Minor in Nature’in the tolerance zone (Others for example use warning Letters for such breaches) RETURN

  22. Inspection Report Form Design and use of the Weighting Approach Design allows the inspecting officer to determine the potential sanction A sanction weightings guideline is provided to each inspecting officer Coding system used for animal identification to describe breach types A Control report is also completed which describes the breach circumstances Summary report form completed and farmer invited to sign it

  23. Cross Compliance .. Weightings and Sanctions Negligence 1 to 6 Tolerance zone and resulting in a 0% sanction but must follow-up 7 to 26 Weightings 1% sanction 27 to 46 Weightings 3% sanction >46 Weightings 5% sanction Intent 15%, 20%, 100% or two Years out RETURN

  24. Principles of the Weighting system Example: Cattle Identification and Registration All breach types are assigned a code within each of the four pillars or areas of identification: 1. Herd Register codes • BRD = Discrepancies in the Register • BRM = Missing entries • BRX1, BRX3, BRX5 missing entries for varying time periods with or without supporting documentation

  25. Principles of the Irish Tolerance system Weights attributed to Cattle Identification and Registration Codes 1. Herd Register • BRD = Weight of 4 • BRM = Weight of 6 • BRX1, BRX3, BRX5 = Weight of 11,31,51 Respectively 2. Passports • BPS = Weight of 2 • BPD = Weight of 4 • BPU = Weight of 6 • BPM = Weight of 11,31,51 Respectively 3. Tagging (weighting examples which are determined by herd size) • BTN = Weight of 10 for 4 animals in breach in herd size 1 to 150 • BT = Weight of 10 for 5 animals in breach in herd size 151 to 200 4. Bovine Database (weighting examples which are determined by herd size for BC) • BCE = Weight of 2 • BCD = Weight of 4 • BC = Weight of 12 for >3 animals in breach in herd size 1 to 50 = Weight of 12 for >7 animals in breach in herd size > 300

  26. Bovine Weightings Table 1% 3% 5%

  27. Cross Compliance .. The Inspection Files tracked on system from first issue of the dossier to its return (AFIT) Inspecting officer issued with work for week; Weighting Guidance provided for each SMR Repetition rules on each inspection report form; Returns to office one day per week and enters results directly to the database; Immediate supervisor checks 100% of files while District Supervisor checks a random 10% and all breach cases; File returned to the central office where a further sample independently checked to ensure accuracy; All paper records scanned to the system and tracked by the AFIT system; RETURN

  28. Cattle Identification An Example Case 1 • 3 animals not notified to the database in herd size of 112 Case 2 • Database notification, tagging and passport breaches found

  29. 1% 8 1% 1% 1% 1%

  30. 35

  31. GAEC Example of a breach of weed controls law

  32. Part 1

  33. Part 2

  34. Managing the Inspections

  35. Managing ..AFIT System

  36. AFIT System

  37. Managing …Cross Compliance Report (CCR)

  38. CCR Contd.

  39. CCR Contd.

  40. SUMMARY REPORT SAIRS

  41. Training All Inspection staff undertake two specialised training coursed each year covering • Land eligibility • Cross compliance • Least Favoured Area inspections • New Beef Cow Welfare Scheme Specialists from the specialised control bodies attend In addition to normal supervisory checks Random reperformance checks are completed and findings used in training programmes Based on the very current data we can evaluate individual and regional variations Regional Managers then meet each month to review need for further staff briefings

  42. Cross Reporting Article 65, para 4, states: Non-compliances shall be deemed to be ‘determined’ if they are established as a consequence of any kind of checks carried out in accordance with this Regulation or after having been brought to the attention of the competent control authority in whatever other way.

  43. Cross Reporting Specialised bodies are requested where breaches are found to provide: • Legislation being contravened. • Specific Articles and paragraphs applicable. • Nature and background of the case including any court reports, field reports and laboratory test results pertinent to the case. • Severity, extent and permanence of the non-compliance and whether it was committed negligently or intentionally. This case is then evaluated and sanctioned as if found by the Cross Compliance Inspector

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