Nico Olie General Assessment

Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The Analysis of Red, Yellow Green


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey Table of content 1. Starting Up / Refresh Memory 2. The MarSurv System in Turkey a. Organization b. Responsibilities c. Execution d. Other observations 3. Diagnosis


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey Starting Up / Refresh Memory (1) ** MarSurv under GPSD and New Approach : “…ensuring a consistent, high level of consumer health and safety protection AND preserving the unity of the internal market …..” ** free circulation of safe products ** conformity with standards gives PRESUMPTION of safety, UNLESS other proof is found ** Industry & Trade responsible for safety ** Authorities responsible for monitoring and enforcement ** intervention if hazards are obvious


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey Starting Up / Refresh Memory (2) ** mutual confidence between partners or Member States ** administrative cooperation (ADCO’s) ** systematic survey of the effectiveness of the Surveillance system  CONFIDENCE in the system is essential


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey Starting Up / Refresh Memory (3) CONFIDENCE of consumers CONFIDENCE of MS reliability for producers and distributors effectiveness – high level of protection


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey 1. Organization : structure, staff, budget, communication 2. Responsibilities : policy, planning, priorities 3. Execution : activities, interventions, support 4. Other observations ** **


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Organization :: structure ** MarSurv fragmented ** funnel-effect ** not transparent ** in fact no links inside or between authorities ** coordination laborious  Visibility (too) low <---> system is unnoticable


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Organization :: coordination ** Advisory Board, 13 Members ** representatives from MarSurv authorities ** different MarSurv motivations : consumer safety, market regulation, etc. ** Chair (UFT) : no executive power ** no binding advise  too heterogeneous, low profile


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Organization :: staff ** high level of education ** high involvement ** most inspectors (too) many different tasks, MarSurv part-time ** almost no specialization or task separation ** most inspectors not selected as such  Human capital, but can deliver more


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Organization :: budget ** no separate budget for MarSurv ** no binding agreement possible between budget and number of activities ** almost no (budget for) samples and lab analysis ** bureaucracy around incidental samples ** lot of complaints about cars, fuel, notebooks, etc.  no contribution to effectivity and efficiency


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Organization :: communication ** incidental, focussed on 1 item ** almost no exchange of information ** in provinces : special role for Governor ** with NGO’s : miscellaneous  to be developed ?


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Responsibilities :: vision ** policy / vision is rule-based, not risk or target group-based. “…..The law says so…..” ** “conformity” dominates “safety” : the CE seems to be the end of all discussions ** no pro-active risk assessment or data collection observed  more awareness of the background of the system needed


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Responsibilities :: policy ** all visions and policy and plans are developed in “Ankara” ** there are frustrations about regional input hardly being taken into account ** the relation between ”Ankara” and the regions is very top-down  risk that valuable practical information is not used


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Responsibilities :: priorities ** in general the number of staff seems to be sufficient ** prioritisation is seldomly necessary ** people are highly motivated for their job, but less for their employer  goodwill is important factor for success


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Execution :: activities (1) ** the numbers of inspections for MarSurv are far from impressive (2006 : no more than 25000) ** inspector’s fte involved : 500 (+/- 100) ** pressure on private sector is very low ** samples are hardly taken <-> limited laboratory capacity  low “presence”


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Execution :: activities (2) ** inspections are mainly checks of conformity (CE or/and documents) ** consequence : in practice consumer products outside New Approach Directives are “not seen” ** sampling and testing (quote)  monitoring is most paperwork  big part of the products not monitored


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Execution :: activities (3) “For effective market surveillance, the new approach adopts in-market control via sampling and testing instead of pre-market control.” Mrs. Ulrike Hauer (EC Delegation) 26 January 2007, Project Kick Off


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Execution :: activities (4) “Adopting laws alone (legal alignment) does not mean that the consumer safety is ensured. The magic word here is "enforcement“. The EU product safety regime encourages Member States to ensure "effective enforcement". Market surveillance authorities of the MSs are responsible for safety checks and to initiate corrective measures or apply sanctions where necessary.”


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Execution :: interventions ** a general intervention policy not observed ** warnings, fines, confiscation and other corrective measures are hardly applied ** big generosity with opportunities to correct ** remarkable low number of recalls  authorities very kind to private sector  private sector not very under pressure


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Execution :: support ** many complaints about little transportation means ** a lot of complaints about absence of Inspectors-ID card (comment later) ** level of IT support extremely low ** no general datasystem for surveillance and enforcement  big loss of time for inspections


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Other observations (1) ** ban on inspection of streetmarket ?? ** obsession against imported products ** apparent contradiction between import and inner market ** trainings on EU-directives: too much information, but not prepared for practitioners ** communication on risks with the consumer is not developed


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System in Turkey : Other observations (2) ** unsafety must be proven, but not always a laboratory is needed ; inspectors could do more than they are doing actually : small testkits ** position of inspectors : “consumer protection cannot work with unprotected inspectors” ** low awareness / interest from “high level”


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey The MarSurv System for Consumer Products in Turkey Diagnosis  low visibility / profile  not powerful  low effectiveness  low efficiency  fragmented, heterogeneous  needs “high level” awareness and interest  human capital


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey A question or 2 now ….


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey A question or 2 now …. Do you have confidence in this system


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey A question or 2 now …. Do you have confidence in this system ….. as a consumer…..?


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey A question or 2 now …. Do you have confidence in this system ….. as a consumer…..? ….. as a trading foreigner…..? (do not think longer than 8 seconds !!!!)


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey What is the best solution ?


Reinforcement of Institutional Capacityfor Establishing a Product Safety System in Turkey : Reinforcement of Institutional Capacity for Establishing a Product Safety System in Turkey What is the best solution ? Establishing a Product Safety System in Turkey


Slide32 : consumerproductsafetyturkey@gmail.com