QSM-07: program requirements for facilities registered in the emerald ash borer program

On this page

• Introduction
• 1. Scope
• 2. References
• 3. Definitions, abbreviations and acronyms
• 4. Program registration
• 5. Preventive control plan
  • 5.1 General requirements
  • 5.2 Administration
  • 5.3 Staff Training
  • 5.4 Phytosanitary control points
  • 5.5 Records and documentation
  • 5.6 Supplier list
  • 5.7 Transportation of non-compliant regulated articles
  • 5.8 Movement certificates
  • 5.9 Heat treatment
  • 5.10 Facility non-conformance
  • 5.11 Clean-up and disposal of by-products
  • 5.12 Pest notification
  • 5.13 Internal audits
• 6. Domestic firewood movement
• 7. Audits and reviews
  • 7.1 PCP review
  • 7.2 Authorization audit
  • 7.3 Systems audit
• 8. Program non-conformance
• 9. Suspension, revocation, reinstatement and voluntary withdrawal
• Appendix 1: movement certificate log
• Appendix 2: classification of non-conformance
• Appendix 3: audit and facility status flow chart

Introduction

This document supplements the Canadian Food Inspection Agency (CFIA) directive D-03-08: Phytosanitary requirements to prevent the introduction into and spread within Canada of the emerald ash borer, Agrilus planipennis (Fairmaire). It outlines the requirements that facilities must meet to be approved on the emerald ash borer program. The program enables facilities in good standing to ship regulated articles out of regulated areas without a pre-shipment CFIA inspection and allows facilities in non-regulated areas to receive regulated articles during certain low-risk times of the year. The program is a systems-based risk mitigation program, administered by the CFIA.

1. Scope

This document outlines the requirements for facilities that wish to participate in the program. Facilities not registered in the program should refer to directive D-03-08 for regulatory guidelines.

2. References

• D-13-01: Canadian Heat-Treated Wood Products Certification Program (HT program)
• D-03-08: Phytosanitary requirements to prevent the introduction into and spread within Canada of the emerald ash borer, Agrilus planipennis (Fairmaire)
• QSM-08: guidelines for Canadian Food Inspection Agency to administer the emerald ash borer program
• Technical Heat Treatment Guidelines and Operating Conditions Manual (PI-07)
• ISPM No. 5, Glossary of Phytosanitary Terms, FAO (updated annually)
• ISPM No. 15, Guidelines for Regulating Wood Packaging in International Trade, Publication, FAO, 2009
• ISO (International Organization for Standardization) Guide 8402, Quality Systems Terminology

3. Definitions, abbreviations and acronyms

Definitions for terms used in the present document can be found in the Plant health glossary of terms or in the International Plant Protection Convention (IPPC) (ISPM No. 5) glossary of phytosanitary terms.

4. Program registration

To apply to the emerald ash borer program, the facility must submit a new service request and a copy of the facility's preventive control plan (PCP) through their My CFIA account.

A facility registration number will be assigned by the CFIA when the registration is approved

Once approved a facility must maintain a current copy of its PCP, and make it available to the CFIA, immediately upon request.

5. Preventive control plan

The preventive control plan (PCP) must outline the procedures and processes implemented by a facility to mitigate the phytosanitary risk of emerald ash borer spread associated with the movement of regulated articles.

The PCP must include all of the elements of a facility's operations that relate to emerald ash borer risk mitigation. Details of these requirements are described below.

A phytosanitary management system that follows International Organization for Standardization guidelines or a similar management system and is amended to include the required elements of the program can be used as a PCP.

5.1 General requirements

5.2 Administration

5.3 Staff training

The PCP must describe the training procedures of staff responsible for procedures that mitigate the spread of emerald ash borer in accordance with the program. This includes the specific training elements and the intervals between training sessions. The training records must include the names of the employees trained. An example of a training record must be appended to the PCP.

Information on the signs and symptoms of emerald ash borer, a copy of the facility's PCP, and D-03-08 must be accessible to all facility staff that contribute to meeting the program requirements.

5.4 Phytosanitary control points

Phytosanitary control points are critical processing steps where regulated articles must be processed in accordance with program and D-03-08 in order to mitigate the spread of emerald ash borer. These may include stages where regulated articles are received, segregated, processed and shipped.

Facilities are encouraged to conduct internal audits following critical processing steps (for example, inspection of lumber to ensure all bark and wane are removed). If the facility does internal audits, the PCP must identify all phytosanitary control points and outline how the facility will conduct the internal audits of the points to verify that regulated articles are processed in accordance with program. The facility could develop a flow diagram to identify control points. Audit records at these control points should be current and complete, as specified in section 5.5.

Staff must fully understand their roles and responsibilities regarding phytosanitary control points.

5.5 Records and documentation

Facilities are required to maintain records that track all activities related to the program for a minimum of 3 years. Examples of these records include incoming shipping documents (requirement for sources of incoming ash outside of a regulated area only), movement certificates and log journals, inspection records for incoming regulated articles in non-regulated areas, training records, sales records for regulated articles sold, audit reports and corrective actions.

5.6 Supplier list

Facilities that do not further process the regulated articles (for example, firewood brokers) must maintain a list of suppliers from where regulated articles will be sourced. Changes made to the suppliers list must be communicated to the CFIA. Facilities that do process the regulated articles should keep a suppliers list of sources from non-regulated areas. Contact your local CFIA office for more information.

5.7 Transportation of non-compliant regulated articles

Regulated articles must be transported under the conditions outlined in D-03-08, Section 2 for domestic movement and Section 3 for imports. The PCP must outline how the facility will meet the requirements for transport of regulated articles.

Facilities using their own vehicles to transport non-compliant regulated articles must outline the procedures (for example, cleaning of trailer after unloading regulated articles) used to mitigate the risk of emerald ash borer spread.

5.8 Movement certificates

Facilities approved in the program will be issued a movement certificate to allow the movement of regulated articles. The PCP must indicate the specific procedures and employees responsible for the care and control of the movement certificates. Specific information such as the movement certificate number, article, quantity, date of shipment, origin/destination of shipment, must be maintained for each shipment transported under the authority of the movement certificate. Appendix 1 contains a suggested template for how this information can be recorded.

Most importantly, the PCP must include the procedure surrounding what final inspection is done to signify that the shipment meets the conditions on the movement certificate (in other words, how does the employee responsible for control of the movement certificate know that the entire shipment is compliant?).

5.9 Heat treatment

Facilities not registered under the Canadian Heat-Treated Wood Products Certification Program (HT program) but intending to use heat treatment to generate compliant articles must meet the treatment requirements outlined in the Technical Heat Treatment Guidelines and Operating Manual (PI-07).

Alternately, the CFIA will recognize specific treatment schedules developed by a recognized CFIA heat treatment evaluator. A list of CFIA recognized heat treatment evaluators is available on our Web site

In all cases, the PCP must describe the kiln layout, including dimensions, direction of air flow, and location of all sensors. An example of the charge report, showing calculations used to confirm that heat treatment requirements are met must also be included in the PCP.

5.10 Facility non-conformance

The facility must specify an internal system for addressing and recording non-conformances.

A non-conformance record must include the following information:

• description of the non-conformance
• date of occurrence
• employees involved
• corrective actions taken
• signature of approval by the program manager

Examples of non- conformances are listed in Appendix 2.

An example of the facilities' non-conformance record must be included in the PCP. The CFIA must be notified within 24 hours of a non-conformance that affects the ability of the facility to meet the requirements of program.

5.11 Clean-up and disposal of by-products

Facilities in non-regulated areas must specify that processing, treatment, clean-up and disposal of regulated articles will be completed by March 31, which is the end of the low-risk period. Procedures to contact CFIA once the final clean-up is completed must be outlined in the PCP. Clean-up and disposal activities will be verified by CFIA.

5.12 Pest notification

Live emerald ash borer or signs of emerald ash borer damage, may be encountered by facility staff during the processing of regulated articles. All facilities must clearly specify in their PCP a commitment to notify the CFIA immediately if emerald ash borer in any life stage or signs of emerald ash borer are found on regulated articles sourced from a non-regulated area.

5.13 Internal audits

Facilities are encouraged to conduct internal audits on a routine basis. Internal audits are internal checks that verify all procedures are carried out as outlined in the facilities' PCP. The internal audits should include an audit of all the phytosanitary critical control points and should be recorded. If internal audits are conducted, a copy of the internal audit log must be included in the PCP.

Internal audit reports must be made available to the CFIA during audits.

6. Domestic firewood movement

Movement certificates for non ash slabwood and firewood are required for movement out of a regulated area. Movement certificates may only be granted to facilities under the program. Facility procedures must include how ash is segregated and excluded from other tree genera.

For movement of firewood within a regulated area, no restrictions apply.

7. Audits and reviews

A flow chart outlining audits and facility status is provided in Appendix 3.

7.1 PCP review

Upon registration, a review of the PCP will be conducted by the CFIA to verify that all prescribed elements in D-03-08 and section 5 of this document are addressed.

7.2 Authorization audit

An authorization audit is a systemic examination conducted by CFIA, to verify that a facility is capable of consistently meeting the program requirements as outlined in the facility's PCP. Once CFIA approves the PCP and a facility receives good standing on the authorization audit, the facility will be approved under the program.

7.3 Systems audit

Systems audits are verifications that the processes and procedures described in the facility's PCP are implemented to consistently mitigate the phytosanitary risks of emerald ash borer spread. The audit frequency is outlined in table 1.

Facilities located in non-regulated areas may only operate under the program during the low-risk season (October 1 to March 31). For these facilities, the clean-up surveillance audit prior to the start of the high-risk season will focus on ensuring that all regulated articles have been processed/treated/disposed of as per appendices 5 and 6 of D-03-08. These audits must be completed by March 31. However, where the final clean up/processing activities can not be completed due to harsh winter environmental conditions, the CFIA will review each situation on a case-by-case basis and will adjust the date of the final audit accordingly.

Facilities in regulated areas are subject to audits throughout the year.

Table 1: audit frequency

8. Program non-conformance

When CFIA audits identify that an approved facility is not in conformance with their PCP, QSM-07 or D-03-08, the facility must implement corrective actions. CFIA will provide a corrective action request to the approved facility identifying the details of the non-conformance. Examples of non-conformances are listed in Appendix 2.

9. Suspension, revocation, reinstatement and voluntary withdrawal

If a facility audit has determined that the approved facility no longer meets the requirements of the program, its registration status will be suspended or revoked. Once all necessary corrective actions developed by the facility have been implemented and approved by the CFIA, a facility may be reinstated on the program. Facilities that are unable to implement the necessary corrective will have their registration status on the program cancelled/revoked.

Facilities who have had their registration revoked, will be removed from the CFIA list of approved facilities and have their Movement Certificates cancelled immediately. To be re-registered, these facilities must submit a new service request through their My CFIA account with a revised PCP. The facility must demonstrate their ability to meet program requirements during the authorization audit.

If a facility wishes to voluntarily withdraw their registration from the program, they can notify their local CFIA office or make this request through their My CFIA account. The facility may re-register for participation under the program at any time.

Individuals or companies that do not comply with the Plant Protection Act and Plant Protection Regulations may be subject to additional penalties including prosecution.

A facility in a non-regulated area may become inactive during the high risk season and be reinstated in the program as an active approved facility during the low risk season. The facility must contact the local CFIA office to request reinstatement. It is strongly recommended that the facility make a reinstatement request a month before the desired reinstatement date. In this case, a new application and a revised PCP are not required. However, an audit to verify suitability for reinstatement in the program will be conducted and include a review of the PCP and the phytosanitary critical control points to mitigate the risk of emerald ash borer spread.

Appendix 1: movement certificate log

Appendix 2: classification of non-conformance

Type of non-conformance	Consequences of non-conformance	Non-exhaustive list of examples
Minor Table Note a An isolated incident of non-conformance which has no direct impact on the integrity of the product and that remedial action can be taken within a time period defined by the inspector.	The corrective action request (CAR) must be implemented and approved by CFIA by the next scheduled audit or the facility's program registration may be revoked.	Positions of responsibilities under the program are not listed in the PCP Outdated PCP of the facility are found in circulation Missing pages in PCP

4 minors found = 1 major

Type of non-Conformance	Consequences of non-conformance	Non-exhaustive list of examples
Major Table Note a The integrity of the program may be compromised due to a non-conformance.	Written authorization for the movement of regulated articles may not be issued. The CAR must be implemented and approved by CFIA within 10 business days or the facility's program registration may be revoked.	Some records (invoices, movement certificate) related to program are missing or incomplete Staff not trained as per facility's training plan Segregation procedures (for example signage) are not maintained PCP revisions have not been submitted to the CFIA prior to procedural changes Heat treatment (HT) records incomplete to confirm HT to 56/30 is adequate Minor non-conformances have not been corrected Facility non-conformance mechanism not effective

3 majors found = 1 critical

Type of non-conformance	Consequences of non-conformance	Non-exhaustive list of examples
Critical Table Note a The integrity of the program has been compromised, there is a serious breakdown at a critical control point, or the risk of emerald ash borer spread is very high.	The facility's program registration is revoked.	Segregation of compliant and non-compliant ash articles is not being maintained Ash lumber not fully debarked has been shipped out of a regulated area Movement certificates are found to not accompany each outgoing load Facility clean up not complete by March 31 annually or by pre-arranged date with the CFIA

Appendix 3: audit and facility status flow chart

Click on image for larger view

Audit and facility status flow chart – Text version

This flow chart consists of 2 processes. One entitled Application Process the other entitled Audit Process.

The fist box of the Application Process is called Facility applies: submits Manual. The chart points you to the Manual Review box. If you fail the Manual review you are re-directed to the Gaps Identified box, which returns to the start of the Application Process Facility Applies submits Manual box.

If you pass the Manual review component, you are then directed to the Facility Evaluation Audit box. If you fail the Facility Evaluation Audit you are however, re-directed to the Facility addresses audit failure box, which then returns you to the Facility Evaluation Audit component. Having passed the Facility Evaluation Audit you continue to the Facility Approved box.

Having passed the Facility Approved you are brought to the to the Audit Process of the flow-chart and directed to the Surveillance Audits, Systems Audits and the Cleanup Audits (non-regulated areas only) processes.

Depending on the outcome of the Surveillance Audits, Systems Audits and the Cleanup Audits (non-regulated areas only) processes, you are directed to either the Critical non-conformance box, which leads you to the Facility cancellation box, which in turn brings you to the start of the Application Process to Facility applies submits Manual box. Alternatively, if the outcome of the Surveillance Audits, Systems Audits and the Cleanup Audits (non-regulated areas only) processes was Major non-conformance, you are directed to the CAR implementation and approved within 10 days box, which leads to the Follow up Audit box. Which in turn leads you back to the Surveillance Audits, Systems Audits and the Cleanup Audits (non-regulated areas only) processes. However, if the outcome of the Surveillance Audits, Systems Audits and the Cleanup Audits (non-regulated areas only) processes was Minor non-conformance, you are brought to the CAR implemented and approved by next audit box, which also leads to the Follow up Audit box. Which in turn leads you back to the Surveillance Audits, Systems Audits and the Cleanup Audits (non-regulated areas only) processes.