Appendix B: How to build a preventive control plan for a farm unit with a potato wart restricted field

The introduction of plant pests and diseases onto a farm may occur through a wide range of pathways, including but not limited to seed and plant material, vehicles or equipment, staff and visitors, irrigation water or water run-off, manure, compost or soil, and wind. Knowing the pests of concern for a specific farming operation and identifying the pathways for introduction and spread, are key considerations when developing a preventive control plan (PCP).

The National Potato Wart Response Plan requires that all users of fields restricted for potato wart develop and implement a PCP to obtain a written authorization to move regulated things. A PCP is a formalized written plan that describes the risks that a farming operation is trying to mitigate. The response plan specifies the risks associated with potato wart that must be addressed in the farm unit's PCP, including how the risks will be mitigated to help contain, control and prevent the spread, as well as who will be responsible to implement, verify and monitor each element of the PCP. A PCP can be built off existing farm plans including an on-farm biosecurity plan. A well developed and implemented PCP can be a very effective pest risk management tool.

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Roles and responsibilities

Regulated parties, including owners and users of potato wart restricted fields, processors, packers, shippers, and brokers, that conduct activities that require specific risk mitigation measures related to potato wart are responsible for complying with the applicable requirements in the response plan, the Plant Protection Act and Regulations, and the Potato Wart Order. They must demonstrate compliance by ensuring that all specified phytosanitary measures to help contain, control and prevent further spread of potato wart are met.

The Canadian Food Inspection Agency (CFIA) verifies the compliance of the regulated parties by conducting activities that include inspection, monitoring and surveillance. When a non-compliance is identified, the CFIA takes appropriate compliance and enforcement actions.

Who needs a written a PCP

If you are in care or control of one or more potato wart restricted fields, you must have an implemented PCP to obtain written authorization to move regulated things. The implemented PCP must include procedures and processes to effectively address the specific phytosanitary risks associated with potato wart on the farm unit.

Why is it required

An implemented PCP is one of the conditions that must be met for the CFIA to issue authorizations for the movement of regulated things including potatoes and equipment as specified in the response plan and any official notifications issued to the landowner/ land user.

How to develop a PCP

A PCP is a combination of control measures that, when taken as a whole, provide a science-based approach to managing specific risks posed by potato wart. The PCP describes how risks associated with the movement of regulated things are mitigated to help prevent further spread of potato wart.

How to implement the PCP

Once the PCP has been prepared, action should be taken to immediately implement any procedures or processes included in the PCP that are not already common practice on the operation. The PCP should be fully implemented for the CFIA to issue authorizations for the movement of regulated things including potatoes and equipment.

Elements of a preventive control plan

All users of potato wart restricted fields (including service providers such as contractors and custom applicators) must be included in the farm unit's PCP. Rental or lease agreements for restricted fields should include a requirement that the user (person in care or control of the field) maintain and implement a PCP that includes the restricted field in their lists of fields in production.

The PCP must be reviewed on an annual basis by the person in care or control of the field(s) to ensure that the procedures and processes effectively address the specific phytosanitary risks associated with potato wart and have been implemented on-farm. Records must demonstrate how all users have been trained and are involved in the implementation of the PCP.

Incoming inputs

Consideration:

  • Seed potatoes and other crop inputs such as fertilizer and manure are sourced and managed to help contain, control and prevent the introduction and spread of potato wart and other pests and diseases.

The farm unit must indicate:

  • measures to be taken to ensure that all crop inputs received at the farm unit are sourced in a way that helps prevent introduction or spread of potato wart
  • how seed potato source(s) are documented.

Product control

Considerations:

  • Crop production, end use and tuber movement must meet the specified restrictions for all restricted fields.
  • Movement of regulated products must meet the requirements of the Potato Wart Order and any regulatory notices.

The farm unit must indicate:

  • measures to be taken to ensure the restrictions as outlined in the response plan on crop production, end use and tuber movement for each classification of restricted field are met
  • measures to be taken to ensure the requirements of the Potato Wart Order and all regulatory notices are met.

Sanitation, biosecurity and biocontainment

Considerations:

  • Effective equipment cleaning procedure/ protocol and sequencing of field usage, when possible, is in place to help prevent introduction, establishment or spread of potato wart and/or diseases.
  • When freedom from soil requirements are in place, to facilitate equipment cleaning/ decontamination, an area separated from the restricted field soil (gravel or similar purpose) is required at the entrance/ exit of an index, adjacent and/ or primary contact field. Run-off from the cleaning area must be directed to prevent contamination of other fields.

The farm unit must indicate:

  • measures to be taken to ensure the "equipment cleanliness" requirement is met and associated on-farm risks identified
  • measures to be taken when freedom from soil requirements are in place, to ensure that all machinery, equipment, and conveyances (from the farm or coming from outside the farm such as service providers) are cleaned, free from soil and plant debris and are authorized to move by the CFIA prior to leaving the field.

See PI-016: Procedure for inspecting regulated articles for freedom from soil, plants, plant parts and related matter for details on freedom from soil requirements for additional details. It is recommended to follow a risk-based sequencing of fields, when possible.

Pest controls

Consideration:

  • Early detection of pests and diseases is critical to minimize the impact and to successfully contain and/or eradicate pests and diseases.

The farm unit must:

  • detail the process for an employee to report potato wart suspect tubers within the farm unit and immediate next steps including reporting the suspect tuber to the CFIA if potato wart is suspected.
  • maintain accurate records, noting when any suspect tubers are identified, and follow-up actions taken.

Water management

Consideration:

  • To minimize the risk of disease spread through water run-off especially in fields with a sloping topography.

The farm unit must indicate:

  • measures to be taken to manage water runoff to prevent soil erosion and potential potato wart spores from moving between fields (particularly between restricted and unrestricted fields).

Biosecurity practices

Consideration:

  • Biosecurity zones are areas where biosecurity measures are implemented to control access, exit, and movement of a pest or a disease. To be effective, these zones must be clearly defined (visible) and controlled, and their importance understood by employees, service providers and visitors.

The farm unit must indicate:

  • measures to be taken to ensure biosecurity practices are being followed by farm personnel, visitors, and service providers.

Employee training

Considerations:

  • All farm unit personnel including management, operations leads, labourers, etc..) must receive adequate training to be able to recognize potato wart symptoms and be familiar with reporting procedures. They should also be familiar with biosecurity practices and measures that include movement of product, machinery, equipment, and conveyances, and waste disposal elements specific to the farm unit as appropriate for their roles and responsibilities.
  • Visitors and service providers must be aware of any specific potato wart requirements that would apply to them based on their roles / responsibilities while onsite.

The farm unit must indicate:

  • the training material that is provided to the employees, such as pest fact sheets, potato wart poster and training sessions
  • the training material that is provided to the employees responsible for freedom from soil or equipment cleanliness activities
  • how the effectiveness of the training is monitored, verified, and maintained for all employees and frequency of training / updates
  • a list of trainees including date trained and responsible trainer
  • how visitors and service providers are informed of applicable potato wart requirements.

Premises and surroundings

Considerations:

  • Farm unit has detailed maps to identify all fields in production (including newly acquired or rented / leased land) and potential risks for the introduction and spread of pests via the movement of people, inputs, vehicles, equipment, water, and wind
  • The identification of the physical attributes of the farm layout, buildings, roads, and fences assists the producer in visualizing potential pest access points
  • Sanitation procedures are implemented to minimize the risk of contamination, infestation, or infection, as applicable.

The farm unit must indicate:

  • measures to be taken to ensure sanitation procedures are implemented to help prevent the potential introduction and the spread of potato wart to other fields
  • measures to be taken to ensure sanitation procedures are implemented to help prevent contamination of potatoes in storage.

Waste disposal

Considerations:

  • Potato culls, waste material, rogued plants, soil, and water used for the washing of potatoes pose biosecurity risks and are pathways that must be addressed. The pests and pathogens that these materials may contain can easily spread to growing potato crops on the farm and to other farms in the area. Proper disposal is a critical component to mitigate risks associated with waste material
  • Waste storage and disposal systems are designed, constructed and maintained to prevent contamination of regulated commodities and the environment.

The farm unit must indicate:

  • measures to be taken to ensure that soil and plant material that is contaminated with soil are only moved from the restricted field with a written authorization from the CFIA. Waste material including soil and potato waste must be disposed of in an approved manner as specified in the PCP.

Receiving, transportation and storage

Consideration:

  • Lot integrity at all stages during production, storage, and subsequent steps including grading, packing and shipping should be identified and maintained.

The farm unit must indicate:

Traceability and control

Consideration:

  • Traceability and lot integrity are critical to ensure that restricted product and any product comingled with restricted product are managed to mitigate potential risks and to ensure compliance with the Potato Wart Order and the importing requirements of trading partners.

The farm unit must indicate:

  • measures to be taken by the farm unit to help contain, control, and prevent the risk of spread of potato wart from restricted fields that are part of their farm operation, and the records maintained to document these processes and procedures during all stages for crop production and handling, including:
    • the procedures for informing CFIA where required by the Plant Protection Act and Regulations of a non-compliant product
    • the procedures for informing CFIA of critical information including changes in ownership or land use/ users and annual cropping information
    • how traceability will be implemented, including records related to host crop production such as source of seed potatoes and shipment details and equipment movement
    • how internal verification is implemented to ensure the PCP is followed. The PCP must identify a responsible person to conduct the verification
    • the steps that will be taken following an observed non-compliance or a deviation at all stages of the production.

Records help document that the farm unit has implemented the identified preventive controls and that those controls are effective in meeting the phytosanitary measures and help to mitigate risk. The farm unit will generate several different types of records, based on their individual operations, which must be available for review by the CFIA.

The farm unit will need to identify records associated with each element of their PCP and retain them for a period of ten years. Some examples may include:

  • a list and a map of all fields and restricted fields with their classification history
  • cropping / production records
  • visual inspection / monitoring records
  • all input sourcing records
  • transport/shipping records
  • storage records
  • disposal/processing records
  • training records
  • biosecurity practices records such as a visitor log
  • domestic movement certificates
  • verification of procedures
  • non-compliances / deviations and corrective actions taken.

Authorization for movement

The CFIA authorization for movement may be voided at any time if the person the movement certificate has been issued to has not complied with any one of the conditions set out in the movement certificate.

The CFIA will follow the guiding principles in its Compliance and Enforcement Policy when informing regulated parties, assessing and monitoring compliance and responding to instances of non-compliance.

Amendment of the preventive control plan

The PCP must be reviewed on a regular basis by the farm unit management / operations team to ensure that it is fully implemented, and that the phytosanitary measures on all restricted fields are in place to help contain, control and prevent further spread of the pest to other fields.

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