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D-13-01: Canadian Heat Treated Wood Products Certification Program (HT program)

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Effective Date: June 16, 2022
(1st revision)

Subject

The Canadian Heat Treated Wood Products Certification Program (HT program) is a phytosanitary certification program administered by the Canadian Food Inspection Agency (CFIA). The program provides a basis for meeting the foreign phytosanitary import requirements for heat treated wood products. Where prescribed by importing countries, heat treatment of wood products is a phytosanitary import requirement intended to prevent the movement of plant quarantine pests.

The HT program establishes the requirements for facilities registered under the program to produce and/or handle (that is, produce, manufacture, reuse, or sell) wood that has been heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes. The heat treatment standard also applies to the production of wood packaging material in accordance with the provisions of the International Standard for Phytosanitary Measures (ISPM 15): Regulation of Wood packaging material in International Trade.

Some National Plant Protection Organizations (NPPOs) may establish additional phytosanitary import requirements.

This directive has been revised to:

This document supersedes the previous version of directive D-13-01.

On this page

Review

This directive will be updated as required. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).

Amendment record

Amendments to this directive and its appendices shall be dated and distributed as outlined in the distribution below.

Distribution

Since the early 1990s, there has been an increasing emphasis on phytosanitary concerns regarding the international movement of wood products. In some cases, to prevent the movement of pests, wood products are required to be heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

The International Plant Protection Convention (IPPC) established the International Standards for Phytosanitary Measures (ISPM 15): Regulation of Wood Packaging Material in International Trade (2009) which sets guidelines for the regulatory control of wood packaging material moving in international trade including treatment of the wood and specific marking.

This directive sets out the certification program in place within Canada for the production of heat treated wood products, including wood packaging material, subjected to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

Wood packaging products exported to the United States may be eligible for ISPM 15 exemption if the accompanying export/shipping documents clearly state that the wood packaging, including dunnage, in the shipment is made of wood that originates from either Canada or the U.S., was produced in either Canada and/or the U.S., and, is free of live pests, weed seeds and soil.

Scope

This directive is intended for use by facilities registered in or those seeking registration in the HT program for the production and/or the handling (that is, production, manufacture, reuse, or sale) of heat treated wood products (including wood packaging material) to meet foreign phytosanitary import requirements, and for use by custom brokers, freight forwarders, exporters, Recognized Heat Treatment Evaluators, The Canadian Lumber Standards Accreditation Board (CLSAB) and their accredited agencies, CFIA Approved Third Party Auditors, and CFIA inspection staff. It sets out the phytosanitary requirements for the production of heat treated wood products and the production of ISPM 15 compliant wood packaging material. It also describes the process by which facility conformance is verified.

References

Definitions, abbreviations and acronyms

Definitions for terms used in the present document can be found in the Plant Health Glossary of Terms.

1.0 General requirements

1.1. Legislative authority

1.2. Fees

The CFIA will be charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. Exporters requiring more information on fee schedules may contact any CFIA Regional office or visit the Fees Notice.

CFIA Approved Third Party Auditors or CLSAB Accredited Agencies will be collecting CFIA program fees on the behalf of the CFIA.

CLSAB Accredited Agencies and CFIA Approved Third Party Auditors may also charge fees for registration and audit services provided under this program.

1.3. Regulated commodities

The CFIA's Plant Protection Act and regulations requires anything exported from Canada to comply with the importing country's phytosanitary import requirements. Additionally, materials moving in-transit through another country prior to reaching their final destination are required to meet the phytosanitary import requirements of the in-transit country.

Importing countries may require the imported sawn wood (lumber or timber) and other wood products from Canadian and foreign origins, to be heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes prior to export.

Regulated commodities also include all non-processed wood packaging and loose wood dunnage from Canadian and foreign origins to be exported from Canada to countries that have adopted ISPM 15.

Wood products (including wood packaging) may also be regulated within Canada when moving from an area where such products are regulated for a pest of quarantine concern to an unregulated area.

Foreign phytosanitary import requirements are subject to change. Therefore it is the exporters' responsibility to consult with a local CFIA office to obtain the specific phytosanitary import requirements of the destination country.

1.4. Commodities exempt

Wood products that are not required to be heat treated (for example processed wood) are usually not regulated.

The following wood packaging commodities are exempt from ISPM 15 standard and therefore not included in the scope of the HT program (unless otherwise stated by specific countries' phytosanitary import requirements):

Note: not all types of gift boxes and barrels are constructed in a manner that renders them pest free. For this reason, some of these products may be regulated within the scope of this directive. These include boxes for fruit and vegetables, barrels used in the transport of industrial commodities. For more information on what is considered a regulated or unregulated wood products, please contact your local CFIA office.

2.0 Phytosanitary requirements

2.1 Heat treatment

Wood products certified under this program are required to be heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

Registered facilities may achieve the heat treatment standard by following the production methods:

2.2 Certification of wood packaging material

Wood packaging material, including dunnage, is considered wood that has been used in a manner, that supports, protects or carries a commodity in export trade. They exclude wood products which have not been assembled into the finished unit, prior to export (including unassembled wooden boxes, etc.).

All wood packaging material and dunnage exported from Canada to any country other than the United States must be produced by a registered facility in such a manner that ensures and verifies that systems related to export of such wood packaging material comply with ISPM 15. They must include the IPPC mark as described in Appendix 1 of ISPM 15 and Appendix 2 of this document.

The ISPM 15 mark on wood packaging material and dunnage constitutes an official document. This mark cannot be used for any purpose other than for the identification of ISPM 15 compliant wood packaging material and in line with the requirements of the HT program.

A phytosanitary certificate or an HT certificate shall not be issued for ISPM 15 stamped material.

Wood packaging material, with the exception of shipborne dunnage, that is compliant with ISPM 15 and that has not been repaired or altered, may be re-used and re-exported from Canada without re-treatment.

Shipborne dunnage: requirements for reuse and re-export of ship-borne dunnage unloaded in Canada are different from requirements for other wood packaging materials. For more information, please consult the CFIA directive D-98-08: Entry Requirements for Wood Packaging Material into Canada.

2.3 Certification of heat treated wood products (excluding wood packaging material)

Export shipments of heat treated wood products (excluding wood packaging material) may be required by the importing country to be certified by way of:

2.3.1 Phytosanitary certificates

A phytosanitary certificate is an official Government of Canada document issued by the CFIA to the NPPO of the importing country. Details on the issuance of phytosanitary certificates are contained in the CFIA policy directive D- 99-06: Policy on the Issuance of Phytosanitary Certificates.

Where countries require phytosanitary certificates to accompany shipments of heat treated wood products, an exporter who is registered in the HT program shall submit an application for export to the CFIA with the appropriate information for the verification of registration. The wood product destined for export must meet the following:

2.3.2 Heat Treatment Certificates

Heat Treatment Certificates are issued by a registered facility under the authority of the CFIA in accordance with the instructions provided on the certificate. The certificate attests that the wood products have been heat treated in accordance with foreign phytosanitary import requirements for those countries which accept industry-issued Heat Treatment Certificates. Refer to Appendix 1 for information on the Heat Treatment Certificate for use in Canada only and the different types of export Heat Treatment Certificates.

Registered facilities consolidating treated lots may issue a single Heat Treatment Certificate to cover the entire consignment consolidated from other registered facilities. The consolidated certificate must provide the relevant documentation to allow for traceability of each lot to a registered facility.

3.0 Program requirements

Facilities wishing to participate in the HT program must complete an application form, seek the service of a CLSAB Accredited Agency or a CFIA Approved Third Party Auditor and develop a phytosanitary management system that identifies procedures used by the facility to meet the foreign phytosanitary import requirements. The facility's processes shall be documented in a phytosanitary management system manual. There are 6 critical control points that need to be upheld in order to meet the phytosanitary requirements of the HT program and they are outlined in Appendix 5.

Note: not all CFIA Approved Third Party Auditors are eligible to verify all production and export activities indicated in the HT program. Certain foreign phytosanitary import requirements stipulate the types of auditors eligible to oversee certain export commodities (see Appendix 1 for details).

4.0 Program oversight

Facility level audits will be conducted by CFIA Approved Third Party Auditors or CLSAB Accredited Agencies on behalf of the CFIA to ensure the conformance of approved facilities to meet the phytosanitary requirements. Third Party Auditors are under a formal agreement with CFIA and CLSAB Accredited Agencies operate under the CFIA-CLSAB Agreement, to conduct auditing activities.

An evaluation audit is a systematic review of the facility before registration to ensure the facility has documented systems to comply with treatment and production requirements. Once a facility is registered, the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor will conduct system audits to verify that the registered facility remains in conformance with the program requirements and their phytosanitary management system. It includes the review and approval of the facility manual and an audit of the processes used by the facility to meet the program requirements.

A system audit is a review of the phytosanitary management system operating at a registered facility. System audits will be conducted by a CLSAB Accredited Agency or the CFIA Third Party Auditor to verify that the approved facility remains in conformance with the program requirements and their phytosanitary management system.

Note: heat treated softwood lumber requiring HT certification that is exported to the US from Canada shall be treated by an American Lumber Standard Committee (ALSC) Accredited Agency and shall be marked in accordance with the ALSC heat treatment requirements.

Audit frequencies are provided in appendices 3 and 4:

Structural lumber is defined as all lumber capable of use or application or design where working stresses are required; but it does not include hardwood and assembled structures such as trusses, prefab walls and flooring structures.

Should non-conformances be identified by a CLSAB Accredited Agency or a CFIA Approved Third Party Auditor, the frequency of audits may be increased to verify that all corrective actions have been completed and the facility is capable of maintaining the requirements.

4.1. Non-conformances

A non-conformance is a failure to comply with a specified requirement of the HT program.

The interception of non-compliant wood products by a foreign government could result in the destruction or the return to origin of the entire shipment (the wood packaging material and the commodity it supports or carries). Failure to meet the phytosanitary import requirements of a foreign importing country is also a violation of the Plant Protection Regulations and may lead to investigation and enforcement actions by the CFIA and suspension or cancellation from this program.

The CLSAB Accredited Agency or the CFIA Approved Third Party Auditor shall require a registered facility to take corrective action on any non-conformance identified. These corrective actions will be monitored by the auditor which may increase the frequency of audits until satisfactory corrective actions are completed.

Upon the identification of a non-conformance, the auditor will provide a written report to the registered facility identifying the non-conformance, corrective actions necessary and the need for follow-up audits.

Should a non-compliant product be found in the Canadian marketplace, the CFIA may take enforcement action.

Non-conformances are categorized as "major", "minor", or "observations".

4.1.1. Major non-conformances

Major non-conformances are those that affect the integrity of the program and are required to be corrected immediately. When major non-conformances are detected, the facility will be notified verbally and in writing by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor. The detection of a major non-conformance may result in a suspension of the facility or a stop in production until such time as the non-conformance is addressed to the satisfaction of the auditor. The auditor may conduct an additional audit(s) to verify that the corrective actions have been completed and that the non-conformance is not likely to recur. See section 4.2 for more information on suspension and cancellation of registered facilities.

Examples of major non-conformances appear in Appendix 6.

4.1.2. Minor non-conformances

Minor non-conformances are audit findings that reveal an isolated incident of non-conformance which has no direct impact on the integrity of the product. When minor non-conformances are detected, the registered facility will be notified in writing by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor.

Registered facilities are required to correct minor non-conformances before the next scheduled audit of the facility (or timeframes dictated by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor). Depending on the number of non-conformances detected, the auditor may schedule an audit to verify corrective actions as part of the routine audit schedule or as a specific audit in addition to the routine audit frequency.

Examples of minor non-conformances appear in Appendix 7.

4.1.3. Observations

Observations are defined as comments or notes taken during the audit where 1 or more elements of the program are not adequately implemented but do not affect the phytosanitary integrity of the program.

Where observations have been recorded and not addressed within 60 days from the date of the audit, they may be elevated and recorded as minor non-conformances.

Examples of observations appear in Appendix 8.

4.2. Suspension and cancellation

Where a major non-conformance compromises the integrity of the certification program and is not addressed by the facility to the satisfaction of the CLSAB Accredited Agency, the CFIA Approved Third Party Auditor or the CFIA, or where the annual fees are not paid, the facility registration will be subject to a suspension or cancellation. The CLSAB or the CFIA Approved Third Party Auditor will recommend in writing, suspension or cancellation of the registered facility to the CFIA. Upon receipt of that recommendation, the CFIA will issue an official letter to inform the registered facility of the decision.

In cases where the integrity of the certification program is compromised, if applicable, the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor may remove the IPSM 15 stamp from the facility pending the review by the CFIA.

During the suspension period, the facility will not be permitted to ship any of the product produced under the certification program and will not be able to mark any product with any of the certification marks approved under this program. Other corrective actions may be ordered in writing by the CFIA to ensure that the phytosanitary integrity of the program is maintained. The facility will be given a set time frame to affect the necessary corrective actions.

A registered facility that has been suspended or cancelled due to major non-conformance(s) will not be allowed to request services from a different service provider until all issues have been resolved to the satisfaction of the CLSAB or the CFIA Approved Third Party Auditor and of the CFIA.

A facility which has been suspended or cancelled may contact the CFIA's Complaints and Appeals Office to request a review of the decision to suspend or cancel.

5.0 Appendices

Appendix 1 – Heat Treatment Certificates

Heat Treatment Certificates for structural lumber may only be issued by a registered facility which is under the care and control of a CLSAB Accredited Agency.

Heat Treatment Certificates for wood products not including structural lumber may be issued by facilities registered under the program.

Heat Treatment Certificates shall not be issued for wood packaging material that has the ISPM 15 mark.

Heat Treatment Certificates for the European Union (EU) countries

The Heat Treatment Certificates shall only be issued to certify wood specifically destined to the European Union. The Heat Treatment Certificate for consolidated shipments is permitted provided that there is an original heat treatment certificate(s) covering all of the material. The following declaration appears on the certificate:

"The coniferous lumber to which this certificate applies has been heat treated, and during the process, has achieved thermal death times for Pinewood Nematode (PWN) and its vector."

Heat Treatment Certificates for countries other than the European Union (with the exception of Mexico, see below)

The Heat Treatment Certificate shall only be used to certify wood products specifically destined to countries other than the member countries of the European Union, with the exception of Mexico, and that accept industry issued Heat Treatment Certificates. The following declaration appears on the certificate:

"The sawn wood in this shipment has been treated at a CFIA registered facility to achieve a minimum wood core temperature of 56°C for a minimum of 30 minutes."

Heat Treatment Certificate to Mexico

The Heat Treatment Certificate shall only be used to certify wood specifically destined to Mexico. The following declaration must appear on the certificate:

"The sawn wood to which this certificate applies has been heat treated to a minimum of 56°C throughout the profile of the wood (including its core) to a minimum of 30 minutes and dried."

Heat Treatment Certificate for use in Canada Only

A Heat Treatment Certificate for use in Canada Only may be issued to certify heat treatment (56°C at the core of the wood for 30 minutes) of wood products or wood packaging or dunnage that has not been marked and is moved within Canada between registered facilities by registered facilities (this includes brokers). This certificate may be used to verify the compliance of the wood products with the treatment requirements identified in ISPM 15.

Appendix 2 – ISPM 15 wood packaging certification

The following wood packaging production standards must be upheld for wood packaging to be considered ISPM 15 compliant and registered facilities must outline production procedures in their manual.

Use of debarked wood

In addition to heat treatment, the ISPM 15 standard requires that wood packaging material be made of wood that has been debarked. Any number of visually separate and clearly distinct small pieces of bark may remain, provided these are:

Reuse and repair of previously certified wood packaging material

1. Reuse of wood packaging material

A unit of wood packaging material that has been treated and remains marked in accordance with ISPM 15 and that has not been repaired, remanufactured or otherwise altered does not require re-treatment or reapplication of the mark throughout the service life of the unit.

2. Repair of certified wood packaging material

Repaired wood packaging material is wood packaging material that has had up to approximately one third of its components removed and replaced.

When ISPM 15 marked wood packaging material is repaired with the intent to carry forward its certification, only wood treated in accordance with ISPM 15 can be used for the repair, or wood pieces constructed or fabricated from processed wood material shall be used. Each added component must be individually marked with the repairing facility's IPPC mark in accordance with ISPM 15. In all cases involving the repair of certified wood packaging, the original certification marks must be maintained and must conform to the ISPM 15 standard.

Where there is any doubt that all components of a unit of repaired wood packaging material have been treated in accordance with ISPM 15, or the origin of the unit of wood packaging material or its components is difficult to ascertain, the wood packaging material must be re-treated and certified with a Canadian ISPM 15 mark, destroyed, or the original certification marks must be obliterated and the unit prevented from moving in international trade as compliant with ISPM 15.

Note: obliteration of the mark means to render it permanently invisible or unreadable, such as, but not limited to, grinding or covering with paint.

When any unit is re-treated, any previous applications of the mark must be permanently obliterated and a new mark must be applied on the component in accordance with ISPM 15.

Important notes:

3. Remanufacture of wood packaging material

If a unit of wood packaging material has had more than approximately one third of its components replaced, the unit is considered to be remanufactured.

Remanufactured wood packaging material may incorporate both new and previously used components.

Remanufactured wood packaging material must have any previous applications of the IPPC mark permanently obliterated on all its components.

Remanufactured wood packaging material must be re-treated in its entirety and the IPPC mark must then be reapplied in accordance with ISPM 15.

ISPM 15 wood packaging material certification mark

Wood packaging material may consist of a single piece of wood or be composed of multiple pieces of wood attached together to form a composite unit, which may be considered as a single unit for marking purposes. Furthermore, on composite wood packaging material (composed of both processed and non-processed wood products), it may be appropriate for the mark to appear on processed wood components to ensure that the mark is in a visible location and is of sufficient size.

The mark will be comprised of the following required components:

IPPC recognized symbol: the design of the symbol must closely resemble that of the examples below and be placed to the left side of all other components

Country code: must be the International Organization for Standards (ISO) 2-letter country code (indicated as "XX" in Figure 1) and must be separated by a hyphen from the producer/treatment provider code

Producer/Treatment provider code: this is a unique code provided by CFIA (indicated as "00000" in Figure1). The code is 5 digits in length including "0" at the beginning. This code identifies the facility as a registered facility under the HT program

Treatment code: the abbreviation for the specific treatment used (indicated as "YY" in Figure 1). HT is the code for materials that are heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes. Other treatment types are not approved under the HT program.

International Standard for Phytosanitary Measures Number 15 Wood Packaging Recognized Mark
Figure 1: the above are examples of wood packaging recognized mark formats.

The size, shape and position of the mark may vary from facility to facility but each mark must be:

The mark must not be hand drawn and red or orange must not be used because these colors are used in the labeling of dangerous goods.

No other information (such as producer trademark, logo of authorizing body, date of treatment or marking to identify dunnage material) may be contained within the wood packaging certification mark.

National Plant Protection Organizations of the importing countries may at their discretion request control numbers or other information used for identifying specific lots provided it is not confusing, misleading or deceptive.

The wood packaging certification mark may only be applied by wood packaging facilities or treatment facilities registered by the CFIA and operating under the HT program and can only be applied in Canada.

Appendix 3 – Frequency of audit of facilities supervised by the Canadian Lumber Standards Accreditation Board (CLSAB)

The CFIA has established an arrangement with the CLSAB to supervise accredited agencies listed on CLSAB website under the "Accredited Agencies menu" which oversee some facilities registered in the HT program for export. The CFIA has approved the operating plan of the CLSAB which includes the audit frequency of registered facilities described in section 3.5.16 of the CLSAB regulations. The auditing standards prescribed by the CLSAB are equivalent to the American Lumber Standards Committee Inc. specification for heat treated wood products as referenced in section 4.0 program oversight of this directive.

Where a major non-conformance is identified, enforcement actions may be taken in accordance with the CLSAB Operating Plan.

Appendix 4 – Frequency of audit of facilities supervised by an approved Third Party Auditor

The CFIA has entered into agreements with Third Party Auditors to oversee the activities of some registered facilities. The CFIA directly supervises the activities of approved third parties. Minimal performance-based frequency of auditing of facilities operating under a Third Party Auditor is described in Table 1. These standards address the risks associated with the phytosanitary activities conducted by registered facilities.

Table 1: Audit frequencies for facilities supervised by Third Party Auditors
Initial annual audit frequency at approval Annual audit frequency after a period without a major non-conformance
Producers heat treating wood packaging material and wood products not included in structural lumber 12 6 (after 3 years)
Producers heat treating appearance grade hardwood with moisture reduction 6 4 (after 1 year)
Producers of wood packaging material and other wood products except for structural lumber from heat treated sawn wood 6 3 (after 1 year)
Wholesalers and shippers 4 3 (after 1 year)

In the circumstance where a CFIA approved Third Party Auditor identifies a major non-conformance at a facility, the auditor will consult with the CFIA and provide in writing an increased audit frequency to the facility. To ensure the facility can maintain consistent conformance with the requirements, the increased frequencies will be maintained for a period of time determined by the CFIA in consultation with the approved third party. Once the auditor is satisfied that the facility can maintain conformance, the facility may be returned to the frequency established for it based upon its record of compliance prior to the detection of the major non-conformance.

Note: the Third Party Auditor should perform the prescribed minimum inspections per calendar year at approximately equal intervals at each facility.

Appendix 5 – Elements of the phytosanitary management system

The phytosanitary management system is based on 6 critical control points. The registered facility should, where appropriate, develop processes and procedures that meet these critical control points.

Competency requirements

The procedures used in ensuring that staff responsible for phytosanitary activities are competent.

Heat treating requirements

The procedures used in meeting the requirements for heat treatment as described in PI-07 and /or site specific schedules as established by a CFIA approved Heat Treatment Evaluator.

Wood packaging requirements

Traceability and segregation requirements

Documentation and record keeping

Note: if heat treated lumber from the US could eventually need to be certified by the CFIA for exports out of Canada:

Corrective actions

The procedures used by the registered facility to record, address and follow-up on non-conformances that may occur during routine operations.

Appendix 6 – Examples of major non-conformances

Major non-conformances – Audit findings that impact the integrity of the program requiring immediate correction. The following are examples of major non-conformances.

Appendix 7 – Examples of minor non-conformances

Minor non-conformances – Audit findings that reveal an isolated incident of non-conformance which has no direct impact on the integrity of the product

Appendix 8 – Examples of observations

Observations – Where non-phytosanitary issues arise during an audit, they will be recorded as observations and should be addressed within 60 days from the date of the audit by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor. Where observations have been recorded and not addressed within 60 days from the date of the audit, they may be elevated and recorded as minor non-conformances.

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