PI-016: Procedure for inspecting regulated articles for freedom from soil, plants, plant parts and related matter
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Table of contents
- Amendment Record
- Introduction and scope
- 1.0 Objectives
- 2.0 References
- 3.0 Definitions, Abbreviations and Acronyms
- 4.0 Background
- 5.0 Administration
- 6.0 Specific requirements
- 6.1 Inspection
- 6.2 Health and safety
- 6.3 Inspection location
- 6.4 Owner or person in charge of the regulated article
- 7.0 Assessing freedom from soil, plants, plant parts and related matter
- 8.0 Alternate treatments
- 9.0 Documentation and Communication
- Appendix 1: Legislative Authority and directives in Canada
- Appendix 2 - Checklist and Inspection Report
- Appendix 3 - Good Cleaning Practices
- Appendix 4 - Recommended Combine Cleaning Procedure
The Contact for the review of this document is the National Manager of the Potato Section, Canadian Food Inspection Agency (CFIA).
The CFIA shall review PI-016 every 5 years, or earlier, as required.
Joanne Rousson, Project Coordinator
Greg Stubbings, Chief Plant Health Officer
Amendments to this document will be given consecutive numbers. Amendments to this document will be posted on the CFIA website.
|Number of amendment:||Amended by:||Date of submission for approval:||Summary of amendment and number of amended page(s):|
The most up to date version of this document will be maintained on the CFIA internal website. In addition, the signed original and the master electronic copy will be kept by the Project Coordinator.
Introduction and scope
This inspection procedure has been developed for Canadian inspectors designated by the Minister under the Plant Protection Act ("Act") (such as Canadian Food inspection Agency (CFIA), Canada Border Services Agency (CBSA), etc.) and any owner or person having the possession, care or control of a thing that is required under the Act to be free from quarantine plants pests, soil, plants, plant parts and related matter. Under the Plant Protection Act or regulations made under the Act, such as the Plant Protection Regulations or the Golden Nematode Infested Places Order, things may be required to be free from plant pests, soil, plants, plant parts and related matter in order to be imported into Canada or to be moved outside or within regulated areas in Canada. The procedures described in this document may also be used to meet phytosanitary import requirements of foreign countries.
For the purposes of this procedure, the term regulated article refers to any type of vehicle (car, military vehicle, truck, etc.), machinery (tractor, harvester, etc.), equipment (plough, sprayer, etc.), tools, blocks of stone (granite, etc.), containers (crates, tote bag, etc.) or any other inanimate item that has to meet the "freedom from plant pests, soil, plants, plant parts and related matter" requirements.
Proper cleaning and sanitization of regulated articles are of concern to various sections of the CFIA Plant Health and Biosecurity Directorate including Potato, Horticulture, Forestry and Invasive Alien Species.
Regulated articles covered under this procedure may also require approval and/or a Permit to Import under the Health of Animals Act and/or the Fertilizers Act. For information regarding requirements for products under the Health of Animals Act, contact the Animal Health Directorate, Import/Export Section. For information regarding requirements for products under the Fertilizers Act, contact the Crop Inputs Division - Plant Health and Biosecurity Directorate of the CFIA.
Local CFIA Plant Health Offices should be contacted for further guidance on this inspection procedure.
The purpose of the "freedom from soil, plants, plant parts and related matter" requirement is to prevent the introduction and spread of regulated by preventing the movement of soil and plant debris that may contain such pests. The primary objective of this document is to describe the inspection procedure to ensure that regulated articles are free from soil, plants, plant parts and related matter. Examples of alternative treatments to render various plant pests non-viable are also proposed.
Sub-objectives consist of, but are not limited to:
- Explain the importance of soil as a plant pest pathway;
- Describe the inspection requirements;
- Define and clarify what is meant by "freedom from soil, plants, plant parts and related matter";
- Identify the critical points to inspect on vehicles, machinery equipment and other inanimate regulated articles to assess freedom from soil, plants, plant parts and related matter;
- Provide suggestions for good cleaning practices.
- Identify alternative treatment options that may be used when it is not possible to remove all soil, plants, plant parts and related matter from a regulated article.
- Plant Protection Act, S.C. 1990, C.22.
- Plant Protection Regulations, SOR/95-212.
- Golden Nematode Infested Places Order
- D-08-05, Canadian Fruit Tree Export Program (CFTEP) for Malus, Pyrus, Chaenomeles, Cydonia and Prunus spp.
- D-02-04, The Blueberry Certification Program and domestic phytosanitary requirements to prevent the spread of blueberry maggot (Rhagoletis mendax) within Canada
- D-01-01, Phytosanitary Requirements to Prevent the Entry and Spread of Phytophthora ramorum
- D-95-26, Phytosanitary requirements for soil and related matter, and for items contaminated with soil and related matter
- D-95-18, Seed Potato Certification Program - Investigation Procedure after Clavibacter michiganensis subsp. sepedonicus Has Been Detected on a Seed Potato Farming Unit
- D-97-06, Plant Protection Export Certification Program for Grapevine Nursery Stock (PPECP), Vitis spp.
- Memorandum D19-12-1, Importation of Vehicles, Canadian Border Services Agency
3.0 Definitions, Abbreviations and Acronyms
Definitions for terms used in the present document can be found in the Plant Health Glossary of Terms.
4.1 Legislative Authority
CFIA has established strict phytosanitary restrictions on the importation or domestic movement of regulated articles that are susceptible to contamination and could contribute to infestation by regulated plant pests that are associated with soil and plant debris. The primary federal legislation and CFIA directives related to this inspection procedure are listed in Appendix 1.
The following web link to the CFIA's website, Plant Pest Information, may also be consulted for additional information on soil-borne and other plant pests.
4.2 International Obligations
Canada is a signatory to the International Plant Protection Convention (IPPC), and therefore has specific international obligations with regard to plant protection. The CFIA is Canada's National Plant Protection Organization (NPPO) and has the responsibility to protect Canada's plant resource base by preventing the importation, exportation and spread of regulated pests, and by controlling or eradicating regulated pests in Canada. More information on international plant protection convention and related organizations can be found on the IPPC and the North American Plant Protection Organisation (NAPPO) web sites.
4.3 Soil and plant residues as a pathway for plant pests
At the international level, it is acknowledged that soil is an important pathway for numerous plant and animal pests including bacteria, fungi, insects, nematodes and weeds. Examples include potato cyst nematodes (Globodera spp.), potato wart (Synchytrium endobioticum), sudden oak death (Phytophthora ramorum), and foot-and-mouth disease (Aphtae epizooticae). The NAPPO position paper on soil movement signed on April 24, 2003 by members of the NAPPO Executive Committee describes the risks and complexities associated with soil and its associated pests:
"Soil, as evidenced from the international restrictions and prohibitions concerning its movement, is considered to be a high risk pathway for spreading a wide range of pests including, but not limited to: bacteria, fungi, insects, nematodes and weeds. Numerous soil-borne pests can survive for many years, with or without suitable hosts. Some of these pests can be detected visually while the detection of others requires sophisticated diagnostics."
Plant residues are also an important vector of plant pests, pathogens and invasive alien species, such as Blueberry maggot (Rhagoletis mendax), Bacterial Ring rot (Clavibacter michiganensis subsp. sepedonicus) and Woolly Cup Grass (Eriochloa villosa).
As international trade continues to increase, so does the movement of regulated articles potentially contaminated with soil and plant residues and the risk of moving plant pests associated with them from one country to another. At the domestic level, a regulated article contaminated with soil and plant debris poses a high risk of the movement of plant pests and establishments when moved from one field to another or from one farm unit to another. Fungal spores, bacteria, nematode cysts and invasive plant seeds can be moved in infested soil that adheres to machinery, equipment, vehicles, etc. Plant pests and invasive plants can then establish themselves in fields where contaminated equipment has been moved to. Regulated soil-borne pests present in Canada pose challenges with respect to limiting their spread within the country.
4.4 Soil borne plant pests and pathogens size
The minuscule size of soil-borne pests makes them very difficult to detect on a regulated article. For instance, a golden nematode (Globodera rostochiensis) cyst is 1000 µm (1mm) - approximately the size of a coarse grain of sand. Some fungal spores, including the one responsible for potato wart (Synchytrium endobioticum) are impossible to see with the naked eye as their 50 µm diameter size makes them smaller than a very fine grain of sand. Potato wart inoculum has been shown to be associated with small soil aggregates ranging from 100 to 2000 µm diameter in size. This reinforces the fact that soil-borne pests can be present in a minimal amount of soil.
On the other hand, the seeds of Woolly Cup Grass (Eriochloa villosa) measure 4.5 - 5mm in length and 2 - 3mm in width and the pupae of blueberry maggot (Rhagoletis mendax) measures approximately 6mm in length. They are visible to the naked eye and can easily be moved between fields on contaminated machinery and equipment.
There are numerous regulated plant pests that can be associated with soil and plant debris. Follow this link for a list of Plant pests regulated by Canada. These pests are known to occur in many countries around the world. This list is not exhaustive and may be modified based on available scientific data.
4.5 Impacts of soil borne plant pests and pathogens
The introduction and spread of regulated soil borne plant pests within Canada can lead to yield losses, increased production costs and a biological and/or regulatory inability to grow certain crops. On a larger scale, the environmental effects can be devastating and the country's economy can be severely hampered due to market access interruption for agricultural and forestry products and the cost of dealing with introduced pests.
"If left unmanaged, golden nematode (Globodera rostochiensis) can reduce yields of potatoes and other host crops such as tomatoes and eggplants by up to 80 per cent. These pests infest the soil and are very difficult to eradicate because they can persist, dormant in the soil, for several decades."
"Losses in crop yield and quality related to the introduction and propagation of Aegilops cylindrica (jointed goatgrass) in the United States are estimated at $150 million annually. Field experiments demonstrated a first year infestation of 1 to 5 plants per square metre led to yield losses of 3 to 30% the following year."
5.1 Request for Inspection
Regardless of destination, regulated articles that are to be moved out of a regulated area in Canada require an inspection prior to movement. Inspections may also be required for the movement of regulated articles within a regulated area as defined by the Prohibition or Restriction of Activity (CFIA/ACIA 0110). The owners or designated person in charge of regulated articles must contact their local CFIA office to arrange for inspection. The timeframe between the request for inspection and the delivery of the service can vary depending on local office hours of operation and the availability of inspectors.
An official request for inspection is not required for imported regulated articles, as the Canadian Border Services Agency (CBSA) will either perform the necessary inspection at the Canadian border or they will notify the CFIA if an additional inspection is required.
5.2 Official documentation issued by CFIA
A Movement Certificate (CFIA/ACIA 0108) may be required to permit the movement of regulated articles within Canada. This document can only be issued by a CFIA inspector and is based on an inspection indicating all the applicable movement requirements have been met. These requirements may include freedom from soil, plants, plant parts and related matter as described in section 7. A Movement Certificate will not be issued if the inspection cannot be completed or if the regulated article fails to meet the movement requirements.
Other official documents may be issued depending on the situation. For example, a CFIA inspector could issue a Notice of Detention (CFIA/ACIA 3256) for any non-compliant regulated article that has either been imported into Canada or that has been moved outside of a regulated area. A Notice of Release from Detention (CFIA/ACIA 3257) will only be issued after a CFIA inspection indicates that the regulated article is compliant with all the applicable laws and regulations and will then be eligible for a Movement Certificate. Other official documents include the Notice of Requirement to Treat/ Process (CFIA/ACIA 0112), the Notice to Dispose - Plant Protection (CFIA/ACIA 0107) and the Phytosanitary Certificate (CFIA/ACIA 4743; CFIA/ACIA 1327).
5.3 Inspection fees
The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. For information regarding fees associated with imported product, please contact the CFIA Import Service Centre (ISC). Anyone requiring other information regarding fees may contact any local CFIA office or visit our Fees Notice web site.
6.0 Specific requirements
The objective of a "freedom from soil, plants, plant parts and related matter" inspection is to verify that the regulated article is free from soil, soil related matter and plant debris. The owner or person in charge of the regulated article must provide a safe and secure location to allow for proper inspection and they are required to provide additional support whenever requested by the inspector.
6.2 Health and safety
Inspectors should be aware of the potential hazards related to an inspection at all times and keep these hazards in mind when proceeding with the inspection. Inspectors are required to:
- Use sound judgement, taking all reasonable and necessary precautions to protect their health and safety, and that of others;
- Use all the required safety equipment and clothing, such as head protection, non-slip and sturdy footwear, eye and hand protection, hearing protection, etc.
- Follow established safe work procedures as determined by their respective CFIA OSH area advisors and comply with all instructions concerning health and safety for the workplace;
- Comply with other safety measures implemented by the owner or person in charge of the regulated article, and as indicated on the safety warnings on the regulated article presented for inspection;
Unsafe conditions and situations must be corrected prior to beginning the inspection process.
6.3 Inspection location
To perform a thorough inspection, the inspector must have full access to the regulated article presented for inspection and be able to easily reach and view the entire regulated article. Some locations or situations will not meet these requirements.
6.3.1 Low light levels
The regulated article presented for inspection must be presented in a well lit location. If the owner or person in charge and the inspector choose to conduct evening or night inspections, a properly lit location or supplemental lighting must be provided.
6.3.2 Incomplete view
Anything that impedes the inspector's view of the regulated article presented for inspection (e.g. grass, piles of soil, debris, etc.) must be removed by the owner or person in charge before the inspection can begin. In some cases, the regulated article to be inspected may also have to be moved to a more suitable location.
6.3.3 Regulated article presented for inspection is not accessible
The regulated article to be inspected must be directly accessible by the inspector (e.g. it cannot be on the other side of a window or behind a fence).
6.3.4 Inspection surface
There are different reasons an inspection for freedom from soil, plants, plant parts and related matter would be conducted and each has different cleaning location requirements associated with it. These include:
- to permit the movement of an regulated article from an area regulated for a specific pest
- cleaning and inspection location must be located inside the regulated area
- to permit the movement of an regulated article from an individual field regulated for a specific pest
- cleaning and inspection location must be located at the exit point of the individual field
- to ensure imported regulated articles meet the import standard
- wash facilities must be approved by the CFIA.
- to ensure regulated articles for export meet the requirements of the importing country
- no specific requirements
The regulated article presented for inspection must be on an appropriate inspection surface. An appropriate inspection surface should:
- Meet regulatory requirements and the conditions of any applicable directives. For example, an import inspection should only be performed within an approved area.
- Be in a regulated area or be located on a site that can also be used as a cleaning site or allows the regulated article to be moved to a cleaning site without risking contamination of other areas. When located outside a regulated area, the inspection surface must allow the removal and proper disposal of all dislodged soil, plants, plants parts and related matter. Ideal surfaces include concrete and asphalt.
- Be located on a site that will prevent the regulated article from becoming re-contaminated with soil as it leaves the inspection site. For example, an inspection for domestic movement cannot be performed in a muddy area (see Figure 25) as the regulated article will come in contact with soil as soon at it is moved.
6.4 Owner or person in charge of the regulated article
The owner or person in charge is expected to:
6.4.1 Be present
The owner or the person in charge of the regulated article presented for inspection must be present for the duration of the inspection to assist the inspector.
6.4.2 Provide full access
If the regulated article to be inspected is located in a locked or secured facility, the owner or person in charge must provide full access to the inspector.
6.4.3 Move or handle the regulated article presented for inspection
Inspectors should not move or handle any regulated article to be inspected. At the inspector's request, the owner or person in charge may need to move the regulated article to a better inspection location or to provide an alternate view. The owner or person in charge may also be asked to adjust any moving parts, to remove or open panels and lids, etc.
Failure to cooperate may result in an incomplete or non-compliant inspection. The regulated article must have been inspected and confirmed to meet import and/or domestic requirements before movement will be permitted.
7.0 Assessing freedom from soil, plants, plant parts and related matter
As mentioned above, soil-borne pests are closely associated with soil. Therefore, the presence of soil can be used as a risk level indicator. A regulated article that is free from soil, plants, plant parts and related matter is considered to pose a very low phytosanitary risk level and is permitted to move as long as no additional treatments are specified in the applicable directives.
Inspectors must thoroughly inspect all areas of the regulated article presented for inspection to verify that it meets the requirements. Depending on the regulated article being inspected, there may be many areas, including some that are difficult to access and view, which must be inspected to ensure that the regulated article meets the freedom from soil, plants, plant parts and related matter requirement.
7.1 Cleaning site
If specific cleaning site requirements are in place, the inspector must verify that the cleaning has been done in a way and at a location that meets the applicable requirements. Wash facilities cleaning soil-contaminated imported regulated articles must be approved by the CFIA. Domestic issues are covered by pest-specific directives or are contained within facility compliance agreements. See Appendix 3 for more details.
7.2 Definition of the "freedom from soil, plants, plant parts and related matter" requirement
The inspector must inspect the entire regulated article to ensure it meets the "freedom from soil, plants, plant parts and related matter" requirement and inform the owner or person in charge of the regulated article of the inspection results (see section 9 for details).
During the inspection, the inspector may find some soil residue remaining on the regulated article. From a plant health perspective, the accepted amount of soil residue is equivalent to a fine film of dust, such as that left by dirty wash water. The fine film of dust is composed of tiny soil particles that remain on the regulated article after the wash water has evaporated. This dust is primarily composed of clay and silt particles that are smaller than 50µm. By comparison, the size of a Golden Nematode cyst is approximately 1000µm (1mm). Other plant pests are generally much larger than clay particles.
If more than a fine film of dust is present on a regulated article, it does not meet the CFIA requirements of "freedom from soil, plants, plant parts and related matter". The regulated article is considered non-compliant and requires additional cleaning before it can meet the inspection requirement. To illustrate "freedom from soil, plants, plant parts and related matter", the following section provides photographs of compliant and non compliant regulated article surfaces with brief explanations. It is important to note that one can not conclude whether a surface is compliant or not based on a photograph. The conclusions discussed in this section are based on the results of on-site inspections.
Figure 1. Non-compliant tire
Figure 2. Non-compliant front fender
Figure 3. Non-compliant rear fender
Figures 1, 2 and 3 are images of non-compliant regulated articles with clearly visible soil particles. Clumps of soil are easily seen and are large enough to be brushed away by hand. The clumps of soil and the dull cast on both the tractor and tire would allow the inspector to conclude that this tractor has not been cleaned correctly.
Figure 4. Zones of a non-compliant tire
Figure 5. Enlargement of zone B
Figures 4 and 5 are images of a non-compliant washed tire.
Zone "a" in Figure 4 clearly shows that the regulated article is not free from soil. This soil most likely fell off the fender during the cleaning process and it has obviously not been properly washed away afterward. Zone "b", however, shows both dried wash water and visible soil particles. Zone "c" shows an area where dirty wash water has dried, which would meet the fine film of dust requirement. This regulated article is not compliant.
Figure 5 is an enlargement of zone "b" in Figure 4 and shows that a light touch can easily remove the soil. It was therefore more than a fine film of dust.
Figure 6. Zones of a rear fender
Figure 6 shows an image of the same fender seen in Figure 3 after it has been cleaned. Zone "d" in Figure 6 could be considered acceptable if no more than a fine film of dust is visible after it dries although the clearly visible soil particles in zone "e" would make the regulated article non-compliant.
Figure 7, Figure 8. Compliant rear fender
Figure 7 shows another image of the fender in Figure 3 after it has had time to dry. On first glance, the dull cast could lead an inspector to think that the cleaning has not been completed correctly.
Upon closer inspection (Figure 8), it is clear there are no soil particles or debris present. The fender is now compliant. It has been thoroughly cleaned.
Figure 9. Compliant wet tire
Figure 10. Compliant dry tire
Figures 9 and 10 are images of the same washed tire. In Figure 9, the tire appears clean and no soil or debris particles are visible but a glossy and shiny wet cast can make a non-compliant regulated article appear to be compliant.
In Figure 10, there are areas with dried wash water visible on the top of the tire.
In both cases, the inspector must look closely for soil and debris particles. If the only visible soil is a fine film of dust, as seen in Figure 10, the regulated article is compliant. The inspector should not be influenced by a wet or a dull cast. In the examples, the regulated articles in both Figures 9 and 10 are compliant.
Figure 11. Non-compliant front fender
Figure 12. Compliant front fender
Figures 11 and 12 are images of a tractor front fender. Figure 11 has the same dull cast and soil particles present in Figure 3 and is non-compliant, while Figure 12 is compliant.
Though not easy to see at first glance, the key difference between the two images is the absence of soil and debris particles in Figure 12. These images show the importance of actively looking for soil and debris particles and not to base conclusions on a shiny or dull cast on the regulated article surface.
Figure 13. Non-compliant rusty metal frame
Surfaces with a rough texture or visible signs of rust require more careful examination than smooth surfaces. It can be challenging to see soil particles on a cleaned, rust-covered regulated article as presented in Figures 13 to 16.
Figure 13 shows an obvious non-compliant situation. Figures 14 and 15 are images of a wet and dry surface that is challenging to inspect.
Figure 14. Compliant wet metal frame
Surfaces with a rough texture or visible signs of rust require more careful examination than smooth surfaces. It can be challenging to see soil particles on a cleaned, rust-covered regulated article as presented in Figures 13 to 16.
The inspector must ensure there are no soil or debris particles adhering to the surface due to the presence of rust. Touching the surface to feel for raised or rough areas and/or using a cloth to ensure that there are no soil or debris particles present is recommended.
A closer inspection would reveal that the rusty portions of the equipment in Figures 14 and 15 are compliant.
Figure 15, Figure 16. Compliant dry metal frame
Figure 16 is an enlargement of Figure 15, showing that this particular surface is obviously free of soil and debris.
Note: The blue axle located behind the rust-covered regulated article in Figures 14 and 15 is non-compliant. This specific area of the regulated article would require additional cleaning to meet the "freedom from soil, plants, plant parts and related matter" requirement.
7.3 Critical inspection points
Critical inspection points are areas where soil tends to remain after cleaning has been completed. They are often areas that are difficult to access or are located in areas that tend to be missed or overlooked during the cleaning process. These areas must meet the same requirement for freedom from soil, plants, plant parts and related matter as all other parts of the regulated article. The inspector should take extra care while inspecting these areas.
Fenders and wheel wells
Wheel wells are often somewhat closed or protected by a plastic or metal liner, but others, as seen in Figure 17 (combine), are open to the inner parts of the equipment. Wheel wells are areas that are rarely forgotten during the cleaning process as tires are typically the first part of a regulated article one would think of as harbouring soil.
Figure 17. Open wheel well of a combine
Fenders and wheel wells are critical inspection points because they often contain many ridges and ledges that are difficult to see and reach during cleaning and inspection. When present, hubcaps should also be thoroughly inspected as soil and debris can become trapped behind them.
Protective covers and panels
Plates, covers, panels and safety guards protect sensitive or moving parts from damage by the elements, soil, impact, etc. Following the cleaning process, there may be soil and debris remaining in the space behind them. The hood of any vehicle should also be opened and the area around the motor inspected.
Figure 18. Open panel of a potato harvester
Figure 18 shows an example of a removable panel on a potato harvester. The inspector is responsible for locating removable plates, covers or panels and should request the owner or person in charge to open/remove them to ensure a complete inspection of the regulated article.
Figure 19. Hollow beams
Hollow beams are common on agricultural equipment and unless they have been fitted with properly fitting end caps they can easily trap soil and are very difficult locations to clean properly. Figure 19 shows an example of hollow beams: one with soil present (potato V-trailer) and another that meets the requirements for freedom from soil, plants, plant parts and related matter (fertilizers injector).
Figure 20. Non-compliant cabin
The interior of a vehicle or piece of equipment is often an area that is forgotten during the cleaning process as those responsible for cleaning typically focus on the exterior surfaces. It is a very important area to inspect as it can contain large amounts of soil and debris (Figure 20). Driver movement in and out of the cabin is considered a potential pathway for soil-borne pests. The underside of floor pedals is an example of an area that is sometimes overlooked during the cleaning process.
Electronics located in the cabin can make cleaning difficult as water may damage them but the entire area must meet the requirements for freedom from soil and debris.
Vacuum cleaners and dusting products may need to be used in conjunction with washing before the cabin can be considered free from soil and debris. If washing or other cleaning products cannot be used to clean the regulated article due to potential risk of damage, alternative treatments may be considered (see Section 8).
Moving parts are commonly found on agricultural equipment. Moving parts include conveyors, belts, chains, etc. A large proportion of the moving parts may not be visible when the equipment is not in operation (Figure 21). In order to thoroughly inspect all areas, the moving parts must be moved at least one full rotation, in small increments, by the owner or person in charge of the regulated article. Moving parts are often protected by a panel or a cover so the covered areas must also be inspected. Figure 22 shows an open view of Figure 21.
Figure 21. V-trailer conveyor
Figure 22. Open view of a V-trailer
Other moving parts such as the articulated arms found on sprayers may not be accessible or visible to the inspector. If this is the case, the inspector must ask the owner or the person in charge to deploy the moving parts so they can be inspected.
Note: It may not be possible to deploy moving parts during inspections of imported regulated articles at point of entry. If this is the case, it is important to look closely at the visible parts of the regulated article and confirm that it has been thoroughly washed.
Figure 23. Very dirty tracks
Agricultural tractors and military vehicles may have continuous tracks instead of tires. These tracks typically have large quantities of soil and plant debris associated with them (Figure 23) and are very difficult to clean to meet the requirements for freedom from soil, plants, plant parts and related matter. They have many hidden crevices and may also have panels that can trap soil.
Figure 24. Enlargement of tracks section
Figure 24 shows a crevice from which it is very difficult to remove soil. It is an enlargement of the encircled area in Figure 23, after it has been thoroughly cleaned. The metal surface is compliant, but the inspector should also look inside the crevice to confirm that there are no traces of soil or debris.
Figure 25. Non-compliant inspection location
Like all regulated articles presented for inspection, tracks get dirty easily and may be particularly susceptible to recontamination when an unsuitable cleaning and inspection location is used. Figure 25 shows an unacceptable situation where the inspector must ask the owner or the person in charge to move the regulated article to a proper location to complete the cleaning and inspection.
Figure 26. Non-compliant tractor
The under carriage of a vehicle (Figure 26) or piece of equipment is often difficult to access, and is therefore difficult to clean and inspect. It is often forgotten during the cleaning process as it is not readily visible.
Even following the most thorough cleaning, some soil or debris can often be found on the under carriage. Fingers and long handled mirrors are good tools to inspect areas that cannot be directly viewed (Figure 27). Horizontal structures often have some soil or debris remaining on top of them.
Figure 27. Fingers reveal soil
Figure 28. Non-compliant military tank
Figure 28 shows an undercarriage of a military tank that has been thoroughly cleaned with the exception of the encircled area. It is easier to inspect undercarriages in an inspection location with an even, dry and clean surface.
Grease is a very common product used during the operation of vehicles, machinery and equipment to lubricate moving parts such as wheels, articulated arms, rotating parts, hydraulic systems, etc. Some types of grease are difficult to remove, even with a high-pressure washer.
During a "freedom from soil, plants, plant parts and related matter" inspection the presence of some grease is acceptable. Small isolated particles trapped in the grease are permitted.
Figure 29 presents a good example of a grease-covered area on a potato digger. Zone "a" is covered with a blend of soil and grease, while zone "b" appears to be almost pure grease.
Figure 29. Grease covered area
"Freedom from soil, plants, plant parts and related matter" requirements would require zone "a" to be thoroughly cleaned but zone "b" would be considered compliant if no free soil or debris particles remain. A closer inspection would be necessary.
Figures 30 and 31 are images of hydraulic outlets located at the back of a tractor. This area is often covered with a blend of hydraulic oil, soil and debris (Figure 30) which can easily be removed by high-pressure cleaning equipment, especially if hot water is used. Oily soil or debris must be removed.
Figure 30. Non-compliant hydraulic outlets
Figure 31. Compliant hydraulic outlets
Figure 31 shows a picture of compliant hydraulic outlets.
8.0 Alternate treatments
In situations where it is impossible to remove the soil and debris, or for specific pests for which the removal of soil and debris is not adequate to ensure that the regulated article is free from the pest, the CFIA may accept other treatments on a case-by-case basis. Fumigation and heat treatment may be acceptable alternatives.
For example, regulated articles moving from a PCN regulated area that can not be adequately cleaned using other methods may be treated in a steam heated enclosure for 60 minutes after specifically placed temperature probes reach a minimum temperature of 60 °C. Another option would be the use of dry heat for 60 minutes at 105 °C or 45 minutes at 114 °C.
Refer to the appropriate protocols or directives or contact your local CFIA office or program specialist for further details. For alternative treatments to be effective, it is critical to use highly specialized equipment, apply appropriate protocols, and ensure adequate monitoring.
9.0 Documentation and Communication
9.1 Checklist and inspection report
A link to the inspection report and checklist form CFIA/ACIA 5668 is provided in Appendix 2. This form must be used by any inspectors performing "freedom from soil, plants, plant parts and related matter" inspections. It is a document that includes 4 sections:
- Section 1: Information on facility
- Section 2: Inspection information
- Section 3: Inspection report
- Section 4: Inspection checklist
9.1.1 Section 1: Information on facility
The inspector must record the complete coordinates of the facility responsible for the regulated article. It could be the owner of the regulated article, a transporter or a storage facility. The contact information for the person in charge must also be recorded. For traceability purposes, a complete description of the regulated article(s) to be inspected, including the quantity and any unique identifier must be provided.
It is possible to combine multiple regulated articles to be inspected in the same report but only if the inspection's conclusions are the same for all regulated articles inspected i.e. all compliant or all non-compliant. If regulated articles have a different inspection status they must each have their own inspection report.
9.1.2 Section 2: Inspection information
The inspector must indicate the exact location of the inspection. If it is the same location as recorded under "information on facility" this must be indicated. All areas of the form must be completed and it must be signed off by the inspector.
9.1.3 Section 3: Inspection report
The name of the facility responsible for the regulated article(s) to be inspected must be recorded along with the inspection location. A short description of the regulated article(s) must also be included.
The inspector must indicate the inspection result in the appropriate section. The "compliant" section must simply be checked, signed off and dated. If the regulated article is "not compliant", the inspector must indicate that the regulated article failed inspection due to the presence of soil, plants, plant parts and related matter, or that the inspection could not be completed because the requirements for inspection as identified in Section 6 could not be met. If the inspection could not be completed, the checklist must include the relevant details (see Section 9.1.4).
The appropriate notice(s) should be indicated when applicable.
9.1.4 Section 4: Inspection checklist
The inspection checklist has been developed to cover the key requirements that have been identified in this document. The requirements have been written in such a way that a "yes" indicates that the regulated article or situation is compliant and a "no" indicates that it is not compliant.
The "comments" column is provided to include important information that the inspector may want to add to clarify the specific situation. Comments are mandatory when the response to any of the criteria is "no". If the requirement does not apply to the specific situation, the inspector must write "non-applicable" (NA) in this box.
Pre-inspection requirements must be met before the inspection for freedom from soil, plants, plant parts and related matter can be performed. Failure to comply with any of these requirements would result in a termination of the inspection (see Section 9.1.3).
The "General" and "Critical points" sections are included to ensure that the regulated article is free from soil, plants, plant parts and related matter.
Inspectors are encouraged to take pictures of the inspected regulated article(s) to support their compliant or non-compliant conclusion. If pictures are taken it is important to have a general view of the regulated article and appropriate close-ups of questionable or non-compliant areas. Detailed notes should be recorded for each picture taken to ensure proper cross-referencing with the inspection report.
9.3 Communicating the Result
The inspection is complete when the inspector has a high degree of confidence that the regulated article is either compliant or not compliant. The inspector is expected to share the result of the inspection with the owner or the person in charge as soon as the result is considered final.
The final result can be given verbally and is accompanied by a copy of the inspection report (pages 1 and 2 of CFIA/ACIA 5668 - see Appendix 2 for link) and any other documents that are issued. If the regulated article is compliant it is permitted to move. If the regulated article is not compliant the inspector must explain why the regulated article failed to meet the required standard.
9.4 Record Archiving
The Checklist and Inspection Report, pictures and any related documents should be retained for a period of ten years.
Appendix 1: Legislative Authority and directives in Canada
Below are examples of Federal Acts, Regulations and CFIA directives associated with this inspection procedure, including a brief citation of the precise requirements relative to regulated articles. The list is not exhaustive and is subject to change.
Plant Protection Act
[ ...] no person shall move, grow, raise, culture or produce any thing that there are reasonable grounds to believe is a pest, that is or could be infested with a pest or that constitutes or could constitute a biological obstacle to the control of a pest.(Section 6. (1))
Plant Protection Regulations
Where the Minister or an inspector believes on reasonable grounds that a thing is a pest, or a thing or place is or could be infested or constitutes or could constitute a biological obstacle to the control of a pest, any inspector may, in order to eradicate, or prevent the spread of, the pest or biological obstacle, decide that the thing or place shall be treated or processed and may determine the treatment or process and manner of treatment or processing. (Aricle. 17.(1))
CFIA policy D-95-26: Phytosanitary requirements for soil and related matter, and for items contaminated with soil and related matter
A Movement Certificate issued by the CFIA is required to transport soil and related matter, plants with soil and items contaminated with soil and related matter from a regulated area of Canada to non-regulated areas. The appropriate condition(s) must be stated on the Movement Certificate. (Section 3.0)
Golden Nematode Infested Places Order
[...] No person except an inspector shall move a regulated thing out of an infested place unless [ ...¦] machinery, implements and vehicles have only been used on land that has not been exposed to Golden Nematode, and most of the vegetal debris and soil have been removed prior to movement, so that only a negligible quantity remains. (Section 2 (2) (c))
CFIA policy D-95-18: Seed Potato Certification Program - Investigation Procedure after Clavibacter Michiganensis Subsp. Sepedonicus has been Detected on a Seed Potato Farming Unit
[ ...] Cleanup and disinfection of equipment, storage(s), etc. must be done to the satisfaction of CFIA inspectors before consideration for the production of seed potatoes will be given to the owner of the farm unit. (Section 2.2)
CFIA policy D-08-05: Canadian Fruit Tree Export Program (CFTEP) for Malus, Pyrus, Chaenomeles, Cydonia and Prunus spp.
Sanitation and Cultural Practices: Operators must take steps to ensure that tractors and other equipment used in the CFTEP approved block are free of soil prior to entering the block. Suitable precautions must be taken to prevent the introduction of pathogen-vectoring nematodes, which may be associated with soil and could be moved into the CFTEP blocks with cultivation or spray equipment. (Section 126.96.36.199)
CFIA policy D-02-04: The Blueberry Certification Program and domestic phytosanitary requirements to prevent the spread of blueberry maggot (Rhagoletis mendax) within Canada
Used farm machinery and equipment: The equipment must have been washed completely free of soil, sand, fruits and plant debris that may harbour one of the stages of the blueberry maggot. (Section 188.8.131.52)
CFIA policy D-97-06: Plant Protection Export Certification Program for Grapevine Nursery Stock (PPECP), Vitis spp.
Suitable precautions must be taken to prevent the introduction of virus-vectoring nematodes through cultivation or spray equipment: Before cultivating or spraying grapevines under the PPECP, remove all soil clinging to wheels and other equipment parts that contact the soil. (Section 14)
Plant Protection Act
No person shall import or admit into Canada or export from Canada any thing that is a pest, that is or could be infested with a pest or that constitutes or could constitute a biological obstacle to the control of a pest [ ...]. (Section 7(1))
CFIA policy D-95-26: Phytosanitary requirements for soil and related matter and for items contaminated with soil and related matter
The importation of items contaminated with soil and related matter from all countries is prohibited. (Section 2.2)
Canadian Border Services Agency policy D19-12-1: Importation of Vehicles
Regardless of origin, imported used vehicles, farm equipment and related earth moving vehicles and equipment must be free from soil, sand, earth, plant residue, manure and related debris. (Section 76)
Note: Several Canadian provincial governments and industry association may also have various protocols, rules and regulations to control the spread of plant pests through the cleaning and sanitization of articles that are likely to be contaminated with soil, plants, plant parts and related matter.
Appendix 2 - Checklist and Inspection Report
For a copy of the Freedom from soil, plants, plant parts and related matter checklist and inspection report for vehicles, machinery and equipment (internal access only).
If you can not access the link, please contact your local CFIA office for a copy of the form.
Appendix 3 - Good Cleaning Practices
A. The cleaning process
The importation of regulated articles that are contaminated with soil and related matter is prohibited. Under exceptional circumstances, soil-contaminated goods may be imported and directed to an approved cleaning facility. Specified phytosanitary measures must also be followed for the domestic movement of regulated articles contaminated with soil, plants, plant parts and related matter from a regulated area to a non-regulated area.
A. 1 Cleaning Sites
Any cleaning site should be designed to contain any soil and debris that are removed and disposal of this waste must use methods to minimize the risk associated with any potential pests. Machinery and vehicle traffic must be avoided in the cleaning area. If a contaminated regulated article needs to be moved to a cleaning site, it must be in a sealed container or secured by a tarpaulin of sufficient size and thickness to ensure any soil dislodged during transport to the cleaning site is contained. The tarpaulin, transport container, and contaminated goods, are then considered regulated articles and therefore must also be washed in accordance with this procedure after they reach the cleaning site.
A.1.1 Imported Regulated articles
Regulated articles contaminated with soil or related matter may be permitted to enter Canada if prior arrangements are in place to send them to a CFIA approved cleaning facility before they are released to the importer.
A.1 2. Domestic Regulated articles
All regulated articles moving from a regulated area within Canada to another location within Canada, as determined by the applicable regulations, must be cleaned free from soil, plants, plant parts and related matter. The requirements for this type of cleaning site are not as specific as they are for imported items; however, the cleaning site must be selected to limit contamination of adjacent areas. It should be on a stable surface, ideally composed of asphalt, concrete or rubber, to prevent recontamination. In many situations a permanent site is not possible and a graveled or grassed area is an option, but there is an increased risk of recontamination on these types of surfaces. The appropriate pest-specific CFIA directive should be consulted when applicable.
A.1.3 Cleaning Site within an Infested Area
Regulated areas are often composed of infested (pest detected), exposed (adjacent or associated with an infested field) and non-exposed (not associated with an infested field) areas. If machinery or equipment is washed in an infested area, there is no need for water or debris to be contained, as long as it cannot enter watercourses. Water and debris can go back into the infested field but, ideally, the cleaning site should be designed to allow contaminants to be collected in a containment area.
A.1.4 Cleaning Site Outside of the Regulated Area
There may be circumstances when cleaning in the regulated area will not be possible (e.g., water and electricity are not available). In these cases, the regulated article may need to be moved to a cleaning site but a partial cleaning must be done before leaving the regulated area. The partial cleaning must be adequate to prevent soil and debris from being dislodged during transit to the cleaning site. A tarpaulin can also be used on non-moving parts to contain soil and debris en route.
A permanent cleaning site should be constructed so it is accessible to all types of machinery, but no through vehicle traffic should be permitted. It should be designed so that wash water, soil and debris reach a containment area or a storage tank. Phyiscal barriers to prevent water and contaminants from running off the site should also be in place.
A.2 Tools and equipment for cleaning
A large variety of tools and equipment may be necessary to thoroughly clean regulated articles contaminated with soil and other related matter and to provide adequate personal protection to both the inspector and the individual completing the cleaning process. For more information regarding personal protective equipment, see Section 6.2 of this inspection procedure.
The cleaning equipment must effectively remove all soil and debris adhering to machinery, vehicles or any other equipment contaminated with soil, soil related matter and plant debris. The following sections describe some different types of equipment that can be used for cleaning such regulated articles.
A.2.1 Domestic High-Pressure Washer
This type of equipment is usually electric and is used for minor cleaning due to the limited flow of water. It is a highly portable tool mainly used to clean vehicles and machinery that are not heavily contaminated with soil. It can also be used to clean small equipment and instruments (boots, probes, shovels, etc.)
A.2.2 Commercial High-Pressure Washer
This is an industrial version of the above-mentioned tool with higher pressure and uses a much larger volume of water. It includes a compressor powered by a gas engine and is equipped with a long, narrow nozzle to ensure that the water is at high pressure thus making the cleaning more effective. The nozzle can be straight, but a 45o nozzle can be very useful to clean difficult-to-reach areas, including the vehicle undercarriage and elevated parts.
A.2.3 Hot Water Cleaning Equipment
This type of equipment is usually used to clean dirty machinery or equipment. Hot water facilitates the cleaning, particularly the removal of grease and oil.
A.2.4 High-Flow Cleaning Equipment
This type of equipment is a smaller version of the equipment used by firefighters. It expels high volumes of water. It is typically used to complete the pre-cleaning of heavily soiled machinery or equipment.
A.2.5 Compressed Air
An air compressor is primarily used to clean machinery with electronic equipment that can be damaged by water. It is frequently used in combination with a high-pressure washer to complete the cleaning of the regulated article.
A.2.6 Other Tools
The following tools can be used to clean soil and debris lodged in crevices or that adhere to areas that are difficult to reach. They can also be useful when performing the post-cleaning inspection.
- Brush, broom
- Spade, spatula, scoop, knife, scraper
- Rod, probe, wire
- Tools to remove covers or guards
In order to facilitate the cleaning of the underside of the machinery, a mechanic's creeper or a mechanic's pit may be used.
A.3 Good Practices: Cleaning Procedures
A.3.1 Pre-Wash Preparations
Before beginning the cleaning process, make sure that the machinery or equipment has been properly secured and appropriate safety precautions have been taken.
All parts of the machinery that can hide contaminants and thus hamper the cleaning should be removed. Below are examples of parts that should be removed when possible and applicable:
- Spare tires
- Dual wheels and hubcaps
- Seat cushions
- Removable canopies
- Detachable running-boards
A.3.2 Washing of Vehicles, Machinery and Equipment
The type of cleaning equipment to be used and the time it will take to complete the cleaning depend on:
- The type of regulated article to be washed
- The type of work that has been done with the regulated article
- Weather conditions (wet soil vs. dry soil)
- Soil characteristics (sand, silt, clay, etc.)
- Time elapsed since the last cleaning
The interior of the regulated article should always be cleaned first. If soil and debris are dry, a vacuum cleaner or any other appropriate tools could be used. Once the interior is cleaned, the exterior surfaces should be cleaned. Cleaning should be done from top to bottom in order to prevent recontamination. Particular attention should be paid to all critical points (see Section 7.3).
If the machinery or equipment is heavily soiled, high-flow equipment may be used as a first step to remove large chunks of soil and debris. If soil adheres to the equipment or machinery, a scraper, brush, knife or any other manual tools that allow dirt and soil to be properly removed may be used. For areas that should not be washed (such as fertilizer and seed tanks that have not been emptied), manual tools should be used when soil adheres and compressed air is not effective.
Once the pre-wash has been completed, pressurized water can be applied from top to bottom to finish the cleaning. Extra precautions should be taken for pieces of equipment that could be damaged by pressurized water or compressed air. These pieces of equipment are expensive and delicate and should be protected appropriately (e.g. covered tightly with garbage bags). Water is suitable for equipment components which work under the ground and the external parts of most machinery. Use air or manual cleaning equipment for more delicate parts.
In all cases, a good knowledge of the vehicle, machinery or equipment will facilitate its cleaning.
A.4 After Cleaning
Before leaving the regulated area or cleaning site, it is important that all contaminated tools, footwear and equipment used for cleaning be cleaned. Heavily soiled clothing should be bagged and laundered before its next use and all soiled clothing should be laundered before entering an uninfested production area. If a vehicle other than the regulated article to be cleaned was used, it should also be cleaned in accordance with this procedure.
A.5 Examination by the Cleaner
The person responsible for the cleaning process should visually scan the regulated article to ensure that it is free from soil, plants, plant parts and related matter before calling the CFIA to inspect it. Section 7 explains the CFIA's requirement for freedom from soil, plants, plant parts and related matter. The CFIA inspector checklist presented in Appendix 2 provides additional details that may help the person responsible for cleaning the regulated article ensure that the requirement is met before the inspector arrives. Precautions should be taken to ensure the regulated article can be moved from the cleaning area without coming into contact with regulated soil and debris.
Appendix 4 : Recommended Combine Cleaning Procedure
A combine is a complicated piece of agricultural equipment with many specialized parts. Removal of all soil and plant debris serves as a risk mitigating measure to prevent the movement of regulated plant pests. Steam cleaning, pressure washing, or the use of forced air may be required for effective removal of soil, plants, plant parts and related matter. The combine should be cleaned systematically from front to back and top to bottom.
Below are a list of recommended steps that will assist in ensuring that the combine meets the standard specified in CFIA PI-016 although specific clean-out procedures will be dependent on the make and model of the equipment.
- Consult the Owner's Manual on cleanout procedures, access doors, component disassembly, and safety procedures.
- Choose a suitable location for the cleanup (See CFIA PI-016 Section 6.3.4; Appendix 3 A1).
- Collect appropriate personal protective equipment - eye protection, dust mask, gloves, hard hat, ear protection.
- Evaluate appropriate cleaning equipment for each area - air compressor with wands, shop-vac, leaf blower, large tarp, broom/whisk broom/steel brush, screwdriver, pressure washer and other tools as needed.
- Run discharge auger two minutes, or until grain tank and auger are clean.
- Drive combine across end rows to dislodge grain and debris before moving to the cleanout area.
- Remove grain head making sure to safely secure the feeder house with cylinder stops.
- Move combine to clean-out area.
- Place tarp under combine to capture the debris being removed.
- Inspect and clean cab roof.
- Lower feeder house and clean inside and outside. Pay special attention to areas where grain or weed seeds may catch.
- Raise feeder house and clean stone trap and remove all material.
- Clean grain tank, remove grain from top and bottom augers, ledges, corners.
- Clean the cylinder or rotor and concave threshing area and separating area by opening all access doors identified in the owner's manual and removing all material.
- Clean the straw walkers (if equipped). Open all access doors.
- Clean tailings and grain elevators by opening bottom access doors and removing grain. Empty and clean the moisture sensor if equipped.
- Clean the cleaning shoe area by removing chaffers and sieves for easier access, or by opening and closing the sieves several times to loosen debris and remove grain and debris. Access and empty lower grain cross-augers as far as possible.
- Clean rear axle, chopper and spreader areas to remove all grain and plant debris.
- Consider operating the combine with the traps open to remove additional debris but ensure that everyone is away from the running equipment.
- Ensure the radiator and radiator screen are free from soil and plant debris.
- Replace all safety shields, making sure all elevators have been reassembled and all doors and openings are closed and fastened.
- Clean the grain platform by removing stems, soil and grain from the cutter area, under platform auger and reel. Check inside auger area via inspection plates if present. Clean under side shields.
- Clean the head by removing all soil, plant debris, and loose grain. Shouts on the corn head should be lifted and vacuumed to remove grain and other plant debris.
- Ensure that the operator cab is also free from soil and plant debris. Check the cab filtration system to ensure that it is free from debris.
When the cleaning operation is complete the combine should be inspected and confirmed to meet the requirements for freedom from soil, plants, plant parts and related matter as specified in CFIA PI-016).
(Adapted from Combine Cleaning Procedure Ontario Ministry of Agriculture, Food and Rural Affairs, Ontario, 2008.)
Combine Critical Point Checklist
- Feeder house
- Clean grain auger
- Tailings auger
- Threshed grain auger
- Other auger
- Grain traps
- Tailing return trap
- Rock trap
- Cleaning fan
- Combine frame
- Tires and tire rims
- Spreader and chopper
- Chaff Spreader
- Final drive
- Radiator / radiator screen
(Adapted from Karnal Bunt SOPs for Harvest Equipment, Kansas State University Agricultural Experiment Station and Cooperative Extension Services, May 2003.)
Figure A4.1 Diagram of a grain combine showing basic functional components.
- Reel (pickup type)
- Reciprocating cutter-bar
- Stalk divider
- Conveyor auger
- Crop feeder -conveyor
- Threshing cylinder
- Stone trap
- Straw guide drum
- Straw walker
- Flap sieve
- Twin-nose sieve
- Bottom sieve
- Fan blower
- Grain auger and grain elevator
- Tank-filling auger
- Tank auger and unloading auger
- Header unit
- Threshing system
- Winnowing and cleaning systems
(Adapted from Handbook of Post-harvest Technology, Edited by Hosahalli S . Ramaswamy, G. S. Vijaya Raghavan, Amalendu Chakraverty, and Arun S. Mujumdar, CRC Press 2003, Chapter 4. pages 57-117.)
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