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Quality System Manual
for
Authorized Certification Official (ACO) Program
for the Signing of Phytosanitary Certificates

Copy No.  
Issued No.  

Plant Health Division
Canadian Food Inspection Agency
59 Camelot Drive
Ottawa, Ontario
K1A 0Y9


TABLE OF CONTENTS

REVIEW

ENDORSEMENT

AMENDMENT RECORD

DISTRIBUTION

INTRODUCTION
1.1 SCOPE
1.2 REFERENCES
1.3 DEFINITIONS, ABBREVIATIONS AND ACRONYMS
1.4 OUTLINE OF THE ACO PROGRAM

2.0 AUTHORITY

3.0 MANAGEMENT RESPONSIBILITY
3.1 PROGRAM RESPONSIBILITY
3.2 OPERATIONS RESPONSIBILITY

4.0 REQUIREMENTS
4.1 BASIC QUALIFICATIONS OF AN ACO
4.2 TRAINING AND EVALUATION
4.3 PROCEDURE FOR AUTHORIZATION
4.4 PROCEDURE FOR RENEWED AUTHORIZATION
4.5 PHYTOSANITARY CERTIFICATION REVIEW PROCESS
4.6 SUSPENSION AND RE-AUTHORIZATION
4.7 RECORDS

5.0 AUDIT
5.1 PROGRAM AUDIT
5.2 REVIEW BY NAPPO

6.0 APPENDICES
APPENDIX 1: AUTHORIZED CERTIFICATION OFFICIALS (ACO) CHECKLIST
APPENDIX 2: ADMINISTRATIVE GUIDELINES FOR THE ACO TRAINING PROGRAM
APPENDIX 3: CERTIFICATE OF TRAINING
APPENDIX 4: ACO ASSESSOR'S QUARTERLY ACTIVITY REPORT
APPENDIX 5: ACO ASSESSOR'S REVIEW RECORD
APPENDIX 6: CORRECTIVE ACTION REQUEST

REVIEW

This Quality System Manual (QSM) for the Authorized Certification Officials (ACO) Program is subject to periodic review. Amendments will be issued to ensure the QSM continues to meet current needs.

ENDORSEMENT

This Quality System Manual for the ACO Program is hereby approved.

_________________________________________________
Quality System Documents Committee Representative
____________
Date
_________________________________________________
Director, Plant Health Division

AMENDMENT RECORD

Amendments to this QSM will be given a consecutive number and will be dated.

Please ensure that all amendments are inserted, obsolete pages removed, and the record below is completed.

Amendment No. Amendment Content and Pages Entered by: Date:
1 Clarification for date of authorization of the ACO, Section 4.3.4, page 12 Andrew Lam Sept19/03
2 Clarification for date of authorization of the ACO on the Certificate of Training - page 25 Andrew Lam Sept 19/03
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DISTRIBUTION (Controlled Copies)

Name Position Copy No.
Yudi Singh A/Director, Plant Health Division 1
Cameron Prince Executive Director, Atlantic Operations Area 2
Yvon Bertrand Executive Director, Quebec Operations Area 3
Bill Teeter Executive Director, Ontario Operations Area 4
Phil Amundson Executive Director, Western Operations Area 5
Jarvis Mawhinney Director, Plant Programs Network 6
Daniel Dansereau Director, Plant Programs Network 7
Doreen Moore Director, Plant Programs Network 8
Gary Koivisto Director, Plant Programs Network 9
Andrew Lam National ACO Coordinator 10
Dawn Miller-Cormier Area ACO Coordinator, Atlantic 11
Jacques Audette Area ACO Coordinator, Quebec 12
Louise Sharpe Area ACO Coordinator, Ontario 13
Rob Ormrod Area ACO Coordinator, Western 14

INTRODUCTION

1.1 SCOPE

The quality system (QS) described in this manual covers the ongoing management of the Authorized Certification Official (ACO) program and the implementation of the requirements for a Canadian Food Inspection Agency (CFIA) inspector to be certified as an ACO under the North American Plant Protection Organization (NAPPO) Standard for The Accreditation of Individuals to Sign Federal Phytosanitary Certificates.

1.2 REFERENCES

  • NAPPO, 2000. NAPPO Standards for Phytosanitary Measures - The Accreditation of Individuals to Sign Federal Phytosanitary Certificates, RSPM #8 October, 2000.
  • NAPPO, 1999. NAPPO Glossary of Phytosanitary Terms. RSPM #5
  • Plant Protection Act, s.c. 1990, c.22
  • Plant Protection Regulations, SOR/95-212
  • Plant Health Division Policy Directive, D-99-06: Policy on the Issuance of Phytosanitary Certificates.

1.3 DEFINITIONS, ABBREVIATIONS AND ACRONYMS

Note 1: For simplicity, the mention of Phytosanitary Certificates shall also imply Phytosanitary Certificates for Re-export unless a specific distinction is being made.

Note 2: The definitions of Area ACO Coordinator, ACO Evaluator, and Phytosanitary Certification Assessor are intended to show the functions which have to be carried out by staff in the Operations Branch for the management and maintenance of the ACO Program. These are not positions which must be created by the Operations management. But the functions must be carried out by staff designated by the Area Executive Director, in consultation with the Plant Program Network Director. It is conceivable that the same person could be performing the functions of an Area ACO Coordinator as well as an ACO Evaluator, or the functions of an ACO Evaluator as well as a Phytosanitary Certification Assessor. These functions may be carried out by Operation or Program Network staff as is deemed appropriate for the Operational Area..

ACO Evaluator: The person designated to mark the ACO evaluations, conduct practical evaluations / assessments as required by the ACO Program, and interpret the content of the training material as required. This person must have experience with the phytosanitary certification process, knowledge of the relevant policies, the ACO Program, the QSM, and any relevant training material. This person must have also successfully passed any formal training evaluation, e.g the Export Certification Training Module.

Area ACO Coordinator: The person within an Operations Area, designated to coordinate activities related to the ACO program in the Area.

Area Training Officer (ATO): The person within the Operations Management structure tasked with the duties of the Area Training Officer or Area Training and Development Coordinator.

Authorized Certification Official (ACO): A public officer who is authorized by the National Plant Protection Organization (NPPO) and accredited for the signing of phytosanitary certificates, on the basis that he / she: 1) possesses the required education, experience, and training; and 2) has written confirmation of having successfully passed an approved examination (NAPPO, 1999). In Canada, Plant Health Division (PHD) is the NPPO. The ACO must be a person designated as an inspector pursuant to Section 21 of the Plant Protection Act.

CFIA: Canadian Food Inspection Agency

Manager or Supervisor: For the purpose of the ACO Program, this is the person with supervisory responsibility for a particular ACO.

National ACO Coordinator: The person who is designated by the Director of PHD to coordinate activities related to the ACO program at the national level.

NPPO: National Plant Protection Organization

Operations Program Officer (OPO): The person(s) within an Operations Area who form a liaison between the Operations and Program Branches. The OPO is often the first point of contact for inspection staff seeking guidance or interpretation of program standards. They monitor the delivery of programs for adherence to set standards and identify the need to modify program standards when required. Another major role of the OPO is to work with various industry groups and provincial / municipal governments to understand the import requirements of foreign countries and how CFIA delivers the export certification programs. The OPO provides basic training for the ACO.

PHD: The Plant Health Division, CFIA. It has the lead role in the development, maintenance and tracking of programs in support of the Plant Protection Act and Regulations and all associated legislation administered by the CFIA.

Phytosanitary Certification Assessor: Phytosanitary Certification Assessor: The person responsible for the regular assessment of the phytosanitary certification process and phytosanitary certificates issued by an ACO. This could be the OPO or Program Specialist, who already has the responsibility to provide program guidance to inspectors on such matters as how to issue phytosanitary certificates correctly. This person must have successfully completed the ACO training and have no less than one year of phytosanitary certification experience.

Program Specialist: Plant Program Network within an Operations Area may have Program Specialists in different programs. The Program Specialist provides interpretation of and advice on program policies and standards, including export certification, to Operations staff and clients of the CFIA.

PTDD: The Professional and Technical Development Division, CFIA. It has the lead role in coordinating the development, maintenance and tracking of official training programs, including those which support the certification of CFIA staff to conduct defined activities or functions. It is also responsible for the maintenance of an official list of ACOs.

QS: Quality system

QSM: Quality System Manual

1.4 OUTLINE OF THE ACO PROGRAM

The ACO Program of the CFIA is a program run jointly by the Programs and Operations Branches to accredit inspectors for the issuance of Phytosanitary Certificates for export and re-export purposes. The accreditation conforms with the NAPPO Standard for the Accreditation of Individuals to Sign Federal Phytosanitary Certificates.

Under this program, inspectors must meet education and experience standards as prescribed in Section 4 of this document, receive the appropriate training and successfully complete an evaluation (examination) with a mark of 80% or higher, before they are authorized as ACOs to sign and issue Phytosanitary Certificates. Both the supervisor of the ACO candidate and an OPO or Plant Health Program Specialist will have to co-sign an Authorized Certification Officials (ACO) Checklist (APPENDIX 1) to attest to the ability, knowledge and experience of the candidate prior to the candidate being admitted to the evaluation.

As prescribed by the NAPPO Standard, the status of an ACO is valid for three years, after which the inspector or officer will need to be re-evaluated to renew the ACO status according to section 4.4 in this QSM.

There is a phytosanitary certification review process, as described in Section 4.5 of this QSM, for the ongoing assessment of the performance of the ACOs. Comprehensive program audits will also be conducted from time to time. The first program audit will be conducted three years after the implementation of the QS, and thereafter at an interval to be determined by the Director of Plant Health. Together, the phytosanitary certification assessment and program audit will ensure that the integrity of the Canadian phytosanitary certification system is maintained.

The following table summarizes the essential components of the ACO Program:

Components Requirements Responsibility
1) Basic qualifications Education, experience & training as prescribed in 4.1 in the QSM Supervisor of ACO candidate and OPO or Program Specialist to verify
2) Evaluation (examination) Successful completion of the Export Certification Training Module with 80% or higher evaluation score PHD & PTDD: training material
ATO: coordination
ACO Evaluator: marking evaluation
3) Authorization Certificate of Training (App.3) issued after satisfying 1) and 2) above Approved by Regional Director (RD) and Network Director (ND)
4) Ongoing assessment Assessment of phytosanitary certificates issued by ACO and certification process Phytosanitary Certification Assessor
5) Program audit Periodic comprehensive program audit PHD
6) Re-authorization 3 years after last authorization, or required by non-conformance (4.3 & 4.5 in the QSM) PHD & PTDD: method and process RD & ND: approval

2.0 AUTHORITY

The authority of an inspector is drawn from Sections 21 and 22 of the Plant Protection Act, s.c. 1990, c.22. Under the NAPPO Standard for the Accreditation of Individuals to Sign Federal Phytosanitary Certificates, which was approved by Canada, the US and Mexico in October, 2000, a CFIA inspector or officer is required to be certified as an ACO in order to sign Phytosanitary Certificates.

3.0 MANAGEMENT RESPONSIBILITY

3.1 PROGRAM RESPONSIBILITY

The responsibilities of the Plant Protection Program management are as follows:

3.1.1 To participate on the NAPPO Accreditation Panel for the verification that the NAPPO Standard is being applied consistently across member countries;

3.1.2 To discuss any amendment or update of the NAPPO Standard with NAPPO member countries;

3.1.3 To provide the overall direction and interpretation of the ACO Program requirements to Operations;

3.1.4 To coordinate with PTDD and Operations for the required training and evaluation to take place;

3.1.5 To update and amend the ACO QS and this Manual as required;

3.1.6 To audit Operations for the implementation of the ACO Program according to the QSM.

3.2 OPERATIONS RESPONSIBILITY

The responsibilities of Operations management, i.e. the Area Executive Director and Regional Directors, are as follows:

3.2.1 To implement the ACO Program according to the QSM;

3.2.2 To ensure that inspectors meet the ACO requirements prior to being able to sign Phytosanitary Certificates;

3.2.3 To maintain the list of current ACOs in each Operations Area;

3.2.4 To provide feedback to PHD for continuous improvements of the QS for the ACO Program.

4.0 REQUIREMENTS

4.1 BASIC QUALIFICATIONS OF AN ACO

ACOs must meet the criteria outlined in the NAPPO Standard based on a combination of training, experience and education, with the following standards established by the NPPO:

4.1.1 Level of Education: An ACO candidate must have gained knowledge of plant health through workshops, on the job training, or taken secondary or higher level courses in such subjects as: biology, biotechnology, botany, crop science, entomology, forestry, horticulture, nematology, pest control, pest management, plant ecology, plant identification, plant pathology, plant physiology, plant taxonomy, virology, or weed science.

4.1.2 Level of Experience: A minimum of one year's experience in plant protection regulatory activities working with or under the supervision of an ACO. This experience must occur immediately prior to becoming an ACO. Officials who do not perform certification within a year of completing the basic export certification training requirement, or ACOs who have not performed certification for more than two years are required to complete 60 days of experience under an ACO and complete a refresher course as required.

4.1.3 Training: An ACO must receive the minimum export certification training as prescribed in Section 4.2.

4.1.4 Evaluation (examination): An ACO must be evaluated as prescribed in Section 4.2.

4.2 TRAINING AND EVALUATION

4.2.1 In addition to meeting the education and experience requirements as described in section 4.1.1 and 4.1.2, an ACO must also meet the following training requirements.

4.2.1.1 Export certification Training: An ACO candidate is required to successfully complete the Training Module: Export Certification - Authorization of Staff to Sign Phytosanitary Certificates, and pass an evaluation (examination) by attaining a mark of 80% or higher.

4.2.1.2 Additional Training: The Plant Protection Program may require the successful completion of additional formal training for an ACO. Such formal training shall be nationally endorsed and incorporated into the ACO program, as required.

4.2.1.3 National Endorsement of Training Programs: Endorsement of training programs and courses related to the ACO Program shall consist of an approval statement signed by the Director, PHD and the National Manager of the Professional and Technical Development Division (PTDD).

4.2.1.4 Official Copies of Training Courses: The PTDD shall be responsible for filing and maintaining the official, master copy of training material under the control of CFIA. The PTDD shall be responsible for the distribution of the training material in accordance with agreements among the Programs and Operations Branches of the CFIA.

4.2.1.5 Amendments to Training Material: The PTDD shall coordinate amendments to the training material based on input from the users and the PHD Program management. The PTDD shall track and distribute any substantive amendments to the nationally endorsed training material. Amendments to the training material shall be made in response to substantive changes to the NAPPO Standard or Program policies and standards. Additional training sessions may need to be delivered depending upon the nature of the changes.

4.2.1.6 Periodic Review: In addition to amendments to the training material necessitated by changes to the NAPPO Standard or Program policies and standards, nationally endorsed training material is subject to regular, periodic review by the PTDD and the PHD. The frequency of the review shall be stated in the official copies of the training material.

4.2.1.7 Administrative Guide: The PTDD shall develop and maintain an administrative guide that outlines the administration of the training and evaluation related to the ACO program (see APPENDIX 2).

4.2.2 Evaluations of ACO candidates shall be developed according to the criteria set out in this QSM and administered according to the guidelines described in the Administrative Guidelines for the ACO Training Program. These procedures shall also apply to re-evaluations associated with performance assessment and renewed authorizations of ACOs.

4.2.2.1 National Bank of Questions: National Bank of Questions: The PTDD shall maintain a National Bank of Questions from which evaluation sets will be designed. The PTDD shall put in place a method to receive feedback on the evaluation sets to incorporate improvements as required. The National Bank of Questions shall be reviewed annually by PHD and amendments shall be made to reflect current program policy interpretations and procedures. The PTDD shall coordinate the review process.

4.2.2.2 Control of Evaluations: The PTDD shall have administrative control of the Evaluation Sets used in the ACO Training Program. Evaluation Sets will have version controls in place. Master copies of the versions shall be maintained by the PTDD for a period set out by the CFIA guidelines for the retention of records.

4.2.2.3 Scheduling of Evaluations: Regular evaluations shall be scheduled for the second Thursday of June and December. The PTDD shall provide the ATOs with two months notice of the scheduled evaluations. The ACO, upon the request of an Area ACO Coordinator, may schedule a candidate's evaluation outside of these dates if there are reasonable grounds, e.g., sickness, leave of absence, or critical operational requirements. A candidate who has not yet fulfilled the experience requirement as described in Section 4.1.2 may take the evaluation, but will not be authorized as an ACO until the experience requirement has been met.

4.2.2.4 Scheduling of Re-evaluations: An ACO candidate who does not attain 80% or higher in the evaluation is entitled to a re-evaluation within three months of the first evaluation, as arranged by the ATO and the Area ACO Coordinator. A candidate can be re-evaluated only once, after which he / she will have to wait until the next scheduled evaluation.

4.2.2.5 Marking of Evaluations: Marking of Evaluations: The evaluations shall be marked by an ACO Evaluator. The ACO Evaluators shall receive from the Area ACO Coordinators periodic training related to the ACO program interpretation and direction.

4.2.2.6 Results of Evaluations: Results of the evaluations shall be recorded as either meeting or not meeting the evaluation standard. Once completed, evaluations are considered confidential information. Distribution of information about the evaluations shall be governed by the confidentiality guidelines regarding personal information established by the CFIA. Results of evaluations (i.e. meeting or not meeting the evaluation standard) shall be forwarded by the ACO Evaluator to the ATO, the Area ACO Coordinator, and the Supervisor of the ACO candidate. The ACO Evaluator shall provide written, confidential notice of the result of the evaluation (including mark achieved) to the candidate. The notice shall include the procedure for requesting a review of the evaluation. The actual mark achieved by the candidate is considered confidential information.

4.2.2.7 Review of Evaluations: A candidate is allowed to request a review of the evaluation with the ACO Evaluator who marked the evaluation. A candidate may view their evaluation sets but can not mark, retain, or make copies of the documents.

4.2.2.8 Challenge of Evaluation: The ACO Evaluator will strive to resolve concerns regarding the marking of an evaluation. If concerns can not be resolved, the candidate may request that the evaluation be reassessed by an ACO Evaluator from another Area. Such requests shall be made to the candidate's ATO, who will make arrangements for the re-assessment according to the Administrative Guidelines.

4.3 PROCEDURE FOR AUTHORIZATION

A candidate shall be recognized as an ATO provided the following criteria have been met:

4.3.1 Completion of the Required Course: An ACO candidate must complete the required course as described in Section 4.2.1.1.

4.3.2 Achievement of the standard set for the evaluations: The standard set for the evaluations shall be provided in the official copies of the training material. For example, the standard set for the training module Export Certification - Authorization of Staff to Sign Phytosanitary Certificates is 80% based on open book tests featuring a combination of true / false; matching; multiple choice; short Answer; and the completion of forms.

4.3.3 Attestation of Program Experience: The Manager / Supervisor of the ACO candidate, together with an OPO or Plant Health Program Specialist will have to co-sign an Authorized Certification Officials (ACO) Checklist (APPENDIX 1) to attest to the candidate's ability, knowledge and experience in the Plant Protection Program prior to the candidate being admitted to the formal evaluation (examination). This Checklist is to form part of the official record for the candidate.

4.3.4 Issuance of ACO Certificate: The issuance of an ACO Certificate (APPENDIX 3) shall be arranged by the ATO, if the criteria set out in Sections 4.3.1 to 4.3.3 have been met. The certificate shall be signed by the candidate's Regional Director and Plant Program Network Director, and the date of issuance on the certificate shall be the date of authorization of the ACO, and is the date of the notification letter issued to the ACO candidate by the ACO evaluator. An ACO's certification status shall expire in the third year following the date of issue.

4.4 PROCEDURE FOR RENEWED AUTHORIZATION

The authorization of an ACO is required to be renewed three years after the issuance of their ACO certificate. The PTDD shall review the official list in January and provide notification to the ATOs as to which ATOs would need to have their authorization renewed. The following procedure for renewed authorization applies to someone who has maintained his/her standing in the program. See Section 4.6 for procedures to follow for ACOs who have been suspended from the program for inactivity or other reasons.

4.4.1 Re-certification training: An ACO must undertake re-certification training based on a combination of the fundamentals covered in the basic training and training developed to reflect local Area issues. The Area ACO Coordinator shall be responsible for ensuring that local Area issues are identified for training purpose. The PTDD shall coordinate development of training material for re-certification purpose.

4.4.2 Re-certification Evaluations: Evaluations for re-certification shall be developed through the coordination of PTDD, and endorsed by the Director of Plant Health Division and PTDD.

4.4.3 Administration of the Re-certification Evaluations: Evaluations shall be administered in accordance with the procedures outlined for initial evaluations as described in this document and the Administrative Guidelines.

4.5 PHYTOSANITARY CERTIFICATION REVIEW PROCESS

4.5.1 Purpose

The purpose of the phytosanitary certification review process is to ensure that Phytosanitary Certificates are issued in a manner that is consistent with the CFIA Policy on the Issuance of Phytosanitary Certificates (D-99-06), to ensure that the phytosanitary certification system meets international obligations such as the NAPPO phytosanitary standards for the accreditation of individuals to sign federal Phytosanitary Certificates, and to foster an environment of continuous improvement.

4.5.2 Method

The phytosanitary certification review process includes the assessment of individual certificates, the assessment of the processes used to support the Phytosanitary Certificate and an overall assessment of the compliance of phytosanitary certification system as prescribed in D-99-06, Policy on the Issuance of Phytosanitary Certificates.

The assessments shall be conducted in such a manner as to maximize the possibility of identifying improvements for overall compliance to the requirements of phytosanitary certification. Identified corrective actions are to be undertaken to support improvement of the overall phytosanitary certification system.

All ACOs will be assessed at least once a year. Each Assessor shall ensure that he/she has conducted certificate and process assessments (see 4.5.3.1 and 4.5.3.2) at least once a year for each ACO assigned to them. A Phytosanitary Certification Assessor who is also an active ACO shall not review his / her own work.

A Quarterly Activity Report for ACO Review (APPENDIX 4) shall be completed by each Assessor and maintained for three years by the Phytosanitary Certification Assessor. These reports will be available to the Area ACO Coordinator as required. Each Assessor shall also maintain a Review Record after each review of an ACO (APPENDIX 5).

4.5.2.1 Assessment of Certificates

The selection of Phytosanitary Certificates for review may be random or targeted. Normally, the selection will be on a random basis. However, the following criteria should cause the selection to be targeted: specific requests or complaints received from a foreign country or the Plant Protection Program, complexity of the export, frequency of issuance (e.g. non-routine issuance), or past problems identified by the Manager / Supervisor of the ACO, an OPO or a Plant Health Program Specialist. Appropriate assessment of a certificate may require input from the issuing ACO and others involved in the inspection and certification of the shipment.

4.5.2.2 Assessment of Process

The assessment of processes undertaken in support of phytosanitary certification shall involve the selection of issued Phytosanitary Certificates, a review of documentation available in support of the issued certificates and an interview with the ACO(s) who issued the certificates. Recognizing that the phytosanitary certification process may involve the refusal to issue a certificate based on ineligibility of a product, the assessment of the process may also include a review of the documentation in support of a refusal to certify. Assessments shall determine if the established policies and procedures were applied in support of certification or rejection.

4.5.3 Non-conformance

During the phytosanitary certification review process, deviations from established policies and procedures could be identified. Deviations could be related to the conduct of activities in support of the issuance of Phytosanitary Certificates (process oriented), or the completion of the Phytosanitary Certificates (document oriented). Upon their identification, the Assessor shall discuss the deviation with the ACO to determine the reason for the deviation. In the event that the deviation is not supported by valid reason, it shall be deemed to be a non-conformance. If supported, the circumstances of the deviation may be brought to the attention of the Operations and Program Management to determine if changes to established policies and procedures are warranted.

4.5.3.1 Types of Phytosanitary Certificate Non-conformance

Three types of non-conformance are described. The following subsections identify these types of non-conformance and offer for each, examples arising from process and document deviations. The examples are not exhaustive, but are offered to provide guidance to the Phytosanitary Certification Assessor.

4.5.3.1.1 Critical Non-conformance

A critical non-conformance has or could result in the rejection or destruction of a shipment. This is considered to be a phytosanitary system failure. Examples are:

A) a prohibited or ineligible product is certified
B) the origin of a product is not established when critical to its phytosanitary status
C) required treatments are not verified for conformance to procedures

4.5.3.1.2 Major Non-conformance

A major non-conformance could result in the detention of, or the rejection of a shipment. A foreign NPPO may determine that an extended inquiry into the acceptability of a product may be required because the shipment or the accompanying documentation raises doubts as to the phytosanitary status of the shipment. Examples are:

A) conditions prescribed by the FPQIR and associated documentation such as Permits to Import or special instructions from the Export/Import Section of the Plant Health and Production Division are not followed
B) Phytosanitary Certificate issued for a non-regulated product
C) regulatory information not kept up to date
D) inspection staff not informed of regulatory conditions affecting inspection procedures
E) missing, incomplete or incorrect additional declarations
F) incorrect scientific name for a commodity or pest
G) Phytosanitary Certificate not stamped
H) importer country differs from country of destination at the top of the Phytosanitary Certificate
I) missing, incomplete or incorrect treatment descriptions
J) issuance of an unsigned Phytosanitary Certificate
K) no country of destination listed on the Phytosanitary Certificate
L) no Canadian exporter listed on the Phytosanitary Certificate

4.5.3.1.3 Minor Non-conformance

A minor non-conformance suggests the need for improvement in performance. In, a single incidence, a non-conformance may be deemed minor, but repeated minor non-conformance could jeopardize the integrity of the phytosanitary certification process. The cumulative effect of repeated minor non-conformance impacts both the national and international perception of the Canadian phytosanitary certification system. Examples are:

A) spelling errors in areas other than address or reference blocks
B) trade information entered in an inappropriate place on the Phytosanitary Certificate
C) improper address format on the Phytosanitary Certificate
D) using a language other than English or French except in the address of the consignee.

4.5.4 Corrective Actions

A Corrective Action Request (CAR) (APPENDIX 6) will be used as a tool for the Phytosanitary Certification Assessor to action and document follow up actions required on any un-supported phytosanitary system non-conformance. Because of the nature of phytosanitary certification, most corrective actions will be for future application, although some will be candidates for immediate action if the shipment in question has not reached its final destination.

A CAR will be issued when the Assessor has made an assessment that a non-conformance has occurred that may be considered critical or major, or the Assessor feels an excessive number of minor non-conformance have occurred.

The elements of the CAR will include: identification of the issue; the urgency (time frame); level of involvement, i.e. local or national management, for resolution; and the responsibility for resolution.

4.6 SUSPENSION AND RE-AUTHORIZATION

4.6.1 No Certification Activity: An ACO who, upon the regular phytosanitary certification review by the Phytosanitary Certification Assessor, has been found not to have carried out phytosanitary certification activities for a period of two (2) years or more, shall be suspended from the program until a 60 day certification experience under another ACO has been completed.

4.6.2 Failure to Meet Re-certification Evaluation Standard: An ACO shall be suspended from the program if he/she fails to meet the evaluation standard set for the re-certification process.

4.6.3 Certification Assessment Problems: If a phytosanitary certification review has found un-supported non-conformance which are critical or major, as indicated in Section 4.5, the ACO may, upon recommendation of the Phytosanitary Certification Assessor, be suspended from the program until corrective actions requested in the CARs have been implemented.

4.6.4 Re-authorization of a Suspended ACO: A suspended ACO may be granted re-authorization if he/she has completed renewed certification experience required as the result of inactivity, implemented corrective actions following a phytosanitary certification review, or completed any necessary re-certification training. The responsible Phytosanitary Certification Assessor and the supervisor shall jointly indicate to the Area ACO Coordinator that all re-certification requirements have been met, and recommend the re-authorization of the suspended ACO.

4.7 RECORDS

The following records shall be maintained in support of the ACO Program. The records shall be maintained in accordance with any CFIA and Canadian government requirements and guidelines for confidential personnel information.

4.7.1 Training Records: The training records for an individual shall be maintained by the training group responsible for the records of that individual. For an Operations Inspector or Officer, this person would be the Area Training Officer.

4.7.2 Initial and Re-certification Evaluations: The completed evaluation documents and the marks of an evaluation are considered confidential information. The completed evaluation documents are to be filed with the responsible training group in the candidate's personal file. The documents are to be retained for the length of the authorization period. Whether or not a candidate has met the standard for the evaluation is recorded in the training database maintained by the responsible training group.

4.7.3 Program Experience and Restrictions: Attestations of program experience and any restrictions regarding the certification duties of an ACO are to be maintained by the responsible training group in the training file for that ACO. Any restrictions on certification duties are to be recorded in the Official List of ACOs.

4.7.4 Official List of ACOs: The PTDD shall maintain a detailed official list of ACOs and their status. An abbreviated list with names of the ACOs and their office locations shall be posted by the Plant Health Division in the CFIA intranet (Merlin). The same abbreviated list shall be incorporated in the Export Certification System (ECS). A candidate's name is entered on the official list after PTDD receives the notice from the ATO that an ACO certificate has been issued for the candidate. The ATOs shall notify PTDD, every quarter, of any changes in the status of the ACOs resident in their Area.

The detailed official ACO list shall contain the following information:

Name of the ACO
Region, Network, or work location other than Region or Network
Date of initial authorization, i.e. date of first successful passing of the formal evaluation (examination)
Date of last authorization
Restrictions on Certification Activity, if any
Date the list was last updated

5.0 AUDIT

The audit of the ACO Program shall be conducted according to the following criteria:

5.1 PROGRAM AUDIT

A comprehensive ACO Program audit is to be conducted not later than three years after the implementation of the QS, and subsequently at a frequency determined by the Director of PHD.

5.1.1 Responsibility

The National ACO Coordinator is responsible for ensuring an ACO Program audit is carried out at the required interval. The program audit is to be included in the annual program audit plan of PHD for submission to the Planning, Performance and Program Review Division (PPP&R). The normal procedure and protocol for CFIA program audit is to be followed.

5.1.2 Audit Criteria

The following audit criteria are to be followed. Other criteria may be added as deemed appropriate by the National ACO Coordinator, in consultation with the Director of PHD, Area ACO Coordinators, the (PPP&R), and PTDD.

5.1.2.1 The ACO list is up to date

5.1.2.2 The ACO Evaluators have taken all required training

5.1.2.3 The regular review of the phytosanitary certification process and certificates have been carried out according to section 4.5.

5.1.2.4 Guidelines are being followed regarding training, evaluations and records

5.1.2.5 Confidentiality guidelines are being followed

5.1.2.6 Training material is up to date

5.1.2.7 Operations Areas are using up to date training material and evaluations

5.1.2.8 Program experience attestations are properly completed

5.1.2.9 ACOs have successfully completed the required courses as described in sections 4.1.1, 4.2.1.1. and 4.2.1.2, and achieved the experience levels

5.1.3 Result of Audit

The program audit report and corrective actions requested are to be forwarded to the Director of the PHD who will track the implementation of the corrective actions.

5.2 REVIEW BY NAPPO

The CFIA ACO Program will be reviewed by representatives of NAPPO for conformance with the NAPPO Standard: The Accreditation of Staff to Sign Federal Phytosanitary Certificates. The timing and criteria of the review will be determined by the NAPPO Accreditation Panel or the NAPPO Executive Committee. The first review of the Canadian ACO Program has been set to take place in June, 2002.

6.0 APPENDICES

Appendix 1: Authorized Certification Officials (ACO) Checklist
Appendix 2: Administrative Guidelines for the ACO Training Program
Appendix 3: Certificate of Training
Appendix 4: ACO Assessor’s Quarterly Activity Report
Appendix 5: ACO Assessor’s Review Record
Appendix 6: Corrective Action Request

APPENDIX 1: AUTHORIZED CERTIFICATION OFFICIALS (ACO) CHECKLIST

The Export Certification - Authorization of Staff to Sign Phytosanitary Certificates module may be completed at any time, but the following pre-requisites must be satisfactorily completed prior to recommending a candidate to complete the module examination. The signers of the Checklist should provide justifications on a separate sheet when recommending candidates on borderline situations.

Name of ACO Candidate Recommended: _____________________________________

Ability Yes No
Has the candidate demonstrated the ability to:
Apply sound judgement that appropriate phytosanitary procedures have been carried out in accordance with policies and procedures?
Apply principles and make sound judgement regarding anomalies and violations?
Has the candidate demonstrated the ability to properly complete the steps in the phytosanitary certification process, e.g.

1. process a request for certification?
2. identify appropriate requirements?
3. communicate required phytosanitary measures?
4. verify that appropriate measures have been carried out?
5. process certificates?
   
Knowledge Yes No
Has the candidate demonstrated a knowledge of:
Theory and principles of plant protection?
Legislation and requirements that authorize phytosanitary certification?
   
Experience Yes No
Does the candidate possess a minimum of 1 year experience in plant protection regulatory activities with or under the supervision of an ACO?

Was this experience obtained immediately prior to applying to become an ACO?
   


__________________________
Immediate Supervisor


__________________________
Officer/Specialist, Plant Protection Program

APPENDIX 2: ADMINISTRATIVE GUIDELINES FOR THE ACO TRAINING PROGRAM

1. Purpose of Guide

2. Purpose of Training

3. Responsibilities of Area Training Officers

3.1 Receive training requests from Area ACO Coordinators
3.2 Contact Area ACO Coordinators to schedule training
3.3 Distribute required training material
3.4 Coordinate required training resources
3.5 Maintain files of evaluations according to CFIA guidelines for file retention
3.6 Maintain records of training (databases) for Area and Network staff
3.7 Arrange issuance of authorization certificates for successful candidates

4. Responsibilities of Area ACO Coordinators

4.1 Provide liaison for training and evaluation for ACO Program in the Area
4.2 Receive requests for training from Inspection Managers or supervisors of the ACO candidates
4.3 Schedule training with ATO and provide advisory role regarding use of training material
4.4 Manage the input for the content of training material
4.5 Oversee the administration of the evaluations
4.6 Act as Evaluators (if qualified) or arrange for qualified Evaluators to conduct assessments
4.7 Receive information from Evaluators for candidates meeting or not meeting the evaluation standard
4.8 Receive requests for re-training and re-evaluations, including requests by supervisor of the ACOs requiring re-training or re-evaluation as identified in any CAR resulting from the regular phytosanitary certification review
4.9 Arranges with the ATO for remedial training of an ACO as required
4.10 Oversee the administration of the evaluations of remedial training as required
4.11 Resolve concerns regarding marking of evaluation, including arranging for re-evaluation of the original evaluation result
4.12 Arrange with another Evaluator for re-evaluation as required
4.13 Act as an independent Evaluator for re-evaluation if qualified, and as required
4.14 Periodic training of ACO Evaluators and Phytosanitary Certification Assessors related to program interpretation and direction
4.15 Support ACO program audit in the Area
4.16 Take part in program audits as deemed appropriate by the National ACO Coordinator, and if qualified as an auditor according the the CFIA Audit Protocol.
4.17 Work with the National ACO Coordinator to update or modify the ACO Program and the QSM for the ACO Program, as required.

5. Tips for Preparing the Training Sessions

5.1 Requesting Training: A candidate seeking training under the ACO program shall submit a completed CFIA/ACIA 4623E - Training Application and Authorization to the ATO.
5.2 Scheduling of Training: Upon receipt of a request for training, the ATO shall contact the Area ACO coordinator as to their availability as a resource. The ATO shall also discuss arrangements for training time with the supervisor or manager of the candidates.
5.3 Obtaining Training Materials: The ATO shall obtain or reproduce the training material from master copies supplied by the PTDD. The ATO shall ensure that the training material that is reproduced contains all the circulated amendments.
5.4 Checklist for Administering the Training: The PTDD will supply a checklist of administrative steps to be completed by the ATO and the Area ACO Coordinator.
5.5 Administration of the Evaluations:
1) The Area ACO Coordinator shall oversee the administration of the evaluations by arranging with the ATO for the duplication, distribution and control of the evaluations before and after the evaluation session.
2) The ACO Coordinator may make arrangements with the candidate's supervisor or manager for the supervision of the evaluation, in which case the ACO Coordinator shall provide instructions to the supervisor or manager on how to conduct the evaluations.
3) The Area ACO Coordinator will act as Evaluator if qualified, or arrange for qualified Evaluators to conduct evaluation of the examination.
4) All evaluations, whether completed or not must be returned to the ACO Coordinator. Once marked, the results and evaluations shall be forwarded to the ATO for record keeping.
5) The Evaluator shall discuss the results of the evaluation with the ACO candidate. The Evaluator should also inform the candidates their right to request the Area ACO Coordinator for a re-evaluation of the evaluation result.
6) The Evaluator shall indicate attainment level (i.e. meet or not meet the required standard), and any recommendations regarding remedial training to both the ATO and the Area ACO Coordinator.
7) Whoever supervises the evaluation should report any suggestions for improvement on the comment sheet provided with the evaluation packages.

6) Developing Remedial Training

The remedial training that is developed will depend on the nature of the problems encountered in the evaluations. The Area ACO Coordinator should discuss the need for remedial training with the ATO or PTDD office, who may provide guidance on the design and delivery of the remedial training.

7) Administration of Evaluations for Remedial Training

Evaluations conducted after remedial training shall be taken from the National Bank of Questions and administered according to these guidelines. All evaluations shall form part of the official record for the candidate.

8) Requesting re-certification training

Candidates requesting re-certification training under the ACO program should submit their applications forms (C4623EV2.itp) to the ATO.

9) Administration of Evaluations for Re-training

These evaluations shall be administered in the same manner as regular course evaluations.

10) Lists of contacts

For example, list of ACO Coordinators, ATOs, PTDD reps, Program Management contacts. These lists shall be posted on the CFIA Intranet site (Merlin).

APPENDIX 3: CERTIFICATE OF TRAINING

Certificate of Training

APPENDIX 4: ACO ASSESSOR'S QUARTERLY ACTIVITY REPORT
Reporting Period _______________ to _____________, 200 __

Minimum Time Commitment
For the 2002-2003 fiscal year, there is an expectation that Assessors will, on an annual basis, spend an average of 4 hours per assigned ACO per year on ACO review activities.

 

Names of individual ACOs
who have had their phytosanitary certification activities reviewed in the quarter:
 





Total number of Phytosanitary Certificates (including re-export certificates) issued in the Assessor's area of responsibility during the reporting period.  
Total number of Phytosanitary Certificates reviewed.
The Assessor should use the ACO Assessor's Review Record (Appendix 5) as personal records of certificates and certification process reviewed in the current quarter.
 
Corrective Action Requests
issued in the quarter
Critical1 Major Minor Total
Open Corrective Action Requests
all unresolved CARs from previous Quarterly Reports
 
Total time
on ACO reviews in this quarter
 
Assessor ___________________________ Signature ___________________________ Date ______________

1Refer to Section 4.5.3 in the Quality System Manual for Authorized Certification Official (ACO) Program for the Signing of Phytosanitary Certificates for examples of types of non-conformance.

APPENDIX 5: ACO ASSESSOR'S REVIEW RECORD (For use as personal record of review)

Name of individual reviewed: _________________________________ Date of review: ________________

Certificate nos.
Random selection: __________________________________________________
Targeted selection: __________________________________________________

Accuracy of certificates (which certificate is inaccurate and reason for inaccuracy):
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________

Process review (indicate if certification process is reviewed, staff involved in the process being
reviewed, and documentation reviewed):
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________

Corrective Action Requests raised (indicate whether they are caused by critical, major or
minor non-conformance, and number them for your record as required):
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
Reasons for non-conformance2:
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________

2For examples of types of non-conformance, refer to footnote 1. Use the attached summary of guideline from the NAPPO
Standards for Phytosanitary Measures - The Accreditation of Indivuduals to Sign Federal Phytosanitary Certificates
to check for process non-conformance.

CHECKLIST FOR NON-CONFORMANCE TO CERTIFICATION PROCESS

1. Request for certification:

  • Is there verification that critical information is obtained, i.e. detail concerning the product, e.g. plants, plant products, other regulated articles?
  • Is required information identified and appropriate parties notified in a clear manner?
  • Are adequate records maintained by the ACO, e.g. commodity, origin and destination?

2. Identify requirements:

  • Are requirements of importing country determined and verified?
  • Is the need for additional information determined and obtained, e.g. survey results?
  • Are clear instructions regarding requirements communicated to appropriate staff?
  • Are adequate records maintained by the ACO?

3. Communicate required phytosanitary measures

  • Have required phytosanitary measures been communicated and explained to appropriate parties, e.g. laboratories, producers, and inspectors?
  • Are adequate records maintained and distributed to appropriate staff?

APPENDIX 6: CORRECTIVE ACTION REQUEST

Name of ACO reviewed: _____________________________ Office: _____________________________

Date of review:
Part A: Description of non-conformity and related observations/aspect not supported by valid reasons and requiring correction:



Reference or Criteria: ____________________________

Phytosanitary certification Assessor*: ____________________________

ACO: _________________________________ Date: ________________

Supervisor of ACO*: _________________________________ Date: ________________
Part B: Description of corrective action, to include level of management for resolution and the responsibility for resolution:



Date for completion of corrective action: ________________

Responsible person for corrective action*: _________________________________ Date: ________________
Part C: Verification of Corrective Action (Describe how the corrective action was implemented):





CAR closed: Yes ____ No ____

Phytosanitary certification Assessor*: _________________________________ Date: ________________

* Print name below signature



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