1. How can importers demonstrate that they have taken appropriate
actions to prevent the entry of LLRICE601 into the Canadian food or livestock
feed marketplace? |
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The CFIA recommends that importers obtain documentation indicating that the
presence of LLRICE601 is not in their imports. If an import arrives without
appropriate supporting documentation, it is more likely to be selected for testing
by the CFIA. Appropriate documentation should demonstrate, for example, that:
- the shipment does not originate from the US, or
- the shipment does not contain long grain rice (at present, LLRICE601 has
not been found in short or medium grain rice), or
- the shipment contains rice that will not be used in food or livestock feed (e.g. the rice is intended for food that will be re-exported to the US.)
- if none of the above apply, the importer can supply documentation which demonstrates that the shipment has been tested using an appropriate sampling plan and detection method,
for the presence of LLRICE601
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2. What are appropriate options for sampling and testing for LLRICE601 in a shipment? |
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As an interim measure, the CFIA recommends using a combination of testing and sampling procedures
during this initial period to deliver at least a sensitivity of 0.5 per cent (i.e. LLRICE601 will be detected
if present at a level of at least 0.5 per cent of the shipment) at a 95 per cent
confidence interval. Importers should note that any test result indicating a
presence of LLRICE601 would be considered out of compliance and that the shipment
cannot enter the food or livestock feed marketplace.
For specific guidance on techniques to ensure representative sampling of rice
shipments, please refer to
GIPSA Rice Inspection Handbook available online at http://archive.gipsa.usda.gov/reference-library/handbooks/rice/rice-chapt02.pdf#search=%22GIPSA%20rice%20sampling%20handbook%22.
Two currently available test methods can be applied to detect LLRICE601 in
a rice shipment at a level of sensitivity of at least 0.5 per cent. These are
described below. Importers must choose the approach that best meets their own
individual needs. Any questions about the acceptability of other methods can
be directed to the CFIA contact person listed at the end of this document.
(i). PCR testing at one of four commercial labs in the US that are providing
diagnostic services to detect LLRICE601. Their addresses are available from
Bayer CropScience: http://www.bayercropscience.com/BAYER/CropScience/BCSUS.nsf/id/Bio_TestingServices
If importers opt to use the PCR testing provided by these commercial laboratories,
their records of the testing should indicate:
- the name and address of the testing laboratory
- the date of the test
- the sample ID number
- the type of material being tested
- the number (or other identifier) of the lot that the sample represents
- the size of the lot that the sample represents
- the sampling size
- the method and test used (e.g. Semi-Quantitative TaqMan PCR, 35S-bar)
- the test result
(ii). Commercially available test kits (lateral flow strip testing) can also be used. The manufacturers of these kits are:
Strategic Diagnostics Inc. (SDI)
111 Pencader Drive
Newark, DE
19702
Phone: 302-456-6789 Ext. 222
Kit number: 7000048
EnviroLogix Inc.
500 Riverside Industrial Parkway
Portland, Maine 04103-1486
USA
Phone: 207-797-0300 or 1-866-408-4597
Kit number: AS 013 RB
If importers opt to use the SDI or EnviroLogix test kits, they must ensure that the sampling protocols are adjusted to provide a sensitivity of at least 0.5 per cent. In addition, their records should indicate:
- the name and occupation of the person who performed the test, and the name
and address of the company employing this person
- an attestation of the accuracy of the information supplied, signed by a senior
official in this company
- the date of the test
- the address of the facility where the test was conducted
- the sample ID number
- the type of material being tested
- the number (or other identifier) of the lot that the sample represents
- the size of the lot that the sample represents
- the number and size of sub samples analysed
- the volume of buffer or water used (ml)
- the lot number of the buffer (where applicable)
- the strip test name and lot number
- the results of all of the individual strip test results run to provide a
minimum sensitivity of 0.5 per cent.
If you require more information about how to achieve at least a 0.5 per cent level of sensitivity using an SDI or EnviroLogix test kits, please contact the CFIA representative listed in section 11.
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3.
What will happen after the 2 month review? |
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The Agency will evaluate this strategy after approximately two months. Following this review, any changes will be communicated to affected industry representatives and through web updates. Our current expectation is that, by the end of the initial two month period, industry will have obtained access to, and will have migrated to using the PCR methodology in a manner that will achieve a sensitivity of 0.1 per cent. |
4. How and where will shipments be targeted for compliance verification
by the CFIA? |
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The CFIA will conduct spot checks of imports for compliance verification at the first point of distribution, or the importer’s warehouses, after the shipments have entered Canada. |
5. What specific types of products will the CFIA be targeting for
compliance verification? |
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The CFIA will initially focus on imports of single-ingredient rice products
that represent the majority of long grain rice imports into Canada, such as milled
or semi-milled long grain rice; husked (brown) long grain rice; milled or semi-milled
parboiled long grain rice.
Please note that this is not an exhaustive list.
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6. What will happen if the CFIA targets an import for compliance
verification? |
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The CFIA will first ask the importer to supply any available documentation
about the rice shipment, as described in question 1. After a review
of any available documentation, inspectors will select some rice shipments for sampling and compliance verification testing to be conducted by CFIA laboratories. If an importer’s shipment is selected for this testing, the importer will be advised to hold the shipment until the results become available.
If an import arrives without any supporting documentation, it is more likely
to be selected for testing by the CFIA.
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7. If a shipment is tested by the CFIA, how long before the test
results will be available? |
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CFIA results will be available 2 days after the laboratory has received the
sample. |
8. What happens if the CFIA testing detects LLRICE601? |
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The product may not be offered for sale as food or livestock feed in Canada.
The importer must demonstrate to the CFIA that the product has been re-exported
to the US or disposed of in an appropriate manner, to ensure that LLRICE601 does
not enter the Canadian food or livestock feed marketplace. |
9. Will CFIA labs be providing testing services to importers? |
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No. See question 2 for available options for laboratory testing. |
10. Don’t some of the test methods referenced above detect LLRICE62,
an approved product in Canada? |
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Yes, lateral strip tests and the 35S-bar PCR method detect the presence of
both LLRICE601 and LLRICE62. Importers are free to decide how they will demonstrate
that they have taken appropriate measures to prevent the inadvertent entry of
LLRICE601 into Canada. They may choose to do this by either testing for LLRICE601
specifically, or they may choose to use a less specific test that also detects
the approved product, LLRICE62.
Any enforcement actions taken by the CFIA will be based on CFIA testing that
detects the presence of LLRICE601 specifically.
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11. Who can I contact for more information? |
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Angela Bilkhu
Program Officer
Food Safety Division
Canadian Food Inspection Agency
Telephone: (613) 221-7205
Fax: (613) 221-7295
Email: bilkhua@inspection.gc.ca
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