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Plants > Plant Protection Policy Directives > Grains and Field Crops  

Review

This directive will be reviewed every 3 years unless otherwise needed. The next review date for this directive is February 12, 2007. The contact for this directive is Joanne Rousson. For further information or clarification, please contact the Grains and Field Crops Section (GFC).

Endorsement

Approved by:

Distribution

1. Directive mail list (Regions, PHRA, USDA)
2. Provincial Government, Industry (via Regions)
3. Canadian Hay Association
4. Internet

Introduction

A potential growth industry exists in Western Canada in the production of hay for export to foreign markets. In response, the Canadian Food Inspection Agency (CFIA), in co-operation with the Canadian forage industry, has developed a Canadian Hay Certification Program (CHCP) for the phytosanitary certification of densified or baled hay for export. This new program will be mandatory for processors, shippers and exporters of densified or baled hay, destined for countries that regulate certain quarantine pests.

The objective of the CHCP is to produce hay which meets the plant quarantine import requirements of importing countries, including freedom from hosts of the Hessian fly.

To participate in the CHCP, the facility must design and implement a Quality Management System (QMS). This will include preparation of a Quality Management Systems Manual (QMSP) which outlines procedures (QMSP) to be followed. As part of the quality management system, the facility must take appropriate measures (eg. quality control protocol, hay examination and audit procedures, employee training program, etc.) to ensure that Canadian hay intended for export is grown and processed following acceptable agronomic practices that will result in the hay meeting the plant quarantine requirements of the importing countries.

Fumigation and heat treatment protocols for baled hay are being studied but are not options under the CHCP at this time. If fumigation, heat treatment or other protocols are successfully developed in the future, and accepted by importing countries, these options may be added to the CHCP and implemented accordingly.

Currently, only Japan and Korea require imported hay to be free from Hessian fly and its hosts. Hessian fly is known to occur in Canada and the United States.

Definitions, Abbreviations and Acronyms

1.0 General Requirements

1.1 Legislative Authority

The Plant Protection Act, s.c. 1990, c.22
The Plant Protection Regulations, SOR/95-212
Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part 1 (05/13/2000)

1.2 Fees

The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. Anyone requiring further information regarding fees may contact any local office or visit our web site.

1.3 Regulated pests

Hessian fly, Mayetiola destructor
Other quarantine pests as may be named by the importing country.

1.4 Regulated Commodities

Baled or densified hay produced for export to countries which require a phytosanitary certificate.

1.5 Regulated Areas

Canada (all areas).

2.0 Specific Requirements

In order for a process facility to be approved under the CHCP, the process facility must apply for approval to the CFIA and have a quality management system in place, to ensure that only hay eligible for export is presented for phytosanitary certification.

2.1 Hay eligible for certification

Pure stands or mixes of timothy, alfalfa, clover, bromegrass, orchard grass, ryegrass, fescue and oat hay produced (grown) in Canada are eligible for certification. If other hay species are to be considered, the CFIA must be contacted for verification of acceptability of the species.

The following are examples of hay types exported to Japan and other countries from Canada to date.

2.2 Plant Quarantine Import Requirements

Quarantine pests are usually listed in importing country's plant quarantine import requirements as prohibited pests.

All hay exported under the CHCP from an approved process facility must meet the plant quarantine import requirements of country of destination, as follows:

For Japan and Korea, hay must be:

• free from quarantine pests (eg. Hessian fly).
• free from other visible pests, other than Hessian fly
• free from hosts of Hessian fly (Mayetiola destructor), including straw, culm (stem), and leaves of wheat (Triticum spp.) barley (Hordeum spp.), rye (Secale spp.), and Wheatgrass/Couchgrass (Agropyron spp.). Appendix 2 provides a more detailed list.
• free from soil.

• Other Countries:

  For details relating to FPQIRs of countries other than Japan or Korea, a local CFIA office can be contacted.

2.3 Administrative requirements

In order for a process facility to be approved to participate in the CHCP, the facility must meet the following administrative criteria:

2.3.1 Eligible Applicants

Eligible applicants are established processors of baled and/or densified hay. Hay shipped by an exporter may be processed at their own facility, or in another facility if approved in the program. The application must be signed at the management level, and must include a clear, firm management commitment to training of sufficient competent staff to carry out the requirements of the program.

2.3.2 Application for Participation

An application form (Appendix 1) must be completed and signed by the owner/operator of the process facility indicating compliance with the terms, conditions and requirements of the CHCP. Based on the facility's ability to meet the requirements of the program, a CFIA plant health program officer may approve the applicant. An applicant's ability to meet the requirements of the program will be based on the findings, and results of an evaluation audit (section 2.7.1). Along with the copy of the signed application, a copy of the process facility's QMSM should be forwarded to the plant health inspector/program officer at the CFIA Regional or District Office. Upon reviewing the process facility QMSM, and the successful completion of the evaluation audit, the CFIA officer will approve the applicant for participation in the program.

2.3.3 Documentation Controls

2.3.3.1 Approved Facility Records

An approved facility must have a system for maintaining records in each establishment. Each process facility must maintain records associated with examinations of each hay source, quantity, lot identification, country of destination and other export information.

A current copy of this directive and the facility's QMSM must be easily accessible to Pest Control Manager and process facility staff at all times and made available to CFIA upon request.

All records must be kept for at least one year from the final date of shipment of an individual hay lot.

2.3.3.2 Phytosanitary Certification

Prior to export of a consignment, exporters of hay are required to complete and submit an Application for Phytosanitary Certification to the CFIA. A phytosanitary certificate will be issued by CFIA Authorized Certification Official once it has been determined that the consignment meet the requirements of the importing country. Phytosanitary Certificate will be issued in accordance with D-99-06 (Policy on the issuance of phytosanitary certificates).

2.4 Qualification and Training of Hay Processing Plant Personnel

An approved facility shall employ, sufficient competent staff to ensure the requirements of the CHCP are met. For this program, an applicant shall identify a qualified Pest Control Manager for each process facility. The Pest Control Manager, along with other personnel responsible for hay examination must have a thorough understanding of this program. The Pest Control Manager and senior management must be committed to ensuring compliance with the program is maintained. This includes having personnel aware and trained to carry out functions essential to the delivery of the program.

2.4.1 Qualifications of the Pest Control Manager

The member of staff designated as the Pest Control Manager under this program must at a minimum:

• understand the plant quarantine requirements of the importing country.
• be familiar with good production practices for hay as recommended by the provincial department of Agriculture.
• be actively involved with the approved facility in hay examination and in carrying out their Quality Management System.
• be aware of the procedures to follow in their QMSM to ensure compliance with the CHCP.
• possess the ability to identify prohibited hosts of the insect Hessian fly [i.e., wheat (Triticum spp.), barley (Hordeum spp.), rye (Secale cereale), and quack/couch/wheat grasses (Agropyron spp.)].
• possess general knowledge of hay types, weeds, diseases, and insects, with specific knowledge of Hessian fly.

2.4.2 Training

• An approved facility must outline a CHCP training program in their QMSM and conduct training of their personnel responsible for hay and/or field examination.
• Records of staff training must be maintained by the approved facility as outlined in their facility QMSM

2.4.3 Evaluation

• For the purpose of evaluation of the facility's compliance with the QMSM , it is recommended that each process facility conduct an internal audit within 12 months of approval.
• An approved facility must be able to demonstrate the ability to perform trace-back of consignments for the identification of specific sources of non-compliance should non-compliance occurs.

2.5 Pest Management

Approved facilities must include in their QMSM an appropriate pest management program based on the requirements of the country of destination and follow their QMSM to ensure consistent compliance with requirements. The pest management program may be specifically developed by an approved facility, or recommended by a provincial agency or the Canadian Hay Association. The procedures followed in the program must be documented for review and approved by CFIA. Elements of the pest management program should include:

2.5.1 Examination of incoming plant material

New stock to be brought into an approved facility, intended for export under the program must be examined to meet the plant quarantine import requirements. Examination of approved hay may be done at source, prior to arrival at the facility or held for examination by the Pest Control Manager or his/her appointee. Hay meeting the requirements under the program may be moved into the storage and the processing areas for export. If pests or host plants of Hessian fly are found at the time of examination at the facility, appropriate measures, including segregation of the product away from the approved hay, must be carried out immediately, in order to ensure compliance with the CHCP. Written reports as per Section 2.5.4 must be completed.

2.5.2 Examination of export shipments, processing and shipping areas

All hay in an approved facility, including products destined for domestic market, and markets without specific phytosanitary requirements should be examined by the Pest Control Manager or his/her appointee at the frequency specified in the process facility QMSM. If pests or host plant material of Hessian fly are detected, control measures must be taken to ensure compliance with the CHCP. Storage of each hay lot must include clear lot identification. When export shipments are being processed, facility staff should ensure that baled hay, processing areas and shipping containers meet the requirements of the CHCP.

Loading of shipping containers must be conducted in a manner to prevent contamination from windblown material, for example: foxtail barley, Hordeum jubatum.

2.5.3 Field Examinations

Some process facilities may conduct field examinations of the growing crop. This may include examinations of the standing crop prior to harvest or baling, and assembling hay into hay stacks, prior to delivery to the processing facility. Hay baled from a field meeting the conditions of an importing country, must be segregated from other lots which do not qualify. Segregation may include a physical barrier between lots, identification marks on lots or a distance separation between lots.

2.5.4 Written Reports

The Pest Control Manager or his/her appointee must prepare a written report, "Hay Examination Report"(Appendix 3) prepared before or at the time the hay enters the approved facility. This report is used for reference purposes for issuing phytosanitary certificates. A hay examination report must also be completed for hay baled and stacked from a crop where field examinations were conducted.

2.6 Non compliance

Where audits determine that an approved facility no longer meets the requirements of the CHCP (as described in Appendix 7), its approval status will be revoked or the frequency of surveillance audits increased. The CFIA program officer shall notify the approved facility in writing of this action.

A facility which has had its approval revoked may re-apply for CHCP recognition once all necessary corrective actions have been implemented. However, the facility must re-submit a QMSM and a detailed report of the corrective actions taken. The CFIA will conduct a re-evaluation of the facility to determine whether corrective actions are sufficient. A new frequency shall be assigned to the facility until the facility has demonstrated on going compliance with CHCP. Once the facility has demonstrated an ongoing compliance with the program requirements, the facility shall return to the normal frequency.

2.7 CFIA Responsibilities

Note: CFIA Occupational Safety and Health (OSH) policy should be strictly adhered to when working on site at an approved facility. Any individual facility OSH requirements must also be adhered to by CFIA staff on such premises.

2.7.1 Evaluation Audit

Prior to granting an approval to a facility, the CFIA will conduct a pre-approval evaluation audit of a processing facility, to ensure that all conditions of the program have been met. The evaluation audit is necessary to demonstrate to the CFIA that the company has developed a QMS, is following the procedures contained in their QMSM and can meet the requirements of the CHCP (Appendix 4).

2.7.2 CFIA Surveillance Audit

In the first year, the CFIA will carry out regular surveillance audits at a minimum of six (6) times per year, using the "Surveillance Audit of Hay Facility" form (Appendix 5) to determine product compliance with the CHCP. In subsequent years, an approved facility that has maintained compliance in the program will be inspected at a minimum of four (4) times a year.

The timing and frequency of the surveillance audit may be based on the length of the shipping season and the volume of hay that the facility exports. Where a process facility ships hay on a limited, seasonal basis, the CFIA plant health Program Officer may approve a reduced frequency of surveillance audits for the establishment.

For those approved facilities which do not meet the phytosanitary standards during the audit inspection by CFIA, follow up audits will be required to verify program compliance. Any audits required to verify corrective actions will be in addition to the minimum frequency of surveillance audits per year.

2.7.3 CFIA Systems Audit

Once a year CFIA will conduct a systems audit of a facility to assess the overall performance of the participant. This audit may involve assessment of any and/or all facets of the program, including the review of the facility QMSM, records and verification of the pest management program implemented by the approved facility (Appendix 6).

2.7.4 Administrative Requirements

A Phytosanitary Certificate will be issued in accordance with D-99-06 by an ACO for each shipment of hay to be exported. A Phytosanitary Certificate will be issued based on the process facility compliance with their QMSM and meeting the requirements of the program. The CFIA will post on the CFIA web-site, a list of process facilities approved under the program.

CFIA personnel in Network/Regional offices will maintain files on each approved facility participating in the CHCP. Records on each approved facility must include:

• Application for approval in the Canadian Hay Certification Program (1 copy - Appendix 1)
• Audit evaluation for Pre-approval (1 copy - form for use only)
• Surveillance Audit of Hay Facility reports
• Annual Systems audit report
• Approved facility QMSM (1 copy)

3.0 Appendices

Appendix 1: Application for Approval in the Canadian Hay Certification Program
Appendix 2: Host Species of Hessian Fly Prohibited Entry into Japan and Korea
Appendix 3: Hay Examination Report
Appendix 4: CHCP Evaluation Audit Checklist
Appendix 5: CHCP Surveillance Audit Checklist
Appendix 6: CHCP Annual Systems Audit Checklist
Appendix 7: Classification of Non-compliance

Appendix 1

Appendix 2

HOST SPECIES OF HESSIAN FLY
THE Prohibited Entry into Japan and Korea

A. Wheat

• Common Wheat, Triticum aestivum, including winter and spring wheat
• Spelt wheat - Triticum spelta
• Durum Wheat - Triticum durum
• all other Triticum spp.

B. Barley

• Common barley - Hordeum vulgare
• Foxtail barley - Hordeum jubatum
• Little barley - Hordeum pusilium
• Other Hordeum spp.

C. Rye

• Secale cereale

D. Agropyron spp. include:

• Couchgrass/Quackgrass - Agropyron repens
• Crested Wheatgrass - Agropyron cristatum
• Northern Wheatgrass - Agropyron dasystachyum
• Slender Wheatgrass - Agropyron trachycaulum
• Pubescent Wheatgrass - Agropyron trichophorum
• Other Wheatgrasses - Agropyron spp.

Appendix 3

HAY EXAMINATION REPORT

Number:_____________________

Appendix 4

CHCP EVALUATION AUDIT CHECKLIST

Name of Facility:__________________________________________________________

Location:__________________________________________________________

Date: __________________________ CFIA Inspector:__________________________

Appendix 5

CHCP SURVEILLANCE AUDIT CHECKLIST

Name of Facility:__________________________________________________________

Location:__________________________________________________________

Date: __________________________ CFIA Inspector:__________________________

Appendix 6

CHCP ANNUAL SYSTEMS AUDIT CHECKLIST

Name of Facility:__________________________________________________________

Location:__________________________________________________________

Date: __________________________ CFIA Inspector:__________________________

Appendix 7

CLASSIFICATION OF NON-COMPLIANCE

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