Subject

This directive describes the Canadian Hay Certification Program (CHCP); a program which allows approved facilities to export hay or straw which meets foreign plant health import requirements.

This directive has been revised to update the review date, as well as minor administrative changes. The content of this directive has not changed.

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Table of Contents

• Review
• Endorsement
• Distribution
• Introduction
• Scope
• References
• Definitions, Abbreviations and Acronyms
• 1.0 General Requirements
  • 1.1 Legislative Authority
  • 1.2 Fees
  • 1.3 Regulated pests
  • 1.4 Regulated Commodities
  • 1.5 Regulated Areas
• 2.0 Specific Requirements
  • 2.1 Hay eligible for certification
  • 2.2 Plant Quarantine Import Requirements
  • 2.3 Administrative requirements
    • 2.3.1 Eligible Applicants
    • 2.3.2 Application for Participation
    • 2.3.3 Documentation Controls
  • 2.4 Qualification and Training of Hay Processing Plant Personnel
    • 2.4.1 Qualifications of the Pest Control Manager
    • 2.4.2 Training
    • 2.4.3 Evaluation
  • 2.5 Pest Management
    • 2.5.1 Examination of incoming plant material
    • 2.5.2 Examination of export shipments, processing and shipping areas
    • 2.5.3 Field Examinations
    • 2.5.4 Written Reports
  • 2.6 Non compliance
  • 2.7 CFIA Responsibilities
    • 2.7.1 CFIA Evaluation Audit
    • 2.7.2 CFIA Surveillance Audit
    • 2.7.3 CFIA Systems Audit
    • 2.7.4 CFIA Administrative Requirements
• 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

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Review

This directive will be reviewed every 4 years unless otherwise needed. The next review date for this directive is January 27, 2013. The contact for this directive is Joanne Rousson. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).

Endorsement

Approved by:

Chief Plant Health Officer:

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 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. Densified hay is sometimes referred to as double-compressed or high density, as it has been compressed into a product 2-3 times its initial density using a hydraulic compressing machine. This program is 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. This will include preparation of a Quality Management Systems Manual (herein referred to as the "manual") which outlines quality management systems procedures to be followed. As part of the quality management system, the facility must take appropriate measures (e.g. 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.

Scope

This document establishes and describes the minimum standards that must be met by all approved facilities, with respect to establishing quality management system and conducting examinations of hay for the purposes of export certification by the CFIA. (For the purpose of CHCP, an approved is one which has applied for and has been approved to process baled hay or densified hay and which has demonstrated competence to the satisfaction of th CFIA in their quality management system and in performing the type(s) of examination(s) and related administrative activities as specified in this directive.) This document provides the information needed for participants to establish and conduct an examination program with technical competence and thoroughness.

This document and the requirements contained within, apply in all cases where the CFIA issues phytosanitary certificates for hay exports to meet foreign plant quarantine import requirements (FPQIR) of an importing country.

This directive does not cover requirements for pelletized hay and highly processed hay products.

References

D-99-06 (1^st Revision), September 30, 2003. Policy On The Issuance of Phytosanitary Certificates.

ISPM No. 5, Glossary of Phytosanitary Terms. IPPC. Rome. Italy (updated annually).

ISO/I.C. Guide 39: 1988. General requirements for the acceptance of inspection bodies.

ISO Standards Compendium (Sixth Edition): 1996. ISO 9000 Quality Management. International Organization for Standardization. 382 pp.

This document supersedes D-03-14 (Original), T-93-03 dated August 26, 1993.

Definitions, Abbreviations and Acronyms

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

1.0 General Requirements

1.1 Legislative Authority

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 I (as amended from time to time)

1.2 Fees

The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. Anyone requiring other information regarding fees may contact any local CFIA office or Canadian Food Inspection Agency Fees Notice website.

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 (defined as a facility for processing hay products) 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.

PRODUCT (TYPES OF HAY)	SCIENTIFIC NAME
Timothy	Phleum pratense
Orchard Grass	Dactylis glomerata
Bromegrass	Bromus spp.
Alfalfa	Medicago sativa
Oat Hay	Avena sativa
Fescue	Festuca spp.
Ryegrass	Lolium spp.
Clover	Trifolium spp.

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 (e.g. 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 manual should be forwarded to the plant health inspector/program officer at the CFIA Regional or District Office. Upon reviewing the process facility manual, 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 manual 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 manual 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 manual 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 manual.

2.4.3 Evaluation

• For the purpose of evaluation of the facility's compliance with the manual, 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 occur.

2.5 Pest Management

Approved facilities must include in their manual an appropriate pest management program based on the requirements of the country of destination and follow their manual 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 manual. 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. A surveillance audit is defined as an examination to determine if prescribed inspection procedures are being applied properly. 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 manual 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 CFIA 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 quality management system, is following the procedures contained in their manual 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 manual, records and verification of the pest management program implemented by the approved facility (Appendix 6).

2.7.4 CFIA Administrative Requirements

A Phytosanitary Certificate will be issued in accordance with D-99-06 by an authorized certification official for each shipment of hay to be exported. A Phytosanitary Certificate will be issued based on the process facility compliance with their manual 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 CFIA use only)
• Surveillance Audit of Hay Facility reports
• Annual Systems audit report
• Approved facility manual (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

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Appendix 1

Application for Approval in the Canadian Hay Certification Program

Name of Process Facility:

Owner/Operator of Facility:

Pest Control Manager:

Address:

Conditions for exporting baled hay under the Canadian Hay Certification Program (CHCP).

1. Each export shipment must consist only of hay which meets the plant quarantine import requirements of the country of destination. The approved facility understands the phytosanitary requirements of the importing country.
2. Hay must be processed in a facility approved by the CFIA under the Canadian Hay Certification Program. The facility understands the conditions specified in the CFIA Plant Health Directive, D-03-14.
3. Records of hay received, handled and processed in an approved facility must be maintained for at least one year after shipment. The facility must be able to demonstrate ongoing traceability of hay shipments to both the source of the lot(s), and to each phytosanitary certificate.
4. The facility must be able to demonstrate how it prevents the export of non-compliant hay, including how it prevents contamination of compliant hay with non-compliant hay.
5. All approved facilities must have a quality management system and quality management system manual (herein referred to as the manual) explaining how they will meet the requirements of the CHCP. The approved facility must implement and follow their manual. CFIA will review and approve the manual.
6. The approved facility must agree to have the company's name listed on the CFIA's approved CHCP list which shall be posted on the CFIA web-site.

I, , the owner/operator in possession, care, or control of the above named process facility have read and understood all the terms, conditions, obligations and requirements stated herein (D-03-14) by which I may be approved to export specific genera of forage product (hay), in accordance with the Canadian Hay Certification Program.

Further, I am and shall be responsible for and shall indemnify and save harmless Her Majesty the Queen in Right of Canada, including the Canadian Food Inspection Agency, Her officers, Employees, Successors and Assigns, from and against all manners of actions, causes of action, claims, demands, loss, costs, damages, actions or other proceedings by whomsoever made, sustained, brought or prosecuted in any manner based upon, caused by, arising out of, attributable to or with respect to any failure, inadvertent or otherwise, by act or omission, to fully comply with the said terms, conditions and requirements.

Dated:   at:  Province of:

Recommendation of Applicant for Participation in Program

Quality Plan Approved by:

Quality Evaluation Completed and Facility Recommended for Approval by:

Approved for Participation in the Canadian Hay Certification Program:

 

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Appendix 2

Host Species of Hessian Fly 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.

 

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Appendix 3

Hay Examination Report

Click on Image for Larger View

Hay Examination Report

 

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Appendix 4

CHCP Evaluation Audit Checklist

Name of Facility:

Location:

Date:   CFIA Inspector:

Standard - Preliminary Standards	Yes	No	Notes
Application has been completed and signed.
Quality Management System Manual has been submitted.
Pest Control Manager has been identified on the application. Pest Control Manager is qualified as per Section 2.4.1.

Standard - Organization (Responsibility and Authority)	Yes	No	Notes
Current organizational chart (including names and titles).
Description of major responsibilities of each employee involved in Quality management system procedures.
Description of the company (products/services). May include company history.
Procedure to follow if the manual is altered, amended, or corrected.
Name/position of the person responsible for submitting any alterations, amendments, or corrections of the manual to the CFIA.
Name/position of the person responsible for organizing the regular review of the manual.

Standard - Pest Management	Yes	No	Notes
The manual describes company's method of Hay Examination to meet phytosanitary requirements (include samples of any forms used).
The manual describes company's method of tracking the source of hay lots (include samples of any forms used).
The manual has identified method of receiving incoming hay lots (include samples of any forms used).
The manual describes the segregation of eligible hay lots (physical barrier, distance separation, identification markings).
Verify that segregation is consistently maintained and contamination is avoided. (include samples of any forms used).
A regular inventory/count of eligible hay lots is completed (include samples of any forms used).

Standard - Compliance and Corrective Action	Yes	No	Notes
A description of non-compliance procedures (include samples of any forms used).
Name/position of the person responsible for handling non-compliance activities.
A description of corrective action plans/procedures (include samples of any forms used).
Name/position of the person responsible for taking corrective action.

Standard - Employee Training	Yes	No	Notes
Names/positions of the employees who receive training relative to the CHCP, including the dates that training was received/completed.
A training plan/process (including training elements and time lines) to train employees in elements of CHCP.
Documentation for staff training for knowledge and identification capability of prohibited hosts is retained and updated (include samples of any forms used).
Name/position of the person(s) responsible for training.
PCM/delegated appointee are aware of the manual, its contents, and its location.

Standard - Records Management	Yes	No	Notes
The facility commits to retain all records pertaining to the quality system for a minimum of one year from the final date of last shipment of an individual lot.
The facility retains a sample of the record of approval for any alterations, amendments, or corrections of the manual.
The manual contains a sample of hay/field examination reports.
The manual contains a sample of the record of receiving incoming hay.
The manual contains a sample of the documentation used for the product segregation process and organization in the facility.
The manual contains a sample of the record of the regular inventory/count of eligible hay lots.
The manual contains a sample of the record of the destination of all lots (both domestic and export) shipped from the facility.
The manual contains a sample of the record of non-compliance activities.
The manual contains a sample of the record of corrective actions taken.
The manual contains a sample of the record of the names/positions of the employees who received training relative to the CHCP, including dates that training was received/completed.

 

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Appendix 5

CHCP Surveillance Audit Checklist

Name of Facility:

Location:

Date:   CFIA Inspector:

Standard - Facility Operation	Yes	No	Non-Compliance	Corrective Action	Due Date
Process Facility operating with Pest Control Manager
Verify process facility is following manual procedures for receiving hay lots
Hay examination and/or other reports made available to CFIA on request
Verify process facility is following manual procedures for storage for eligible hay lots
Verify process facility is following manual procedures for segregation for eligible hay lots
Verify process facility is following manual procedures for lot identification for eligible hay lots
Verify process facility is following manual procedures for segregation through processing and shipping areas
Does process facility have sufficient staff to meet the quality management system procedures

Standard - Hay Examination	Yes	No	Non-Compliance	Corrective Action	Due Date
Verify eligible hay free from prohibited materials in storage
Verify eligible hay free from prohibited materials in processing
Verify eligible hay free from prohibited materials in shipping
Verify shipping containers handled as per manual

 

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Appendix 6

CHCP Annual Systems Audit Checklist

Name of Facility:

Location:

Date:   CFIA Inspector:

Standard	Yes	No	Non-Compliance	Corrective Action	Due Date
Does the process facility have a copy of their current manual available?
Does process facility have a Pest Control Manager?
Does the Pest Control Manager meet the qualifications of Section 2.4.1 of Directive?
Verify the records/reports listed in the manual are complete and available.
Verify the ability of the process facility to trace back shipments with the above records/reports.
Verify the process facility follows their manual procedure for examination of hay lots.
Verify the process facility follows their manual procedure for storage of hay lots.
Verify the process facility follows their manual for identification of hay lots.
Verify the process facility follows their manual procedure for segregating export eligible hay.
Verify the process facility follows their manual procedure for making corrective actions.
Are corrective actions done with-in the time specified?
Are training records up to date?
Verify the facility maintains records/documentation for 1 year after final shipment of an individual lot.
Does the process facility have available an up to date copy of the CHCP Directive.
Does the process facility consistently have sufficient staff to meet quality management system procedures?

 

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Appendix 7

Classification of Non-Compliance

Critical Non-Compliance

Critical instances are those that place the integrity of this program in jeopardy. Certificates must not be issued as this non-compliance will directly affect export markets. The facility is suspended from this program. Examples include:

1. The process facility knowingly exports product contaminated with non-conforming product.
2. The process facility completely fails to follow their own Quality System Procedure.
3. The process facility fails to do follow-up and corrective action following notification by importing country of rejection for prohibited pests.

Minor Non-Compliance

Inspection findings that reveal one isolated incident of non-conformance which has no direct impact on the integrity of the product provided that remedial action can be taken within a period defined by the inspector. Corrective action must be carried out to the satisfaction of CFIA or participation of the facility may be suspended. More than 2 minor non-compliances = a major non-compliance

1. Process facility does not have a current copy of their manual available.
2. Reports and records listed in the manual are not complete, up to date or available.
3. The process facility does not completely follow their manual procedure for hay examination.
4. The process facility does not completely follow their manual procedure for hay storage.
5. The process facility does not follow their manual procedure for hay identification.
6. The process facility does not completely follow their manual procedure for hay segregation.
7. Training records have not been maintained or staff training has not been completed on a consistent basis.
8. Records/documentation have not been consistently maintained for 1 year following shipment.
9. The process facility does not have available a current copy of the CHCP directive.
10. The process facility does not have sufficient staff to meet quality management system procedures.
11. The process facility does not have manual procedure for receiving hay.
12. The process facility does not consistently handle shipping container as per manual for cleanliness.

Major Non-Compliance

Inspection findings that reveal that the integrity of this program may be compromised. Corrective action must be carried out within the time frame specified by CFIA or participation of the facility may be suspended. More than 2 major non-compliances = a critical non-compliance.

1. The Process facility operating without a Pest Control Manager.
2. Pest Control Manager is not qualified as per Section 2.4.1.
3. The process facility cannot trace back shipments.
4. The process facility fails to make corrective actions identified from previous audit.
5. Hay being processed contains pests prohibited by Importing Country.
6. Process facility consistently does not have sufficient staff to meet Quality Management System procedures.
7. The process facility does not follow their manual for hay examination.
8. The process facility does not follow their manual for hay storage.
9. The process facility does not follow their manual for hay segregation.
10. The process facility does not handle shipping containers as per manual for cleanliness.
11. Records/ documentation have not been maintained for 1 year after shipment.