Questions and Answers - Canadian Nursery Certification Program (CNCP) and Canadian Greenhouse Certification Program (CGCP)

General information about the CNCP/CGCP
General information about Phytosanitary Certificates
CFIA audits
Information for owners of nurseries and greenhouses
Shipping certified plant material within Canada
Shipping certified plant material to the U.S.
Acronyms

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General information about the CNCP/CGCP

Q1 What is the Canadian Nursery Certification Program (CNCP)?

The CNCP is a phytosanitary certification program for Canadian nurseries and greenhouses that ship nursery stock to the United States (U.S.) or to other Certified Facilities (CF) within Canada. The CNCP uses a Phytosanitary Management System (PSMS) to minimize pest risks so that plants consistently meet U.S. import requirements. The program offers an alternative to traditional phytosanitary certification for shipments to the U.S.

Q2 How is the CNCP different from traditional phytosanitary certification?

Traditional phytosanitary certification is based primarily on end product inspection by a Canadian Food Inspection Agency (CFIA) inspector. Inspectors examine plant material before it is shipped. They issue CFIA Phytosanitary Certificates if the material meets the phytosanitary requirements of the importing country.

The CNCP uses a systems approach, meaning a CF takes various pest risk management measures throughout its plant production process. These measures include documenting plant production and pest management practices, auditing and reviewing the plant production system, and determining pest prevalence throughout production.

In lieu of traditional CFIA Phytosanitary Certificates, CNCP CFs can apply a pre-printed Phytosanitary Certification Label to completed CNCP Export Label Documents to form a CNCP Phytosanitary Certificate, which is used to certify shipments to the U.S. that meet all the requirements of the program.

Q3 What is the Canadian Greenhouse Certification Program (CGCP)?

The CGCP is a similar phytosanitary certification program for greenhouses that export low-risk indoor foliage and flowering plants to the U.S. The CGCP allows designated greenhouses to export greenhouse plants to the U.S. under an export certification label in lieu of a traditional CFIA Phytosanitary Certificate.

Q4 Why has the CFIA developed the CNCP and the CGCP?

The international trade in plants for planting is a high-risk pathway for the spread of plant pests and diseases. The CNCP and CGCP implements the International Plant Protection Convention (IPPC) Standard of using a systems approach to mitigate pest risk. It also meets the guidelines of the North American Plant Protection Organization (NAPPO).

• International Standards for Phytosanitary Measures (ISPM) 14
• Regional Standards for Phytosanitary Measures (RSPM) 24

Q5 What is the difference between the CNCP and the CGCP?

The CGCP has similar requirements to the CNCP, but is less stringent. Only greenhouse plant species with low-risk of disease or pest infestation are eligible for certification under the CGCP.

Q6 Is the CNCP going to replace the CGCP?

No. The CNCP is not intended to replace or supercede the CGCP now or in the future. The CGCP is designed for certifying lower risk greenhouse plants for export to the U.S. Greenhouse plants are considered low risk because there are fewer pests of concern associated with them, greenhouse plants are unlikely to establish in the environment, and greenhouse plants are grown in greenhouses under controlled conditions.

Q7 Who is eligible to participate in the CNCP?

Eligible applicants are nurseries and greenhouses, including those that are wholesalers and brokers of plants. Brokers who do not operate nursery or greenhouse facilities may not participate in the CNCP

Q8 Who is eligible to participate in the CGCP?

Greenhouses, and nurseries that have greenhouse production areas are eligible participants. Brokers may also apply for certification under the CGCP, provided they purchase CGCP certified plant material from CFs in Canada and export the material directly to the U.S. or supply it to other CFs in Canada.

Q9 What are the advantages of participating in the CNCP and the CGCP?

There are a number of advantages to participating in the CNCP/CGCP:

• Shipping flexibility - Certification labels will be available on site, meaning the CF will no longer have to wait for the CFIA to issue individual Phytosanitary Certificates before export.
• Cost - The cost of labels, stamps and audits is expected to be significantly lower than the cost of individual inspections and traditional CFIA Phytosanitary Certificates, especially for larger U.S. exports
• Fewer non-compliances - Implementing the CNCP/CGCP will result in products that consistently meet U.S. import requirements.
• Quality Product - Facilities that apply PSMS to their production find that they consistently produce higher quality products.

Many Canadian greenhouse and nursery facilities are already doing most of what is required under these certification programs. However, under the CNCP/CGCP, facilities must demonstrate compliance by documenting their PSMS and keeping records to verify that the program has been implemented correctly.

Q10 Are additional resources (HR and financial) required to implement the CNCP/CGCP?

Yes. Additional resources are required for the following reasons:

• Paperwork - Documenting processes and keeping records to verify that procedures have been implemented requires nursery staff to take the time to complete the required paperwork.
• Training - Training staff to implement the certification program may result in increased costs.
• Increased expenses - Developing and implementing CNCP Manual requires a significant commitment of resources.

Q11 What plant material is eligible for certification under the CGCP/CNCP?

Plant species that are eligible for certification under the CNCP include all plants commonly known and recognized as nursery stock, except those that have been excluded by the United States Department of Agriculture (USDA).

Only those plants that are grown within an enclosed structure (i.e. greenhouse) for most of their growing cycle and, where the conditions for growth within the structure are strictly regulated, are eligible for inclusion in the CGCP.

Q12 How long do plants have to be grown in Canada to be considered of Canadian origin?

Plants or plant products are considered to be of Canadian origin

1. when plant material is grown only in Canada, OR
2. when plant material is imported into Canada and meets all of the conditions outlined in the U.S. Federal Register: Code of Federal Regulations: Title 7 part 319 section 37

General information about Phytosanitary Certificates

Q1 What is a Phytosanitary Certificate?

A Phytosanitary Certificate is an official document issued by the plant protection organization of an exporting country to the plant protection organization of the importing country. It certifies that the plants or plant products covered by the certificate are considered to be free from quarantine pests, and that they conform to the current phytosanitary regulations of the importing country.

Canadian Phytosanitary Certificates issued by the Canadian Food Inspection Agency (CFIA) are (a) patterned after the model certificates of the International Plant Protection Convention (IPPC) ( ISPM 12, 2001); and (b) signed by an Authorized Certification Official (ACO) and sealed with an official Canadian Phytosanitary Certificate seal; (Plant Protection Regulations, Section 55(1)).

Q2 What is a CNCP Phytosanitary Certificate?

The CNCP Phytosanitary Certificate is composed of a pre-printed label called a CNCP Phytosanitary Certification Label, which is affixed to a CNCP Export Label Document. The CNCP Phytosanitary Certification Label is pre-printed with a unique serial number, the Certified Facility's (CF) identification number, the name and address of the CF, the signature of the CFIA Director of Plant Health, the CFIA seal, a certification statement and a liability statement.

The CNCP Export Label Document is an official CFIA form that is completed and printed by the CF. It has a large space designated for affixing the Phytosanitary Certification Label. It also contains the date, the name and address of the exporter, references to invoices, a description of the consignment and its means of conveyance, the additional declaration for the CNCP, a description of any treatments that are applied to meet export requirements, and a list of the scientific names of all the plants contained in the shipment.

When the CNCP Phytosanitary Certification Label is placed in the designated space on a completed CNCP Export Label Document it forms a CNCP Phytosanitary Certificate (which contains all the information found on a traditional CFIA Phytosanitary Certificate). The CNCP Phytosanitary Certification Label may only be applied to the completed CNCP Export Label Document after the product has been examined for pests and verified to meet all the requirements for certification under the CNCP and within 72 hours of shipping the certified product. The shipment must be safeguarded prior to shipping to protect its phytosanitary integrity.

Q3 What is a CGCP Export Certification Label?

Each facility approved under the CGCP will be assigned a registration number. This number, as well as a serial number, appears on the export certification labels issued by the designated facility. The registration number and serial number make each export label unique.

The export certification label is placed on either a copy of the commercial invoice or a blank sheet of paper listing the plant species contained in the shipment (label document). This label document will be retained by the USDA at the port of entry and replaces the Phytosanitary Certificate normally required for the entry of plants to the U.S.

Q4 Will traditional Phytosanitary Certificates still be used?

Yes. The CNCP currently only applies to plant shipments exported to the U.S. by CNCP CFs. Traditional Phytosanitary Certificates will continue to be issued when exporting plants to countries other than the U.S. and when exporting plant material to the U.S. that meets U.S. import requirements but does not meet the requirements for certification under the CNCP.

The Horticulture Section at the CFIA provides the specifications for the labels and stamps to the printing company. A Regional Program Officer (RPO) of the CFIA must authorize the printing of labels and stamps and indicate the quantity and serial numbers to be used. All Phytosanitary Certification Labels and Interfacility stamps (IFS) remain the property of CFIA, although the CF is responsible for paying all costs associated with obtaining the labels, stamps and Phytosanitary Certificates.

Q5 Are the proof of origin requirements more stringent for facilities certified under the CNCP than for facilities that ship using traditional Phytosanitary Certificates?

No. Proof of origin requirements are the same for all plants destined for export to the U.S. whether they are certified using a CNCP Phytosanitary Certificate or a traditional CFIA Phytosanitary Certificate.

CFIA audits

Q1 If facilities are able to certify their own material for export to the U.S., how will the CFIA ensure that the material meets U.S. requirements?

The CFIA will conduct regular audits of all facilities that are approved to ship plant material under the CNCP. The overall objective of these audits is to ensure that the facility is compliant with the CNCP.

Q2 What are systems audits?

Systems audits are annual examinations of an organization's structure, procedures, processes and resources used to implement the CNCP. The objective of a systems audit is to determine whether the procedures and processes described in the CNCP Manual conform to the requirements of the directive, and whether the resources and infrastructure are in place to effectively implement the CNCP.

Q3 What are surveillance audits?

Surveillance audits verify that the facility's plant material, pest management program, records and administrative procedures conform to the CNCP Manual. Surveillance audits evaluate the facility's resources, infrastructure and staff; determine if nursery stock meets CNCP requirements; and verify that CNCP manual procedures are implemented and documented. Surveillance audits are carried out during periods of active plant growth.

Q4 What happens if the audit detects a non-conformance?

Corrective Action Requests (CAR) will be generated for each non-conformance detected in the Certified Facility (CF). CARs will generally require the facility to amend its PSMS to the CNCP Manual. CARs are classified as either critical, major or minor in nature. Consequences of a non-conformance vary depending on its classification. See D-04-01 Section 3.5 for more information.

Q5 When would a non-conformance result in a facility being suspended from the CNCP/CGCP?

A facility may be suspended if activities or products are found to be in contravention of the CNCP. Examples include non-conformances detected during CFIA surveillance audit inspections, internal audits conducted by the CF, or under examinations of plant material.

Information for owners of nurseries and greenhouses

Q1 How do I certify my production facility under the CNCP/CGCP?

Eligible applicants are nurseries and greenhouses, including those that are also wholesalers and brokers of plants. Applicants must:

• be located in Canada;
• complete and sign a CNCP Application Form for Facilities, indicating that the applicant is willing and able to comply with the terms and conditions of the CNCP;
• designate a qualified individual to be the Certification Manager (CM) and/or Crop Protection Manager (CPM) (D-04-01, Appendix 7);
• develop a CNCP Manual that contains a PSMS and a Pest Magement Plan (PMP), and forward a copy of the CNCP Manual to the local CFIA Regional Program Officer (RPO) for approval.

Q2 Is participation in the CNCP/CGCP mandatory?

Not yet. The CNCP/CGCP is expected to become mandatory in the future. At that time, all high risk plants from off-continent sources will be required to originate from pre-approved facilities in its country of origin.

Q3 How do I determine which program, the CGCP or the CNCP, is most appropriate for my business?

It is important to consider whether the plants you export to the U.S. are low-risk plants grown in a greenhouse or higher-risk plants grown outdoors. Only greenhouse plants that present a low phytosanitary risk are eligible to participate in the CGCP. Woody perennials, shrubs and trees are not eligible for certification under the CGCP. Facilities that produce plants with a higher phytosanitary risk may participate in the CNCP.

Q4 I raise plants in a greenhouse and outside. Must I participate in both the CNCP and the CGCP?

No. The requirements of the CGCP program are a sub-set of the CNCP requirements. CGCP is only intended for greenhouse grown plants that are considered to present a low phytosanitary risk. Woody perennials, shrubs and trees are not eligible for certification under the CGCP. Facilities that harden off plants outside, or that produce plants present a higher phytosanitary risk, may participate in the Canadian Nursery Certification Program (CNCP), rather than the CGCP.

Example: A greenhouse grower who buys cuttings and roots them in a greenhouse may be certified under the CGCP. Once sold to a facility that grows plants outdoors, the plants must be certified under the CNCP.

Q5 What if I have more than one facility?

If an applicant owns distinct, separate facilities, each one requires a CNCP Manual and an application form. A separate facility is one that is under different management and/or an autonomous management structure. The Area Horticulture Specialist of CFIA will make the final decision as to a facility's status.

Q6 Is there a cost to register under the CNCP or CGCP?

Yes. Facilities applying to be registered are charged $130.00 plus tax. There is no pro-rating or return of this fee. All participants must pay an annual fee of $130.00 per year plus tax. This fee must be received by April 1 of the new fiscal year.

• Complete list of fees associated with plant protection

Q7 What are Certification Managers (CM) and Crop Protection Managers (CPM)?

The facility must designate a CM that is a member of the facility's management team. The CM must have a thorough understanding of the CNCP and of the systems approach to mitigating pest risk. The CM must demonstrate the capability to carry out the requirements of the CNCP, commit to ensuring compliance with the CNCP, and develop and implement a PSMS.

The CPM must either be employed or contracted by the CF to provide technical pest management services or be the owner or employee of a Canadian business that provides technical pest management services.

The CM or CPM ensures that all pest and commodity specific requirements are met prior to shipping. CMs or CPMs must successfully complete an introductory Quality Management Systems course (ISO 9001), or a CFIA recognized Lead Auditor Course, or have at least two years of experience implementing the CNCP at a CF.

Q8 What is a CNCP Manual?

A CNCP Manual describes the procedures implemented by a CF to ensure that plants certified under the CNCP meet all of its requirements as well as the requirements for entry into the U.S. and for domestic movement. The CNCP Manual has two key components: a description of the PSMS and a PMP. A checklist outlining the specific elements that must be contained within the CNCP Manual can be found in Addendum 2 of the policy directive.

Q9 What is a Phytosanitary Management System (PSMS)?

A PSMS must include procedures relating to sourcing plant material; maintaining product identity; shipping certified material; controlling non-conforming products; conducting internal audits; generating corrective action requests; improving and maintaining the PSMS, the CNCP Manual, and the administrative systems; and maintaining detailed records that verify compliance with the directive.

Q10 What internal audits are required?

The CM must perform, or designate and supervise parties to perform, one internal system audit per year and four surveillance audits per year. The surveillance audits must be conducted at least once during the active growing season and at least once during the shipping season. Records from each audit must be maintained and within two weeks of an audit, a report must be prepared detailing any non-conformances, corrective actions and opportunities for improvement. Audit reports must be made available to the CFIA external audit teams, which will review records from the internal audits as part of the audits by CFIA.

Note: Internal audits focus on the systems in place in a CF and are NOT the same as pest scouting or monitoring.

Q11 Why do facilities need to conduct internal audits?

Internal systems are necessary for continuous improvement and audits verify

• the adequacy and effectiveness of the facility's processes in meeting the CNCP requirements;
• whether the required documentation is sufficient, current and readily available to staff;
• whether the PSMS is operating in accordance with the specified requirements, including the performance of all staff identified in the CNCP Manual; and
• the establishment of a corrective action plan to deal with each non-conformance identified.

Internal Surveillance Audits verify

• the effectiveness of the PMP in preventing the introduction or establishment of pests;
• the competency of facility employees in identifying and controlling pests and carrying out duties and responsibilities as outlined in the CNCP Manual;
• that the record keeping aspects of the facility are compliant with the CNCP Manual and sufficient to keep track of the country of origin of plant material, labels, etc.; and
• that actions are taken on outstanding non-conformances and CARs.

Q12 When should internal audits be performed?

The CFIA suggests that internal audits be carried out prior to each CFIA audit and that audits be performed to compliment the certification of plants. The persons performing internal audits must not audit their own work. Examples of audit checklists can be found in Addendums 4 and 5.

Q13 What is a Pest Management Plan (PMP)?

Each facility must develop a PMP that outlines any sampling, testing, treatment and cultural practices, best management practices, or other measures put in place that ensure end-products are certified according to all phytosanitary requirements. The names and qualifications of each laboratory used for testing must be included in the PMP. The PMP must be readily available for use by employees involved in implementing the CNCP.

If additional pest or commodity specific policy directives apply to the CF or to its products, the facility's CNCP Manual must include Modules, which describe how the additional requirements of the additional policy directive are being met.

Q14 When must modules to be included in the CNCP Manual?

Modules are required when a CF produces higher risk plant material. Higher risk plant material may include plants that are hosts to specific pests of concern, plants imported from outside continental North America, plants exported to states within the U.S. that have additional certification standards, or stock plants that are held for longer than a growing season.

Q15 What information will need to be included in the modules?

The modules must outline any sampling, testing, treatments, cultural practices, best management practices, or other measures in place to ensure that the product meets all of the phytosanitary requirements necessary to certify the product. The CM or CPM must ensure that all pest and commodity specific requirements are met prior to shipping. The names and qualifications of any laboratories used for testing must be included in the PMP.

Q16 What about plants at a contract grower's facility that are produced under the PMP of a certified facility?

These plants may be certified, provided they are grown according to the procedures described in the facility's CNCP Manual and approved and audited by the CFIA.

Q17 Can I obtain exemptions from particular sections of the CNCP?

Yes, if an applicant can demonstrate that particular sections are not relevant to their business. The Area Horticulture Specialist of CFIA will make the final decision as to whether any of the requirements of this directive do not apply to a particular facility.

Q18 How do I determine if my plant material meets the requirements for certification under the program.

Please refer to Section 2.3 of the directive D-04-01 in order to determine if the material meets the requirements for certification under the program.

Q19 What documentation is required for verification of origin?

Many different documents could be used to verify origin provided they contain the appropriate information: Phytosanitary Certificated, invoiced, airway bill, propagation records, bills of lading, etc.

Q20 For how long must verification of origin documents be kept?

Records that pertain to product identity and trace back and trace forward of certified plant material (records described in Section 5.1.1 and 5.1.2 of the directive D-04-01) must be maintained for at least seven years. Other records that are required by the CNCP must be maintained for a minimum of three years.

Q21 Under the CNCP pilot program, 30 per cent of material originating from outside Canada and the continental U.S. can be flipped, or re-exported without spending a minimum amount of time in the production facility. Is this permitted under the new CNCP?

No. The CNCP does not allow for the immediate flipping of material that originates from outside Canada and the continental U.S. Plant material that originates in Canada and/or the U.S. must meet the requirements for eligibility in order to be certified under the CNCP.

Shipping certified plant material within Canada

Q1 Will the CNCP/CGCP facilitate the movement of plant material within Canada?

Yes. Certified material can be shipped between Certified Facilities (CF) without losing its certified status if it is accompanied by documentation with an Interfacility Stamp (IFS). This material can then be shipped to another certified facility in Canada or exported to the U.S.

Q2 What is an Interfacility Stamp (IFS)?

The IFS informs facilities and brokers purchasing plant material that it satisfies criteria for certification under the CNCP/CGCP and is eligible to be shipped to the U.S. Once a facility is approved under the CNCP/CGCP, it is assigned a unique registration number. This number appears on the IFS and on each CNCP Phytosanitary Certification Label and each CGCP Export Certification Label.

A CF may use the IFS for all shipments containing CNCP/CGCP certified material, even if the shipment includes plant material that does not meet the requirements of the CNCP/CGCP. In such cases, this plant material must be identified on the invoice by an asterisk (*). If none of the material in the shipment meets the requirements for certification, the IFS may not be used.

Q3 Can a CF use the IFS in lieu of a Domestic Movement Certficitae for plant material that is not intended to be re-exported?

No. A Domestic Movement Certificate must be issued by a CFIA inspector as per the requirements in pest specific directives.

Q4 Will plants retain their certified status when transferred from a CNCP/CGCP CF to a non-CF within Canada?

No. Certified plant material will lose its certified status if it is shipped to a non-CF within Canada, even if it is accompanied by documentation stamped with an IFS. This material must be inspected and issued a traditional Phytosanitary Certificate by the CFIA before it can be exported to the U.S.

Q5 Will plant material purchased from a CGCP-certified facility by a CNCP-certified facility (or vice versa) retain it's certified status?

Yes. Plant material certified under either program that is moved to another facility certified in the same program will maintain its certified status without inspection by the CFIA, provided it is accompanied by appropriate documentation and an IFS.

Q6 How do I obtain an IFS?

Each facility certified under the CNCP or CGCP must complete an order form which must be signed by the Certification Manager and submitted to the local CFIA office. The CFIA provides the specifications for the stamps to a printing company. CFs are responsible for paying all costs associated with labels, stamps and Phytosanitary Certificates; however, all IFS remain the property of the CFIA.

Shipping certified plant material to the U.S.

Q1 What documentation is required to export plants for planting to the U.S.?

A Phytosanitary Certificate.

Q2 Do facilities certified under CNCP/CGCP need to obtain a Phytosanitary Certificate from the CFIA for each shipment to the U.S.?

No. In lieu of a traditional CFIA Phytosanitary Certificate, CNCP CFs can apply pre-printed Phytosanitary Certification Labels to completed CNCP Export Label Documents to form a CNCP Phytosanitary Certificate, which is used to certify shipments to the U.S. that meet all the requirements of the program.

In lieu of a traditional CFIA Phytosanitary Certificate, CGCP CFs can apply an Export Certification Label to shipping documents to certify that the shipment meets all requirements of the program.

Q3 Does the U.S. have similar nursery and greenhouse certification programs?

Yes. The United States Greenhouse Certification Program (GCP) has been in place since 1996 and a pilot United States Nursery Certification Program (NCP) began in 2005.

The Canadian and American programs are similar. Both countries have designed certification programs that meet international standards, particularly the North American Plant Protection Organization (NAPPO) standard "Integrated Pest Risk Management Measures for the Importation of Plants for Planting into NAPPO Member Countries" (RSPM 24).

Acronyms

ACO Authorized Certification Official

CAR Corrective Action Requests

CF Certified Facilities

CFIA Canadian Food Inspection Agency

CGCP Canadian Greenhouse Certification Program

CM Certification Manager

CNCP Canadian Nursery Certification Program

CPM Crop Protection Manager

IFS Interfacility stamp

IPPC International Plant Protection Convention

NAPPO North American Plant Protection Organization

PMP Pest Magement Plan

PSMS Phytosanitary Management System

RPO Regional Program Officer

U.S. United States

USDA United States Department of Agriculture