D-10-02: The Canadian Grain Sampling Program (CGSP)

Effective date: August 22, 2012
(Original)

Subject

Under the voluntary Canadian Grain Sampling Program (CGSP) companies can collect and submit samples from consignments of seed, grain and grain products to support phytosanitary certification for export from Canada. This directive establishes the criteria that will be used by the Canadian Food Inspection Agency (CFIA) for approval of companies under the CGSP. In addition, this directive outlines the procedures that must be followed for the collection and submission of samples to the CFIA. Laboratory results from samples submitted by approved companies will be used as the basis for issuance of Phytosanitary Certificates by the CFIA.

Review
Endorsement
Amendment Record
Distribution List
Introduction
Scope
References
Definitions, Abbreviations and Acronyms
1.0 General Requirements
2.0 Export Certification
- 2.1 Approval of Material Prior to Export
3.0 Program Requirements of the CGSP
4.0 Manual
5.0 CFIA Audits
6.0 Enforcement and Suspension
7.0 Appendices

Review

This directive will be reviewed every 5 years unless otherwise needed. For further information or clarification, please contact the CFIA.

Endorsement

Approved by:

Chief Plant Health Officer

Amendment Record

Amendments to this directive will be dated and distributed as outlined in the distribution below.

Distribution List

Directive mail list (Regions, PHRA, USDA)
Provincial Government, Industry (determined by Author)
National Industry Organizations (determined by Author)
Internet

Introduction

The Plant Protection Act and Regulations require that plants and plant products exported from Canada meet the phytosanitary requirements of the importing country. Phytosanitary Certificates are issued based on the model set out in the International Plant Protection Convention to indicate that consignments of plants, plant products or other regulated articles meet specified phytosanitary requirements of the importing country. The CFIA as the National Plant Protection Organization of Canada is responsible for the phytosanitary export certification of plants and plant products and for the development of certification programs to address phytosanitary requirements of importing countries.

Most countries have phytosanitary import requirements that must be met prior to exportation to ensure that pest risks are effectively mitigated. International trade of seed, grain and grain products has been identified as a pathway for the introduction of regulated pests. As a major exporter of these commodities, Canada recognizes that trade in these products is only possible if this pathway is addressed to ensure there is a minimal risk of transporting pests to the importing country.

Since 1991, the CFIA has approved companies to submit samples for phytosanitary certification under the Designated Inspector Sampling Program. In 1997, the Phytosanitary/Quality Certification Program Pilot Project was implemented in Ontario. This program allowed exporting companies to submit samples to the Canadian Grain Commission (CGC) for phytosanitary analysis. Both programs have remained relatively unchanged since their initial implementation, and have recently undergone a review by the CFIA.

The CGSP supercedes the Designated Sampling Program and the Ontario Phytosanitary/Quality Certification Program Pilot Project and incorporates features of both programs into a Quality Management System. The CGSP will be offered to clients across Canada as a single harmonized program. All companies previously approved under these two programs must seek approval under the CGSP, should they wish to continue to submit samples for phytosanitary certification.

Scope

This document is intended for use by the various branches of the CFIA, and by the companies approved, or seeking approval, to collect samples for phytosanitary certification. This directive establishes the criteria and requirements allowing companies to collect official samples, the results of which will be used as the basis for issuance of Phytosanitary Certificates by the CFIA.

Under this program, samples could be collected from bulk and bagged shipments of cereals, pulses, oilseeds, and other specialty crops, for export from Canada and intended for any end use (e.g. propagation; processing; human or animal consumption), and may be stored or handled by inland handling and processing facilities; container trans-loading facilities, etc. The sampled lot must be kept segregated from other lots, and handled in such a manner to prevent potential introduction, development or reproduction of plant pests, until export.

This program does not allow for the sampling of product at terminal /transfer grain elevators, flour mills or malt plants, which are covered under other inspection programs.

The CGSP is a voluntary program. Exporting facilities not participating in this program or not using the services of an approved third party sampler can still opt to have official samples drawn by a CFIA inspector for phytosanitary certification.

References

ISO Guide 8402, Quality Systems Terminology.
ISPM No. 5, Glossary of Phytosanitary Terms, FAO, Rome (updated annually).
Canadian Grain Commission Sampling Systems Handbook and Approval Guide, 2007.
CFIA R-006, Canadian Grain Sampling Program – Audit Manual
ISPM No. 31, Methodologies for Sampling of Consignments.

This directive supersedes: CFIA Policy. Designated Inspector Sampling Manual, 1991. and Phytosanitary/Quality Certification Program Pilot Project, April 1, 1997.

Definitions, Abbreviations and Acronyms

Definitions of terms used in this 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, SORS/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 visit our Fees Notice Web Site.

Audit of facilities and third parties, as well as issuance of Phytosanitary Certificates are cost recovered according to the Plant Protection Fees.

1.3 Regulated Pests

Seed, grain and grain products are a pathway for the movement of a number of regulated pests. Commodity specific regulated pests are generally listed in an importing country's phytosanitary requirements. Please contact a local office of the CFIA to obtain country specific phytosanitary requirements for the commodity intended to be exported.

1.4 Eligible Commodities

All seed, grain and grain products of cereals, pulses, oilseeds, and other specialty crops that require the issuance of a Phytosanitary Certificate prior to export are eligible to be sampled under this program.

1.5 Exempt Commodities

Commodities that do not require a CFIA Phytosanitary Certificate prior to export are exempt from this program. Please contact a local office of the CFIA to obtain country specific phytosanitary requirements for the commodity intended to be exported.

1.6 Eligible Applicants

Only facilities located in Canada are eligible to participate in the CGSP. Eligible applicants include facilities which are involved in the processing, handling and export of seed, grain and grain products. Businesses or individuals samples of grain or grain products for export on behalf of an exporter are also eligible to apply under the program as "third party" samplers.

Facilities, businesses or individuals drawing samples under this program will be referred to as company (ies), hereafter in this document.

Terminal and transfer elevators, flour mills and malt plants are not eligible to apply for participation in the CGSP. The phytosanitary certification of products shipped from these facilities is based on other CFIA inspection programs.

2.0 Export Certification

All samples drawn by approved companies will be analysed according to the phytosanitary requirements of the importing country. As such, the test results obtained will be used as a basis for issuance of Phytosanitary Certificates by the CFIA. A Phytosanitary Certificate will only be issued when the test result(s) obtained from the representative sample(s) is compliant with the phytosanitary requirements of the importing country.

It is possible that the phytosanitary import requirements of some countries may require that the CFIA conduct additional laboratory testing for certification. This may require that additional samples and/or larger sample sizes in excess of the standard CGSP guidelines be taken and submitted. It is the responsibility of the exporter to be aware of these requirements and to communicate them to their CGSP sampling company.

Please refer to D-99-06 "Policy on the Issuance of Phytosanitary Certificates" for further information on the CFIA's phytosanitary certification policy and procedures.

2.1 Approval of Material Prior to Export

Material in storage intended for export can be approved by sampling and testing for pests regulated by the importing country, prior to the loading of conveyances and movement into export position. Facilities interested in such an approval must ensure that the sampled lot is kept segregated and its identity preserved until the product is exported. Procedures to maintain the integrity and identity of the lot from which the sample has been drawn must be described in the Manual (see Section 4.0).

It is the responsibility of the exporter to coordinate sample collection and submission between the company approved to draw samples and the CFIA. The exporter should allow for the time necessary to confirm freedom from pests in the submitted samples as it is this confirmation which forms the basis for phytosanitary certification. As a general guideline, the lot should be sampled within one month of the intended date of export.

Additional sampling and testing may be required to verify the pest free status of that lot in the following cases:

when duration of storage exceeds 30 days from the time of sampling until the request for phytosanitary certification is received by the CFIA
where storage or handling conditions subject an approved lot to potential infestation
where the integrity of the lot has been compromised while in storage
where the lot has not been approved for regulated pests of the importing country

In these cases, the decision to re-sample and test will be at the discretion of the CFIA.

3.0 Program Requirements of the CGSP

3.1 Submission of documents

A company seeking approval under the CGSP is required to submit an "Application for Participation in the Canadian Grain Sampling Program" (Appendix 1), and a completed Quality Management System Manual, (hereafter referred to as the Manual) to the local office of the CFIA for review. The completed application must be signed off by a manager (section 3.3.2) of the company, who will have overall responsibility for delivery of the program.

A company must operate under a Quality Management System that ensures consistent compliance with the phytosanitary principles of sampling. The company must document the procedures that they will be following in their quality system to meet the conditions of the CGSP. This documentation is the company's Manual.

Businesses or individuals acting as third party samplers will be required to submit an application and Manual per office.

3.2 Review by the CFIA

The CFIA will review the application and assess the company's Manual according to the requirements of Section 4.0 and Appendix 3 outlined in this document. If the Manual does not meet the requirements, areas requiring changes will be identified to the applicant. When these modifications to the manual are made it can be resubmitted, and if requirements of the program are met an initial evaluation audit will be scheduled by the CFIA.

During the evaluation audit, the CFIA will assess if the company can comply with the procedures outlined in their Manual and if those procedures conform to the goals of the CGSP. For third party samplers, the CFIA's scheduling of the evaluation audit will involve an on-site visit at a client's facility.

Companies successfully completing a Manual and evaluation audit will receive a copy of the approved application from the CFIA providing them with their unique identification number. They will be added to the list of approved companies on the CFIA web site. The approved company must maintain a current copy of its Manual and make it available to the CFIA upon request.

In subsequent years, the CFIA will conduct a system audit annually.

3.3 Company Responsibilities

3.3.1 Management

A Manual documenting the company's sampling procedures related to the CGSP program requirements must be developed and maintained.
The management must appoint a Manager who will meet the requirements listed in Section 3.3.2. The management must designate qualified alternates capable of replacing the Manager or have a contingency plan in place, approved by the CFIA. Failure to meet this requirement will disqualify the company from consideration in the CGSP.
The management will ensure that methods and procedures described in the Manual are followed to ensure the integrity of the sampling process.
The management must provide all employees involved in implementing the Manual with training related to those components for which each employee has responsibility. The training program must be described in the Manual.
The management must provide assistance to CFIA staff during audits and allow the audit team to examine records and documents, collect samples, inspect product and interview employees who are identified in training records as being involved in the sampling process.

3.3.2 Manager

The Manager must:

Have a thorough understanding of the CGSP.
Have the authority and responsibility for the development and implementation of a Manual that meets the requirements of the CGSP.
Be committed to ensuring compliance with the CGSP by managing the Quality Management System of the company, including the development and implementation of a record management and retention system.
Maintain detailed records that document internal audits, non-conformances, corrective actions taken, and follow-up audit.
Understand the situations which require the CFIA to be notified and incorporate within the Manual a procedure for providing that notification.
Be responsible for implementation of corrective actions.
Ensure that employees conducting sampling have expertise in performing CGSP related tasks and are adequately trained.
Conduct internal audits.

While the Manager is responsible for overall Manual, he/she may designate qualified personnel or contractors to assist with developing and implementing different components of the Manual, such as document control, record keeping, administration and internal audits. The Manager may only designate those tasks to a qualified individual.

The Manager, or a designated alternate, must be present at the facility during a CFIA audit.

4.0 Manual

4.1 Administration

The Manual must provide information as to the function and responsibilities of staff members involved in maintaining the CGSP requirements. An organizational chart may be a simple means of achieving this requirement. The manual should be typed and all pages numbered. The Manual must provide the company name, address, table of contents, and a list of where copies of the Manual were distributed.

A procedure to amend the Manual must be identified. It must describe how the CFIA will be informed of any updates to the Manual as they occur. A list of amendments must be maintained and a list of the manual locations should be included in the Manual. The list must identify those individuals receiving copies of amendments, so the company is able to track versions of the Manual.

The company must describe the procedures for ensuring that records pertaining to every aspect of the CGSP are maintained and retrievable for a minimum of two years. All records must be made available to the CFIA upon request. Refer to Appendix 2 for additional Manual guidelines.

4.2 Health and Safety Issues

The sampler should be familiar with the company's sampling and safety procedures prior to sampling the product. Each company should have their own safety procedures which should be adhered to when sampling. It is recommended that appropriate personal protective equipment be used in all situations. If the product has been chemically treated appropriate safety precautions as determined by the employer should be taken.

4.3 Sanitation

Good sanitation practices are the first steps in preventing infestations and keeping insect management costs to a minimum. Grain spillage, dust and old residues provide an available food source and can harbour insect populations that can continually spread to other areas of the facility. Grain residues reduce the effectiveness of pesticide treatments by protecting insects from contact insecticides or by absorbing insecticides and thereby reducing the amount available for controlling insects. In addition, the presence of food may result in insects being able to recover from pesticide treatments. Therefore cleaning of grain spillage, residues and dust should always be done prior to applying an insecticide. As well, proper sanitation practices can also reduce human health and safety hazard issues.

The companies participating in the program are encouraged to include a sanitation policy and procedures chapter in their Manual.

4.4 Sampling Procedures

It is the responsibility of exporters and participants in the CGSP to work cooperatively with each other and with the CFIA to verify commodity specific phytosanitary requirements of the importing country. Country specific phytosanitary import requirements should be taken into consideration prior to initiating sampling, as they may affect sample submission and testing requirements.

The sampler plays a critical role in sampling lots for testing; thorough sampling and the information submitted with the sample are vital to the validity of any subsequent test results.

4.4.1 Determining the Lot

Under this program, the CFIA will allow a single submitted sample to represent a maximum lot size of 300 metric tonnes (mt). Where the size of a lot is in excess of 300 mt, submitted samples representative of each 300 mt increment, or portion thereof, must be provided. Prior to sampling, verify the correct lot to be sampled, determine the type of product, number of bags or containers, and lot number. The sample should be collected with care, the choice of equipment and sampling method must ensure that samples are representative of the entire lot.

4.4.2 Sampling Equipment and Methodology

It is mandatory to have proper equipment available to draw samples and the equipment must be kept clean to eliminate any cross contamination between samples from different lots. A company's sampling procedures need to be described in detail in their Manual. Refer to Refer to Appendix 4 for further details on sampling equipment and methods.

4.4.3 Sampling Intensity

A primary sample represents a small portion of the product taken from a lot during one single sampling action. The number of primary samples of a product required to be taken from a lot to ensure that a representative sample is obtained, is dependent on the number of bags or net weight of bulk shipments. Appendix 5 summarizes the minimum required sampling intensities for bulk and bagged export lot shipments.

4.5 Sample Reduction and Preparation

A composite sample of the entire lot is obtained by the combining of all primary samples that have been collected. The composite sample is normally more than the amount of product required for analysis. Therefore, the composite sample must be reduced to an acceptable size that can be submitted. This must be done in a way that ensures the final sample submitted to the CFIA is representative of the lot for export.

In all cases, the submitted sample must weigh, at minimum 1 kg (for excessively bulky crops kinds, e.g. brome grass, needle grass, etc. you should submit minimum volume of 2 litres). This ensures that a sufficient amount of product is available for the CFIA or a CFIA approved laboratory to analyze. Refer to Appendix 6 for laboratory testing options.

The specific phytosanitary requirements of some importing countries may dictate that a larger submitted sample or more than one submitted sample is required to allow for additional testing.

The following are acceptable methods of sample reduction:

A. Boerner-type Divider

A Boerner-type divider is a gravity-operated dividing apparatus that reduces a grain sample. The sample is placed in the upper hopper and released by opening the valve in the hopper throat. The sample flows downward and is evenly dispersed over a cone with evenly spaced separations. The divided sample is reformed into two grain streams which empty into two collecting pans at the bottom.

B. Riffle Divider

A Riffle Divider consists of a hopper with attached channels or ducts, a frame to hold the hopper, four receiving pans and a pouring pan. Alternating ducts or channels lead from the hopper to the collecting pans on either side. This divider is suitable for most crop kinds. Riffle dividers are available with a range of channel sizes and those with large channels are approved for large crop kinds.

C. Manual Reduction

Where a Boerner-type or Riffle divider is not available, composite samples may be manually reduced to provide a sample for submission using the following procedure. Since the finer components of the sample are likely to settle to the bottom of a container during mixing, the composite sample should be poured in a shallow layer onto a clean surface (e.g. paper or plastic), and using a clean board or ruler, dividing the sample as required to create a sub-sample, which is representative of the composite sample, and of the sufficient weight for submission for analysis.

An alternative method for manually reducing a composite sample allows for the hand mixing of the composite sample in a large container and then re-sampling to obtain a representative portion that will serve as the submitted sample.

4.6 Sample Submission

A sample submission form must be completed to submit a sample for analysis. The sample submission form used by the company must be approved by the CFIA during Evaluation Audit. If multiple samples are part of the same shipment they can be submitted using the same form, however all railcar, container, truck or lot identification numbers must be listed. A log of the samples submitted must be maintained by the company. Samples must be placed in a sturdy, sealed cloth or plastic bags that will not break or leak during shipping. A completed sample submission form (Appendix 7) must be securely attached to the sample bag. It is advisable to print some unique information directly onto the bag, which corresponds to the sample submission form, in the event that the form and sample become separated during shipping. A lead sheet summarizing all submitted samples should also be included if sending multiple samples.

Sample bags should be packed in a sturdy box or container with sufficient packing material to prevent damage during transit. If samples cannot be sent immediately after collection they should be stored in a secure, climate-controlled location.

If the product, represented by the sample, has been chemically treated (i.e.; seed treatment or fumigant), this must be indicated in the appropriate area on the sample submission form. A Material Safety Data Sheet (MSDS) must accompany any treated sample. The local CFIA office must be notified in advance of sending chemically treated or fumigated samples. A "degas" certificate should accompany any submitted samples that have been previously fumigated.

Sampling records are required to ensure that the sample can be linked to the shipment intended to be exported. Phytosanitary certificates will not be issued if there is not a clear link between the submitted sample and the lot being exported. Sample integrity and identification must be maintained at all times following the completion of sampling. The sample must be submitted to CFIA (or where recognized by CFIA, to the Canadian Grain Commission (CGC)) as soon as possible following sampling.

The sample must be identified in a manner that will clearly link it to the "Application for Export Inspection and Phytosanitary Certification" (CFIA/ACIA 3369). This application is to be completed by or on behalf of the exporter and should be submitted to the CFIA in sufficient time to complete the laboratory analysis on the samples that would permit issuance of the Phytosanitary Certificate. A Phytosanitary Certificate can be issued up to one month from the time the representative sample(s) corresponding to that consignment is submitted for analysis. The CFIA Authorized Certification Officer (ACO) may use his/her discretion to issue phytosanitary certificates later than one month following receipt of samples for that consignment, where laboratory testing requires a longer period of time to confirm results and/or in instances where the ACO can verify that the consignment has been stored since sampling in a manner to prevent potential introduction, development or reproduction of plant pests, or commingling with other lots.

If a sample has been taken and submitted prior to the transfer of the consignment between conveyances at a trans-loading facility, a Trans loading Facility Stuffing Report (Appendix 8) must be completed and made available to CFIA upon request. This is to document the linkage between the submitted sample taken prior to transfer and the final export conveyance. If the sample cannot be linked to the export shipment, a Phytosanitary Certificate will not be issued.

4.7 Storage of Product prior to Export

It is the exporter's responsibility to ensure that the phytosanitary integrity of the sampled lot is maintained prior to export. Sampling consignments as near to the final point of export, where they can be safeguarded from potential infestation or contamination is recommended. At the time of submission of the "Application for Export Inspection and Phytosanitary Certification" (CFIA/ACIA 3369), the exporter will be required to provide the link between the sample submitted by the CGSP approved company and the actual consignment for exportation. This may involve the sampling company providing additional information to the CFIA.

If a company samples product being transferred into storage bins, the company must include a section in their Manual on the procedures being followed to ensure identity preservation of the product prior to shipment.

4.8 Training

The company must outline the training plan for staff involved in any aspect of the CGSP. It must describe the frequency of training, what was covered, who has been trained and how training records will be kept. The Manual should be sufficiently detailed that it is possible to the CFIA to assess that people are adequately trained.

4.9 Internal Audit

The company must describe the internal audit process to be conducted that will ensure the sampling processes are being conducted in a consistent manner. Internal audit must be conducted on a quarterly basis the first year and a minimum of twice a year the following years. During the course of a year, all criteria in Appendix 1 of R-006, should be evaluated. The company must notify the CFIA immediately when there is a critical or major non-conformance. Records of internal audits must be available for review during the annual CFIA systems audit.

4.10 Non-conformance

Non-fulfillment of specified requirement of the CGSP is considered to be non-conformances. Non-conformances can be detected either during internal audits conducted by the company or audits done by the CFIA.

The company must specify procedures for addressing non-conformances and must include a plan for dealing with specific processes and activities that fail to comply with one or more of the specified elements. Refer to section 5.3 for additional information.

5.0 CFIA Audits

5.1 Evaluation Audit

An evaluation audit must be conducted by the CFIA on a company prior to approval under the CGSP. This audit will be scheduled by the CFIA when it is determined that the Manual submitted by the company meets all the criteria established in the CGSP. The evaluation audit is necessary to demonstrate to the CFIA that the company is able to follow the procedures outlined in their Manual and that those procedures conform to the goals of the CGSP. Companies successfully completing an evaluation audit will receive a copy of the approved application with their unique identification number.

However, if deficiencies are identified in the Manual or in the implementation of the Manual procedures; the company must address those deficiencies and inform the CFIA. At that time the CFIA may schedule a second evaluation audit to determine if the company can be approved for the CGSP. The CFIA will maintain a list of approved CGSP companies on its web site.

5.2 System Audit

A system audit will be performed by the CFIA at a minimum of once a year but the frequency can be increased if compliance issues arise. The system audit will evaluate how well the company's practices correspond with the requirements of the CGSP. The audit may involve assessment of the program, including review of the company's Manual, sampling records, interviews and observation of company staff responsible for conducting CGSP activities.

The overall objective of the system audit is to ensure the company is in compliance with the CGSP and that all commodities sampled and submitted for testing meet the criteria of the CGSP. The audit will evaluate whether the company is implementing their Manual and facilitate continual improvement to the company's sampling procedures. The company must meet CGSP requirements. It is acceptable to exceed these requirements. However, if the system audit reveals the company is not following their Manual, observation will be put in the Audit Report (R -006 Appendix 1).

Audits of companies will be composed of two elements: documentation review and onsite review of sampling and preparation of samples for submission. Each component of the audit may be conducted at different times. The auditor will review the documentation that the company is keeping for the Manual to ensure they are fulfilling the conditions of the CGSP. At this time the auditor will arrange a location for the practical component of the audit. This component will be conducted at a facility where the company carries out sampling. The CFIA will provide an Audit Report (R-006 Appendix 1) that summarizes the audit findings. Follow-up audits may be required to verify corrective actions, if noted in the audit report.

For more specific audit information refer toR-006 "Canadian Grain Sampling Program Audit Manual".

5.3 Non-Conformance

A Corrective Action Request (CAR) form (R-006 Appendix 2) will be generated by the CFIA for each non-conformance that is detected during the system audit of a company. Observations on suggested changes or improvements to a company's Manual will be documented in the CGSP Audit Report.

The number and type of non-conformances found will determine the status of the company and the subsequent auditing frequency. Each CAR must be accompanied by an action plan that includes a detailed description of the measures that need to be implemented to prevent recurrences of the non-conformances. Corrective actions must be undertaken by the company within a time limit specified by the auditor.

A. Critical - Audit findings indicate that the integrity of the CGSP is in jeopardy. The company will be immediately suspended from the CGSP if any critical non-conformances are found.

B. Major - Isolated incidents of non-conformance, which do not immediately impact the integrity of the CGSP but may become a problem over time. To maintain their approved status, corrective actions must be carried out within 10 business days of receiving the CAR.

If two or more are detected during an audit, or if the company fails to carry out the required corrective actions within the specified time period, the non-conformance will be assessed as critical and the company will be immediately suspended.

C. Minor - Do not immediately and/or significantly affect the status of the CGSP, but could lead to a major non-conformance if not addressed. The company will be required to address these within the time limit specified by the CFIA.

If three (3) minor non-conformances are detected in any one audit this is considered equivalent to one major non-conformance (e.g. Four (4) minor non-conformances are equal to one major non-conformance and one minor non-conformance and all four should be addressed in 10 business days. Similarly, six (6) minor non-conformances are equal to two major non-conformances, which constitutes a critical and the company would be immediately suspended from the CGSP).

Observations are points or practices, which also may be noted during audits and could be used to improve the company's Manual. An observation may be used to identify a situation of concern that does not warrant a CAR, or to highlight, suggest or reinforce particular practices.

6.0 Enforcement and Suspension

When audits determine that a company no longer fully meets the requirements of the CGSP, its approval status will either be suspended or the frequency of audits increased dependent on the level of non-conformance. This may result in the company being removed from the list of approved companies maintained by the CFIA.

A company, which has had its approval suspended, may re-apply for participation under the CGSP at any time, provided a detailed report of the corrective actions taken to address the previous non-conformances is included with the application form (Appendix 1). The CFIA will conduct an evaluation audit to verify if the corrective actions are adequate. If re-approved, the CFIA will re-list the company on the list of approved companies on the CFIA web site.

Suspended companies cannot submit sample(s) for phytosanitary certification to the CFIA. The options available will be either product sampling by the CFIA or by another CGSP company, the use of which must be approved by the CFIA. The suspended company should work closely with the CFIA to determine the best course of action for re-approval.

7.0 Appendices

Appendix 1: Application for Participation in the Canadian Grain Sampling Program

Appendix 2: Manual

1. Administration

1.1 The Manual must be typed, dated and include a table content and a version number. Pages must be numbered.
1.2 Title page must include the name and address of the facility, the date, the name of the person(s) that prepared the document, and the Manager's name.
1.3 A general description of the facility, including pertinent specifics, such as name, address, phone and fax number, contact person, and e-mail.
1.4 The Manual must include a distribution list.
1.5 Structure of the organization (organizational chart). Function and responsibilities of staff members involved in the program.

2. Sampling

2.1 List sampling equipment used, when it is used and how it will be maintained.
2.2 Describe sanitation procedures for tools and equipment to avoid cross-contamination and how this will be ensured.
2.3 Describe procedures for sampling each "type" of shipment (bulk, bagged) including where in the facility this sampling will occur (include schematic diagrams of facility if appropriate).
2.4 If utilizing an automatic sampling system, complete part I of the Automatic Sampler Checklist (Appendix 9), including a summary of equipment being used, the checklist confirming the correct operation of equipment, and system calibration requirements.
2.5 Describe sample reduction procedures.
2.6 Describe sample identification, packaging and labelling procedures.
2.7 Describe how sample integrity will be maintained (i.e. packaging is intact).
2.8 Describe sample submission procedures.
2.9 Describe or provide an example of the sampling records that will be maintained. As a minimum, the following information must be recorded: sampling date, sampler's name, commodity, lot number, number of bags sampled or frequency of stream samples for bulk product, date when the sample was sent and name of CFIA office or CFIA approved testing body that the sample was submitted to.

3. Storage of Product prior Export

3.1 Describe how shipment integrity will be maintained if sampling occurs prior to the loading of the conveyance.
3.2 Describe how the facility maintains the association between the submitted sample and the lot that it represents.

4. Training

4.1 Training plan; including methods by which training will occur, frequency of training and refresher training.
4.2 Maintain records of who was trained, and when, and what are their responsibilities relative to the CGSP.

5. Non-conformance

5.1 Describe procedure for addressing non-conformances.

6. Internal Audit

6.1 Describe how internal audits will be performed; by whom, components examined, frequency, etc.
6.2 Describe the process used for employee performance evaluations relating to the CGSP.

7. Amendment to the Manual

7.1 Describe how changes to the manual will be made.
7.2 Maintain list of amendments made.
7.3 Maintain a distribution list.

8. Record Keeping

The company must describe the procedures for ensuring that written records pertaining to every aspect of the CGSP are maintained and retrievable for a minimum of two years. These written records include, but not limited to, the following:
8.1 Sampling (sampling log, copy of submission form, automatic sampler checklist, etc.)
8.2 Shipping (sample information linked to export shipment, transfer stuffing report, etc.)
8.3 Internal audit (audit checklist, records of non-conformances, corrective actions taken, etc.)
8.4 Training (training plan, names of trainees, date, etc.)
8.5 Updates to manual (dates, changes, recipients of changes, etc.)

N.B.: All records must be made available to the CFIA upon request.

Appendix 3: Manual Review Checklist

Facility Name and Address Review No. Date of Review

Appendix 4: Sample Equipment and Methodology

1. Sampling Equipment

1.1 Automatic Sampling

There are many types and designs of automatic sampling devices. Automatic samplers take the most representative sample from a lot because there is no human bias involved. They draw a sample automatically by removing a portion of the product from the flow at regular intervals.

If a company is utilizing automatic sampling equipment, their Manual should make reference to:

a description of the components making up the sampling system including the sampler, divider and delivery system (makes and models);
the location of sampling device (i.e., schematic diagram);
the frequency in which primary samples are taken;
how the integrity of the sample is maintained after the sample is drawn;
the frequency of maintenance and calibration of automatic sampling equipment;
procedures to follow in the event that there are problems with the automatic sampling equipment;
alternative sampling procedure if the automatic sampler is not operative.

Appendix 9 is an automatic sampler checklist that each company must complete and include as an attachment to their Manual, and must then be reviewed and updated by the company as a part of their internal audits. Part III of the checklist includes the requirement for calibration of the delivery system at a minimum frequency of once every three years or when changes are made to the sample delivery system.

Calibration can be completed by the company or an outside party, following the Canadian Grain Commission's protocol detailed in Sampling System's Handbook and Approval Guideline found on their web site.

Facilities having valid CGC approval of their automatic sampling system will be recognized by the CFIA. A company will be required to provide proof of this approval to the CFIA.

1.2 Manual Static Sampling Equipment and Procedures

Manual sampling of a static lot is usually done using a probe or a trier. When selecting the appropriate sampling equipment, the sampler should consider the commodity being sampled, the size and type of the containers, whether one is sampling vertically or horizontally, the number of primary samples to be drawn and the required composite sample size. The sampling device should not select the product by size or damage the product being sampled.

Certain types of chaffy grasses which are difficult to sample with a trier may be sampled by the hand method (section 1.2.5).

1.2.1 The Nobbe Trier

This type of trier is a pointed tube with an oval opening near the pointed end. It is relatively compact making it easy to transport. The risk of contamination is low as the trier is easy to keep clean. A Nobbe trier is suitable for sampling free-flowing product in bags (legumes, timothy, rapeseed, mustard) but only where the trier can reach to the centre of the container. It may only be used horizontally and its use is limited to penetrable containers.

Follow these steps to use the Nobbe Trier:

Insert the trier gently into the centre of the container with the trier opening facing downwards and the trier tilted upwards at an angle of approximately 30 degrees to the horizontal.
When sampling from the end of a container, the opening of the trier must reach the centre of the container. Insert the trier as close to the bottom edge of the container as possible (i.e. below stitching).
When sampling from the side, the opening of the trier must reach the opposite side of the container. Insert the trier at the bottom edge of the container such that the 30 degree angle is achieved.
Rotate the trier through 180 degrees, bringing the slot to face upwards.
Withdraw the trier with gentle agitation to help maintain an even flow of product.
The trier must not be agitated without withdrawing.
When sampling from the end, withdraw with decreasing speed so that the quantity of product obtained from successive locations increases progressively from the centre to the container.
When sampling from the side, withdraw with a constant speed.

1.2.2 The Double Sleeve Trier

This type of trier is suitable for sampling static bulk lots in standard or large containers of both small and large crop kinds. The double sleeve trier consists of a hollow tube with a solid pointed end and a close fitting inner tube such that the product cannot slip between the two sleeves. The inner tube may be with or without partitions between the slots.

Multiple openings (slots/holes) are cut into both the inner and outer tubes so that turning the inner tube aligns the openings in the inner and outer tubes. There is a greater risk of contamination with this type of trier. Care must be taken to ensure that all the openings in both the inner and outer tubes are clean. When closing the openings there is a risk of damaging the product trapped between the edges of the slots but this damage can be reduced by closing the openings slowly to the point where resistance is felt.

The contents of the entire tube represent one sample. There is no possibility of varying the amount of product obtained from the inner and outer part of the container by adjusting the speed with which the trier is withdrawn as the trier draws the same size of sample in each sampling action. The trier must always be long enough to reach the opposite end of the container on the diagonal. When sampling the containers vertically, a partitioned trier must be used and the trier must be long enough to reach the bottom of the container.

Follow these steps to use the double sleeve trier, horizontally or vertically:

With the trier in the closed position carefully insert it into the container until it reaches the opposite side. Be careful not to push the trier through the opposite side.
Open the trier and agitated slightly to allow the openings to fill.
Gently close the trier to the point of resistance and withdraw it from the container.
Pour out the sample onto a clean, long piece of paper or into a suitable clean container that is the same length as the trier to check for uniformity.

1.2.3 The Grain Probe

The grain probe (see Figure 1) is a very large double sleeved trier. It is used for sampling bulk commodities in railcars, trucks, containers, bins, or holds of ships. Probes vary in length from 1 meter to 3.65 meters. Grain probes may be partitioned or non-partitioned. Non-partitioned grain probes may only be used horizontally which limits their usefulness. Partitioned grain probes may be used vertically or horizontally.

Appendix 4 - Grain Probe
Figure 1 The Grain Probe

1.2.4 Approved trier (nobbe and double sleeved) sizes by crop kind

Small: Nobbe or Double-sleeve trier with slot size width 8 mm to 14 mm
Medium: Nobbe or Double-sleeve trier with slot size width 15 mm to 19 mm
Large: Nobbe or Double-sleeve trier with slot size width 20 mm or greater

Crop Kind	Trier Size
Alfalfa	Small
Alkaligrass, Weeping	Small
Barley	Large
Bean, Field	Large
Bean, Faba	Large
Bean, Faba	Large
Beet	Medium
Bentgrass	Small
Bluegrass	Small
Brassica spp.	Small
Bromegrass, Sweet	Large
Bromegrass, Meadow	Medium
Bromegrass, Smooth	Medium
Canarygrass, Reed	Small
Canarygrass	Medium
Chickpea	Large
Clover, alsike	Small
Clover, crimson	Small
Clover, red	Small
Clover, hop	Small
Clover, Persian	Small
Clover, strawberry	Small
Clover, subterranean	Small
Clover, white	Small
Corn	Large
Cowpea	Large
Fescues	Medium
Flax	Medium
Foxtails	Medium
Lentil	Medium
Lespedeza spp.	Small
Medick, Black	Small
Milk-vetch, Cicer	Small
Millet, Proso	Small
Millet, Foxtail or Italian	Small
Millet, Japanese	Medium
Mustard, black	Small
Mustard, Oriental or Indian	Small
Mustard, white	Small
Oat	Large
Oatgrass, Tall	Medium
Orchardgrass	Medium
Pea	Large
Rape, forage	Small
Rapeseed, Oilseed Rape including Canola	Small
Redtop	Small
Rye	Large
Ryegrass	Medium
Sainfoin	Medium
Sorghum spp.	Medium
Soybean	Large
Soybean, Natto-type	Medium
Sudan grass	Medium
Sunflower	Large
Timothy	Small
Trefoil, Bird's-foot	Small
Triticale	Large
Vetch, Crown	Small
Vetch, Kidney	Small
Vetches	Medium
Wheat, Durum	Large
Wheat, Common	Medium
Wheatgrass	Medium
Wheatgrass, Crested	Medium
Wild-rye	Medium
Very chaffy grasses - Hand or stream sampling

Note: Where sampling crop kinds other than those in this table, contact the CFIA.

1.2.5 Sampling by hand

Hand sampling of chaffy, non-free-flowing grasses that bunch in the trier, or hand sampling from the top of the bag during the bagging of grain or grain products prior to stitching, may be the only practical sampling alternatives in some situations.

Various position within the bag should be sampled as practical.

Use the following procedure:

Insert your open hand through the top of the container with fingers held tightly together, until the desired depth is reached.
Close your hand with the fingers held tightly together to ensure that few, if any, particles escape, and slowly withdraw your hand.

Repeat this process a number of times in different parts of the lot and at different depths, to obtain the required number of primary samples as specified in Appendix 5.

1.3 Manual Stream Sampling Equipment and Procedures

Select the appropriate location to take the stream sample. This should be at the last step before the product enters the container to be sealed.
Determine the sampling frequency required as specified in Appendix 5.
Ensure that the equipment does not select or separate the product during sampling, due to size, buoyancy or chaffiness.
The entire cross section of the stream must be sampled or various alternating points in the product flow. Each pass of the sampling tool through the stream is defined as one sampling action to obtain one primary sample.
Sampling should be at regular intervals and should reflect the entire lot from the beginning of the flow to the end.

1.3.1 Pelican Type

A Pelican-type sampling tool is approved for hand-sampling dynamic flows of grain for export. To be acceptable, it must:

have an opening at least two times larger than the largest diameter of the particles (seed and contaminants) in the lot;
have sides tall enough to prevent particles from bouncing out;
be of sufficient length to span the complete cross section (side to side) of the stream;
be of sufficient capacity to prevent any overflow when taking a primary sample; and
be such that it can be cleaned properly between lots.

When using a Pelican-type, draw the sampling tool once through the stream from back to front to ensure the entire cross-section of the stream is sampled.

1.3.2 Hand scoop

The hand scoop (See Figure 2) is a sampling device consisting of a rigid material scoop attached to a 50-100 centimetre handle which is stiff and durable. The sample collector capacity must be a minimum of 50 grams and not more than 200 grams.

When using a hand scoop, insert the sampling tool into the stream at an alternate point across the stream (left, middle, right) for each sampling action. The scoop should be placed into the flow of product "upstream" and matching the belt speed or fall of the grain (if possible). As the scoop moves "downstream" it is turned and allowed to fill with grain. Moving the scoop with the flow allows sampling of the appropriate location on the belt without splashing product or overflowing the scoop.

Appendix 4 - Hand scoop
Figure 2 Hand scoop

2. Cleaning and Care of Sampling Equipment

All equipment used for manual sampling must be thoroughly cleaned before each use, and free from all extraneous matter including crop and weed seeds; disease bodies or spores; any seed parts, chaff, dust and inert foreign bodies; and chemical residues such as seed treatments. Triers with residues of extraneous matter could cause cross contamination of other lots.

For the trier, the more polished the inner surface of the trier is, the more freely the product will flow. The rough edges and points of double sleeve triers should be occasionally dressed (removing sharp edges) with a file, emery or very fine sandpaper. This will greatly improve its ease of use for probing jute or poly bags.

The method for cleaning will be based on the type of equipment and the purpose and test for which the sample is to be drawn. Recommended cleaning methods are: cleaning wipes, cleaning solutions such as hand or dish soap, citric acid, rubbing alcohol or water, compressed air, bottle cleaning or gun cleaning tools.

For further information on sampling tools and methodology, refer to Canadian Grain Commission web site.

Appendix 5: Sampling Intensity

1. Sampling for product in bags*

Bags are generally considered to weigh <100 kg

Number of bags	Number of Primary Samples
1 - 14	One sample from each bag
15 - 19	15
20 - 21	16
22 - 27	17
28 - 35	18
36 - 37	19
38 - 46	20
47 - 56	21
57 - 66	22
67 - 77	23
78 - 105	24
106 - 136	25
137 - 187	26
188 - 299	27
300 - 799	28
800 - 999	29
<1000	30

2. Sampling of product in totes*

Totes are grain sacks generally weighing <100 kg

All totes must be sampled, collecting a minimum of two (2) primary samples per tote. These samples may be taken by using a trier/probe or by stream sampling during the loading of each tote.

3. Stream sampling (automatic or manual pelican/sampling cup) bulk grain during loading or filling of containers, railcars, trucks or bins.

The sampling frequency is determined by how much time is needed to load the grain and the total lot size. During the loading of a truck, container, railcar, or bin, samples should be collected systemically at timed intervals, with at least one primary sample taken for every 4 metric tonnes loaded. If a larger composite sample is required, reduce the interval between primary sample collection, or use a larger sampling cup (only practical for manual stream sampling).

Example: The grain lot is 2 containers of 20 metric tones each, and will be loaded in about 30 minutes and will be stream sampled using a hand scoop.

A minimum of 10 primary samples are required (40 mt / 4 mt = 10 samples)

A sample will be taken every 3 minutes (30 minutes / 10 samples = 3 minutes)

The hand scoop to be used has a capacity of 200 grams. 10 x 200 grams = 2000 grams sample will be collected.

* The maximum lot size that can be represented by a submitted sample is 300 metric tonnes for all sampling types.

Appendix 6: Sample Testing Options

Approved testing bodies (Y)
Not approved testing bodies (X)

Testing Required:	CFIA	CGC*	CFIA Accredited Labs/Analysts
entomology/soil	Y	Y	X
weed seeds	Y	Y	Upon CFIA approval
bacteriology, virology mycology, nematology	Y	X	X

* subject to change. Local CFIA offices will be able to provide additional information and updates on available submission and testing options.

Appendix 7: Example of a Sample Submission Form

Appendix 8: Trans-loading Facility (Transfer/Stuffing) Report (Example)

Receiving CFIA Office:

Address:

Name of Transfer Facility: