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QSM-02 (2nd Revision): Quality System Requirements For Facility Registration under the Canadian Wood Packaging Certification Program (CWPCP) or the Canadian Heat Treated Wood Products Certification Program (CHTWPCP)

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Table of Contents

Contact and Review

The next review date for this procedure is October 1, 2011. For further information or clarification, please contact the CFIA Forestry Division.

Endorsement

Approved by:


Quality System Document Committee Representative


Date


Chief Plant Health Officer


Date

Amendment Record

Number of Amendment Amended by Date of submission for approvalof amendment Summary of amendment and number of amended page(s)
1 Mireille Marcotte September 8, 2009 Housekeeping throughout the document re: glossary of terms and removal of references to the former KD/HT Program; Addition/updating of elements that need to be part of the facility's manual re: debarking (section 7.1.3), repair and remanufacturing (section 7.4), pallet kits (section 7.6) and stamping off-site (section 7.7); Section 7.1.6 Adding: The CFIA Network Specialist must be notified whenever a significant change is made to the facility's operating procedures; Section 8.1.2 and 8.2 Adding: The facilities must be available for audits by the Service Provider and/or the CFIA within 24 to 48 hour notice.

Distribution

  1. Directive mail list (Regions, Areas and PHRA)
  2. National Industry Organizations (determined by Author)
  3. Service provider
  4. CHTWPCP and CWPCP Working Group
  5. Internet

Note: For the purpose of this document, a registered facility is a facility that has applied and has been approved by a program officer of the CFIA to participate in the CWPCP or the CHTWPCP.

Introduction

The Quality System Requirements For Facilities Under The Canadian Wood Packaging Certification Program (CWPCP) or The Canadian Heat Treated Wood Products Certification Program (CHTWPCP) is a supplementary document to CFIA Policy D-03-02, Canadian Heat Treated Wood Products Certification Program for Export (CHTWPCP), CFIA Policy D-01-05, Canadian Wood Packaging Certification Program (CWPCP) and The Technical Heat Treatment Guidelines and Operating Conditions Manual (PI-07).

This manual outlines the registration and auditing requirements of:

  1. Registered facilities heat treating wood (lumber, logs or wood packaging).
  2. Registered facilities manufacturing or producing heat treated wood products (broker, wood packaging facilities, pre-fab homes, etc.)
  3. Facilities heat treating and/or exporting heat treated wood products covered by a Phytosanitary Certificate (pre-fab homes or heat treating facilities).

1.0 Scope

This document is intended for the use by facilities registered under the CHTWPCP and CWPCP, CFIA Service Providers, the Canadian Lumber Standards Accreditation Board (CLSAB) and its grading agencies involved in these two programs, CFIA inspection staff and any other authorized parties. This outlines the requirements for facilities seeking registration and ongoing operation under these programs.

2.0 References

  • ISPM No. 5, Glossary of Phytosanitary Terms, FAO, (updated annually).
  • ISO Guide 8402, Quality Systems Terminology.
  • ISPM No. 15, Regulations of Wood Packaging Material in International Trade, FAO.
  • ISPM No. 7, Export Certification Systems, Publication, FAO.
  • CFIA Policy D-01-05, The Canadian Wood Packaging Certification Program.
  • CFIA Policy D-03-02, The Canadian Heat Treated Wood Products Certification Program.
  • CFIA PI-07, The Technical Heat Treatment Guidelines and Operating Conditions Manual.
  • Canadian Lumber Standards Accreditation Board Regulations.
  • QSM-05, Quality System Requirements for CLSAB and CLSAB Accredited Lumber Agencies Approved under the CHTWPCP.

3.0 Definitions, Abbreviations and Acronyms

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

4.0 Type of Audits

Evaluation Audit

  • A systematic examination performed at the time of registration which verifies the extent to which an entity is capable of fulfilling the requirements of the CWPCP or the CHTWPCP.

System Audit

  • A review by CFIA of the organizational structure, procedures, processes and resources used by registered facilities or Service Providers in implementing the certification program.

Verification Audit

  • A review by a Service Provider of the organizational structure, procedures, processes and resources used by a registered facility in implementing the certification program.

5.0 Registration

5.1 Application for Registration

A facility seeking registration under the CFIA Policy D-03-02 or D-01-05 must adhere to the administrative and operational requirements outlined in this document. A signed application for registration and a copy of the facility's Quality Management System Manual (herein referred to as the manual) must be sent to a CFIA recognized Service Provider. A list of recognized Service Providers can be found on the CFIA Forestry web site.

The manual must outline the facility's methods and measures for complying with the procedures and phytosanitary standards set within the CHTWPCP or the CWPCP and the requirements set out in this document. The completed application must be signed by an authorized official of the facility.

5.2 Facility Registration

The Service Provider will review and compare the facility's manual to the requirements specified in D-03-02 or D-01-05, to PI-07 and to this document. An evaluation audit of the facility will also be conducted as outlined in Appendix 1 or Appendix 2 (whichever is applicable). Provided that the manual meets the requirements and the evaluation audit is satisfactory, the Service Provider will approve the manual and sign the application form.

For those Service Providers that have not applied through the CLSAB to be recognized as a Service Provider and where they have applied directly to the CFIA for recognition as a Service Provider, the application along with the manual is to be sent to the CFIA regional office for final approval and registration.

For those Lumber Grading Agencies that have applied through the CLSAB for recognition as Service Providers under the CHTWPCP, the Lumber Grading Agency shall submit the following documents to the CLSAB to recommend the facility for approval under the CHTWPCP:

  • the application for facility registration, and
  • the signed statement approved by CLSAB stating that to the best of their knowledge, following a full review of the manual, the operating procedures of the facility conform to the requirements specified in D-03-02, PI-07 and this manual.

Upon CLSAB's approval, CLSAB will forward the signed application, together with the signed statement confirming that the Operating Procedures are contained in a manual to a CFIA regional office. The CLSAB will make available to the CFIA a copy of the facility's manual when requested. The application shall contain the assigned Agency nomenclature and Facility Number, which will appear on the facility's Grade Marks and/or Certificates issued by the facility.

Following a recommendation by the Service Provider, approval by CLSAB, and final approval by CFIA, a registration number will be issued. In the case where a facility has made an application and received approval for registration under ISPM No. 15, CFIA shall issue the CA and five digit registration number.

Note: The ISPM Mark must be separate from any other marks.

Once approved a facility must maintain a current copy of its manual, and make it available to the Service Provider, the CLSAB or the CFIA, immediately upon request.

6.0 Facility Management Responsibility

A registered facility is responsible for the employment and training of sufficient and competent staff to carry out the requirements of these programs. All staff members responsible for quality control activities or involved in the production of certified treated lumber must be aware of the phytosanitary requirements of this program and be appropriately trained in all functions specific to these programs. A manual documenting the facility's quality procedures related to the phytosanitary requirements specified under the CHTWPCP or the CWPCP must be developed and maintained.

7.0 Manual Elements

7.1 Manual Elements Required of All Facilities Registered in the CHTWPCP or CWPCP

The manual will generally include the facility's objectives, quality processes and interactions of those processes, descriptions of documentation control, the structure of the organization, the facility's common terminology, and the responsibilities of the employees involved with the phytosanitary processes. It must also cover the elements identified within section 6.0. Facilities applying for registration under policy D-03-02 or D-01-05 and those facilities requesting phytosanitary certification for export, must provide information on the following elements in their manual.

7.1.1 Administration

The manual must provide the facility identification, address and distribution list and if needed include an index. All pages must be numbered.

7.1.2 Structure of the Organization

The facility must provide information as to the function and responsibilities of staff members involved in maintaining phytosanitary requirements. An organization flow chart may be a simple means of achieving this requirement.

7.1.3 Training

The facility must describe the training procedures of staff performing duties related to the phytosanitary requirements of the CHTWPCP or CWPCP, including the specific training elements and the intervals between training and re-training. An example of the training record must be provided.

7.1.4 Non-Conformances

The facility must specify the procedures for addressing non-conformances and must include an action plan for dealing with specific processes and activities that fail to comply one or more of the specified elements.

7.1.5 Internal Quality Audits

The facility may describe any internal quality audit conducted by the facility on a routine basis to ensure that the quality processes are being conducted in a consistent manner.

7.1.6 Amendment of the Manual

Procedures used to amend the manual must be identified. A list of amendments must be maintained and example of the listing must be included in the manual. The list must identify those receiving copies of amendments, including the Service Provider. The CFIA Network Specialist must also be notified whenever a significant change is made to the facility's operating procedures.

7.1.7 Identification of Heat Treated Wood

The facility must identify how wood, that has been heat treated, is traceable to a treatment.

7.1.7.1 Identification of Treated Wood for Domestic Movement

The manual must clearly specify a procedure for identifying how wood is traceable to treatment. For the movement of treated wood between Canadian registered facilities, the procedure must meet the specifications identified in Section 2.4 of D-03-02 (CHTWPCP).

7.1.7.2 Identification of Heat Treated Wood Products for Export

If the facility exports heat treated wood products, the facility must specify the procedures used in meeting the conditions identified in Section 2.3.1.3 of D-03-02.

7.1.7.3 Identification of Heat Treated Wood Packaging Material Including Dunnage

The facility must specify how dunnage or wood packaging material used to support or secure the export products is marked in compliance with the phytosanitary requirements of the importing country. Where dunnage is attached to the actual wood products, and where accepted by the importing country, a heat treatment certificate and/or a phytosanitary certificate may be used. For dunnage or wood packaging material which is not attached, refer to section 2.3.2.2 and 2.3.2.3 of the D-03-02 or section 12.1 of D-01-05.

7.1.8 Segregation of wood

The facility must specify how treated wood is segregated from untreated wood (e.g. a schematic may be used).

7.1.9 Heat Treatment Certificate

The facility's manual must specify the procedure for the issuance of heat treatment certificates including the persons responsible for issuance, the numbering system used, etc. An example of the specific type of certificate issued by the facility must be provided in the manual (if applicable).

7.1.10 Document Control

The facility must state the retention period for all records used by the facility to track activities or procedures related to the CHTWPCP or CWPCP. The documents must be retained for a minimum of 2 years.

7.2 Specific Manual Elements for Registered Facilities Heat Treating Wood Products (Lumber and/or Wood Packaging)

While heat treatment operating procedures vary, facilities heat treating wood products must address at least the following additional requirements.

7.2.1 Heat treatment chamber

The manual must specify how the general operating requirements set out in PI-07 are met and maintained. These conditions include air flow rate, operation of fans, wet bulb/dry bulb sensor descriptions and locations, the strategy for changing air flow directions and if applicable, the process for determining initial wood core temperature.

The manual must provide a description of the heat treatment chamber with the location of heat sensors (e.g. a schematic).

7.2.2 Treatment options

The facility must identify the phytosanitary heat treatment option(s) selected (from PI-07) or provide a recognized heat treatment evaluator's kiln schedule. For the purpose of this document, a recognized heat treatment evaluator is an organization, company or person that has been authorized by the CFIA to conduct a scientific analysis pertaining to the treatment of wood products.

7.2.3 Treatment documentation

The manual must include the method of recording the recognized heat treatment process referred to in 7.2.2 above. The method must demonstrate how the records relate to the specific phytosanitary requirements with respect to minimum time and temperature. A method of recording the heat treatment process must be included. The manual must specify the species to be treated, dimensions of the wood being treated, and the size of stickers.

7.2.4 Treatment Records

Each facility shall maintain records that verify that each treatment has met the technical specifications outlined in the CWPCP. The facility shall indicate in the manual the type of information to be maintained. Records are to be kept for a minimum of 2 years after treatment.

7.2.5 Verification of the Measuring System

The facility must provide a documented procedure for verifying that the measuring system (temperature sensors) is operating within prescribed standards.

7.2.6 Final Moisture Content

For option B, C, D and F, a process must be specified for ensuring that the moisture content of wood that has been treated complies with the specifications in PI-07 and how the facility deals with non-conforming treatments.

7.3 Specific Manual Elements of Facilities Producing Certified Wood Packaging Material for Export

If the facility heat treats wood packaging material or the facility produces certified wood packaging from heat treated wood, the facility must describe the marking method used to identify compliant products in accordance with Section 2.3.2 of D-03-02. The facility must also provide an example of the wood packaging certification mark in the manual.

7.3.1 Use of Debarked Wood in the Production of Wood Packaging Materials for Export

Facilities producing certified wood packaging materials must describe in their manual, the process used in ensuring compliance with the debarking requirement, as specified in Section 6.0 of the D-01-05.

7.4 Specific Manual Elements of Facilities Repairing or Remanufacturing Previously Certified Wood Packaging Materials

If the facility repairs or remanufactures previously certified wood packaging materials for export or domestic movement out of a regulated area for a quarantine pest, the facility repairing/recycling the wood packaging must specify in its manual the process used in ensuring compliance with the standards prescribed in Section 8.0 and 9.0 of the D-01-05.

7.5 Specific Manual Elements for Registered Facilities Handling Heat Treated Wood Products (Including Brokers, Wood Packaging Facilities, Pre-fabricated Home Facilities)

Facilities producing new wood packaging material, pre-fabricated homes or those handling certified treated wood in which the identity of the wood is changed, must assure that the export products are traceable to a registered heat treatment facility and that all products are marked in compliance with the phytosanitary requirements of the importing country.

7.5.1 Purchasing

Where the facility purchases heat treated wood products, these wood products must be sourced from facilities registered under the CHTWPCP or the CWPCP. The manual must specify the markings or identification methods used for the treated wood received and properly segregated.

7.6 Specific Manual Elements for Facilities Producing Wood Packaging Material Kits to be Assembled in a Non-Registered Facility

Facilities producing wood packaging material kits to be assembled in a non-registered facility must specify in their manual the process used in ensuring compliance with the standards prescribed in Section 10.0 of D-01-05.

7.7 Specific Manual Elements for Facilities Using the Wood Packaging Certification Mark Outside the Registered Facility

Where it is impossible for the registered facility to assemble and stamp the wood packaging materials on-site, procedures used in ensuring the compliance with section 11.0 of the D-01-05 must be specified in the manual of the registered facility.

7.8 Consolidation Wood Produced at Other Facilities

Facilities consolidating wood products produced at other facilities must be registered under the program and must indicate the procedure for the issuance of consolidated heat treatment certificates including the persons responsible for the issuance of certificates, and the certificate numbering system, etc. The facility must also specify the procedures used in ensuring that consolidated certificates are traceable to an approved treatment.

8.0 Document Review and Audits Conducted by the CFIA or the Service Provider

During an evaluation audit, a verification audit, or a system audit, a document review will be conducted to verify that the facility continues to meet the requirements prescribed in D-03-02 or D-01-05, PI-07 and this document, and is operating within the instructions of its manual.

The audit type and audit frequency on initial and subsequent visits to the facility to verify compliance with the facility's manual and D-03-02 or D-01-05 is described in Appendix 1 or Appendix 2 (whichever is applicable).

8.1 First Year of Program Participation

8.1.1 Evaluation Audit

In order to complete the registration process, new applicants will require an evaluation audit before registration. The audit verifies that a facility is capable of meeting the requirements prescribed in D-03-02 or D-01-05, to PI-07 and this document and is operating in compliance with its manual. An evaluation audit may also be necessary to confirm that a facility that has been suspended for non-conformance has adequately addressed necessary corrective actions to avoid non-conformances in the future.

This evaluation audit will be done by the Service Provider and the CFIA reserves the right to participate in the evaluation audit. If the facility is not performing within the specifications of the approved manual or the requirements specified in D-03-02 or D-01-05, PI-07 or this document, the facility must complete corrective actions as required by the Service Provider or CFIA. If the corrective actions are not completed to the satisfaction of the CFIA, the facility will be removed from the program.

8.1.2 Verification Audits

Verification audits determine if the manual, the facility's procedures and work instructions are fully implemented and conform with D-03-02 or D-01-05, to PI-07 and this document. During the first year of operation, verification audits will be conducted as outlined in Appendix 1 or Appendix 2, (whichever is applicable). The facility must be available for audits by the Service Provider and/or the CFIA within 24-48 hours notice.

8.2 Second and Subsequent Years of Program Participation

Where the facility has maintained the phytosanitary requirements during the first year of participation, the frequency of audits may be reduced. Note: industry standards may specify higher audit frequencies for certain wood products.

8.2.1 Verification Audits

Verification audits will be conducted, as outlined in Appendix 1 or Appendix 2, (whichever is applicable) to ensure that the facility is still performing within the phytosanitary requirements. The audit will focus on key areas that are most critical for the delivery of compliant wood products. The audit will determine if the manual, procedures and work instructions of the facility are fully implemented and conform to D-01-05 or D-03-02. Should non-conformances be identified by CFIA or a Service Provider, CFIA or Service Provider may increase the frequency of audits to verify that corrective actions are complete or that corrective actions taken are ensuring that the non-conformance does not recur. The facility must be available for audits by the Service Provider and/or the CFIA within 24-48 hours notice.

9.0 Non-Conformance

The CFIA or a Service Provider will require a registered facility, to take corrective action on any non-conformance identified. These corrective actions will be monitored by the CFIA and the Service Provider.

Where the CFIA or a Service Provider finds that a registered facility is not in conformance, the CFIA or the Service Provider may increase the frequency of inspection, until satisfactory corrective actions are complete. CFIA may increase the frequency of inspections applied to Service Providers where non-conformances exist.

Upon the identification of a non-conformance, CFIA or the Service Provider will provide a written report to the registered facility identifying the non-conformance, corrective actions necessary and the need for follow-up inspections.

Where repetitive non-conformances are identified at a facility or where a non-conformance jeopardizes the integrity of the CHTWPCP or the CWPCP, the facility registration may be suspended or the facility registration may be revoked by the CFIA, following consultation with the Service Provider. The CFIA shall notify the registered facility in writing of this action

Non-conformances may be major or minor. For definitions and examples of non-conformances, refer to Appendix 3.

9.1 Minor Non-Conformances

Notification of minor non-conformances identified by the Service Provider, including a description of the non-conformance and the required corrective action plan, shall be made available to the registered facility by the Service Provider within five (5) working days. The Service Provider will follow-up on the corrective actions within a reasonable time frame, not exceeding 1 month from notification.

Information regarding the recorded minor non-conformances, the planned corrective actions and follow-up confirmation that the corrective actions have been completed shall be provided annually by the Service Provider to the CFIA or to the CLSAB where applicable.

9.2 Major Non-Conformances

Notification of major non-conformances, including a description of the non-conformance and the required corrective action shall be provided by the Service Provider to the registered facility, to CFIA, and to the CLSAB where applicable, within three (3) working days of the audit. Depending on the nature of the non-conformance and following recommendation by the Service Provider and the CLSAB where applicable, the CFIA may apply an interim suspension.

The service provider will request the facility to take corrective action within a time frame appropriate to address the non-conformance but not to exceed 10 working days.

The service provider will follow-up on corrective actions taken by the facility as often as required to verify full compliance within 10 working days of the corrective action due date

Service provider will confirm to the CFIA and to the CLSAB where applicable, that the required corrective action has been taken or has not been taken, within three (3) working days of the follow-up visit intended to verify the corrective action.

Where there is a total failure of the facility's quality management system, the facility will be immediately cancelled from the program and the facility will be required to re-submit an application for registration to the program. If approved, a new facility registration number will be issued.

Service Provider inspection reports must be completed, dated and kept on file at the facility and by the Service Provider's office for review during normal business hours by the CFIA, at its discretion.

10.0 Enforcement

10.1 Suspension of Registration

In cases of suspension, the terms and duration of the suspension will be determined following consultation between the Service Provider, the CLSAB where applicable, and the CFIA.

During a suspension period, the registered facility will not be permitted to apply the CHTWPCP recognized certification mark for wood products and will not be permitted to apply the international recognized certification mark for wood packaging material as outlined in the CHTWPCP or the CWPCP. Failure to comply will result in immediate cancellation of the facility's registration.

If the facility's corrective actions and quality plan are deemed sufficient by the Service Provider, the CFIA will lift the suspension and the Service Provider will assign the facility a new audit frequency. Once the facility has demonstrated to the Service Provider on-going compliance with the requirements of the CHTWPCP or the CWPCP, the Service Provider will reduce the frequency of inspection to that described in Appendix 1 or 2 (whichever is applicable).

10.2 Cancellation of Registration

A facility registration may be cancelled where the facility fails to address the non-conformances identified at the time of suspension, where a major non-conformance which compromises the integrity of the program has been determined by the Service Provider in consultation with CFIA, or where the facility voluntarily withdraws from the CWPCP or the CHTWPCP.

Upon cancellation of Registration, the facility's name and number shall be removed from the CFIA list of approved facilities. Under the terms of the Application for Registration under the CHTWPCP or CWPCP, if the status of the facility is cancelled, the facility must immediately terminate all usage of the CHTWPCP Recognized Certification Mark and the ISPM No.15 Recognized Mark for wood packaging material.

A cancelled wood packaging facility or treatment facility may re-apply for registration once it has completed all corrective actions necessary to the satisfaction of the CFIA, the CLSAB where applicable, and/ or Service Provider to prevent a recurrence of the non-conformance(s). The facility must re-submit a manual and a detailed report of corrective actions taken. The Service Provider, in cooperation with the CFIA, and with the CLSAB where applicable, will conduct a re-evaluation of the facility to determine if the necessary corrective actions were sufficient. A new increased inspection frequency shall be assigned to the facility. Once the facility has demonstrated on-going compliance with the standards of the program satisfactory to CFIA, the CLSAB where applicable, and/or Service Provider, the facility shall return to the normal inspection frequency.

11.0 CFIA System Audits of the Program

CFIA will conduct audits of facilities, the CLSAB where applicable, and Service Providers as described in Appendix 1 or Appendix 2 to verify that the system for production of certified heat treated wood products (including wood packaging) is consistently maintaining the phytosanitary requirements of importing countries and is ensuring that the overall conditions of the CHTWPCP and CWPCP are being met.

Appendix 1

Activities and Audits on Facilities monitored by Service Providers (other than those Service Providers audited by CLSAB for compliance to this program)

Type of Facilities
Activities Facility with a Heat Treatment Chamber (Primary Treatment Facility) Exporters, Shippers, Brokers Consolidating Treated Materials, Secondary Manufacturers Using Heat Treated Products (Including Wood Packaging Facilities)
Application for registration under the CHTWPCP, CWPCP & Submission of the Manual Prior to registration. Prior to registration.
Issuance of facility registration number by CFIA Upon approval of facility's manual. Upon approval of facility's manual.
Evaluation Audit conducted by Service Provider in cooperation with the CFIA To be conducted prior to registration or as a result of suspension from the program. To be conducted prior to registration or as a result of suspension from the program.
Verification Audit conducted by the Service Provider A minimum of 4/year. A minimum of 4/year in the first year of registration or re-registration following suspension and 2/year in subsequent years.
Verification Audit (Response to Non-conformances) At any time until non-conformances are corrected to the satisfaction of the Service Provider and/or CFIA. At any time until non-conformances are corrected to the satisfaction of the Service Provider and/or CFIA.
System Audits conducted by CFIA A representative sample (up to 33%) of registered facilities on an annual basis. A representative sample (up to 33%) of registered facilities on an annual basis.

 

Appendix 2

Activities and Audits on Facilities monitored by Service Providers (Accredited Lumber Grading Agencies) which are audited by the CLSAB for compliance to this program

Application for registration under the CHTWPCP & Submission of the Manual

  • This must be submitted prior to registration.

Issuance of facility registration number by CFIA

  • Upon approval of facility's manual and recommendation received by CLSAB.

Evaluation Audit conducted by a CLSAB accredited Lumber Grading Agency in cooperation with the CFIA

  • To be conducted prior to registration. The CFIA reserves the right to participate on the evaluation audit of the facility and in cooperation with the CFIA, the Lumber Grading Agency will coordinate the evaluation audit with the CFIA, where deemed necessary.

Verification Audit conducted by a CLSAB accredited Lumber Grading Agency

  • 4/year for primary facilities. For secondary facilities, a minimum of 4/year in the first year of registration or re-registration following suspension and 2/year in subsequent years. For those facilities required to meet the ALS requirements, a minimum of 12 visits will be conducted on an annual basis.

Follow-up audit

  • At any time, until the major non-conformances has been corrected to the satisfaction of the accredited Lumber Grading Agency and/or CFIA

Verification Audit conducted by the CLSAB

  • 2 per year on each accredited Lumber Grading Agency and at least 10 percent of the accredited Lumber Grading Agency's facilities in each size group (small, medium and large) are randomly selected. For small lumber grading agencies (less than one billion FBM of shipments) a min. of three facilities or 15% of the total number is sampled, without reference to small, medium and large facilities.

Systems Audits conducted by CFIA

  • An annual audit of the CLSAB and a random sample of the CLSAB accredited Lumber Grading Agencies (*up to 50%) and will include a random sampling (up to 20%) of the agency's registered facilities.

*Note: CFIA shall advise CLSAB of the Lumber Grading Agencies and facilities it intends to audit in order to maximize efficiencies and effectiveness of the audit program.

Appendix 3

Examples of non-conformances at the facility levels

Minor Non-Conformances

Inspection findings that reveal an isolated incident of non-conformance which has no direct impact on the integrity of the product and that remedial action can be taken within a time 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 5 minor non-conformances = a major non-conformance

  1. Facility operating with minor changes to quality processes that have not been approved by CFIA or a CFIA Service Provider.
  2. Facility procedures for documentation or certificate issuances have not been followed or have been poorly followed. Procedures are unclear.
  3. Facility employee involved with implementing the quality procedures (e.g. kiln operator, certificate signing authority, employees responsible for product separation, etc.) is unaware of the phytosanitary specifications pertaining to activities performed by that employee.
  4. Segregation or identification of treated and untreated wood is inadequate, but does not affect the integrity of products ready for export
  5. Facility record-keeping is inadequate but records essential to the integrity of the phytosanitary standard (e.g. treatment records are complete).
  6. Staff training has not been completed or records of training have not been maintained
  7. Registered facility has failed to maintain records of inspections .

Major Non-Conformances

Inspection findings that reveal that the integrity of this program may be compromised. Certificates must not be issued. The registered facility may be suspended from this program

  1. Facility operating with significant changes to kiln operating conditions that have not been approved by CFIA or a CFIA Service Provider.
  2. Corrective actions identified for non-conformance from previous audits have not been implemented
  3. Regulated wood products destined to off-shore markets have not met the phytosanitary standard (i.e. 56°/30 minutes). (e.g. the registered facility fails to meet the treatment specifications in the approved manual, etc.)
  4. Exported material or material designated or consigned for export fails to meet the phytosanitary import requirements of the importing country.
  5. The facility has improperly issued certificates (e.g. failed to meet the specifications on the certificate or the certificate was issued by an unauthorized person, etc.)
  6. Segregation of treated and untreated lots has not been maintained.
  7. Records are significantly incomplete or do not allow CFIA or the Service Provider to conduct traceback of products exported (e.g. treatment records are missing, incomplete, etc. or export certificates not maintained, etc.)
  8. A consolidated shipment has been constructed from wood products that have not been treated in accordance with the standards or has been obtained from a facility not registered.
  9. Employees involved with implementing the quality procedures are not sufficiently trained

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