QSM-05: Quality System Requirements for CLSAB and CLSAB Accredited Agencies Approved under the CHTWPCP

Table of Contents

Contact and Review

The next review date for this manual is anticipated for March 4, 2012. For further information or clarification, please contact the Forestry Bureau, Canadian Food Inspection Agency (CFIA).

Endorsement

Approved by:


Joanne Rousson, Project Coordinator


Date


Greg Stubbings, Chief Plant Health Officer


Date

Amendment Record

Amendments to this QSM will be given a consecutive number and will be dated.

Please ensure that all amendments are inserted, obsolete pages removed, and the record below is completed.

Amendment No.: Amendment Content and Pages: Entered by: Date:
1 Minor administrative changes (throughout) Mireille Marcotte May 13, 2008
2 Minor administrative changes (throughout) Shamina Maccum March 4, 2011
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Distribution List

  1. CLSAB Working Group
  2. National Industry Organizations (determined by Author)
  3. CFIA website
  4. Listserve

1.0 Introduction

The CFIA is the National Plant Protection Organization of Canada responsible for the phytosanitary export certification of plant material and for the development of certification systems which will address the phytosanitary requirements of importing countries.

The CFIA Directive D-03-02, Canadian Heat Treated Wood Products Certification Program for Export (CHTWPCP) outlines the phytosanitary certification requirements for the export of wood products required to be heat treated to a minimum core temperature of 56°C for a minimum of 30 minutes.

The Canadian Lumber Standards Accreditation Board (CLSAB) is responsible for the accreditation of all Canadian Lumber Grading Agencies that monitors the quality of Canada's lumber grading and identification system. The CLSAB is empowered under Canada's National Housing Act and derives its authority and mandate in the form of regulations under the Canadian Standards Association. The CFIA recognizes CLSAB's regulatory regime which provides for the oversight role of its Accredited Grading Agencies and their registered facilities in assuring compliance to the phytosanitary certification requirements as outlined in the CHTWPCP. Under the CHTWPCP, the term facility refers to an establishment with a Heat Treatment Chamber, an Exporter, Shipper, a Broker Consolidating Treated Materials, or other secondary manufacturers using Heat Treated Products. A treatment facility is an officially authorized facility where recognized phytosanitary wood treatments are performed (i.e., within the content of this directive examples include: kiln dried-heat treatment, heat treatment).

This document identifies the functional requirements that must be met by the CLSAB accredited Grading Agencies as Service Providers under the provisions of the CFIA Directive D-03-02, Canadian Heat Treated Wood Products Certification Program for Export (CHTWPCP). Where the CLSAB Regulations specifically addresses any of the functional requirements identified within this document, the particular sections of the CLSAB Regulations have been referenced. The Service Provider's policies and procedures that address these requirements shall be described in their Quality Management Systems Manual (herein referred to as the "Manual") that will be subject to approval by CLSAB and the CFIA and shall be reviewed from time to time. For the purposes of this document, a Service Provider is a CLSAB accredited Grading Agency, who is accountable to the CFIA through CLSAB for the delivery of the CHTWPCP, providing reports of all audits, inspections, incidents of non-conformance, and follow-up activities such as re-inspection of non-compliant facilities. A Manual is a detailed operational manual which specifies measures to be used to meet prescribed standards i.e., all requirements pertaining to the wood product certification program which is referred to in Directive D-03-02, CFIA QSM-02, the PI-07, and this document.

2.0 Scope

This document is intended for use by the CLSAB and CLSAB accredited Grading Agencies participating in the inspection of facilities registered under the CHTWPCP, and CFIA inspection staff.

3.0 References

  • Glossary of Phytosanitary Terms, Publication ISPM No. 5, FAO (updated annually)
  • ISO Guideline 8402, Quality Systems Terminology
  • ISPM No. 15 Guidelines for Regulating Wood Packaging in International Trade, FAO, March 2002
  • ISPM No. 7 Export Certification Systems, FAO, 1997
  • CFIA Directive D-01-05, The Canadian Wood Packaging Certification Program (CWPCP)
  • CFIA Directive D-03-02, Canadian Heat Treated Wood Products Certification Programs (CHTWPCP)
  • CFIA QSM-02 Quality System Requirements for Facility Registration under the Wood Product Certification Programs Canadian Wood Packaging Certification Program (CWPCP) and Canadian Heat Treated Wood Products Certification Program (CHTWPCP)
  • CFIA PI-07, The Technical Heat Treatment Guidelines and Operating Conditions Manual
  • The Canadian Lumber Standards Accreditation Board (CLSAB) Regulations

4.0 Definitions, Abbreviations and Acronyms

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

5.0 Application for Recognition as a Service Provider

CLSAB Accredited Grading Agencies wishing to be recognized as Services Providers must agree to comply with the terms and conditions set under the provisions of the CFIA Directive D-03-02, Canadian Heat Treated Wood Products Certification Program for Export (CHTWPCP).

5.1 Application

An application for recognition of CLSAB accredited Grading Agencies as Service Providers pursuant to the standards shall be submitted in writing by the CLSAB to the CFIA. The application shall include a clear statement as to the scope of the recognition requested, and shall include a Manual from each of the accredited Grading Agencies outlining the agency's procedures and processes to assure compliance with the standards identified within this document.

5.2 Recognition

The CFIA shall formally recognize the accredited Grading Agencies submitted by CLSAB for recognition as Service Providers under the CHTWPCP, once it has determined that Agency Manual has fulfilled the requirements set out in the standards. The CFIA shall make public this decision and agreement by posting the approved CLSAB accredited Grading Agencies as Service Providers for the purpose of the CHTWPCP on the CFIA website.

6.0 General Requirements of the Service Provider

6.1 Organizational Requirements

The Service Provider shall:

  1. Be legally identifiable.
  2. Be responsible for its verification activities.
  3. Have documented policies and decision-making procedures that distinguish between activities for which it has received formal recognition and any other activities in which the body is engaged (Section 3.5 to 3.5.26 of CLSAB regulations).
  4. Not offer consultancies or other services which may compromise the objectivity of its recognition process and decisions (Section 3.5.2 of the CLSAB regulations).
  5. Be soundly supported financially (Section 3.2 to 3.4.9 of the CLSAB regulations).
  6. Be free from commercial or any other influence that might affect its integrity (Section 3.2.1 of the CLSAB regulations).
  7. Ensure sufficient and competent personnel to undertake the requirements of audit program.
  8. Maintain a Manual approved by the CLSAB and the CFIA governing all aspects of the certification program.
  9. In cooperation with CFIA and CLSAB provide registered facilities information with respect to inspection requirements or processes, and notify registered facilities of updates or changes to the regulations as directed by the CFIA and CLSAB.

6.2 Service Provider Responsibilities

On behalf of the CFIA, the Service Provider shall perform the following tasks:

  1. Receive applications from facilities wishing to be registered under the CHTWPCP, review the facility Quality Manual and recommend participation to the CLSAB.
  2. Attend joint audits of facilities with CFIA where necessary.
  3. Monitor the compliance of facilities registered in the CHTWPCP through regular program audits, at the frequency and in the format specified by CLSAB and approved by the CFIA.
  4. Identify, and report to the facility and monitor the resolution of minor non-conformances.
  5. Identify, and report to the facility, the CLSAB, and the CFIA any major non-conformances and inspect as directed to confirm their resolution.
  6. Maintain records and report to the CLSAB and CFIA in the manner and frequency specified under Section 7.3 of this document.
  7. Respond to applications by providing appropriate documentation, guidelines and references.
  8. Maintain knowledge of CFIA policies and guidelines, as well as CFIA's export requirements pertaining to wood exports.
  9. Provide an organizational chart identifying all positions having responsibility for activities included in the provision of service, (Section 3.5.5, and 3.5.6, of the CLSAB Regulations).
  10. Include in its Manual a description of the responsibilities of the Service Provider's employees, their duties in relation to the program, specific individuals identified as having the responsibility of liaising with the CLSAB and the Service Provider's methods for ensuring that employees are fully trained in the requirements of the program, (Section 3.4 of the CLSAB Regulations).
  11. Identify and describe the responsibilities of a key individual to act as contact with the CLSAB and manager of the program.
  12. Identify qualification and training of personnel (Section 3.5.6 of the CLSAB Regulations).
  13. Advise the CLSAB in writing as soon as it comes to its attention that a registered facility ceases to operate under agreement with the Service Provider or has withdrawn from the CHTWPCP.
  14. Complete and date a report of each inspection of a registered facility, and such reports will be kept on file by the Service Provider for periodic review by the CLSAB and CFIA at their discretion.
  15. Maintain for a period of at least two (2) years all records pertaining to its verification of facilities, including but not limited to: assessment reports for registration, audit reports, reports of non-conformances and follow-up audits, authorizations of changes to Manuals and to the training of Service Provider staff. A follow-up audit is an audit performed by a Service Provider to verify that corrective actions ordered on major non-conformances have been completed and that the facility's operations continue to meet the specifications of the facility Manual.

6.3 CLSAB Responsibilities

The CLSAB shall:

  1. Maintain, as per section 3.5.23 of the CLSAB regulations, service agreements with accredited Grading Agencies and a register of all facilities who are participating in the CHTWPCP, and are authorized by CLSAB to label or certify wood products as being heat treated (HT) having achieved a minimum core temperature of at least 56°C for a minimum of 30 minutes.
  2. Inform its accredited Grading Agencies of any changes within this program.
  3. Provide reasonable advance notice to the CFIA of any meeting which may address any issue with respect to the CLSAB Regulations relevant to the CHTWPCP, and other related documents which may be developed from time to time specific to the CHTWPCP.
  4. Update Schedule C of the CLSAB Regulations on an ongoing basis to be consistent with the intent of the CHTWPCP, PI-07 and this document.
  5. Conduct audits of its Service Providers as outlined in the CLSAB Regulations, and in accordance with CHTWPCP requirements and this document.
  6. Inform the CFIA, in writing and in a timely and confidential manner not more than three (3) business days following an audit, of the failure of any approved grading agency or its member facility to meet the requirements of the CHTWPCP or the CLSAB Regulations Schedule C.
  7. Submit a Manual to the CFIA outlining its activities, duties, and its responsibilities pursuant to the CFIA Quality System Requirements for CLSAB and CLSAB Accredited Agencies Approved under the CHTWPCP (QSM-05)
  8. Recommend for registration facilities which have met the requirements of the CHTWPCP to the CFIA and make available to the CFIA a copy of the facility's Manual where requested.
  9. The CLSAB will advise the CFIA in writing as soon as it comes to its attention that a registered facility ceases to operate under agreement with the Service Provider or has withdrawn from the CHTWPCP.

Note: Every facility which is authorized by a Service Provider approved by CLSAB to label or certify the HT designation will be required to register with the CFIA.

6.4 CFIA Responsibilities

The CFIA shall:

  1. Audit the CLSAB annually and conduct random sampling audits of CLSAB Accredited Grading Agencies and their member facilities operating under the CHTWPCP at their respective places of business, operations or appropriate premises, during regular business hours to determine the competency, compliance and verification capacity of the CLSAB and its accredited Grading Agencies to the terms and conditions of this recognition under the CHTWPCP.
  2. Take appropriate action for non-compliance with conditions prescribed in the CHTWPCP as recommended by the CLSAB or as may be determined by the CFIA.
  3. Consult with the CLSAB regarding any proposed improvements to standards, policies and training as they relate to the CHTWPCP and/or Schedule C of the CLSAB Regulations.
  4. Maintain a list of those facilities where the CLSAB indicates that such facilities meet the requirements of the CHTWPCP including maintaining a record of performance of the CLSAB accredited Grading Agency and its registered facilities, upon completion of any random survey audit.

7.0 Facility Registration, Auditing, and other Activities conducted under the CHTWPCP

7.1 Facility Registration

Upon receipt of the required application form, from a facility, applying for registration, together with a copy of the Facility's Manual, and upon receiving from the facility a signed agreement for Service Provider services, in a form satisfactory to the Service Provider, the Service Provider shall:

  1. review and report on the facility's Manual against the conditions specified in the CHTWPCP;
  2. submit the facility's application along with the endorsed Manual to the CLSAB;
  3. recommend the facility for registration to the CLSAB.

7.2 Maintenance of Facility Registration

7.2.1 Audits conducted by Service Provider

  1. The Service Provider will conduct an initial evaluation audit of the facility, in consultation with the CLSAB and CFIA, to verify that it meets the requirements specified in the CHTWPCP which will consist of the facility Manual review and an on-site visit. An evaluation audit is an audit of a facility performed by a Service Provider, at the time of registration, to verify that a facility is capable of meeting the standards prescribed. The audit also verifies that the facility Manual is being adhered to and that facility employees are sufficiently trained.
  2. The Service Provider will audit the facility's operations against the applicable requirements of the CHTWPCP, the Schedule C of the CLSAB Regulations and the applicable components of the Technical Heat Treatment Guidelines and Operating Conditions Manual (PI-07), other requirements of the program as may be agreed to add from time to time, and the facility's Manual.
  3. The Service Provider will conduct all audits in a manner that is consistent with the requirements set out in this document, and in the (QSM-02), Quality System Guidelines for Facility Registration under the Wood Product Certification Programs (CHTWPCP and CWPCP) and without any prejudice or conflict of interest.
  4. Subject to reporting to the CFIA as required under the CHTWPCP, the Service Provider will ensure that all records of audits, enforcement actions taken and any other information pertaining to facilities are kept confidential and secured at all times.

7.2.2 Activities and Frequency of Audits

The following outlines the activities and frequency of audits on facilities registered under the CHTWPCP.

Activities and Frequency of Audits
Activities CHTWPCP Registered Facilities
Application for registration under the CHTWPCP & Submission of the Manual For new applicants, 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 Grading Agency in cooperation with the CFIA For new applicants, to be conducted prior to registration. For existing participants, the evaluation audit is to be conducted by a CLSAB accredited Grading Agency within the first year of registration. An evaluation audit may also be necessary to confirm that a facility that has been suspended for non-conformance has adequately addressed the non-conformances and initiated quality activities that would ensure that future non-conformities may be avoided. The CFIA reserves the right to participate on the evaluation audit of the facility and in cooperation with the CFIA, the Grading Agency will coordinate the evaluation audit with the CFIA, where deemed necessary.
Verification Audit conducted by the CLSAB accredited Grading Agency (i.e., a review of the facility's organizational structure, procedures, processes and resources used by a registered facility in implementing the certification program. 4 times per year. For secondary facilities, a minimum of 4 times year in the first year of registration or re-registration following suspension and 2 times per 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 Grading Agency and/or CFIA
Verification Audit conducted by the CLSAB 2 per year on each accredited agency and at least 10 percent of the Agency's facilities in each size group (small, medium and large) are randomly selected. For small grading agencies (less than one billion FBM of shipments) a minimum of three facilities or 15% of the total number is sampled, without reference to small, medium and large facilities.
Systems Audits conducted by CFIA in cooperation with the CLSAB on the individual Grading Agencies An annual audit of each Grading Agency and a random sample (up to 10%) of the lumber grading agency's registered facilities.

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

7.3 Reporting and Resolution of Facility Non-conformances by the Service Provider

Following a facility audit conducted by a Service Provider, the Service Provider will provide a report to the facility within 5 working days of its audit. In the event that corrective actions are required to address non-conformances which have been identified during the audit, the Service Provider will take the following additional actions:

  1. for a minor non-conformance, as outlined under the Quality System Guidelines for Facility Registration under the Wood Product Certification Programs Canadian Heat Treated Wood Products Certification Program (CHTWPCP) and Canadian Wood Packaging Certification Program (CWPCP) (QSM-02):
    1. the Service Provider shall verify that the corrective actions requested has been completed by the facility within a reasonable time frame, not exceeding one month from the date of initial notification of the non-conformance by the Service Provider;
    2. the Service Provider shall provide the CLSAB and the CFIA in its quarterly report, as described in Section 3.5.19 of the CLSAB regulations, information regarding the non-conformance, the planned corrective action and follow-up confirmation that the corrective action has been completed.
  2. for a major non-conformance, as defined under the Quality System Guidelines for Facility Registration under the Wood Product Certification Programs Canadian Heat Treated Wood Products Certification Program (CHTWPCP) and Canadian Wood Packaging Certification Program (CWPCP) (QSM-02):
    1. the Service Provider shall deliver to the registered facility, the CLSAB, and to the CFIA a notice in writing with a description of the non-conformance and the required corrective action within three working days of such non-conformance;
    2. the Service Provider shall request the facility to take corrective action within a time frame appropriate to address the non-conformance but not to exceed ten working days, during which the facility was operational.
    3. Follow-up on corrective actions taken by the facility as often as required to verify full compliance within ten working days of the correction action due date
    4. the Service Provider shall confirm to the CFIA that the required corrective action has been taken or has not been taken within three working days of the follow-up visit intended to verify the corrective action.
    5. Where the major non-conformance compromises the integrity of the program, the Service Provider will suspend the facility from the program and will remove all stamps and certificates relevant to this program and will notify the CFIA and CLSAB within three working days following the audit.

7.4 CFIA's Activities and Follow-up Actions

  1. In the event of a non-conformance by a registered facility, the CFIA may request the CLSAB to have the Service Provider increase the frequency of inspection of the facility, until corrective actions satisfactory to the CFIA are verified by the Service Provider as being complete.
  2. Where the CFIA has been notified of a major non-conformance which jeopardizes the integrity of the CHTWPCP, the CFIA may require CLSAB to suspend the facility under the CHTWPCP. During the suspension period, the registered facility will not be permitted to certify wood packaging products for export as outlined in the CHTWPCP.
  3. Should the CFIA determine in its sole and unfettered discretion that the proposed corrective action or implemented corrective action by the CLSAB or the Service Provider is unsatisfactory, the Parties agree that the CFIA reserves the right to directly impose or implement upon the registered facility whatever corrective action it deems necessary to correct the non-conformance.
  4. Where the CFIA determines, in its sole and unfettered discretion, that a registered facility is consistently unable to maintain conformance with the CHTWPCP or that a registered facility's non-conformance jeopardizes the integrity of the CHTWPCP, the CFIA will cancel the facility from the program. The CFIA will notify the registered facility in writing that it has been cancelled from the program that the registered facility's registration under the CHTWPCP will be revoked, and will notify the CLSAB of this action. The CFIA will request CLSAB to notify the Service Provider of the cancellation.
  5. If the facility's corrective actions are deemed sufficient by the CLSAB and CFIA, the CFIA will request CLSAB to repeal the suspension and will assign the facility a new inspection frequency. Once the facility has demonstrated to the Service Provider and CLSAB on-going compliance with the requirements of the CHTWPCP, the Service Provider will reduce the frequency of inspection to that specified in the Quality System Procedures for The Export Certification Programs, CHTWPCP (D-03-02) and the CWPCP (D-01-05 and QSM-02).

8.0 General Reports to the CFIA

  1. The CLSAB will provide to the CFIA annually, on or before March 31 of each year, a detailed report in writing of all audits, inspections and follow-up activities completed during that fiscal year. The report will include, but will not be limited to, a listing of facilities by Service Providers, information on the total number of audits performed by each Service Provider, a list of the facilities audited, a list of major non-conformances found, number of facilities added or deleted from the program and relevant dates.
  2. The CLSAB will complete and date a report of each audit conducted on the Service Providers and registered facilities they have audited under the CHTWPCP and CLSAB Regulations, Schedule C, and such reports will be kept on file by the CLSAB for periodic review by the CFIA.
  3. The CLSAB will maintain for a period of at least two years all records pertaining to its verification of its Service Providers, including but not limited to: assessment reports for registration, audit reports, reports of non-conformances and follow-up audits, authorizations of changes to Manuals and to the training of Service Provider staff.
  4. The CLSAB and Service Provider will meet any other reporting requirements as mutually agreed upon from time to time.

9.0 Suspension or Cancellation of Facility Registration

9.1 Suspension

A Registered Facility will be considered for suspension, in full or in part, for a specified period if:

  1. the integrity of the program is compromised;
  2. an audit identifies a system failure that casts doubt on the ability of the facility to adequately discharge its duties;
  3. agreed corrective actions are not implemented within the prescribed time period;
  4. applicable CFIA fees are not paid; or
  5. requested by the Service Provider.

9.2 Cancellation

A Registered Facility will be considered for cancellation, in full or in part, if (as per CLSAB regulations):

  1. requested by the Service Provider, and CLSAB; or
  2. an audit identifies systematic, ongoing failure of the facility to adequately discharge its duties.

If a registered facility is permanently removed from the program, their facility number shall be cancelled from use and removed from the CFIA list of registered facilities. The facility registration number which has been cancelled must not be re-used.

9.3 Reinstating of Facility Registration

Facilities or treatment facilities that have been cancelled from the CHTWPCP must completely re-register starting with submission of the CHTWPCP application form.

10.0 Suspension and Cancellation of the Service Provider

10.1 General information

  1. Where the CFIA determines in its sole and unfettered discretion that the Service Provider has not complied with the requirements of the CHTWPCP or is in default of any representation, covenant, term or condition of this Agreement, the CFIA will provide the CLSAB with a report detailing such non-compliance and/or default.
  2. Upon receipt of such report, the CLSAB will immediately begin remedying such non-conformance and/or default and will demonstrate to the CFIA within one (1) month that such non-conformance and/or default has been remedied to the satisfaction of the CFIA, failing which, the CFIA will be entitled to suspend or revoke, at its sole discretion, recognition of the Service Provider under the CHTWPCP and to communicate the same to the registered facilities contracting with the Service Provider.
  3. Facilities recommended for registration to the CFIA by a Service Provider and registered by CFIA and which has been subsequently cancelled from the program, will be required to seek the service of another CLSAB and/or CFIA recognized Service Provider.

10.2 Suspensions

Recognition of a Service Provider will be considered for suspension, in full or in part, for a specified period (as per section 14.0 of the CLSAB regulations,) if:

  1. an audit identifies a system failure that casts doubt on the ability of the Service Provider to adequately discharge its duties;
  2. agreed corrective actions are not implemented within the prescribed time period;
  3. assessment protocols are altered such that they no longer meet the minimum standards used by the CFIA;
  4. requested by the CLSAB.

10.3 Cancellations

Recognition of a Service Provider will be considered for cancellation, in full or in part, (as per Section 14.1.1 of the CLSAB regulations) if:

  1. requested by the CLSAB;
  2. an audit identifies systematic, ongoing failure to adequately discharge its duties.

11.0 Termination of CFIA's Recognition of CLSAB in its oversight role within the CHTWPCP

Should the CFIA determine in its sole and unfettered discretion that the CLSAB is not in compliance with the provisions hereof or the requirements of the CHTWPCP, the CFIA may, upon giving written notice to the CLSAB, cancel the recognition of the CLSAB, either immediately, or at the expiration of a cure period specified in the notice if the CLSAB has not brought itself into compliance to the satisfaction of the CFIA within that cure period.

Should it be determined by either CLSAB or CFIA that it must cease to participate under this program, CLSAB and CFIA shall endeavor to give to the other party the maximum possible notice of cancellation and, in any event, not less that three (3) months notice, in order to allow for the continual oversight of this certification program.

12.0 Fees

Fees payable by facilities for participation under this program, will be made directly to the CFIA. The CFIA will be charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. Individuals requiring more information on fee schedules may contact any CFIA regional office or visit our Canadian Food Inspection Agency Fees Notice web site.

Note: At time of publication of this document, the annual CFIA registration fee for facilities participating under this program is $400.00. The CFIA reserves the right to charge an additional fee for its service, in accordance with the Canadian Food Inspection Agency Fees Notice, for follow-up inspection activities performed to verify that the requested corrective actions have been taken by the facilities, to address the major non-conformances.