Part I: ISTA Certificates
The recent change to the 2009 ISTA Rules removing the Green International Seed Lot Certificate from the Rules requires that the wording throughout SWI 132.1.1 be amended as follows:
- ISTA Certificates - applies to the types of certificates allowed by the ISTA Rules;
- ISTA International Seed Lot Certificate - Blue will now be referred to as ISTA Blue International Seed Sample Certificate;
- ISTA International Seed Lot Certificate - Orange will now be referred to as ISTA Orange International Seed Lot Certificate.
Part II: Options for Sample Submission
The following is added to Section 15:
15.5.1 Options for submission of marketplace monitoring samples (MPN, MPP, MPI) of large seeded crop kinds (i.e., species in Grade Tables I to VI and XVI to XVIII).
The following options are provided to standardize the procedures used by inspectors when both requesting laboratory purity analysis results and providing their own purity examination results for marketplace monitoring samples. The options are intended to utilize the results of examinations conducted by trained inspectors and to provide support to inspectors when they are in training or have a need for their examination results to be verified. With standardized procedures inspectors' purity examination data can be correctly incorporated in the compliance statements made for each marketplace monitoring sample. Compliance statement refers to: Meets Grade (M), Below Grade, Within Tolerance (BWT) and Below Grade, Out of Tolerance (BOT).
Option 1 (intended for use by inspectors who can not or choose not to do a complete purity examination independently)
The inspector submits an unexamined sample and requests a purity analysis on the LSTS Sample Submission Form indicating that the sample has not been examined. SSTS's results will be entered in the database and reported on the SSTS Lab Report. The results and compliance statements will be part of the marketplace compliance data.
Option 2 (intended for use by inspectors who want verification of their retrieval and identification of impurities, either because they are in training or have found the retrieval/identification to be difficult, or are having their proficiency monitored).
The inspector submits the sample which they have examined. The impurities that were found must be removed from the examined sample, placed in a well sealed envelope, and labelled appropriately. The inspector must indicate the impurities and the quantity of seed in which they were found, either on the LSTS Sample Submission Form, or on the envelope. The inspector should also state the quantity examined on the LSTS Sample Submission Form and indicate that the sample submitted is the examined sample. If the inspector requests a purity analysis on the LSTS Sample Submission Form, the lab will re-examine the submitted sample to verify that all impurities were retrieved and to verify the identification of the impurities in the envelope. The SSTS Lab Report will show the lab results in the Lab Results section of the report and the identification of the impurities in the envelope will be recorded in the Lab Comments section of the report. If the inspector does not request a purity analysis on the LSTS Sample Submission Form, the contents of the envelope will be identified and reported in the Lab Comments section of the SSTS Lab Report. The compliance statement on the SSTS Lab Report will be based on the inspector's results and the results as verified by SSTS, as applicable. The compliance statement will be part of the marketplace compliance data.
Option 3 (intended for use by inspectors who are trained to conduct purity examination of the sampled crop kind)
The inspector submits an LSTS Sample Submission Form but does not submit a sample. The inspector provides his purity examination information (i.e., impurities found, the quantity in which they were found, and a compliance statement) in the Comments section of the LSTS Sample Submission Form. No SSTS Lab Report is issued but the sample and the compliance statement are entered in the lab database and will be part of the marketplace monitoring compliance data. If the inspector submits a sample without a request for purity analysis (i.e., may request a germination or Ustilago nuda analysis) and provides purity examination data and a compliance statement in the Comments section of the LSTS Sample Submission Form, the purity result will be incorporated into the sample compliance statement. The sample compliance statement will be included as part of the marketplace compliance data.
Part III: Preparation for Sampling
11.1 Preparation for Sampling the Seed Lot
d) v) the size of the seed lot to determine the sampling intensity. There are no maximum lot sizes for domestic seed lots or ISTA Blue International Seed Sample Certificates;
Part IV: Obtaining the submitted Sample
13.0 OBTAINING THE SUBMITTED SAMPLE
The third paragraph has been revised to now read "If separate sub-samples from one seed lot are required for different tests (purity, germination, disease or POV), these sub-samples must be taken by:"
13.2 Method for Small - Seeded Crop Kinds (Grade Tables IV, VII-XVII and XIX-XX)
This section has been modified by the following:
The entire composite sample must be submitted to the laboratory. To reduce the risk of cross contamination (which is greater with small-seeded species), the laboratory shall conduct all mixing and dividing operations and submit any required sub-samples to the appropriate testing laboratories. The sampler must indicate the requested tests on the Sample Submission Form (Appendix V).
126.96.36.199 Sampling Requirements for Moisture Test (Oven or Moisture Meter)
This section will now read as follows for these specific paragraphs:
The sample for moisture determination must be obtained immediately after sampling by:
- mixing the entire composite sample, by either stirring the sample in its container with a spoon or by placing the opening of the original container against the opening of a similar container and pouring the seed back and forth between the two containers. This procedure must be done as quickly as possible in order to minimize the loss or gain of moisture during the mixing and sub-sampling operation. The inspector must take a minimum of three sub-samples with a spoon from different positions in the container until the minimum sample size in Appendix III has been obtained. When a moisture meter test is requested, the SSTS must be contacted regarding the sample size requirements.
- the official seed sampler must quickly place the sub-samples into a moisture proof container which, at minimum, is labelled with the lot number or inspection sample number. The moisture proof container must be strong enough to prevent spillage or leakage of the seed. The sampler must ensure that moisture proof container has as much air as possible removed and is closed in such a manner that no moisture can escape or air enter.
Suitable moisture proof containers include:
- non woven plastic (heavy weight plastic bags with a sealing top), re-sealable plastic bags;
- When zip-lock bags or whirl-top bags are used, they are not considered moisture proof if just zipped or the ends of the wired ties twisted together. As much air as possible must be removed and the top of the bag must be folded over at least twice and then taped all around the top (securing the entire folded opening) with official sealing tape or masking tape (not scotch tape).
- polyethylene, or foil packages that can be hermetically sealed;
- Polyethylene, or foil packages must be hermetically sealed immediately after filling.
- tins or glass bottles with an air-tight top.
- If tins or glass bottles with an air-tight top are used they must be filled to the top and the entire lid secured with official sealing tape or masking tape.
The moisture proof container, containing the sample for moisture testing, must be placed into a clean unused cotton bag. Samples for moisture determination must be labelled as described in Section 15.3. All samples drawn for moisture determination must be sealed (Section 15.2). The moisture sample must not be enclosed inside the sample container containing the seed for the other test(s) (e.g., purity or germination), as this destroys the integrity of the sample for those test(s).
A Sample Submission Form (Appendix IV) must accompany the sample. When more than one sample (e.g., purity and/or germination) from the same seed lot is being submitted to the same laboratory, only one Sample Submission Form is required. The samples can be attached and sealed together (Section 15.0).
Part V: ISTA Orange International Seed Lot Certificates
16.3 Issuance of ISTA Orange International Seed Lot Certificates
The following replaces the information provided in the original document:
b) Testing and issuing laboratory - the lab name, address and ISTA accreditation number.
Part VI: Laboratory Retention of Samples and Documentation
The following replaces the information provided in the original document:
16.4 Laboratory Retention of Samples and Documentation
a) EXP samples are retained for one year. For information regarding retention periods for other sample codes, the inspector must contact the SSTS.
Part VII: Dating of OECD Tags
The following is to be included in Section 9.3 at the end of the subsection titled OECD Tag:
When a seed lot must be labelled according to EU Directives, the back of the OECD tag must bear the month and year that the seed was sealed. As a result, seed sampling may only take place if the date on the tag is the same month/year as the date of sampling or a month/year prior to the date of sampling. If the OECD tag bears a future date, the inspector must defer sampling until that future time or require that the OECD tags be corrected. Tags may be corrected manually or by stickering over the incorrect date with the correct date. Corrections are to be made by the establishment and witnessed by the inspector.
The following is to be included at the end of Appendix VII, point g):
If the back of the OECD tags indicate a month and year of sealing, the inspector must ensure that date of sampling does not precede the labelled date of sealing.
Part I: Post Authorization Requirements
Appendix XVIII Approval Process for Automatic Samplers for Obtaining Samples for the Issuance of an ISTA Seed Lot Certificate, Part 3.0 Post Authorization Requirements, is hereby amended with the addition of the following.
The inspector retrieves samples from the automatic sampler and probed samples and submits them to the Seed Science and Technology Section of the CFIA for verification that the two sets of samples are in tolerance with each other.
In addition to taking samples CFIA inspectors should inspect the company's records/books on the automatic sampler, at least annually, to verify that the company is:
- documenting any changes to the installation of the automatic sampler, and
- checking the functionality of the automatic sampler.
Part II: Number of units sampled on the LSTS form
Section 14.1 is amended with the addition of the following.
When submitting seed samples to the Seed Science and Technology Section of the CFIA, Saskatoon Laboratory, the sampler must state on the Sample Submission Form in the field number of units sampled the number of primary samples taken.
Part III: Inclusion of Authorized Exporter Program procedures into SWI 132.1.1
SWI 132.1.1 has been amended to include procedures for sampling by CFIA inspectors to monitor the activities of authorized exporter seed samplers and authorized exporter seed testing laboratories participating in the Authorized Exporter Program. Laboratory sample submission codes have been changed to identify the samples as pertaining to the Authorized Exporter Program.
12.0 Purpose of Submitted Sample
12.5 Samples for Monitoring Authorized Exporter Samplers (Seed Program Code: AES)
Samples taken for monitoring authorized exporter samplers must be taken by a CFIA official seed sampler from a lot previously or concurrently sampled by the authorized exporter sampler. The samples are submitted to the Seed Science and Technology Section laboratory of the CFIA for purity and germination testing only, and not POV, moisture or disease testing. Appendix III provides the quantities required for each species. The name of the authorised exporter sampler must be included on the sample submission form. There is no need to conduct a purity examination of the sample before submitting it to the lab.
12.6 Samples for Monitoring Authorized Exporter Seed Testing Laboratories (Seed Program Code: AEL)
Samples taken for monitoring authorized exporter seed testing laboratories must be taken by a CFIA official seed sampler from the remainder of a sample previously analysed by the authorized exporter seed testing laboratory. The inspector shall provide the laboratory with a written, dated and signed notice that CFIA has removed part or all, of the sample from the laboratory. The documentation should include the private laboratory's sample/test number, the crop kind, variety (if applicable) and any other information pertinent to the sample.
The samples are submitted to the Seed Science and Technology Section laboratory of the CFIA for purity and germination testing only and not POV, moisture or disease testing. Appendix III provides the quantities required for each species. The name of the authorized exporter seed testing laboratory must be included on the sample submission form. There is no need to conduct a purity examination of the sample before submitting it to the laboratory.
Appendix III: Weights for Submitted Samples
Note 7 is added as follows:
Note 7: Authorized exporter samplers submitting samples of export seed lots for testing must submit three (3) times the quantity listed for purity and germination (P & G) testing for those species listed in the EU Directives to allow sufficient volume for monitoring samples to be taken.
Appendix IV Seed Program Codes
The codes AEP, AEM and AEX are deleted.
The following two codes are added:
AES - Exporter Sampler monitoring samples. AES should be used for samples taken for monitoring of the activities of authorized exporter samplers participating in the Authorized Exporter Program to take samples for export seed lots.
AEL - Exporter Laboratory monitoring samples. AEL should be used for samples taken for monitoring of the activities of authorized exporter seed testing laboratories participating in the Authorized Exporter Program to test samples for export seed lots.
Part IV: Distribution of Seed Inspection Certificate (CFIA 1118)
The following is added to the end of Appendix XIV - Seed Inspection Certificate (CFIA 1118)
There is no longer a requirement to send a copy of the Seed Inspection Certificate (CFIA 1118) to the Canadian Seed Trade Association.
Part V: Submission of POV Samples
The address for submission of POV samples is:
Canadian Food Inspection Agency
Cultivar Verification Unit
3851 Fallowfield Road
P.O. Box #11300
Ottawa, Ontario K2H 8P9
Part I: Sampling for Mini Bulk / Mini Tote Containers
Inspectors wishing to take marketplace monitoring samples (MPP or MPN) may encounter situations in which sealed mini bulk bags are not easily accessible and where sampling may pose a hazard. In these circumstances, there are two options:
- The establishment may make the bags accessible to the inspector or
- The inspector may sample from the retained sample provided that the retained sample is of sufficient quantity to allow for this.
Industry, through the CSI, has been advised of the need for increased retained sample sizes when accessibility of mini bulk bags is an issue.
Please note that COM or INV samples must be taken from the bags. Establishments continue to be required to provide reasonable assistance in making bags accessible for sampling for these purposes as required by Section 6(2) of the Seeds Act.
When sampling large lots in stream or from flat bottomed bulk bins, the sampler is required to take one primary sample per 700 kg. As there is no limit on domestic lot size, this may result in extremely large composite samples that are not practical to divide using a Riffle divider. In this situation, the inspector should place the primary samples in one or more large bags, mixing the primary samples to the extent possible as they are added to the bag. Once all primary samples are taken, the inspector should treat the composite sample as if it was a seed lot and take an appropriate number of samples for the size of composite sample, sampling from different angles or locations within the bag(s). For example, if the composite sample is 98 kg and in one large bag, three primary samples are to be taken. If the composite sample is between 100 and 500 kg, 5 primary samples are to be taken. These latter primary samples are then mixed and divided using the Riffle divider method to obtain a working sample of the correct size. When submitting the sample to the laboratory, the sampler must include a detailed explanation of the sampling method used.
Sampling of seed lots in mixed container sizes
Inspectors may need to sample a seed lot that is presented in mixed container sizes/types rather than in uniform container sizes/types. Depending on the purpose of the sampling and testing of the lot presented in mixed containers, the following direction should be followed.
One composite sample should be taken from the containers of the size/type that represent the largest part of the lot. The sampling intensity applied should be that which is listed in Appendix II of SWI 132.1.1 Official Seed Sampling for that portion of the lot only.
- Example: If a lot is presented in 25 totes of 500 kg and 100 bags of 40 kg, then the part of the lot in totes should be sampled since it is the largest part of the lot; the sampling intensity used should be that which is required for sampling 25 totes of 500 kg.
It is assumed that the lot is homogeneous even though it is presented in mixed container sizes/types and that the largest portion of the lot is most representative of the seed that is offered for sale in the marketplace.
If only one container size/type is available for sampling (i.e. if other parts of the lot in different container sizes/types have already been sold), the inspector is only required to sample the part of the lot that is available even though it may not represent the largest part of the lot.
Should the single monitoring sample indicate non-compliance with the labelled grade, the CFIA will target that establishment in the following year (COM samples) and take appropriate compliance action based on the results of the COM samples.
COM and INV samples
The parts of the lot with different container sizes/types must be sampled separately using the sample intensity listed in Appendix II of SWI 132.1.1 Official Seed Sampling for each part of the lot. The composite sample for each part of the seed lot must be submitted singly as one sample and must not be combined with composite samples from other parts of the lot. Unique identifiers must be assigned by the inspector to the samples that represent unique parts of a lot; a separate certificate of analysis will be received for each part of the lot assigned a unique identifier. The link between the samples and the parts of the lot should be reported by the inspector in the Comments section of the LSTS form.
The number of samples submitted for such a seed lot will equal the number of different size/type groupings of containers that make up the lot (e.g. if the seed lot is in two container sizes, then two samples must be submitted).
In cases where the seed lot is in containers of one size but there is leftover seed at the end of the lot in a partially full container or a smaller container, this container is to be included in the lot and is treated as being the same kind of container. If the partially full or small container is in a seed lot with different container sizes/types, it should be considered as part of the lot that is in the smallest containers.
The uniformity of a seed lot is a requirement of a seed lot as defined by the Seeds Regulations. The purpose of sampling and testing separate samples for each part of the lot is to enable verification of the homogeneity of the lot by determining whether or not the test results from the various parts are in tolerance with each other. Should the parts of the lot not be in tolerance with each other, the remainder of the parts must be treated as individual lots, be assigned unique lot numbers, and be regraded.
EXP samples with CND numbers
The ISTA Handbook on Sampling referenced in the ISTA Rules for Seed Testing states that different types of containers for a single lot may be an indicator of lot heterogeneity. For seed lots exported by Canada that require testing according to the ISTA Rules, a CND lot number must represent a lot of seed presented in uniform container sizes/types. As such, use of multiple container sizes/types for lots to be tested according to the ISTA Rules should not occur.
Should an inspector encounter a lot for ISTA sampling that is presented in multiple container sizes/types, he/she should not sample the lot until the lot is presented properly (i.e. the lot is designated multiple CND numbers).
In cases where there is leftover seed in a partially full container or a smaller container, this is considered the end of the seed lot and is treated as being the same kind of container.
Authorized Exporter Program monitoring samples (AES-monitoring of samplers)
As part of the monitoring of AE samplers in the AEP, an inspector may be required to sample a seed lot that has been tested by the ISTA Rules for Seed Testing or by the AOSA Rules for Testing Seeds. The CFIA requires that all seed lots sampled by AE samplers be treated the same, regardless of testing by the ISTA or AOSA Rules, and thus imposes the same sampling requirements for lots tested by the AOSA Rules as those tested by the ISTA Rules.
Therefore, any lot sampled by an AE sampler and tested by either ISTA or AOSA Rules must be presented in one container size and type only. If this appears not to be the case when an inspector is taking AE samples, he/she should investigate. If it is confirmed that the exported lot was made up of more than one container size Seed Section should be informed and the AE must put in place corrective measures to prevent recurrence of this error.
Leftover seed in a partially full container or a smaller container should be considered the end of the seed lot and should be treated as being the same kind of container.
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