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SEED PROGRAM QUALITY SYSTEM PROCEDURE - OFFICIAL SEED SAMPLER CERTIFICATION

QSP 132.4

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TABLE OF CONTENTS

APPENDICES

DATE

This version of the Official Seed Sampler Certification Quality System Procedure (QSP) was issued April 1, 2007.

CONTACT

The contact for this Seed Program QSP is the Chief, Seed Design and Delivery Office, Seed Section.

REVIEW

This Seed Program QSP is subject to periodic review. Amendments will be issued to ensure it continues to meet current needs.

ENDORSEMENT

This Seed Program QSP is hereby approved


Director, Plant Production Division


Date

DISTRIBUTION

The most current version of this document will be maintained on the Canadian Food Inspection Agency (CFIA) Intranet site (Merlin) and/or Internet site. The signed original will be maintained by the National Manager, Seed Section.

0.0 INTRODUCTION

The certification of Canadian Food Inspection Agency (CFIA) inspectors for seed sampling verifies the competency of staff to obtain official seed samples and ensures national consistency.

This certification also facilitates the continued accreditation by the International Seed Testing Association (ISTA) of Canada's official seed testing laboratories to issue ISTA International Seed Analysis Certificates.

1.0 SCOPE

The procedures described in this Quality System Procedure (QSP) describe the standards and procedures required for a CFIA inspector to be certified as an official seed sampler, and the management of the official seed sampler certification program. The authority of an inspector to take seed samples is found in Section 6 of the Seeds Act.

2.0 REFERENCES

The publications referred to in the development of this QSP are those identified in SPRA 111 References for the Seed Program, as well as SPRA 131 Inspection Agency Requirements for the Delivery of the Seed Certification Program, QSP 152.1 Implementation and Administration of the OECD Seed Schemes and EU Seed Directives, the current ISTA International Rules for Seed Testing, Chapter 2: Sampling (ISTA Rules), and the ISTA Handbook on Seed Sampling.

3.0 DEFINITIONS

For the purposes of this QSP, the definitions given in SPRA 101 Definitions for the Seed Program and the following apply:

  • Candidate:
    • an individual seeking to become certified as an official seed sampler.
  • Competency:
    • a cluster of related skills, knowledge and aptitudes required by a number of job categories for a very broad population. It applies to on-the-job performance and can be measured against well- accepted standards.
  • Critical Non-conformance:
    • a deviation from the documented quality system such that compliance is absent and will have a consequential effect on the quality of the product or service.
  • Major Non-conformance:
    • a significant deviation from the documented requirements such that the program integrity or compliance with the requirements is absent. This non-conformance may result in the product or service not meeting the requirements.
  • Minor Non-conformance:
    • a failure in the implementation of the documented quality system resulting in a decrease in confidence that the seed sampler meets the requirements of the activity.
  • Non-conformance:
    • the failure to comply with a requirement, standard, or procedure identified during an audit or a review of submitted documentation.
  • *Official Seed Sampler:
    • an employee of the CFIA who is designated as an inspector pursuant to Section 13 of the CFIA Act or as an analyst and who is trained, evaluated and certified as a seed sampler.
  • Seed Laboratories:
    • the two official CFIA seed laboratories - Quarantine Plant Pathology Diagnostic Laboratory (QPPDL)- (Fallowfield) and Seed Science and Technology Section (SSTS) - (Saskatoon).
  • *Seed Sampler Evaluator:
    • an official seed sampler designated by the National Manager, Seed Section to conduct practical evaluations of seed sampling.
  • *Seed Sample Submission Assessor:
    • a Seed Laboratory employee who is responsible for assessing the acceptability of seed samples and sample submission forms received from official seed samplers.
  • *Seed Sampler Trainer:
    • an official seed sampler designated by the National Manager, Seed Section to conduct training sessions on seed sampling.
  • Supervisor or Manager:
    • the individual with supervisory responsibility for an inspector being trained and evaluated for seed sampling or who has been certified as an official seed sampler.
  • Technical Competency Grid:
    • a tool used to identify the skills and knowledge required by an individual to perform a specific task to a defined level of performance. (Also called Model of Performance).
  • *Test Administrator:
    • a CFIA employee designated by the National Manager, Seed Section to assess written and practical evaluations as required by the official seed sampler certification program.
  • Year
    • the period between July 1 and June 30 of any given year is considered to be the year as referenced in this QSP.

Note: The definitions marked with an asterisk (*) are intended to describe functions to be carried out by CFIA staff as part of the management and maintenance of the official seed sampler certification program. These are not new positions. These functions may be carried out by Operations, Program or Seed Laboratory staff designated by the Seed Section, the Area Operations Executive Directors, the Plant Network Program Managers or the Section Heads of the Ottawa and Saskatoon Seed Laboratories, as appropriate. Some individuals may perform more than one function.

4.0 OUTLINE OF THE OFFICIAL SEED SAMPLER CERTIFICATION PROGRAM

The CFIA, under the authority of the Seeds Act, regulates the testing, inspection, quality and sale of seed in Canada. This legislation provides for the sampling of seed by CFIA inspectors and the analysis of seed at Seed Laboratories. It is critical that each seed sample be drawn according to internationally accepted, science-based methods and procedures to ensure that the sample is representative of the seed lot.

The official seed sampler certification program was developed to ensure that approved methods and procedures for sampling are practised. Seed sampling instructions are found in SWI 132.1.1 Official Seed Sampling and are based on Chapter 2 of the ISTA Rules. All seed inspectors must be certified to draw official seed samples. Surveillance of all seed sample submissions along with periodic assessments of the seed sampler via audits and audits of the official seed sampler certification program will ensure that the integrity of the certification system is maintained. The official seed sampler certification program is administered jointly by the Programs, Operations and Science Branches of the CFIA.

To be certified to draw an Official Seed Sample, candidates must:

  1. have adequate acuity and colour vision (Appendix D to the Occupational Health and Safety Guide)
  2. receive appropriate training;
  3. follow the seed sampling procedures described in SWI 132.1.1 Official Seed Sampling;
  4. demonstrate the knowledge, skills and abilities described in Technical Competencies for Official Seed Samplers (Appendix I);
  5. successfully complete written and practical evaluations;
  6. not be engaged in any form of seed production, processing, marketing or sales or have any additional employment or business in the seed sector.

5.0 GENERAL REQUIREMENTS

5.1 Seed Program Responsibilities

The responsibilities of the Seed Program are to:

  1. provide overall direction and interpretation of the official seed sampler certification program requirements to Operations Branch and the Seed Laboratories;
  2. develop, update and amend this QSP and SWI 132.1.1 Official Seed Sampling in response to substantive changes to program policies and standards and/or to amendments to the ISTA Rules;
  3. communicate to the Seed Laboratories and Operations Branch changes made to this QSP and/or SWI 132.1.1 Official Seed Sampling;
  4. maintain lists of CFIA staff who have been designated as Seed Sampler Trainers and Seed Sampler Evaluators;
  5. participate as required in seed sampler training and evaluation sessions with Operations Branch and the SSTS Laboratory (Saskatoon);
  6. develop, maintain and update seed sampler written and practical evaluations as required;
  7. provide seed sampler written and practical evaluations to invigilators and Seed Sampler Evaluators on a timely basis;
  8. assess completed written evaluations and inform the candidate and his/her supervisor of results on a timely basis;
  9. implement a system for the review of evaluation results at the request of a candidate, as outlined in Section 6.2.3;
  10. certify official seed samplers, issue Official Seed Sampler certificates, and maintain a list of official seed samplers;
  11. forward Signature Verification Forms and copies of "Official Seed Sampler " certificates to the appropriate Seed Laboratory;
  12. issue suspensions, cancellations and reinstatements;
  13. co-ordinate and participate in assessments of the Official Seed Sampler Certification program;
  14. classify unlisted non-conformities as they are identified.

5.2 Operations Responsibilities

The responsibilities of Operations Branch are to:

  1. implement and administer the official seed sampler certification program as described in this QSP;
  2. provide candidates for seed sampler certification with the required training using approved training materials;
  3. ensure that candidates for seed sampler certification are evaluated by a designated Seed Sampler Evaluator;
  4. provide official seed samplers with approved sampling equipment, procedures documents and work instructions;
  5. communicate to official seed samplers any changes in procedures as identified by Seed Section and/or the SSTS Laboratory;
  6. ensure that only official seed samplers are assigned responsibility for taking official seed samples;
  7. ensure that any requests for information or documentation related to the official seed sampler certification program are addressed on a timely basis;
  8. participate in assessments of the Official Seed Sampler Certification program;
  9. ensure that any non-conformances are addressed within specified response times;
  10. provide feedback and technical advice to the Seed Section regarding the official seed sampler certification program in order to ensure continuous improvement of the system.

5.3 Seed Laboratory Responsibilities

The responsibilities of the SSTS Laboratory are to:

  1. ensure that official seed samplers receive the current ISTA Rules, communicate any changes in the ISTA Rules and procedures and document receipt and review by the samplers;
  2. accept official seed samples for testing under the Seed Program only from official seed samplers (subject to the time lines established in section 7 of this QSP;
  3. identify deficiencies in sample submissions from official seed samplers and issue action request forms for follow-up action;
  4. send a copy of the action request forms to Seed Section (when and as required);
  5. maintain a record of seed sample submissions that are not in compliance with SWI 132.1.1 Official Seed Sampling and monitor the implementation of corrective actions;
  6. issue warning letters as appropriate;
  7. maintain an individual file for each official seed sampler containing verification of signature, verification of receipt of ISTA Rules, copy of Official Seed Sampler Certificate and copies of the action request forms issued to the sampler by the SSTS Laboratory.
  8. participate in assessments of the Official Seed Sampler Certification program;
  9. provide feedback and technical advice to the Seed Section regarding the official seed sampler certification program in order to ensure continuous improvement of the system.

5.4 Official Seed Sampler Responsibilities

The responsibilities of an official seed sampler are to:

  1. follow the seed sampling procedures described in SWI 132.1.1 Official Seed Sampling;
  2. maintain sampling proficiency;
  3. not be engaged in any form of seed production, processing, marketing or sales or have any additional employment or business in the seed sector.
  4. implement action requests as required;
  5. review sampling procedure documents in detail prior to resumption of sampling when he/she has not taken and submitted a sample for an extended period.

6.0 CERTIFICATION REQUIREMENTS

Training and evaluation activities will be coordinated by the appropriate Area Seed Network Specialist in cooperation with the Area Training Officer.

Pre-Requisite for Training and Certification

All candidates for this training and certification must familiarize themselves with the content of SWI 132.1.1 (Official Seed Sampling) and complete a minimum of two sampling activities in a seed establishment under the supervision of a certified seed sampler prior to commencement of this training and certification exercise. The supervisor needs to orient new candidates to the typical sampling conditions that an inspector is likely to encounter when conducting seed sampling activities (including types of seed prevalent in the area, etc.). This requirement can be waived by the supervisor if he or she is satisfied that the candidate has already met the pre-requisite requirements.

6.1 Training

Candidates must be provided with self-study, group or individual training and the necessary training materials. With the exception of self-study, training will be provided by Seed Sampler Trainers. Seed certification training must ensure that a candidate will achieve the performance objectives described in Technical Competencies for Official Seed Samplers (Appendix I). When amendments are made to this QSP and/or to documents referenced in this QSP, revisions to the training materials shall be made and additional training sessions may be required depending upon the nature of the changes.

6.1.1 Theory Training

Theory training will provide candidates with the principles, methods and procedures for seed sampling and will familiarize candidates with the official reference documents for seed sampling ( SWI 132.1.1 Official Seed Sampling and ISTA Rules).

6.1.2 Practical Training

Practical training must consist of demonstrations of the seed sampling process conducted by a Seed Sampler Trainer. The candidate shall practice the sampling procedure under the supervision of the trainer. This practical training can be done during formal training sessions or as part of on the job mentoring.

6.2 Evaluation

When a candidate and his/her supervisor determine that a sufficient level of knowledge and skill has been attained, they may then request that the written and practical evaluations be administered. Both evaluations need not be administered together. However, the written portion will normally be completed first.

These evaluations will measure working knowledge and practical ability in sampling seed lots. The evaluations will be based on the established performance objectives described in Technical Competencies for Official Seed Samplers (Appendix I).

6.2.1 Written Evaluation

During the written evaluation, the candidate will be permitted to consult only those documents that would normally be available to a seed sampler in the performance of his/her duties. These are listed in Documents That May Be Referenced During the Written Exam (Appendix II). Any of the documents named in Appendix II may be supplied to the candidate at the beginning of the workshop and as such, may contain highlighted or additional hand written comments made by the candidate. These documents would be acceptable to be referenced during a written evaluation. All questions will be based on these references. Candidates may not communicate with one another or with individuals other than the invigilator during the written evaluation.

The Seed Section shall maintain a bank of questions, approved by the National Manager, Seed Section, from which sets of written evaluations will be developed by the Test Administrator. Sample questions can be found in Sample Written Evaluation Questions (Appendix III).

The Seed Section shall maintain administrative control over the written evaluations and will put in place a procedure to receive feedback and to incorporate improvements as required. The bank of evaluation questions shall be updated as amendments are made to seed sampling reference documents, ISTA Rules, or Seed Program policies and procedures. The Test Administrator will document atypical answers and the marking of these answers in order to provide consistency of marking and interpretation over time.

Written evaluations must be invigilated by either the Test Administrator, a Seed Sampler Evaluator, an Operations supervisor, an Operations program officer or an Area Training Officer. The invigilator is responsible for contacting the Area Seed Network Specialist or Test Administrator to arrange for the delivery of a written evaluation. In order to maintain the integrity of the certification process, the invigilator must retain control of the written evaluation at all times. Evaluation papers must not be copied or distributed and may only be provided to a candidate at the location, time, date and for the duration established for the evaluation. Copies of written evaluations will not be provided for study purposes. Invigilators will be required to complete and submit the Record of Invigilation Form (Appendix X).

It is the responsibility of the invigilator to arrange a location for the written evaluation that has suitable lighting and is free from distractions. He/she must ensure that the documents listed in Appendix II are the only ones being referred to by a candidate during the written evaluation. Where the invigilator is not the Test Administrator, he/she will forward completed evaluations immediately to the Test Administrator for marking. Evaluations must be forwarded in a secure manner, such as by courier or registered mail.

Invigilators will ensure that each candidate completes a Signature Verification Form (Appendix VI) at the time of the written evaluation. This form will be sent to the Test Administrator with the completed written evaluation.

6.2.2 Practical Evaluation

This step in the certification process is designed to evaluate a candidate's skill and ability to assess and respond to a specific sampling situation. The evaluation will be conducted by a Seed Sampler Evaluator at a seed establishment or in a similar environment using the Practical Evaluation Marking Scheme (Appendix IV) that is based on Technical Competencies for Official Seed Samplers (Appendix I). Candidates will not have access to the marking scheme during the practical evaluation. Points will be deducted for incorrect or incomplete answers or improper use of procedures, equipment, etc. The Seed Sampler Evaluator will follow the practical evaluation protocol established by the Test Administrator. The Seed Sampler Evaluator will not terminate the practical evaluation before its completion, even in situations where it becomes evident part way through the evaluation that the candidate will not meet the standard.

6.2.3 Results of Evaluations

A minimum standard of 80% on both the written and practical evaluations is required. Official notification of the evaluation results will be distributed as follows:

  1. Candidate - Actual marks achieved
  2. Candidate's supervisor - Has met or not met the evaluation standards
  3. Test Administrator - Written and practical evaluation papers

Evaluation results are considered confidential information. Distribution of information regarding the evaluations shall be governed by the confidentiality guidelines regarding personal information established in the Privacy Act. All correspondence related to results will be clearly marked as "Personal and Confidential" on the envelope.

No feedback will be provided on an evaluation where the final mark is 95% or higher. Where the final mark is 80-94%, the candidate may make a written request to the Chief of the Seed Design and Delivery Office, Seed Section for information on areas of weakness. Where the final mark is less than 80%, feedback on areas of weakness will be automatic. No remarking of evaluations will be applied to evaluations in which the final mark was 85% or higher. A request for remarking may result in a higher or a lower mark being assessed.

6.2.4 Re-evaluation

An unsuccessful candidate will require additional training. A candidate may request information from the Test Administrator, Seed Section regarding specific areas where remedial training would be beneficial. He/she may retake a written and/or practical evaluation on the recommendation of their supervisor.

7.0 CERTIFICATION PROCESS

An individual designated as an inspector pursuant to Section 13 of the CFIA Act shall be recognized as an official seed sampler provided the following criteria have been met:

  1. achievement of a minimum standard of 80% on both the written and practical evaluations;
  2. issuance of Official Seed Sampler Certificate (Appendix V) signed by the National Manager, Seed Section. The date of certification shall be the date on the certificate;
  3. submission of Signature Verification Form to the SSTS Laboratory (Appendix VI).

Upon certification, the inspector shall be added to the Official Seed Sampler Database and the List of Official Seed Samplers.

As of July 1, 2004, the Seed Laboratories will not accept samples for issuance of ISTA Certificates submitted from inspectors who have not met the above criteria.

As of July 1, 2006, the Seed Laboratories will not accept samples for issuance of domestic seed testing certificates submitted from inspectors who have not met the above criteria.

8.0 PROGRAM MAINTENANCE

8.1 Seed Sample Submission Surveillance

The Seed Laboratories will assess each submitted sample and accompanying documentation to verify that samples have been taken and submitted in a manner consistent with SWI 132.1.1 Official Seed Sampling. When non-conformances are identified, action requests will be initiated. The Seed Laboratories will refuse to analyse any sample where a critical non- conformance exists.

8.1.1 Action Requests

Sampling activities required by the Seed Program must comply with the procedures and techniques set out in SWI 132.1.1 Official Seed Sampling. Where a non-conformance is found upon the receipt of a sample and/or documentation at a Seed Laboratory or as the result of an audit, an action request shall be issued in writing using an Action Request Form (Appendix VIII). Examples of non-conformances are listed in Classification of Non- conformances in Sampling and Documentation Procedures (Appendix VII). Depending on the nature of the non-conformances, appropriate actions may include review of sampling procedure documents, retraining, and/or re-evaluation.

Action request forms related to minor non-conformances will be sent directly to the seed sampler. In cases where the issuance of action request forms leads to issuance of a warning letter or beyond to suspension or cancellation, the lab will send to Seed Section a summary of all non-conformances leading up to the warning letter and/or suspension, cancellation, etc. Action request forms sent to the official seed sampler related to major and critical non- conformances will also be copied to the sampler's supervisor. The lab which issued the action request is not required to send a copy of the closed action request to the Seed Section.

8.1.2 Response Times for Action Requests

The sampler, and their supervisor in the case of major and critical non-conformances, must undertake follow-up actions within specified time frames to ensure performance standards are met. They must notify the SSTS Laboratory when the appropriate actions have been implemented. The maximum allowable response time and maximum time for closure that shall be set for any specific action request is found in the following table:

Non-Conformity Type Maximum Response Time (working days) Maximum Time for Closure (working days)
Critical 2 days 10 days
Major 4 days 15 days
Minor 10 days 30 days

8.2 Audit / Assessment of Official Seed Sampler Certification Program

Audits of official seed samplers will be conducted by qualified CFIA personnel (according to the CFIA Program Audit Protocol). The audits will be conducted based on a post accreditation audit checklist and audit report format. An auditor must be a certified seed sampler and have auditor training. When non-conformances are identified, action requests will be initiated by the audit team. Any non-conformances identified, that are considered to be of a general nature, will be brought to the attention of all districts across the country.

Assessments of official seed samplers will be conducted according to a yearly work plan prepared jointly by Operations, Science and Programs Branches.

8.3 Program Audit

A comprehensive audit of the official seed sampler certification program may be conducted at a frequency determined by the Director of the Plant Production Division. The criteria to be audited are listed in Program Audit Criteria (Appendix IX). Other criteria may be added as deemed appropriate by the Seed Section.

In addition, the official seed sampler certification program may be reviewed by representatives of the ISTA audit team as part of their audit of the CFIA's Seed Laboratories for conformance with ISTA's Seed Testing Laboratory Accreditation Standard.

When non-conformances are identified, action requests will be initiated. Any non- conformances identified that are considered to be of a general nature will be brought to the attention of all districts across the country.

8.4 Records And Administration

Records shall be maintained in support of the official seed sampler certification program. All records shall be maintained in accordance with the confidentiality guidelines regarding personal information established in the Privacy Act.

The following records shall be maintained:

  1. Action Request Forms: shall be retained by the SSTS Laboratory. In the case of action request forms related to major and critical non-conformances, the Seed Section and sampler's supervisor shall also be sent a copy.
     
  2. Audit Records: completed sampler and program audit reports, and related correspondence including copies of action request forms issued as a result of an audit, shall be forwarded to the Seed Section. Copies of the audit report shall be forwarded to the SSTS Lab. Audit records must be kept in a confidential file.
     
  3. Certificates: a copy of a sampler's certificate shall be forwarded from Seed Section to the SSTS Lab and the appropriate Area Training Officer.
     
  4. Evaluation Records: shall be kept in a confidential file by the Test Administrator.
     
  5. List of Official Seed Samplers: the Seed Section shall maintain the list of official seed samplers on the Agency website. This list is accessible to the CFIA inspection offices and Seed Laboratories. A name shall be entered on the list after Seed Section receives the required documentation indicating certification standards have been met, an Official Seed Sampler Certificate has been issued and a signature verification form has been received by the SSTS Lab. Inspection managers will notify Seed Section of any changes in the employment status of an official seed sampler under their jurisdiction. Seed Section will issue a notification when any changes are made to the official list.

    The List of Official Seed Samplers shall contain the following information:
    1. Name of the official seed sampler
    2. Date the list was last updated
       
  6. Official Seed Sampler Database: the Seed Section shall maintain an Official Seed Sampler Database that contains the following information:
    1. Name of the official seed sampler
    2. Inspector number
    3. Work location
    4. Date of certification
    5. Certification status
    6. Dates of suspension, cancellation and/or reinstatement
    7. Date record last updated
       
  7. Submitted Sample Assessment Records: submitted sample assessment records shall be maintained by the SSTS Laboratory.
     
  8. Training Records: shall be kept on file by a candidate's supervisor and the appropriate Area Training Officer.

9.0 WARNING, SUSPENSION, CANCELLATION AND RE-INSTATEMENT

9.1 Warnings

As required by participation in the ISTA seed testing laboratory accreditation standard, a warning letter shall be issued by the Seed Laboratory to an official sampler when a specified number of non-conformances, pertaining to official samples taken for any purpose, have been identified. This warning letter shall be copied to the sampler's supervisor, Seed Section and the Operations Inspection Manager. Warning letters will be issued when a sampler has had identified as a result of seed sample submission surveillance:

  1. in a one year period and pertaining to different sampling activities:
    1. 3 critical non-conformances
    2. 5 major non-conformances
    3. 10 minor non-conformances
    4. any combination of 6 critical and major non-conformances
    5. any combination of 11 critical, major and/or minor non-conformances
  2. in a one year period and pertaining to the same sampling activity:
    1. 2 critical non-conformances

9.2 Suspension

Seed Section will suspend the certification of an official seed sampler when, as a result of seed sample submission surveillance and/or sampler audit, the sampler has had identified:

  1. in a one year period and pertaining to different sampling activities:
    1. 4 critical non-conformances
    2. 6 major non-conformances
    3. 12 minor non-conformances
    4. any combination of 7 critical and major non-conformances
    5. any combination of 13 critical, major and/or minor non-conformances
  2. in a one year period and pertaining to the same sampling activity:
    1. 3 critical non-conformances
  3. in a two year period and pertaining to different sampling activities:
    1. 5 critical non-conformances
    2. 9 major non-conformances
    3. 20 minor non-conformances
    4. any combination of 10 critical and major non-conformances
    5. any combination of 21 critical, major and/or minor non-conformances

Where an action request has been issued to an inspector three times in a one year period or four times in a two year period for the same non-conformance, the classification of the non- conformance will be elevated one level. This requirement is retained upon reinstatement of suspension/ cancellation. If the Corrective Action Request (CAR) is reissued, elevate one level and notify supervisor. e.g. failure to submit documentation upon re-submission of a seed sample to replace a sample rejected due to critical non-conformance is classed as a minor non-conformance. If on three occasions within one year, the sampler fails to submit documentation upon re-submission of a seed sample to replace a sample rejected due to a critical non-conformance, the third action request will indicate that the non-conformity has been elevated to "major".

A sampler's certification will also be suspended when the seed sampler, or the sampler's supervisor, does not respond in writing to an action request related to a critical non- conformance identified during an audit within the specified time frame. Once the criteria for suspension have been met, Seed Section will notify the sampler within five working days. This letter will be copied to the inspector's supervisor, the Operations Inspection Manager and the SSTS Laboratory. Seed Section will amend the Official Seed Sampler Database and the List of Official Seed Samplers to indicate the suspension and date of the suspension. The certification of a sampler will not be suspended where the implementation of the action request is beyond his/her control (e.g. appropriate triers have not been provided to the sampler). Where the certification of the sampler is reinstated following a suspension, and a five year period elapses with no further suspensions, the record of suspension will be removed from all records.

9.3 Cancellation

The certification of an official seed sampler will be cancelled when an official seed sampler:

  1. submits false or misleading documentation pertaining to a sample or the manner in which it was drawn;
  2. submits samples not drawn or documentation not prepared by the sampler or by an individual under the supervision of the sampler;
  3. has already had her/his certification suspended twice within the previous five year period;
  4. has had her/his certification suspended for a period of two years and corrective action has not been implemented; or
  5. leaves her/his employment with the CFIA.

Some non-conformances resulting in cancellation of certification may also result in disciplinary action. Seed Section will notify the inspector within five working days of the cancellation. This letter will be copied to the inspector's supervisor and the SSTS Laboratory. The Seed Section will amend the Official Seed Sampler Database and the List of Official Seed Samplers to indicate the cancellation and the date of the cancellation. The certification of a sampler will not be cancelled where the implementation of the action request is beyond his/her control (e.g. appropriate triers have not been provided to the sampler).

9.4 Reinstatement

Following suspension, the certification of an official seed sampler will be reinstated when the sampler completes remedial training and demonstrates to a Seed Sampler Evaluator that they have corrected the non-conformance(s) that led to suspension. The Seed Section will amend the Official Seed Sampler Database and the List of Official Seed Samplers to indicate the reinstatement.

Following cancellation, the certification of an official seed sampler will be reinstated when the sampler successfully completes both a written and practical re-evaluation. The Seed Section will amend the Official Seed Sampler Database and the List of Official Seed Samplers to indicate the reinstatement

APPENDIX I: TECHNICAL COMPETENCIES FOR OFFICIAL SEED SAMPLERS

TECHNICAL COMPETENCIES FOR OFFICIAL SEED SAMPLERS

TASK AND COMPONENTS

TASK: Identify what to sample

  • Determine specific lot to sample
  • Determine how seed is packaged
  • Determine crop kind
  • Determine size of lot
  • Verify lot identification
  • Check lot against Program work plan

TECHNICAL COMPETENCIES

  • Knowledge of how seed lot is defined and identified
  • Knowledge of seed industry (e.g. crop kinds, methods of processing, processing records, packaging options)
  • Knowledge of seed program objectives & sample codes
  • Demonstrate ability to obtain necessary information from seed records (e.g. blend sheet, seed analysis certificate, seed declarations, crop certificates)

TASK AND COMPONENTS

TASK: Decide whether or not to sample

  • Determine accessibility of seed lot to see if sample can be taken
  • Determine whether seed lot is being offered for sale as seed
  • Determine integrity of seed lot in terms of sealed, intact containers and appropriate tags/documentation

TECHNICAL COMPETENCIES

  • Knowledge of principles of sampling.
  • Knowledge of conditions that must be met in order to ensure sample is representative, and how to determine the integrity of the seed lot
  • Knowledge of definition of a sealed container
  • Knowledge of import standards, grade designations and definition of sale
  • Knowledge of specific export requirements.
  • Knowledge of when seed is exempt from standards

TASK AND COMPONENTS

TASK: Sample seed

  • Select appropriate sampling method/equipment
  • Determine and take required number of primary samples
  • Use proper procedures to take sample
  • Assess uniformity of primary samples

TECHNICAL COMPETENCIES

  • Knowledge of general principles of sampling
  • Knowledge of definition/criteria of seed lot uniformity
  • Knowledge of sampling equipment options
  • Knowledge of sampling method options
  • Knowledge of sampling equipment use
  • Knowledge and ability to follow proper sampling procedures (including those for treated seed)
  • Knowledge of cleaning procedures for sampling equipment

TASK AND COMPONENTS

TASK: Prepare sample for submission

  • If uniform, combine primary samples to form composite sample
  • Subdivide composite sample to obtain submitted sample, if permissible and warranted
  • Select the appropriate sample submission container
  • Label sample submission container
  • Properly close and seal sample submission container
  • Complete sample submission form
  • Attach tags, as required
  • Use investigation sample handling procedures, where continuity of evidence is required

TECHNICAL COMPETENCIES

  • Knowledge and ability to follow proper mixing procedures to form composite sample
  • Knowledge of which samples (crop kinds) must be submitted to the laboratory for subdivision
  • Knowledge and ability to follow proper procedure for dividing composite sample to obtain submitted samples
  • Knowledge of required minimum submitted sample size
  • Knowledge and ability to follow proper method for handling moisture samples
  • Knowledge of proper sample container based on crop kind, test or treated seed
  • Knowledge and ability to follow proper sample identification and sample sealing procedures
  • Knowledge and ability to properly complete sample submission form
  • Knowledge and ability to follow proper procedures for handling investigation samples

TASK AND COMPONENTS

TASK: Ship Sample

  • Pack samples into shipping container
  • Address shipping container correctly
  • Ship according to the priority of samples
  • For investigation samples, use appropriate procedures

TECHNICAL COMPETENCIES

  • Knowledge and ability to follow proper packaging methods and package identification
  • Knowledge of appropriate mode of transportation (timing)
  • Knowledge of appropriate laboratories for specific tests
  • Knowledge of protocols for legal samples

APPENDIX II: DOCUMENTS THAT MAY BE REFERENCED DURING THE WRITTEN EVALUATION

The following documents will be available to a candidate during the written evaluation for official seed sampler certification:

  1. SWI 132.1.1 Official Seed Sampling
  2. QSP 152.1 Implementation and Administration of the OECD Seed Schemes and EU Seed Directives

In addition, the test administrator may direct the invigilator to provide the following:

  1. Seeds Act and Regulations
  2. ISTA International Rules for Seed Testing, Chapter 2 (current version)

Any of the documents named above may be supplied to the candidate at the beginning of the workshop and as such, may contain highlighted or additional hand written comments made by the candidate. These documents would be acceptable to be referenced during the written evaluation.

APPENDIX III: SAMPLE WRITTEN EVALUATION QUESTIONS

The format of questions that may used in the written evaluations includes definitions, calculations, short answers, fill in the blanks and multiple choice. The questions provided in this Appendix are examples of the types of questions that a candidate can anticipate in the written evaluation.

QUESTION: What does the seed program code MPP mean?

ANSWER: Market place monitoring of pedigreed seed (Reference: SWI 132.1.1 Appendix IV)

QUESTION: What sampling intensity is required for a seed lot packaged in 360 - 25 kg bags?

ANSWER: 30 primary samples must be taken (Reference: ISTA Rules Chapter 2 and SWI 132.1.1 Appendix II)

QUESTION: Define "sell" as it pertains to the Seed Program.

ANSWER: Sell includes to agree to sell, offer, keep, expose, transmit, send, convey or deliver for sale, or agree to exchange or to dispose of to any person in any manner for a consideration. (Reference: Seeds Act , Section 2.0)

QUESTION: Where one gram of seed contains 5000 or more seeds, a sample of seed submitted for testing shall be not less than grams (subject to subsection (3)).

ANSWER: 10g (Reference: Seeds Regulations paragraph12. (2)(a))

QUESTION: Which of the following containers would you use to submit a marketplace monitoring sample of a large seeded crop kind to be tested for purity and germination?

  1. Manilla envelope
  2. Whirl-type poly bag
  3. Cotton bag
  4. Glass jar

ANSWER:

  1. Manilla envelope
  2. Cotton bag

(Reference: SWI 132.1.1 )

APPENDIX IV: PRACTICAL EVALUATION MARKING SCHEME

Candidates begin with 120 points and every non-conformance observed/incorrect answer is assigned a point value that is deducted from the beginning point value. Maximum points deducted for a critical non-conformance is 20 points, major is 10 points and minor is 5 points. However, some non-conformances are assigned lesser point values, weighted to reflect its importance in the sampling procedure. The performance of the following 2 critical non- conformances will automatically result in the inspector not meeting the required standard:

  1. use of unapproved trier
  2. incorrect sampling intensity (inability to correctly ascertain the number of primary samples that should be taken for a specific seed lot)

This evaluation will assess the candidate's practical skill and ability when sampling seed lots. The following are examples of the skills that will be verified by this evaluation.

PRACTICAL EVALUATION MARKING SCHEME
Reference Skill/Factor Remarks
ISTA 2.5,
2.6.4A

Critical

 Sampling Equipment
Does the sampler select the appropriate sampling equipment?

2.a) Critical non-conformances may include the following:

  • (40) - use of unapproved trier
  • (15) - use of approved trier which has a smaller slot opening(s) than required or is smaller than required

For the purposes of task weighting, this section is worth 20 marks - however, the performance of this critical non-conformity results in automatic "does not meet the standard"

[Evaluator should note the trier used.]

  
ISTA 2.6.7,
2.6.7A

Minor

Sample Submission Form

Does the sampler properly complete a sample submission form?

8.a) LSTS sample submission form (CFIA/ACIA 5160) found in SWI 132.1.1 Appendix V has mandatory fields completed:

(0.5) sampling plan (program codes)
(0.5) date of sampling
(0.5) eleven digit sample number
(0.5) sampling location
(0.5) lot number
(0.5) sampling method (trier size & kind/hand)
(0.5) number of containers
(0.5) container type
(0.5) weight of each container
(0.5) total weight of lot
(0.5) sampling intensity (primary samples)
(0.5) common name (kind)
(0.5) variety
(0.5) crop certificate number or blend number
(0.5) grade name
(0.5) tests required
(0.5) inspector signature & date
comments
Deduct 0.5 marks per missing or incorrect item to a maximum of 5.

(Q) 8.b LSTS corrections.
(0.5) make on strike out on the error and write in the change
(0.5) initial and date the change

The maximum number of points that may be deducted from this section is 5.

 The questions in Section 8 are to be assessed by reviewing the sample submission form that has been submitted to the evaluator at the completion of the evaluation.

APPENDIX V: OFFICIAL SEED SAMPLER CERTIFICATE

The Canadian Food Inspection Agency (CFIA), in compliance with the standards of SPRA 131 Inspection Agency Requirements for the Delivery of the Seed Certification Program and acting in accordance with seed program quality system procedure 132.4 Official Seed Sampler Certification, hereby certifies as an official seed sampler.

Inspector Number:

Date Certificate Issued:


National Manager, Seed Section

APPENDIX VI: SIGNATURE VERIFICATION FORM

VERIFICATION OF SIGNATURE

Name:

Address:

Town/City: Postal Code:

Phone: Fax:

Email:

Inspector Number: Inspector initials:

Inspector
Signature Date:

Name of
Inspector's Supervisor

APPENDIX VII: CLASSIFICATION OF NON-CONFORMANCES IN SAMPLING AND DOCUMENTATION

The following is a list of non-conformances that may be encountered in seed sampling or seed sampling documentation. Other non-conformances may be found. When an unlisted non- conformance is seen, the Seed Laboratory or auditor shall submit a description, recommended classification and rationale for classification to the Seed Section.

Critical Non-Conformance: Any procedure that would require re-sampling the lot.

  1. use of hand sampling other than for non-flowing chaffy grasses
  2. use of unapproved trier
  3. use of unapproved dividing method
  4. use of trier too small for crop kind sampled
  5. submission of seed sample that deviates from the required minimum sampling intensity
  6. submission of sample for ISTA certificate purposes from seed lot exceeding maximum lot size
  7. submission of sample for export purposes that is not sealed and labelled for ISTA testing
  8. removal of material from sample (e.g. weed seed/other crops when purity analysis is being requested from the lab)
  9. use of an automated sampling device for export sampling not approved by CFIA
  10. size of submitted sample does not meet the minimum sample size requirements
  11. lack of correspondence between sample and documentation
  12. failure to properly seal submitted sample

Major Non-Conformance: Any procedure that would result in a delay in testing a sample.

  1. lack of correspondence between sampling date and sealing date for OECD samples
  2. drawing of sample from seed lot not sealed as required
  3. failure to completely label submitted sample
  4. failure to submit all required documentation with sample
  5. failure to label treated seed sample as treated
  6. failure to use appropriate protective equipment for sampling treated seed
  7. failure to ensure cleanliness of sampling equipment
  8. samples seed lot for export or grading purposes when primary samples are not uniform
  9. samples seed lot where records indicate that the seed lot cannot reasonably be considered uniform
  10. manipulates the trier in a manner not described in SWI 132.1.1
  11. failure to follow the correct procedure when using the Riffle divider
  12. failure to submit documentation upon re-submission of a seed sample to replace a sample rejected due to critical non-conformance
  13. failure to include or to accurately include, in the submitted documentation any of the following:
    1. trier information
    2. number of primary samples
    3. date of sampling
    4. lot number
    5. lot size
    6. number of containers in each lot
    7. size of each container
  14. failure to submit a properly packaged sample when moisture test requested or seed has been treated
  15. presence of discrepancies between sample and documentation requiring documentation amendment
  16. submission of sample and documentation including OECD tags for variety not on OECD list or evidence that the variety is accepted into a variety registration system.
  17. submission of sample and documentation for ISTA certification for a crop kind not listed in the ISTA Rules
  18. submission of sample and documentation for ISTA testing including OECD tags stating EC rules and standards for species not listed in EC Directives
  19. where a lot has been re-sampled for an ISTA Seed Lot Certificate, the re-sampling does not comply with the ISTA requirements
  20. failure to complete CFIA/ACIA 1118 Form for export sample
  21. failure to check each primary sample for uniformity of seed size, colour and amount of chaffy material
  22. sample taken from a seed lot where a portion of the lot is not accessible
  23. use of inappropriate sample container for submitting sample

Minor Non-Conformance: Clarification of information submitted, testing may be initiated.

  1. failure to use LSTS sample submission form
  2. failure to include, or to accurately include, in the submitted documentation any of the following:
    1. crop certificate number
    2. information regarding components of a mixture
  3. failure to provide information regarding seed treatment of a sample labelled as treated seed
  4. submission of conflicting information pertaining to the sample
  5. failure to include OECD tag when submitting export sample
  6. failure to sign LSTS form.

APPENDIX VIII: STANDARD ACTION REQUEST FORM

For lab use only

Export Sampling
Domestic Sampling

Lab sample Number(s):

Action Request Number:

Originator:

Inspector Number:

Date:

Inspector Name and Location:

Inspection Sample No.(s):

Lot number (as applicable):

Non-conformity identified during:

Sample submission surveillance Sampler audit Program audit

Description of non-conformity (and related observations) requiring correction:

Reference:

Classification of non-conformity: Critical Major Minor

Date response required by:

Date closure required by:

Description of action taken to correct the non-conformity or to prevent recurrence:
(this section is to be completed by the sampler) (For audit and critical non-conformity also the sampler's supervisor)

Signature of sampler:

Date:

Signature of sampler's supervisor (only required in the case of critical non-conformity):

Date:

Verification of Implementation: Acceptable Not acceptable


Signature of auditor/seed sample submission assessor

Date

APPENDIX IX: PROGRAM AUDIT CRITERIA

The following criteria will be considered during a Program Audit:

  1. The list of Official Seed Samplers is up to date;
  2. The list of Test Administrators and Seed Sampler Evaluators is up to date;
  3. The Test Administrator and Seed Sampler Evaluators meet all requirements specified in this QSP;
  4. Requirements outlined in this QSP are being followed regarding training, evaluation, records, seed sampler audits, warning, suspension, cancellation and re-instatement;
  5. Confidentiality guidelines are being followed;
  6. Training material is up to date;
  7. Current training materials are being used;
  8. Requirements outlined in this QSP are being followed regarding submitted sample surveillance, and submitted sample assessment records are up to date;
  9. Official seed samplers have, and are using, the most recent versions of :
    Seeds Act and Regulations
    ISTA International Rules for Seed Testing, Chapter 2: Sampling
    SWI 132.1.1 Official Seed Sampling
    QSP 152.1 Implementation and Administration of the OECD Seed Schemes and EU Seed Directives.

APPENDIX X: RECORD OF INVIGILATION FORM

I, hereby confirm that I was present to invigilate when the following candidate(s) completed the written evaluation for official seed sampler certification:






LOCATION:
TIME OF EVALUATION:

By signing this form, the undersigned confirms that he or she did supervise the writing of the above evaluation on the date indicated and that the administration of this evaluation was conducted in conformance with Seed Program QSP 132.4 Official Seed Sampler Certification.


Signature Date

Date Modified: 2007-08-13

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