Fresh Fruit and Vegetable Registered Produce Warehouse (RPW) Program Manual of Procedures
4. Monitoring of a Registered Produce Warehouse

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The monitoring visit includes product inspection, which requires that a minimum amount of produce be examined at the time of a monitoring visit and may include an examination of the establishment in order to see if the operator is meeting the registration and operational requirements.

4.1 Inspection of Establishment and Operations

Inspectors are not required to perform a complete assessment of the operation and maintenance of the establishment during each monitoring visit. Inspectors, however, must not overlook non-compliances with establishment and operational requirements. When such a non-compliance is observed, the inspector must complete the first and last page of the Inspection Report, identify the non-compliance, and include comments and the agreed upon correction date in the Inspector's Comments/Observations section.

It should be noted that all operational and maintenance requirements of a RPW must be assessed on a yearly basis, at a minimum.

4.2 Product Inspection

For the purpose of this section, here are some definitions:

Lot means that quantity of produce, by reason of commodity, variety, grade and/or package which is considered separately from other produce as a subject of an inspection.

Product Inspection means the total of all lots examined in one monitoring inspection or visit.

Infraction means, unless otherwise stated, non-compliance found when an inspected lot or lots fail grade, marking and/or packaging requirements during one product inspection. Therefore, in one product inspection, more than one lot may fail the requirements and only one infraction will be recorded.

During the monitoring visit, any lot of produce bearing a registration number or Canada grade name may be inspected to the requirements of the Canada grade declared, since any lot so marked should meet the grade requirements and could be shipped interprovincially.

The volume of product to be inspected at the time of each monitoring visit to a particular warehouse will be equivalent to half a day's production or whatever is available at the time. If substantially less than half a day's production is inspected, the inspector should return at a later date to ensure that a proper monitoring visit has occurred. The established sampling plan is used as the minimum for each lot inspected.

At the time of the product inspection, the inspector will record all results on a hand written inspection detail sheet or in the Multi Commodity Activities Program (MCAP) under inspection type Shipping Point - RPW Monitoring.

4.2.1 Frequency of Inspection Level (F.O.I.L.)

Product Inspection is based on a statistically valid method of sampling, where samples are chosen at random from a group in which every item is given an equal opportunity of being selected. The results of several such inspections over a period of time will identify whether or not a particular RPW continuously packs its produce according to grade standards.

The F.O.I.L. concept is based on the premise that an establishment's compliance rate reflects its ability to meet regulatory requirements. As such, the frequency of monitoring visits should, consequently, be based on an establishment's compliance rate. If the inspector does not find any non-compliant product over a certain number of visits, the frequency of inspection level can be reduced. Conversely, if the inspector finds one or more lots of produce repeatedly failing the grade, the frequency of inspection level can be increased.

4.2.2 Frequency of Visits

There are three basic frequencies in the F.O.I.L. monitoring scheme.

  1. Reduced
    One (1) visit per four (4) week intervals
  2. Normal
    Two (2) visits per four (4) week intervals
  3. Tightened
    Four (4) visits per four (4) week intervals

The volume of product to be inspected at the time of each visit to a particular RPW will be equivalent to half a day's production or whatever is available at the time. If the establishment runs multiple shifts of operation, these additional shifts should be calculated into the day's production. Every effort should be made to ensure monitoring is representative of all shifts.

All warehouses will be placed in the normal frequency of inspection on initial registration. The frequency with which the warehouse is being inspected at the end of the packing season will be carried over to the beginning of the next packing season. Example, if a warehouse is on tightened frequency at the end of the packing season, it will remain on a tightened frequency for the beginning of the next packing season.

4.2.3 Rules for Switching Frequencies

Note: Infraction, unless otherwise stated, is defined as any non-compliance found in an inspected lot or lots; failure to meet grade, marking and/or packaging requirements during one product inspection. Example, if, out of three (3) lots inspected during one inspection, one (1) fails, there is an infraction within that inspection.

  • a. Reduced to Normal Frequency

When reduced frequency is in effect, normal frequency shall be instituted as soon as an infraction occurs.

  • b. Normal to Tightened Frequency

When normal frequency is in effect, tightened frequency shall be instituted when two (2) infractions occur in two (2) consecutive product inspections, or two (2) infractions occur within five (5) product inspections.

  • c. Tightened Frequency to Suspension

When tightened frequency is in effect, suspension shall be instituted when infractions occur in two (2) or more lots in one product inspection.

Note: During tightened frequency, within one product inspection, each non-compliant lot will be considered as a separate infraction.

While on suspension, the operator shall obtain an inspection for each shipment of produce to be sent or conveyed to another province.

  • d. Suspension to Tightened Frequency

When on suspension, tightened frequency shall be initiated when at least 225,000 kg (495,000 lb) of produce have been consecutively inspected without incurring one infraction. This is approximately 10 loads at 45,000 lb each.

  • e. Tightened to Normal Frequency

When tightened frequency is in effect, normal frequency shall be instituted when five (5) consecutive visits do not show any infractions.

  • f. Normal to Reduced Frequency

When normal frequency is in effect, reduced frequency shall be instituted when five (5) consecutive visits do not show any infractions.

4.2.4 Infractions in Relation to the Product

An infraction can result when any single tolerance or the overall general tolerance for the grade of the produce being inspected (monitored) is exceeded in one or more lots at shipping or at destination, resulting in the lots under inspection failing grade. The lots bearing the registration number or a Canada grade name will be considered for inspection.

In the case of Registered Produce Warehouses that are shipping more than one commodity for which certification would otherwise be required, infraction records will be carried from one commodity to another. Infraction rates are a measure of the warehouse's ability to consistently pack product while meeting requirements, regardless of the commodity. As an example, one potato infraction in a warehouse shipping potatoes and apples will affect the frequency of monitoring at the establishment for both commodities.

Infractions can also result when produce is found, at destination, to fail regulatory requirements. Only lots that fail for permanent defects, packaging or marking requirements at destination will be taken into consideration. In such cases, the destination inspection office will advise the shipping point region, which will have the infraction entered into the Registered Produce Warehouse's file. The destination office will also forward a copy of the destination certificate or the monitoring report to the shipping point region as soon as possible. If it is possible to positively link a failing lot at destination to one that was found to have failed at shipping point, for example, by lot number or Positive Lot Identification, the responsible establishment will incur only one infraction.

Product found to be out of grade or improperly marked or packed, either at shipping point or at destination, must be detained. It is the responsibility of the packer or the dealer to correct the infraction. Such detained lots will be held until re-inspected and released from detention by a CFIA inspector.

4.2.5 Summary of Monitoring Visits

At the completion of the monitoring visit, the inspector is required to review the findings of the monitoring inspection with the plant management. This will include the product inspection results and may include non-compliances in regard to the establishment and operation/maintenance of the establishment. The first and last page of the Inspection Report must be completed. The last page must include any non-compliances identified and the agreed upon dates by which corrective actions must be implemented. The last page of the Inspection Report must also include information on product monitoring and indicate whether product met or failed to meet the grade requirements in accordance with the FFVR. Under Remarks, the inspector must record the particulars of the lot(s) monitored. The inspector must also note any change to the F.O.I.L. under Inspector's Comments/Observations. This will serve to inform the plant management of how well the warehouse is operating. This is particularly important when suspension or cancellation action may be required and this possibility should be clearly indicated. A copy of the report (first and last page) must be provided to the establishment's designated supervisor and the inspector and the establishment's designated supervisor must sign the last page. A copy of either a hand written or MCAP detail sheet may accompany the Inspection Report, and if included, must be signed by the inspector and the establishment's designated supervisor.

Note: At no time should a certificate be issued for the product that has been inspected as part of the F.O.I.L. monitoring. The purpose of the monitoring program is to evaluate the grading and packing abilities of the warehouse and not to issue certification that the lot fails or passes. If the operator of the warehouse wants to have an inspection, they can request it by completing and submitting an application for inspection.

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