D-14-02: Certification Program for the Export of Hardwood Species Regulated for Agrilus spp. to the European Union (EU)

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Effective Date: June 7, 2016
(1st Revision)

This directive describes the Canadian certification program ("Certification Program for the Export of Hardwood Species Regulated for Agrilus spp. to the European Union (EU)") established to meet the phytosanitary import requirements, as prescribed in Council Directive 2000/29/EC and Commission Implementing Decision (EU) 2016/412 of 17 March 2016 (EU derogation).

This directive has been revised to add the export requirements for ash destined for the export to the EU based on a systems approach described in the EU derogation.

Table of Contents

Review

This directive will be updated as required. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).

Amendment Record

Amendments of this directive will be dated and distributed as outlined in the distribution below.

Distribution

  1. Directive mail list
  2. Provincial Government, Industry (via Regions)
  3. National Industry Organizations (determined by Author)
  4. Internet

Introduction

On June 17, 2014, the EU published the Commission Implementing Directive 2014/78/EU which revised phytosanitary import requirements under EU Plant Health Directive 2000/29/EC. The directive, which entered into force on October 1, 2014, prescribes new requirements for importing ash (Fraxinus spp), birch (Betula spp), Japanese walnut (Juglans ailantifolia), Japanese elm (Ulmus davidiana), and Japanese wingnut (Pterocarya rhoifolia) wood to the EU to prevent the entry and spread of the quarantine pests: emerald ash borer (Agrilus plannipenis) and bronze birch borer (Agrilus anxius).

To facilitate the export of sawn wood of host species regulated by the EU, the Canadian Food Inspection Agency (CFIA) has established this certification program similar to an existing audit-based system approach for the import and domestic movement of sawn wood of host species of Agrilus planipennis (D-03-08).

On March 17, 2016, after bilateral discussions with the EU, Canada was granted a derogation for the export of ash wood originating or processed in Canada (Commission Implementing Directive 2016/412 (EU)). The export option under the EU derogation includes heat treatment/kiln drying (HT/KD) for the production of a compliant product under a system approach.

Scope

This directive is intended for use by CFIA inspection staff, approved Canadian exporters intending to export regulated wood products to the EU, and third party auditors of the certification program.

References

Definitions, Abbreviations and Acronyms

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

1. General Requirements

Legislative Authority

The Plant Protection Act, S.C. 1990, c.22
The Plant Protection Regulations, SOR/95-212
Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part 1 (05/13/2000)

Fees

The CFIA charges fees in accordance with the Canadian Food Inspection Agency Fees Notice. Anyone requiring further information regarding fees may contact their local CFIA office or visit the CFIA's Fees Notice website.

Regulated Pests

  • Emerald ash borer (Agrilus plannipenis)
  • Bronze birch borer (Agrilus anxius)

Regulated commodities

Round or sawn wood products (poles, sawn wood, cants, manufactured homes, trusses, etc.) of the following species are regulated to prevent the entry and spread of

  1. Agrilus plannipenis:
    • Fraxinus spp.
    • Juglans ailantifolia
    • Juglans mandshurica
    • Ulmus davidiana
    • Pterocarya rhoifolia
  2. Agrilus anxius:
    • Betula spp.

Regulated Areas

All areas of Canada are regulated. The EU does not recognize Pest Free Areas for emerald ash borer (EAB) in Canada; therefore Pest Free Areas cannot be used as a basis for phytosanitary certification of Canadian origin ash to the EU. Exporters intending to export regulated commodities from all areas must comply with the requirements specified in Section 2 of this policy directive.

The Bronze birch Borer occurs in all areas of Canada and the United States (U.S.), therefore all areas of Canada and the U.S. are regulated by the EU.

2. Export requirements

Facilities intending to export regulated commodities to the EU originating or processed in Canada must register with the CFIA under directive D-14-02. In order to register, a registration form (Appendix 1) must be completed. Facilities are required to develop a quality manual (QM). Guidelines for development of a QM can be found in Appendix 2. Before registration is granted, CFIA will verify if the facility meets the requirements of the certification program.

Under the certification program, facilities must describe their operating procedures in detail in their QM indicating how they will meet the phytosanitary requirements, including all the treatments, as well as other elements such as labelling, traceability and segregation procedures for EU compliant sawn wood.

Facilities currently registered in a CFIA forestry certification program including the Emerald Ash Borer Approved Facility Compliance Program for import under directive D-03-08, or the HT program under directive D-13-01, may amend their QM to add a module describing the specific procedures used to address the export requirements specified in directive D-14-02.

There are two options for the export of ash wood to the EU and one option for birch wood.

2.1 Phytosanitary requirements for the export of ash lumber

Note: The EU recognizes areas of the U.S. that are established to be free from EAB by the USDA-APHIS based on official surveys. For ash wood originating from these areas in the U.S., a phytosanitary certificate stating that ash wood originates from a Pest Free Area is required to allow re-export certification.

Option 1: Debarking and cambium/sapwood removal option

Export shipments must be accompanied by a CFIA issued phytosanitary certificate.

Shipments of ash wood must meet the following processing requirements:

  • Bark and at least 2.5 cm of outer sapwood have been removed in a program approved by the CFIA

In order for the CFIA to certify shipments of ash wood originating in the U.S. and issue a phytosanitary certificate for re-export, the wood must be:

  • Processed in an approved facility under directive D-14-02; or
  • Accompanied by a USDA-APHIS-issued phytosanitary certificate certifying the removal of bark and at least 2.5 cm of outer sapwood and including the appropriate additional declaration required under EU Plant Health Council Directive 2000/29/EC.

Ash wood imported from the U.S. must meet the import requirements under directive D-03-08.

Refer to CFIA directive D-99-06 for processes to receive a phytosanitary certificate or contact your local CFIA office.

Option 2: Export of ash lumber under the derogation (systems approach with HT/KD component)

Export shipments must be accompanied by a CFIA-issued phytosanitary certificate. Shipments of ash wood must meet all of the following elements and processing requirements:

  • Ash wood is produced from debarked round wood; and
  • Ash wood has been debarked to ISPM 15 tolerance (pieces of bark are less than 3 cm in width (regardless of length) or if they are greater than 3 cm in width, the total surface area of each individual piece of bark is less than 50 cm2); and
  • Ash wood is heated through its profile to at least 71 °C for 1200 minutes (20 hours) in a heat chamber approved by the CFIA, or by an agency approved by the CFIA; and
  • Ash wood has a final moisture content of 10% or less; and has been in a kiln for at least a 2 week period; and
  • Each bundle of wood must visibly display both a bundle number and a label with the words 'HT-KD' or 'Heat Treated-Kiln Dried'. That label must be issued by, or under the supervision of, a designated officer of the approved facility after verifying that the processing requirements set out above have been complied with; and
  • The bundle number(s) and the approved facility name must also be on the phytosanitary certificate; and
  • Facilities must be audited by the CFIA or an agency approved by the CFIA, once a month for the duration of the EU derogation (until December 2017); and
  • Facilities must agree to have their information posted on the CFIA's website as per the requirements of the EU derogation.

For the re-export of ash wood originating in the U.S. under the derogation, the wood must be processed in an approved facility in Canada as described above. Ash wood imported from the U.S. must meet the import requirements under directive D-03-08.

Refer to directive D-99-06 for processes to receive a phytosanitary certificate or a phytosanitary certificate for re-export or contact your local CFIA Office.

2.2 Phytosanitary requirements for the export of birch, Japanese walnut, Japanese elm, and Japanese wingnut lumber

Debarking and cambium/sapwood removal

Export shipments must be accompanied by a CFIA issued phytosanitary certificate.

Shipments of birch wood must meet the following requirements:

  • Bark and at least 2.5 cm of outer sapwood has been removed in a program approved by the CFIA

In order for the CFIA to certify shipments of ash wood originating in the U.S. and issue a phytosanitary certificate for re-export, the wood must be:

  • Processed in an approved facility under directive D-14-02 in Canada; or
  • Accompanied by a USDA-APHIS-issued phytosanitary certificate certifying the removal of bark and at least 2.5 cm of outer sapwood and with the appropriate additional declaration under EU plant health council directive 2000/29/EC.

Refer to directive D-99-06 for processes to receive a phytosanitary certificate or a phytosanitary certificate for re-export, or contact your local CFIA office.

3. CFIA Oversight

3.1. Audits

The CFIA or an agency approved by the CFIA will conduct audits of facilities participating in directive D-14-02 to verify compliance with the facility quality manual and section 2 of this directive.

Audits will be on a quarterly basis for facilities exporting under the debarking/cambium removal, or on a monthly basis for those exporting under the EU derogation (systems approach with HT/KD component).

3.2 Non-Compliance

Non-compliant products will not be certified by the CFIA. The exporter may choose to ship the commodity to another destination provided that it complies with the phytosanitary requirements of the receiving country.

Appendix 1: Registration Form for the Certification Program for the Export of Regulated Hardwood Species to the European Union (EU)

Registration form can be found at:

CFIA/ACIA 5745 - Application for Registration under the Certification Program for the Export of Hardwood Species Regulated for Agrilus spp. to the European Union – Policy Directive D-14-02.

Appendix 2: Elements that must be identified in the facility Quality Manual

Facilities that intend to ship hardwood lumber of genera regulated under directive D-14-02 (i.e. ash, birch) to the EU must register under this certification program. All Critical Control Points (CCP) relevant to meeting EU import requirements must be identified and described in the facility's quality manual (QM) to provide assurances to the CFIA that lumber produced under this certification program meets EU import requirements.

The QM must outline the procedures and processes implemented by a facility to mitigate the phytosanitary risk of pest spread associated with the movement of regulated articles.

The QM must include all of the elements of a facility's operations that relate to pest risk mitigation. Details of these requirements are described below.

A quality management system that follows International Organization for Standardization guidelines or a similar management system may also be approved as a QM.

1. General Requirements

1.1 Facility Identification

The QM must provide the facility name, address, a contact name and information of each facility location where regulated articles are received and processed.

1.2 Organization of Quality Manual

A table of contents page may be required at the CFIA's discretion to improve the organization of the QM.

1.3 Quality Manual Modifications

The Facility must have a CFIA-approved and up-to-date copy of the QM with an assigned version number and date of revision. Subsequent changes must have a new version number and replace previous versions. When the QM is altered, the updated version must be sent to the CFIA for approval prior to implementation. Where repeated updates are required, an amendment log must be kept to document changes. A copy of the amendment log must be attached to the QM. Facility employees must be trained and informed of the procedure changes and the changes made to the QM once they have been approved by the CFIA.

2.0 Administration

2.1 Certification Manager

The QM must identify a Certification Manager (CM) and an alternate to the CM. The CM is the official contact with the CFIA and is responsible for developing the QM, enacting changes and updates, providing training to employees with roles and responsibilities under the certification program and conducting optional internal audits. The CM will also be responsible to meet with the CFIA and assign staff to accompany and assist during audits. The CM and alternate must have expertise in identification of tree genera (logs and lumber). This expertise could be obtained from experience or education and must be described in the QM (e.g., number of years of experience, courses taken, etc.).

2.2 Staff Responsibilities

The QM must identify the staff members responsible for ensuring that the facility meets the export requirements. Position titles and a description of responsibilities in relation to this certification program must be documented.

3.0 Staff Training

The QM must describe the training procedures of staff responsible for procedures to meet the export requirements. This includes the specific training elements and the intervals between training sessions. The training records must include the names of the employees trained, and the training topics covered. An example of a training record must be appended to the QM.

Information on the signs and symptoms of Argilus spp., a copy of the facility's QM, and this directive (D-14-02) must be accessible to all facility staff that contributes to meeting export requirements.

4.0 Phytosanitary Critical Control Points

Phytosanitary critical control points are mandatory processing steps where regulated articles must be processed in accordance with the certification program. These may include stages where regulated articles are received, segregated, processed and shipped.

Facilities are encouraged to conduct internal inspections following critical processing steps (e.g., inspection of lumber to ensure bark and wane are removed, or review of charge reports). If the facility does internal inspections, the QM must identify all phytosanitary critical control points and outline how the facility will conduct the internal inspections of the points to verify that regulated articles are processed in accordance with the certification program. The facility could develop a flow diagram to identify control points. Inspection and audit records at these control points must be current and complete.

Staff must fully understand their roles and responsibilities regarding phytosanitary critical control points.

4.1 Receiving Regulated Articles

The QM must document how incoming regulated articles are identified upon receipt. Procedures may include signing off on incoming shipping documents, and applying unique markings for loads of regulated articles. The facility must keep a record/inventory of incoming regulated articles.

Import of regulated articles and their domestic movement must be according to directive D-03-08. Facilities must indicate in the QM how they will meet the import and domestic requirements.

4.2 Segregation

Facilities must have procedures in place to ensure treated lumber destined for the EU is segregated and clearly marked with a unique identifier from lumber destined for domestic movement or export to other countries Segregation methods may include physical barriers such as fencing designating areas identified with specific signage or other identification as described by the facility.

Logs from a Canadian regulated area for EAB coming in for processing must also be segregated where a facility is located in a Canadian area that is not regulated area for EAB.

A site plan may be included with the QM to identify the location of these specific areas.

4.3 Processing/treatment Procedures

Treatment/processing measures to generate compliant products are outlined in section 2.0 of this directive.

The QM must indicate the processing procedures used to generate compliant regulated articles and the procedures used to confirm that the processing conditions are met.

Facilities in Canadian areas that are not regulated for EAB must process all ash material before the end of the low risk season (Before March 31) as per directive D-03-08 to prevent pest spread.

4.4 Traceability of Regulated Articles

Facilities may be required to show the origin of lumber in order to meet the certification requirements to export to some countries. For these specific situations, it is mandatory that procedures be instituted to allow the confirmation of origin. The CFIA may refuse to issue a Phytosanitary Certificate if the origin cannot be confirmed.

Facilities must be able to trace back the bundles of lumber going to the EU throughout the complete chain of processes to make the lumber compliant with the respective option chosen. This includes the traceability of movement of product (within and between facilities/mills) as well as the processing steps between the raw wood, the debarking, the heat treatment, and the kiln drying, as well as the labelling of the final product, as applicable.

4.5 Debarking

The facility must adjust the debarking equipment to remove the required amount of bark whether for meeting the ISPM 15 tolerance or the removal of bark and an additional 2.5 cm of the cambium/sapwood, depending on the option chosen for the export of regulated material. The QM must describe the inspection procedures throughout the process to guarantee debarking meets the EU's phytosanitary requirements for debarking.

If the registered facility is receiving sawn wood from another facility/mill, they must provide proof that lumber was produced from debarked logs as per the ISPM 15 tolerance for bark.

4.6 Heat Treatment and kiln drying under EU derogation

Facilities must meet the treatment requirements of at least 71 °C for 1200 minutes (20 hours) through the profile of the wood and a final moisture content of 10% or less.

The QM must describe the kiln layout, including dimensions, direction of air flow, and location of all sensors and how it meets the kiln verification parameters of PI-07. An example of the charge report, showing the calculations used to confirm that heat treatment requirements are met must also be included in the Manual.

Heat treated lumber to the EU under the system approach must be segregated from heat treated lumber meeting 56 °C /30 min destined to other markets. Bundles must be marked and given a unique identifier which can be traced back to original material and the associated treatment process (Kiln charge report).

The moisture readings as well as the drying period of at least two weeks must be recorded in a way that can be traced back to the bundles destined to the EU.

If the facility receives heat treated lumber from another HT facility, both must be registered under directive D-14-02 and all copies of the kiln charge reports and the information of the HT facility must be kept for traceability and audit purposes.

4.7 Labelling

Each bundle of treated wood must visibly display both a bundle number and a label with the words 'HT-KD' or 'Heat Treated-Kiln Dried' and given a unique identifier for EU eligibility. The label must be issued by, or under the supervision of, a designated officer of the approved facility after verifying that the processing requirements have been complied with.

5.0 Other Control Activities

Other control activities implemented by the facility that may impact the integrity of the certification program must be included in the QM.

6.0 Records and Documentation

Facilities are required to maintain records that track all activities related to this certification program for a minimum of three (3) years. Examples of these records include incoming shipping documents (requirement for sources of incoming wood destined for export), movement certificates and log journals, inspection records for incoming regulated articles in non-regulated areas, training records, sales records for regulated articles sold, audit reports and corrective actions.

Also for the purposes of this certification program, facilities must keep records of procedures for verification by the CFIA or an agency approved by the CFIA, including the duration of treatment, temperatures during treatment, when parameters of schedule H in PI-07 was achieved and the final moisture content for each specific bundle to be exported.

6.1 Supplier List

Facilities must maintain a list of all suppliers, including U.S. suppliers from where regulated articles will be sourced. Changes made to the suppliers list must be documented. Contact your local CFIA office for more information.

6.2 Transportation of Non-Compliant Regulated Articles

Regulated articles must be transported under the conditions outlined in directive D-03-08, Section 2 for domestic movement and Section 3 for imports. The QM must outline how the facility will meet the requirements for transport of regulated articles. If facilities registered in the certification program are issued a Movement Certificate to allow the domestic movement of regulated articles, the QM must indicate the specific procedures and employees responsible for the care and control of theses certificates. Specific information such as the movement certificate number, article, quantity, date of shipment, and origin/destination of shipment, must be maintained for each shipment transported under the authority of the Movement Certificate.

Facilities using their own vehicles to transport non-compliant regulated articles outside of a Canadian regulated area must outline the procedures (e.g., cleaning of trailer after unloading regulated articles) used to mitigate the risk of pest spread.

6.3 Facility Non-Conformance

The facility must specify an internal system for addressing and recording non-conformances.

A non-conformance record must include the following information:

  • Description of the non-conformance
  • Date of occurrence
  • Employees involved
  • Corrective actions taken
  • Deadline for when the corrective action must be completed
  • Signature of approval by the Certification Manager

An example of the facility's non-conformance record must be included in the Manual.

6.4 Clean-Up and Disposal of By-Products

Facilities in Canadian areas not regulated for EAB that are handling articles from Canadian regulated areas for EAB must specify that processing, treatment, clean-up and disposal of regulated articles will be completed by March 31, which is the end of the low-risk period. Procedures to contact CFIA once the final clean-up is completed must be outlined in the QM. Completion of clean-up and disposal activities will be verified by the CFIA.

6.5 Pest Notification

Live EAB or signs of EAB damage, may be encountered by facility staff during the processing of regulated articles. All facilities must clearly specify in their QM a commitment to notify the CFIA immediately if EAB in any life stage or signs of EAB, are found on regulated articles sourced from Canadian areas not regulated for this pest.

6.6 Internal Audits

Facilities are encouraged to conduct internal audits on a routine basis. Internal audits are internal checks that verify all procedures are carried out as outlined in the facilities' Manual. The internal audits should include an audit of all the phytosanitary critical control points and should be recorded. If internal audits are conducted, a copy of the internal audit log must be included in the manual.

Internal Audit reports must be made available to the CFIA during audits.

7.0 Manual Review

Prior to registration, a review of the QM will be conducted by the CFIA to verify that all prescribed elements of this appendix are addressed.

8.0 Evaluation Audit

An evaluation Audit is a systemic examination conducted by the CFIA, to verify that a facility is capable of consistently meeting requirements as outlined in the facility's QM. Once the CFIA approves the QM and a facility receives good standing in the Evaluation Audit, the facility will be approved for registration under the certification program.

9.0 Audits and Reviews

Once approved, a facility will be audited by the CFIA or an agency approved by the CFIA, to verify compliance with the facility quality manual and section 2 of this directive. Audits will be on a quarterly basis for facilities exporting under the debarking/cambium removal option, or on a monthly basis for those exporting under the derogation (systems approach with HT/KD component).

10.0 Cancellation, Reinstatement and Voluntary withdrawal

Facilities that are unable to address the necessary corrective actions or have a total failure of their quality management system will be notified in writing by the CFIA and will be immediately removed from the certification program.

Cancelled facilities will be removed from the CFIA list of approved facilities.

To be reinstated, cancelled facilities must submit a new application and a revised QM. The facility must also receive a good standing on the evaluation Audit.

Facilities that voluntarily withdraw from the certification program need to provide a written notification to the CFIA.

Individuals or companies that do not comply with the Plant Protection Act and Plant Protection Regulations may be subject to additional actions, including enforcement actions.

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