D-13-01: Canadian Heat Treated Wood Products Certification Program (HT Program)

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Effective Date: 20 June 2015
(Original)

Subject:

The Canadian Heat Treated Wood Products Certification Program (HT Program) is a phytosanitary certification program administered by the Canadian Food Inspection Agency (CFIA). The program provides a basis for meeting the foreign phytosanitary import requirements for heat treated wood products. Where prescribed by importing countries, heat treatment of wood products is a phytosanitary import requirement intended to prevent the movement of plant quarantine pests.

The HT Program establishes the requirements for facilities registered under the program to produce and/or handle wood that has been heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes. The heat treatment standard also applies to the production of wood packaging material in accordance with the provisions of the International Standard for Phytosanitary Measures (ISPM 15): Regulation of Wood packaging material in International Trade.

Some National Plant Protection Organizations (NPPOs) may establish additional phytosanitary import requirements.

This Directive supersedes CFIA's policy directive D-03-02, Canadian Heat Treated Wood Products Certification Program (CHTWPCP) and D-01-05, Canadian Wood Packaging Certification Program (CWPCP).

All registered facilities operating under the CWPCP or CHTWPCP, will be moved to D-13-01, Canadian Heat Treated Wood Products Certification Program (HT Program). Changes to facility registration or manuals are not required. Changes to facility audit frequencies are proposed for some facilities but will not be implemented until January 1, 2016.

Table of Contents

Review

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

Endorsement

Approved by:

space
Chief Plant Health Officer

Amendment Record

Amendments to this directive and its appendices shall be dated and distributed as outlined in the distribution below.

Distribution

  • Canadian Lumber Standards Accreditation Board (CLSAB)
  • CLSAB Accredited Agencies
  • Industry Organizations (CWPCA, QWEB, and others)
  • CFIA Approved Third Party Auditors
  • Listserv
  • CFIA website
  • Registered facilities from Third Party Auditors or the CLSAB or CLSAB Accredited Agencies

Introduction

Since the early 1990s, there has been an increasing emphasis on phytosanitary concerns regarding the international movement of wood products. In some cases, to prevent the movement of pests, wood products are required to be heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

The International Plant Protection Convention (IPPC) established the International Standards for Phytosanitary Measures (ISPM 15): Regulation of Wood Packaging Material in International Trade (2009) which sets guidelines for the regulatory control of wood packaging material moving in international trade including treatment of the wood and specific marking.

This Directive sets out the certification program in place within Canada for the production of heat treated wood products, including wood packaging material, subjected to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

Scope

This Directive is intended for use by facilities registered in or those seeking registration in the HT Program for the production of heat treated wood products (including wood packaging material) to meet foreign phytosanitary import requirements, and for use by custom brokers, freight forwarders, exporters, Recognized Heat Treatment Evaluators, The Canadian Lumber Standards Accreditation Board (CLSAB) and their Accredited Agencies, CFIA Approved Third Party Auditors, and CFIA inspection staff. It sets out the phytosanitary requirements for the production of heat treated wood products and the production of ISPM 15 compliant wood packaging material. It also describes the process by which facility conformance is verified.

References

  • ISPM 5, Glossary of Phytosanitary Terms, FAO, Rome.
  • ISO Guide 8402, Quality Systems Terminology.
  • ISPM 15 Regulation of Wood Packaging Material in International Trade, FAO, Rome: 2009
  • ISPM 7 Export certification system, FAO, Rome
  • CFIA PI-07, The Technical Heat Treatment Guidelines and Operating Conditions Manual
  • Canadian Lumber Standards Accreditation Board Regulations

Definitions, abbreviations and acronyms

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

CFIA Canadian Heat Treated Wood Products Certification Program (HT Program) Questions and Answers.

1.0 General Requirements

1.1. Legislative Authority

The Plant Protection Act, S.C. 1990, ch. 22
The Plant Protection Regulations, SOR/95-212
Canadian Food Inspection Agency Fees Notice, Canada Gazette, Part I (as amended from time to time)
Canadian Food Inspection Agency Act, S.C. 1997, ch. 6

1.2. Fees

The CFIA will be charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. Exporters requiring more information on fee schedules may contact any CFIA Regional office or visit the Fees Notice.

CFIA Approved Third Party Auditors or CLSAB Accredited Agencies will be collecting CFIA Program fees on the behalf of the CFIA.

CLSAB Accredited Agencies and CFIA Approved Third Party Auditors may also charge fees for registration and audit services provided under this program.

1.3. Regulated Commodities

The CFIA's Plant Protection Act and Regulations requires anything exported from Canada to comply with the importing country's phytosanitary import requirements. Additionally, materials moving in-transit through another country prior to reaching their final destination are required to meet the phytosanitary import requirements of the in-transit country.

Importing countries may require the imported of sawn wood (lumber or timber) and other wood products, to be heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes prior to export.

Regulated commodities also include all non-processed wood packaging and loose wood dunnage to be exported from Canada to countriesthat have adopted ISPM 15.

Wood products (including wood packaging) may also be regulated within Canada when moving from an area where such products are regulated for a pest of quarantine concern to an unregulated area.

Since foreign phytosanitary import requirements are subject to change, exporters should consult with a CFIA office to export, to obtain the specific phytosanitary import requirements of the destination country.

1.4. Commodities Exempt

Wood products that are not required to be heat treated (e.g. processed wood) are usually not regulated, although some countries may have specific phytosanitary import requirements.

The following wood packaging commodities are exempt from ISPM 15 standards and therefore not included in the scope of the HT Program:

  • Wood packaging material or loose wood dunnage produced wholly (100%) from processed wood (e.g. plywood, particle board, oriented strand board or veneer sheets);
  • Barrels for wine and spirits that have been heated during manufacturing;
  • Gift boxes* for wine, cigars and other commodities made from wood that has been processed and/or manufactured in a way that renders it free of pests;
  • Sawdust, wood wool and wood shavings
  • Thin pieces of wood (6 mm or less in thickness)
  • Wood components permanently affixed to freight vessels and containers

Note: not all types gift boxes and barrels are constructed in a manner that renders them pest free. For this reason, some of these products may be regulated within the scope of this directive. These include boxes for fruit and vegetables, barrels used in the transport of industrial commodities.

2.0 Phytosanitary Requirements

2.1. Phytosanitary Certificates

A Phytosanitary Certificate is an official Government of Canada document issued by the CFIA to the National Plant Protection Organization (NPPO) of the importing country. Details on the issuance of phytosanitary certificates are contained in the CFIA Policy Directive D- 99-06: Policy on the Issuance of Phytosanitary Certificates.

Where countries require Phytosanitary Certificates to accompany shipments of heat treated wood products, an exporter who is registered in the HT Program shall provide to the CFIA:

  1. A copy of the Heat Treatment Certificate(s) issued for the consignment; or
  2. A recognized certification mark appearing on the lot, consisting of:
    • the mark (CA), (Where CA= Canada) and the facility's CFIA issued 5-digit registration number; or
    • the CLSAB Accredited Agency's logo and the agency issued mill designation; and
    • the treatment applied (HT or KD-HT); or
  3. Each piece of lumber must display a CLSAB Accredited Agency logo, the agency issued mill designation and the HT or KD-HT mark.

2.2. Heat Treatment

Wood products certified under this program are required to be heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes.

A number of production methods achieve this heat treatment standard as described in the CFIA's Technical Heat Treatment Guidelines and Operating Conditions Manual (referred to as PI-07). Registered facilities must produce heat treated wood products in accordance with the guidelines prescribed in PI-07.

In addition, registered facilities may achieve the phytosanitary standard for heat treatment specified through a specific monitoring process, which has been approved by a Recognized Heat Treatment Evaluator (e.g., to obtain Custom-made Heat Treatment Schedules).

2.3. Certification of Heat Treated Wood Products (Excluding Wood Packaging Material)

Export shipments of heat treated wood products (excluding wood packaging material) may be required by the importing country to be certified by way of:

  • The issuance of a Heat Treatment Certificate by a facility registered in the HT Program; or
  • The issuance of a phytosanitary certificate by the CFIA.

2.3.1. Heat Treatment Certificates for export purposes

Heat Treatment Certificates are issued by an approved facility under the authority of the CFIA in accordance with the instructions provided on the certificate. The certificate attests that the wood products have been heat treated in accordance with foreign phytosanitary import requirements for those countries which accept industry-issued Heat Treatment Certificates. Please see Appendix 1 for information on the different types of export and domestic Heat Treatment Certificates.

Approved facilities consolidating treated lots may issue a single Heat Treatment Certificate to cover the entire consignment consolidated from other approved facilities. The consolidated certificate must provide the relevant documentation to allow for traceability to an approved facility(ies).

2.4. Certification of Wood Packaging Material

Wood packaging material, including dunnage, is considered wood that has been finished in a manner that supports, protects or carries a commodity in export trade. It does not include wood products which have not been assembled into the finished unit prior to export (including unassembled wooden boxes, etc.).

All wood packaging material and dunnage exported from Canada to a country that has implemented the requirements prescribed in ISPM 15 must comply with ISPM 15 and must include the IPPC mark as described in Appendix 1 of ISPM 15 and Appendix 2 of this document.

The ISPM 15 mark on wood packaging material and dunnage constitutes a document. This mark cannot be used for any purpose other than for the identification of ISPM 15 compliant wood packaging material in compliance with the requirements of the HT Program.

An ISPM 15 compliant wood pallet, box, crate, etc. that has not been repaired may be re-used and re-exported from Canada without re-treatment.

3.0 Program Requirements

Facilities wishing to participate in the HT Program must complete an application form, seek the service of a CSLAB Accredited Agency or a CFIA Approved Third Party Auditor and develop a Phytosanitary Management System that identifies procedures used by the facility in meeting the foreign phytosanitary import requirements. The facility's processes should be documented in a phytosanitary management system manual. There are six (6) critical control points that need to be upheld in order to meet the phytosanitary requirements of the HT Program and they are outlined in Appendix 5.

Note: not all CFIA Approved Third Party Auditors are eligible to verify all production and export activities indicated in the HT Program. Certain foreign phytosanitary import requirements stipulate the types of auditors eligible to oversee certain export commodities (see Appendix 1 for details).

4.0 Program Oversight

Facility level audits will be conducted by CFIA Approved Third Party Auditors or CLSAB Accredited Agencies, which have extensive knowledge of the HT Program, and are under a formal agreement with CFIA, or in the circumstance of a CLSAB Accredited Agency operating under the CFIA-CLSAB Agreement, to conduct auditing activities on behalf of the CFIA to ensure the conformance of approved facilities to meet the phytosanitary requirements.

Note: Heat treated wood products (except when it applies to hardwood commodity lumber) for the US must be treated to the specification of the American Lumber Standard Committee (ALSC) and must be marked in accordance with the ALSC Heat Treatment requirements.

A system audit is a review of the phytosanitary management system operating at a facility approved for the program. It includes the review and approval of the facility manual and an audit of the processes used by the facility to meet the requirements of program. A CLSAB Accredited Agency or a CFIA Approved Third Party Auditor will conduct an initial evaluation, or system audit, of the facility before registration to ensure that the facility has documented systems to comply with treatment and production requirements.

A surveillance audit is a routine monitoring and verification of facility activities to ensure consistent conformance to the phytosanitary management system in place. Once a facility is approved, the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor will conduct surveillance audits to verify that the approved facility remains in conformance with the program requirements and their phytosanitary management system.

Audit frequencies are provided in:

  • Appendix 3 for facilities operating under the CLSAB, and
  • Appendix 4 for facilities producing wood products under third parties supervised by the CFIA. These facilities do not produce Structural Lumber.

Structural Lumber is defined as all lumber capable of use or application or design where working stresses are required; but it does not include hardwood and assembled structures such as trusses, prefab walls and flooring structures.

Should non-conformances be identified by a CLSAB Accredited Agency or a CFIA Approved Third Party Auditor, the frequency of audits may be increased to verify that all corrective actions have been completed and the facility is capable of maintaining the requirements.

4.1. Program Non-Conformances

A non-conformance is a failure to comply with a specified requirement of the HT Program.

The interception of non-compliant wood products by a foreign government could result in the destruction or the return to origin of the entire shipment (not just the wood packaging material). Failure to meet the phytosanitary import requirements of a foreign importing country is also a violation of the Plant Protection Regulations and may lead to enforcement actions by the CFIA and suspension or cancellation from this program.

Should a non-compliant product be found in the Canadian marketplace, the CFIA may take enforcement action.

The CLSAB Accredited Agency or the CFIA Approved Third Party Auditor shall require an approved facility, to take corrective action on any non-conformance identified. These corrective actions will be monitored by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor. The CLSAB Accredited Agency or the CFIA Approved Third Party Auditor may increase the frequency of audits until satisfactory corrective actions are completed.

Upon the identification of a non-conformance, the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor will provide a written report to the approved facility identifying the non-conformance, corrective actions necessary and the need for follow-up audits.

Non-conformances are categorized as "Major", "Minor", or "Observations".

4.1.1. Major Non-Conformances

Major non-conformances are those that affect the integrity of the program and are required to be corrected immediately. When major non-conformances are detected the facility will be notified verbally and in writing by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor. The detection of a major non-conformance may result in a suspension of the facility or a stop in production until such time as the non-conformance is addressed to the satisfaction of the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor. The CLSAB Accredited Agency or the CFIA Approved Third Party Auditor may conduct an additional audit(s) to verify that the corrective actions have been completed and that the non-conformance is not likely to recur.

Examples of major non-conformances appear in Appendix 6.

4.1.2. Minor Non-Conformances

Minor non-conformances are issued in writing when specific elements within the phytosanitary management systems do not conform to the requirements and which may lead, if not corrected, to the production of non-compliant products.

Approved facilities are required to correct minor non-conformances before the next scheduled audit of the facility (or timeframes dictated by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor). Depending on the number of non-conformances detected the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor may schedule an audit to verify corrective actions as part of the routine audit schedule or as a specific audit in addition to the routine audit frequency.

Examples of minor non-conformances appear in Appendix 7.

4.1.3. Observations

Observations are noted where the particular elements are not adequately addressed but do not affect the phytosanitary integrity of the program.

4.2. Suspension and Cancellation

Where a major non-conformance compromises the integrity of the certification program and is not addressed by the facility to the satisfaction of the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor, or where the annual fees are not paid, the facility registration will be subject to a suspension or cancellation. During the suspension period, the facility will not be permitted to ship any of the product produced under the certification program and will not be able to mark any product with any of the certification marks approved under this program. Other corrective actions may be ordered in writing by the CFIA to ensure that the phytosanitary integrity of the program is maintained. The facility will be given a set time frame to affect the necessary corrective actions

A facility which has been suspended or cancelled may contact a CFIA Review Panel to review the decision to suspend or cancel. For further information on review, consult the CFIA website.

5.0 Appendices

  • Appendix 1 – Heat Treatment Certificates
  • Appendix 2 – Wood Packaging Material production standards and the ISPM 15 recognized certification mark
  • Appendix 3 – Frequency of audit of facilities supervised by the Canadian Lumber Standards Accreditation Board (CLSAB)
  • Appendix 4 – Frequency of audit of facilities supervised by an approved third party auditor
  • Appendix 5 – Elements of a Phytosanitary Management System
  • Appendix 6 – Examples of Major Non-Conformances
  • Appendix 7 – Examples of Minor Non-Conformances

Appendix 1 – Heat Treatment Certificates

Heat Treatment Certificates for Structural Lumber may only be issued by an approved facility which is under the care and control of a CLSAB Accredited Agency.

Heat Treatment Certificates for wood products not including Structural Lumber may be issued by facilities registered under the program.

Heat Treatment Certificates for the European Union (EU) Countries

The Heat Treatment certificates may only be issued to certify wood specifically destined to the European Union. The Heat Treatment Certificate for consolidated shipments is permitted provided that there is an original heat treatment certificate(s) covering all of the material. The certificate must contain the following specific declaration:

"The coniferous lumber to which this certificate applies has been heat treated, and during the process, has achieved thermal death times for Pinewood Nematode (PWN) and its vector."

Heat Treatment Certificates for Countries other than the European Union

The Heat Treatment Certificate may only be used to certify wood products specifically destined to countries other than the member countries of the European Union and that accept industry issued Heat Treatment Certificates. The following declaration appears on the certificate:

"The sawn wood in this shipment has been treated at a CFIA registered facility to achieve a minimum wood core temperature of 56°C for a minimum of 30 minutes."

Heat Treatment Certificate to Mexico

The Heat Treatment Certificate may only be used to certify wood specifically destined to Mexico. The following declaration must appear on the certificate:

"The sawn wood to which this certificate applies has been heated treated to a minimum of 56°C throughout the profile of the wood (including its core) to a minimum of 30 minutes and dried."

Domestic Heat Treatment Certificates

A Domestic Heat Treatment Certificate may be issued by registered facilities to provide verification of treatment when heat treated wood products; unstamped wood packaging material that is ISPM 15 compliant or unstamped ISPM 15 compliant dunnage move between registered facilities located in regulated and unregulated areas of Canada.

Appendix 2 - ISPM 15 Wood Packaging Recognized Certification Mark

The following wood packaging production standards must be upheld for wood packaging to be considered ISPM 15 compliant and registered facilities must outline production procedures in their facility manual.

Use of Debarked Wood

The ISPM 15 standard requires that wood packaging material be made of wood that has been debarked. Any number of visually separate and clearly distinct small pieces of bark may remain, provided these are:

  1. less than 3 cm in width (regardless of the length of the piece) or
  2. if greater than 3 cm in width, the total surface area of the individual piece of bark must be less than 50 square cm (generally thought to be smaller than a credit card).

Repair of Previously Certified Wood Packaging Material

Wood packaging material in which less than one third of the original components have been replaced is referred to as "repaired" wood packaging material. Wood packaging material to be repaired must display certification marks from the country of origin and must be repaired using wood products that have met the heat treatment standard. The repairing facility must mark all components that are used in the repair of the wood packaging with its ISPM 15 certification mark.

Note: the original ISPM 15 certification marks (i.e. foreign marks) on repaired wood packaging destined for the United States of America, should not be obliterated. This ensures that the wood origin of the wood packaging material is retained following repair. If the repairing facility wishes to obliterate all foreign marks and apply their ISPM 15 certification mark, then the unit should be treated as remanufactured wood packaging and must be retreated.

Remanufactured Wood Packaging Material

Remanufactured wood packaging materials are defined as wood packaging material that have had more than approximately one third of the materials replaced. Remanufactured wood packaging materials may incorporate new and/or used components. All previous wood packaging marks on the components must be permanently obliterated and the remanufactured wood packaging material must be retreated and a new mark applied The wood packaging mark shown below (Fig. 1) shall certify that the wood packaging material and/or loose wood dunnage material and/or any non-processed wooden articles, that bears these marks have been subjected to approved treatment measures.

ISPM 15 Wood Packaging Material Certification Mark

Wood packaging material may consist of a single piece of wood or be composed of multiple pieces of wood attached together to form a composite unit, which may be considered as a single unit for marking purposes. Furthermore on composite wood packaging material (composed of both processed and non-processed wood products), it may be appropriate for the mark to appear on processed wood components to ensure that the mark is in a visible location and is of sufficient size.

The mark will be comprised of the following required components:

IPPC Recognized Symbol: the design of the symbol must closely resemble that of the examples below and be placed to the left side of all other components.

Country Code: must be the International Organization for Standards (ISO) two-letter country code (indicated as "XX" in Fig. 1) and must be separated by a hyphen from the producer/treatment provider code.

Producer/Treatment Provider Code: this is a unique code provided by CFIA (indicated as "00000" in Fig.1). The code is five digits in length including "0" at the beginning. This code identifies the facility as an approved facility under the HT Program.

Treatment Code: the abbreviation for the specific treatment used (indicated as "YY" in Fig. 1). HT is the code for materials that are heat treated to a minimum temperature of 56°C throughout the profile of the wood (including at its core) for a minimum of 30 minutes. Other treatment types are not approved under the HT Program.

International Standard for Phytosanitary Measures Number 15 Wood Packaging Recognized Mark
Figure 1: The above are examples of wood packaging recognized mark formats.

The size, shape and position of the mark may vary from facility to facility but each mark must be:

  1. Legible;
  2. Permanent and not transferable;
  3. Placed in a visible location and on at least 2 opposite sides of the article being certified;
  4. Rectangular or square in shape;
  5. Border line must be clear and divided by a vertical line separating the IPPC recognized symbol from the other components of the mark;
  6. For dunnage material, the mark must be visible on each individual piece.

The mark must not be hand drawn and red or orange must not be used because these colours are used in the labelling of dangerous goods.

No other information (such as producer trademark, logo of authorizing body, date of treatment or marking to identify dunnage material) may be contained within the wood packaging certification mark.

National Plant Protection Organizations of the importing countries may at their discretion request control numbers or other information used for identifying specific lots provided it is not confusing, misleading or deceptive.

The wood packaging certification mark may only be applied by wood packaging facilities or treatment facilities approved by the CFIA and operating under the HT Program and can only be applied in Canada.

Appendix 3 – Frequency of Audit of Facilities Supervised by the Canadian Lumber Standards Accreditation Board (CLSAB)

The CFIA has established an arrangement with the CLSAB to supervise accredited agencies listed at www.clsab.ca/accredited-agencies.aspx which oversee some facilities registered in the HT program for export. The CFIA has approved the Operating Plan of the CLSAB which includes the audit frequency of registered facilities described in Section 3.5.16 of the CLSAB Regulations. The auditing standards prescribed by the CLSAB are equivalent to the American Lumber Standards Committee Inc. specification for heat treated wood products as referenced in Section 4.0 Program Oversight of this Directive.

Where a major non-conformance is identified, enforcement actions may be taken in accordance with the CLSAB Operating Plan.

Appendix 4 – Frequency of Audit of Facilities Supervised by an Approved Third Party Auditor

The CFIA has entered into agreements with third parties to oversee the activities of some registered facilities. The CFIA directly supervises the activities of approved third parties. Minimal performance-based frequency of auditing of facilities operating under a third party auditor is described in Table 1. These standards address the risks associated with the phytosanitary activities conducted by registered facilities.

Table 1: Audit frequencies for facilities supervised by third party auditors
Initial annual audit frequency at approvalAnnual audit frequency after a period without a major non-conformance
Producers heat treating wood packaging material and wood products not included in Structural Lumber. 12 6 (after three years)
Producers of wood packaging material and other wood products except for Structural Lumber from heat treated sawn wood 6 3 (after one year)
Wholesalers and shippers 4 4

In the circumstance, where a CFIA approved third party auditor identifies a major non-conformance at a facility, the auditor will consult with the CFIA and provide in writing to the facility an increased frequency. To ensure the facility can maintain consistent conformance with the requirements, the increased frequencies will be maintained for a period of time determined by the CFIA in consultation with the approved third party. Once the auditor is satisfied that the facility can maintain conformance, the facility may be returned to the frequency established for it based upon its record of compliance prior to the detection of the major non-conformance.

Note - The Third Party Auditor should perform the prescribed minimum inspections per calendar year at approximately equal intervals at each facility.

Appendix 5 – Elements of the Phytosanitary Management System

The phytosanitary management system is based on six (6) critical control points. The facility should where appropriate develop processes and procedures that meet these critical control points.

Competency requirements

  • The procedures used in ensuring that staff responsible for phytosanitary activities are competent;

Heat treating requirements

  • The procedures used in meeting the requirements for heat treatment (e.g. the generic [as described in PI-07] or site specific schedules)

Wood packaging requirements

  • Procedures used in the production of heat treated wood packaging,
  • Procedures used in the repair and/or remanufacturing of wood packaging material
  • Procedures used in the production and sale of unassembled wood packaging material (if applicable)Footnote 1
  • Procedures used in stamping wood packaging off-site (if applicable)

Traceability and segregation requirements

  • The procedures used to ensure traceability of heat treated wood products back to treatment at an approved facility;
  • The procedures used to segregate treated from untreated wood products including where repair or remanufacture of wood packaging material is undertaken;
  • The procedures used to ensure that heat treated wood products are only sourced from registered facilities and traceableFootnote 2 to the treatment facility;
  • The procedures used in the identification of heat treated wood products for export;
  • The procedures used to ensure traceability of treatment when consolidating heat treated wood;
  • Identification of ISPM 15 compliant wood packaging material and attached dunnage (including an example of the ISPM 15 stamp)

Documentation and record keeping

  • The retention period for all records and completed forms used by the facility to track phytosanitary activities or procedures. Documents must be retained for a minimum of 2 years. (e.g. purchasing records, training records, audit reports, heat treatment certificates, kiln treatment charts, records of non-conformances, etc.)
  • The procedures used to document:
    • Treatment;
    • production of wood packaging from heat treated wood products;
    • that purchased wood has been appropriately heat treated in a compliant facilityFootnote 3;
    • segregation and;
    • that only of compliant wood products are shipped in accordance with requirements.

Corrective Actions

  • The procedures used by the Registered Facility to record, address and follow-up on non-conformances that may occur during routine operations.

Appendix 6 – Examples of Major Non-Conformances

Major Non-conformances – Audit findings that impact the integrity of the program requiring immediate correction. The following are examples of major non-conformances.

  1. Facilities operating with significant changes to kiln operating conditions that have not been approved by a CLSAB Accredited Agency or a CFIA Approved Third Party Auditor.
  2. Minor non-conformance identified from previous audits have not been addressed.
  3. Regulated wood products destined to off-shore markets have not met the phytosanitary standard (i.e. 56°C/30 minutes) or the registered facility fails to meet the treatment specifications in the approved manual.
  4. Exported material or material designated or consigned for export fails to meet the phytosanitary import requirements of the importing country.
  5. Misrepresenting material as meeting program requirements. For example issuing certificates for untreated material, attaching bundle tags to untreated material, etc.
  6. Segregation of treated and untreated material has not been maintained.
  7. Records are significantly incomplete or do not allow the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor to conduct trace-back of products exported (e.g. treatment records are missing, incomplete, etc. or export certificates not maintained, etc.)
  8. A consolidated shipment has been assembled from wood products that have not been treated in accordance with the standards or has been obtained from a facility not registered in the HT Program.
  9. Employees involved with implementing the quality procedures are not sufficiently trained.

Appendix 7 – Examples of Minor Non-Conformances

Minor Non-conformances - Audit findings that reveal an isolated incident of non-conformance which has no direct impact on the integrity of the product

  1. Facilities operating with minor changes to quality processes that have not been approved by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor.
  2. Facility procedures for documentation or certificate issuances have not been followed or have been poorly followed. Procedures are unclear.
  3. Facility employee involved with implementing the quality procedures is unaware of the phytosanitary specifications pertaining to activities performed by that employee.
  4. Segregation or identification of treated and untreated wood is inadequate, but does not affect the integrity of products ready for export.
  5. Staff training has not been completed or records of training have not been maintained.
  6. Registered facility has failed to maintain records of audits.
  7. Items identified as observations on previous audit are still left unaddressed.
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