Elements of a Site Specific Plan: A Guide for Applicants to the BSLB Risk Mitigation Program
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June 3, 2013
A Site Specific Plan outlining how a facility could meet the requirements and obligations under the BSLB Risk Mitigation Program must be developed by the facility and documented. It is recommended that the facility develop its own internal audit system, using checklists to ensure that the critical elements of the BSLB Risk Mitigation Program are being met. The CFIA must review and approve the Site Specific Plan to ensure that the core criteria of the Program (as provided in the program application) will be met by the facility.
The following essential elements of a Site Specific Plan must be met by all applicants as one of the requirements for acceptance into the BSLB Risk Mitigation Program. It is intended solely as a guide for completing the Site Specific Plan and places the CFIA under no obligation to accept the applicant into the Program.
- Endorsement by the Facility's Senior Management: There must be a statement by senior management of the facility that they understand the BSLB Risk Mitigation Program, and agree to abide by all Program terms and conditions.
- Facility Contact Person: The facility must identify a person to act as Facility Contact Person (usually the Quality Manager) - an employee of the company who will be the official contact person with the CFIA and who is empowered to enact any necessary changes to the Site Specific Plan. This person(s) will be responsible to meet with the CFIA, accompany the CFIA during facility inspections and to render all necessary assistance for them to conduct their inspections. As well, the facility must designate an alternative (back-up) contact person.
- Administration: The facility must identify the function and responsibilities of other staff who are critical to the facility in meeting the obligations of the Program.
- Facility Non-Compliance: The facility must establish an internal mechanism or system for detecting and reporting any events of non-compliance with BSLB Risk Mitigation Program. This will require the facility to demonstrate and document that it has operating procedures in place and that it conducts internal audits and inspections for compliance by its staff. Internal records should capture such criteria as:
- description of the event (non-compliance or deviation)
- dates of occurrence
- staff involved
- corrective actions taken
- a final sign-off by the Quality Manager.
The CFIA must be notified within 24 hours of any major non-compliance that would affect the status of the facility being able to meet the requirements of the Program.
- Critical Control Points: Critical Control Points are those areas of the participant's process, where failure to deliver to the participant's internal specifications could have a profound impact on the facility being able to meet its obligations under the Program and that would cause it to be in non-compliance with.
It is recommended that the facility develop a flow diagram identifying its production processes and what it perceives to be its Critical Control Points, and include this with its Site Specific Plan.
- Training: The facility must outline how it will train its staff on their respective obligations under the Site Specific Plan. A checklist must be kept as a record of staff members who have been trained on elements of the Site Specific Plan.
The facility must also post information identifying the signs and symptoms of BSLB for the purposes of facility staff awareness, complete with CFIA contact numbers, in the event that specimens suspected of being BSLB are found.
- Traceability: All BSLB regulated materials on-hand, or entering or departing the facility must be traceable to origin at all times. The facility must address how this will be accomplished.
- Record Maintenance and Retention: All records pertaining to all BSLB regulated materials entering the facility from all origins must be maintained for a period of three (3) years and must be made available to the CFIA upon request. These include, but are not limited to: shipping records, Movement Certificates, Certificates of Origin and copies of Program application forms.
The facility is required to produce records which clearly identify the origin, name of transporter, vehicle licence and dates of arrival and processing for any BSLB regulated materials they receive.
- Inventory Control: It is imperative that the facilities outside the infested area, which are receiving material from within the infested area, develop and document a procedure outlining how it will ensure that BSLB regulated materials do not become co-mingled with non-regulated raw materials or processed products at the facility. This should include the entire chain of production from the arrival of the logs at the facility to the final product (including waste materials such as slabs and culls). This can include but is not limited to signage, segregation and flags or fencing. (Refer to points 5, 7 and 8, above). Flow diagrams may be useful for this purpose. Where co-mingling or integration of regulated and non-regulated articles may occur, all such co-mingled material shall be considered and handled as regulated articles.
- Pest Notification: Because the Program will allow for the movement of regulated material from potentially infested areas to facilities outside of the infested area, there is a possibility that BSLB or signs of BSLB damage may be encountered by the facility staff during handling and processing. While the discovery of BSLB will not be considered a non-compliance within the terms of the Program, failure by the facility to implement a BSLB awareness program to contain and refer insects suspected of being BSLB to the CFIA will be deemed critical.
- Pest Surveillance Activities: The facility must indicate a willingness to permit and assist the CFIA to conduct BSLB pest surveillance activities on and around the facility premises in accordance with the CFIA's National Survey Plan for BSLB.
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