Quality System Procedure 142.1: Pedigreed Seed Crop Inspection

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Table of Contents

Date

Version 9.1 of the Quality Systems Procedures (QSP) 142.1 - Pedigreed Seed Crop Inspection was issued May 10, 2017.

Contact

The contact person for this document is the National Manager, Seed Section. Comments regarding the content of this document should be addressed to the National Manager at:
SeedSemence@inspection.gc.ca.

Review

This Seed Program Quality System Procedure (QSP) is subject to periodic review. Amendments will be issued from time to time to ensure the procedure continues to meet current needs.

Endorsement

This Seed Program QSP is hereby approved.

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Director, Plant Production Division

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Date

Distribution

This document will be maintained on the CFIA website. The National Manager, Seed Section will maintain the signed original. A copy of the latest version is available upon request to SeedSemence@inspection.gc.ca.

0.0 Introduction

This Seed Program Quality System Procedure (QSP) outlines the procedures for pedigreed seed crop inspection in Canada intended to maintain and safeguard varietal identity and varietal purity during seed multiplication. The Canadian Seed Growers' Association (CSGA) is identified in the Seeds Regulations (the Regulations) as the authority for seed crop certification of most crop kinds in Canada except potatoes. The Canadian Food Inspection Agency (CFIA) is Canada's seed certification authority and administers the Seeds Act and the Regulations. The CFIA is also the National Designated Authority for the implementation of the Organisation for Economic Co-operation and Development (OECD) Seed Schemes in Canada (OECD Seed Schemes).

1.0 Scope

This QSP applies in all cases where pedigreed seed crop inspection is provided either by a CFIA seed crop inspector or by a Licensed Seed Crop Inspector (LSCI).

2.0 Definitions, Acronyms and References

For the purposes of this QSP, the definitions, acronyms and references given in SPRA 101 – Definitions, Acronyms, and References for the Seed Program apply.

3.0 Outline

The CFIA inspector or LSCI, hereafter referred to as the seed crop inspector, are certified or licensed by the CFIA as evidence of their proficiency in seed crop inspection. In performing their duties, the seed crop inspector must adhere to this QSP, the applicable specific work instructions (SWI) and CSGA's Canadian Regulations and Procedures for Pedigreed Seed Crop Production (Circular 6).

Seed crop inspectors must pass written and practical evaluations prior to certification or licensing by the CFIA to demonstrate their competence to inspect pedigreed seed crops. LSCI are individually licensed according to QSP 142.2 Licensing of Authorized Seed Crop Inspection Services and Licensed Seed Crop Inspectors and CFIA inspectors are certified according to QSP 142.4 Official Crop Inspector Certification Procedures.

LSCI are subject to oversight by the CFIA to verify their compliance with the conditions of their licence. Oversight of the activities of seed crop inspectors is conducted in accordance with QSP 142.3 CFIA Oversight of Authorized Seed Crop Inspection and SWI 142.3.1 CFIA Oversight of Authorized Seed Crop Inspection.

CFIA inspectors are subject to internal oversight conducted by the CFIA.

4.0 Roles and Responsibilities

Additional information on roles and responsibilities is provided in QSP 142.2 Licensing of Authorized Seed Crop Inspection Services and Licensed Seed Crop Inspectors.

4.1 The Roles and Responsibilities of the CSGA

The CSGA establishes standards for the varietal purity of pedigreed seed crops and issues crop certificates for seed crops meeting the standards.

The CSGA is responsible for:

  • establishing and communicating the standards for pedigreed seed crops in Circular 6;
  • establishing and communicating the reporting requirements for Reports of Seed Crop Inspection;
  • receiving applications for pedigreed seed crop inspection;
  • distributing requests for seed crop inspection and the Reports of Seed Crop Inspection to be completed;
  • receiving and assessing completed Reports of Seed Crop Inspection;
  • issuing crop certificates for pedigreed seed crops conforming to the standards of Circular 6 and/or the OECD Seed Schemes;
  • consulting Authorized Seed Crop Inspection Services (ASCIS) or the CFIA on specific questions related to submitted Reports of Seed Crop Inspection as appropriate;
  • notifying the CFIA when permission for re-certification of a pedigreed seed crop is granted;
  • communicating with the CFIA, the ASCIS and the LSCI, as appropriate; and
  • ensuring seed growers provide field maps in CSGA's SeedCert data management system.

4.2 Roles and Responsibilities of the CFIA

The CFIA will license seed crop inspectors according to QSP 142.2 Authorized Seed Crop Inspection.

The CFIA will oversee the activities of ASCIS and LSCI according to QSP 142.3 CFIA Oversight of Authorized Seed Crop Inspection.

In 2017, the CFIA will offer direct delivery of seed crop inspection for:

  • Seed crops other than CSGA Circular 6 sections 2, 3 and 8 crop types (cereals and pulses, Hybrid Corn);
  • Select plots of all crop kinds;
  • Seed crops of CSGA Circular 6 sections 2, 3 and 8 crop types only in the rare event that a grower has been refused by all ASCIS in their Region and if CFIA resources permit;
  • Hybrid Cereal crops;
  • Seed destined for marketing in the EU as Basic or Pre-Basic seed.

CFIA will not complete seed crop inspection when field maps are not available in CSGA SeedCert

In addition, the CFIA will provide identification services for off-types and weeds encountered during seed crop inspections.

4.3 Roles and Responsibilities of the Lead Inspector/Alternate Lead Inspector of the Authorized Seed Crop Inspection Service (ASCIS)

The Lead Inspector/Alternate Lead Inspector is responsible for:

  • having and maintaining a Group 1 LSCI licence;
  • acting as liaison between LSCI reporting to the ASCIS and the CFIA and the CSGA;
  • providing technical support and advice to the LSCI reporting to the ASCIS as necessary;
  • supervising LSCI inspecting a crop kind for the first time;
  • assessing plant, disease, and weed samples taken by the LSCI reporting to the ASCIS and forwarding the samples to the local CFIA office for further assessment when necessary;
  • reviewing and approving all Reports of Seed Crop Inspection and verifying that the reports are in conformance with seed crop inspection and reporting standards prior to the Report's submission to the CSGA;
  • submitting the finalized Reports of Seed Crop Inspection to the CSGA within two business days of the seed crop inspection; and
  • providing LSCI refresher training as required.

4.4 Roles and Responsibilities of the Seed Crop Inspector

The seed crop inspector is responsible for describing the crop as it appears at the time of inspection in an accurate, unbiased, and comprehensive Report of Seed Crop Inspection. The completed Report of Seed Crop Inspection must be provided to the CSGA within two business days of the actual date of inspection.

The seed crop inspector may inspect only those crop kinds for which they have been licensed and are competent. LSCI must inform the CFIA before inspecting a new crop kind for the first time and must also inform the CFIA when inspecting plots for the first time in each crop kind using CSGA's SeedCert. In addition, LSCI are encouraged to request the assistance of an experienced LSCI or CFIA seed crop inspector when inspecting a new crop kind for the first time.

Seed crop inspectors must maintain the confidentiality and security of seed crop inspection information. This includes market information, volume and/or value of production, and variety parentage or production methods that are of a confidential nature. Seed crop inspectors must not discuss a grower's crop with any other party, and must ensure that neither Reports of Seed Crop Inspections nor their contents are accessible by other parties. Confidential personal or business information under the control of the seed crop inspector must not be disclosed except for the purposes for which it is intended and may only be shared with the CFIA, the CSGA and the grower or assignee.

The seed crop inspector must not, under any circumstance, anticipate the decision the CSGA may take concerning the crop, nor make any recommendation regarding the CSGA's decision on certification of the seed crop.

In addition to confidential grower information, seed crop inspectors are responsible for maintaining confidential breeder information included in the descriptions of the varieties (DoV). The DoVs are provided solely for the purposes of seed crop inspection and variety verification, and must not be distributed. Information included in variety descriptions may be considered confidential business information by the owner of the variety.

LSCI must:

  • be under the supervision of an ASCIS licensed by the CFIA;
  • comply with any conditions contained in their LSCI licence; and
  • operate within the Quality Management System (QMS) of the ASCIS to which they report.

All seed crop inspectors are responsible for:

  • protecting their personal safety by taking reasonable precautions against harm;
  • obtaining all required seed crop inspection tools;
  • advising their supervisor of any potential conflicts of interest;
  • providing any rough inspection notes to their supervisor or ASCIS for retention;
  • being able to identify all prohibited noxious weed species; and
  • being able to identify the common weed species in their geographic area.

The seed crop inspector should also maintain a professional decorum in their work, demonstrated by actions such as:

  • making contact by telephone in advance of arrival for crop inspection;
  • allowing the grower to accompany the seed crop inspector on the crop inspection, if requested;
  • closing any gates the seed crop inspector opens to enter or exit the field;
  • not smoking in the field;
  • wearing appropriate clothing;
  • avoiding damage to crops when driving between fields;
  • being prepared to show appropriate personal identification upon request; and
  • providing copies of completed Reports of Seed Crop Inspection to the grower on a timely basis.

4.5 The Seed Grower's or Applicant's Responsibilities

A grower who wishes to produce a pedigreed seed crop must have the standing crop inspected by seed crop inspector. To do so, the grower must submit an application for seed crop inspection to the CSGA by the established deadline date.

The seed grower must submit a field map into CSGA's SeedCert system. Maps are required for all fields and must include easily recognizable landmarks, adjacent crops and buildings, legal land descriptions, distance measurements and seeding dates. Distances are given in either metric or imperial measurement, indicating units. Individual plots or plots within fields of Foundation status seed crops require detailed maps. Maps are easily uploaded into CSGA SeedCert electronically.

Growers are responsible for ensuring their crops are inspected prior to swathing or harvesting; swathed or cut crops cannot be inspected except under instruction from the CSGA. Roguing activities must be completed and isolation zones established prior to inspection.

The grower may be asked to assist the seed crop inspector during the inspection.

5.0 Application for Seed Crop Inspection

On the application for seed crop inspection submitted to the CSGA, the grower must indicate the name of the ASCIS that will be responsible for the inspection.

If the grower had an inspection the previous year, the application information will be sent to the grower automatically by the CSGA. A first time or returning seed grower should request an application for seed crop inspection from the CSGA. The completed application form contains the information relevant to the inspection and verification of the seed crop's varietal purity. All accepted applicants become members of the CSGA.

Applications for assigned crops are made in the name of the grower of the crop, although the crop certificate can be assigned to a separate entity by completing CSGA Form 179 (Authorization to Assign a Crop Certificate). This contractual agreement is typically made when a grower is producing the crop under contract to a separate entity (the assignee).

Applications for crop inspection of Breeder status plots should be made under the name of the plant breeder or breeding institution, not in the name of the grower.

Fees for seed crop inspections conducted by an LSCI are charged directly to the seed grower by the ASCIS to which the LSCI reports. Seed crop inspections conducted by CFIA inspectors are charged to the CSGA.

The CSGA reviews the application and forwards the inspection assignment through CSGA's SeedCert to the appropriate ASCIS or CFIA office. The ASCIS or CFIA office acknowledges receipt of the application and assigns a seed crop inspector to conduct the inspection.

The ASCIS must provide notice to the CFIA, through CSGA SeedCert, of the inspection schedules of its LSCI prior to the inspection date. The ASCIS must provide notice to the CFIA through CSGA SeedCert of the planned date of inspections two (2) days prior to the inspection so that the CFIA may schedule and conduct check inspections in a timely manner. In addition, when an inspection is conducted, the LSCI must report this inspection by the end of the day on which the inspection is conducted.

New applications for seed crop inspection cannot be accepted by seed crop inspectors and must be submitted to and accepted by the CSGA before a pre-populated Report of Seed Crop Inspection will be generated for the inspection. In the rare instance where the seed crop inspector does not have a pre-populated report for a specific field they may, with ASCIS or CSGA approval, complete the inspection in rough notes. The information is transferred to the pre-populated Report when it becomes available.

6.0 Conducting the Seed Crop Inspection

Seed crop inspection involves:

  • identification of crops;
  • crop impurity counts;
  • checking isolation distances; and
  • verification whether pedigreed seed production procedures have been met.

These tasks are described in detail in SWI 142.1.1 Pedigreed Seed Crop Inspection.

The following inspections are required according to Circular 6:

  • seed crop inspection for certification as pedigreed seed;
  • land use inspections; and
  • re-inspections to verify border removal.

The following inspections are not described in Circular 6, but may be requested on occasion to meet a specific need. These inspections should be dealt with on an individual basis and include:

  • second inspections requested by the grower; and
  • any other crop inspection not previously described.

7.0 Report of Seed Crop Inspection

LSCI are required to submit the 'actual date of inspection', via CSGA SeedCert, of each inspection completed by the end of the day on which the inspection is conducted. This is in addition to completing the Report of Seed Crop inspection in SeedCert.

The Report of Seed Crop Inspection should be completed during or immediately after the inspection. The Report of Seed Crop Inspection provided electronically by the CSGA with the grower and field information pre-populated should be used when it is available.

Reports of Seed Crop Inspection completed by LSCI must be reviewed by the Lead Inspector of the ASCIS to which the LSCI reports prior to submission to the CSGA. The grower is provided a copy of the report by the ASCIS after it has been verified by the Lead Inspector. The ASCIS must maintain any originals or copies of rough notes taken by the seed crop inspector.

Completed and reviewed reports must be submitted to the CSGA within two business days after the inspection. Report submission should be given priority and cannot be delayed while the seed crop inspector gives priority to inspecting additional seed crops.

For seed crops which require more than one inspection during the growing season, the seed crop inspector should follow the crop specific instructions for reporting to CSGA.

The seed crop inspector may wish to communicate to the grower any observations made during the inspection that may cause the CSGA to decline the crop or that may require remedial action on the part of the grower in order to obtain a crop certificate from the CSGA.

Requests for completed Reports of Seed Crop Inspection from persons other than the applicant should be referred to the CSGA.

7.1 Documentation and Information Retention

The seed crop inspector must not destroy the original rough notes (digital or hard copy). Rough notes should be legible, accessible and in a format that can be used by the ASCIS, CFIA, or CSGA to verify and support the completion of the report. Although the development of rough notes is not mandatory, they can be a valuable reference in many situations. Rough notes must be retained by the ASCIS for a period of seven years.

8.0 Inspection of Varieties not Registered in Canada

Varieties that are not registered in Canada should not be inspected unless the seed crop inspector has a Description of Variety (DoV) for the variety. If the DoV is not readily available through the CSGA, it is the responsibility of the grower/applicant to make it available in one of Canada's two official languages.

If it is not at all possible to obtain the DoV, the seed crop inspector should advise the grower/applicant that the crop could be declined pedigreed status. The seed crop inspector may perform the inspection based on the uniformity of the crop, providing that it is noted on the Report of Seed Crop Inspection that no DoV was available.

9.0 Other Inspections

9.1 Complaint/Referee Inspections

If the classification or identification of off-type plants is challenged by the grower, the grower should request the re-inspection from the ASCIS. In the event that the ASCIS cannot provide a re-inspection, or if the grower is still not satisfied, the grower must forward a request through CSGA SeedCert to the CFIA for a complaint/referee inspection. Complaint/Referee inspections are not conducted if the crop has been altered following the first inspection or re-inspection by the ASCIS. This should be verified with the grower prior to the inspection. It is a 'best practice' for all persons involved to go to the field at the same time, with the CFIA inspector.

When a complaint/referee inspection is performed by a CFIA seed crop inspector, the seed grower may be charged an assessment by the CSGA.

Complaint/Referee inspections should be scheduled and performed as resources permit by a seed crop inspector other than the original inspector. The Report of Seed Crop Inspection for the re-inspection should be submitted to the CSGA immediately and a copy provided to the producer.

The CFIA Local Office should be informed of the request for a complaint/referee inspection and the outcome of the inspection must be communicated to the seed section and auditor.

9.2 OECD Field Inspection and Seed destined to the EU as Basic or Pre-Basic seed

Crops being certified pursuant to the OECD Seed Schemes are to be inspected according to Circular 6, QSP 142.1, SWI 142.1, and the crop specific SWIs.

CFIA official inspectors will provide direct inspection when the seed is destined for marketing in the EU as Basic or Pre-Basic seed.

9.3 Inspections for the Re-certification and Re-instatement of Crops

In very rare circumstances seed crop inspectors may receive requests for seed crop inspection from the CSGA for crops planted with Certified status seed. It is possible that the CSGA may consider the crop eligible for re-certification or re-instatement.

The frequency of re-certification requests vary by crop kind and by year with the majority being forage crops.

When the seed crop inspector receives a request for inspection of a crop planted with Certified status seed they should make every effort to contact the grower. The seed crop inspector should attempt to:

  • determine the grower's intentions for the harvested crop;
  • communicate that seed crops planted with Certified status seed are not normally eligible for further certification; and,
  • allow the grower the opportunity to cancel the inspection.

9.3.1 Re-certification of Crops

Recertification in Canada occurs under the two scenarios described below. In both cases, this recertification in Canada is subject to CSGA approval and policy. These inspections are considered lower priority and are subject to the availability of inspection resources.

  • According to the standards of the Association of Official Seed Certification Agencies (ASOCA), the number of generations through which seed may be multiplied may not exceed two generations beyond Foundation status except where an emergency is declared by the certifying agency stating that the supply of Foundation and Registered status seed is not adequate to plant the required Certified status acreage. In this case, the production of an additional generation of Certified status seed may be permitted for one additional year.
  • Re-certification may also be provided for seed exported under the OECD Seed Schemes which includes pedigreed classes of Certified, 2nd generation and Certified, 3rd Generation where Certified, 1st generation is the first generation from OECD Basic seed (equivalent to Canada Certified status seed), Certified, 2nd generation is the second generation from OECD Basic seed and so on.

If the tenth digit (3rd from last) of the crop certificate for the planted seed is a 4 for Certified status (e.g., 13-1234567-401), the crop is being inspected for re-certification. The seed crop inspector should verify that the CSGA has approved re-certification. If the tenth digit of the crop certificate is 8 (e.g., 13-9876543-801), this indicates that this Certified status seed has been produced using re-certified Certified status seed; the crop is therefore not eligible for re-certification.

Because re-certification decisions may not be made until after the crop is planted, it is possible that pedigreed seed tags may no longer be available. In this case, the purchase order or sales invoice may be used to verify the pedigreed status of the planted seed. Similarly, if the original planting intention for the crop was commodity production, previous land use and isolation may not meet CSGA standards.

The seed crop inspector may encounter communication challenges as decisions to have crops re-certified may not have been made until after planting has occurred, and growers may not be familiar with pedigreed seed crop production requirements. Re-certified crops are inspected according to standard procedures for pedigreed seed crop inspection.

9.3.2 Inspection of Crops Planted with Re-instated Seed

Re-instatement occurs when demoted seed already sown is re-instated to its original status or an intermediate status. For example, Foundation status seed demoted to Certified status could be sown as Certified status and inspected as a crop sown with Foundation or Registered status seed.

The seed crop inspector should contact the CSGA to clarify if re-instatement of the crop was granted. If the tenth digit of the crop certificate is an "R" (e.g., 14-1234567-R01), this indicates that the crop has been demoted to Registered status. If it is a "C" (e.g., 14-1234567-C01), this indicates that the crop has been demoted to Certified status. If there is a possibility of re-instatement of the status, the seed crop inspector must report the seed crop inspection in a manner that will allow CSGA to assess the crop at the highest possible pedigreed status.

9.4 Re-inspection to Verify Corrective Action

Should a grower's crop be declined pedigreed status for conditions such as inadequate isolation distances at the time of inspection, the grower may request a re-inspection to verify that actions to correct the conditions, i.e., the isolation distances, have been taken and are appropriate.

When the grower requires a re-inspection to verify the corrective action, the grower should contact the ASCIS to establish if and when a re-inspection will be provided. Re-inspection of a crop may be done only when directed by the CSGA or by the CFIA as part of a corrective action plan. When a seed crop inspector conducts a re-inspection of a crop, they must complete a new Report of Seed Crop Inspection that is classified as a 're-inspection'. This is to ensure that the condition of the crop at the time of re-inspection is clearly communicated to the CSGA and the grower.

For those crop kinds listed in Sections 2, 3 or 12 of Circular 6, verification of isolation corrective actions require the seed crop inspector to return to the field after harvest and observe that the required isolation distance was not harvested from the field and remained standing. These re-inspections are conducted as permitted by resources and weather. Where resources are not available, it is the responsibility of the ASCIS to contact the CSGA to communicate the need for alternative arrangements.

10.0 Emerging Trends

Where repeated problems are noted with a specific variety, the seed crop inspector should communicate these to their supervisor or Lead Inspector. The Lead Inspector must communicate validated concerns to their local CFIA contact in a timely manner. When required, the CFIA will request that the ASCIS Lead Inspector completes the "Possible Error with Variety Description Form" in SeedCert. The CFIA's Seed Section, the CSGA and the plant breeder are informed.

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