D-07-02: Canadian Debarking and Grub Hole Control Program (CDGHCP) for the Export of Cedar Forest Products to the European Union
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Effective Date: November 18, 2010
This directive summarizes the phytosanitary certification requirements of untreated cedar products being exported to the European Union including: lumber, logs, pre-fabricated buildings, and log houses made with cedar wood (Thuja spp.).
Appendix 2, Certificate of Debarking and Grub Hole Control has been revised to ensure that the text of the Appendix is consistent with European import requirements. The Appendix has also been removed from the policy directive and has been placed as a sample on the Canadian Debarking and Grub Hole Control Program (CDGHCP) for the export of Cedar Forest Products to the European Union webpage. An interactive form should be obtained through a verification body.
Table of Contents
- Amendment Record
- Definitions, Abbreviations and Acronyms
- 1.0 General Requirements
- 2.0 Specific Requirements
- 3.0 Product Requirements
- 4.0 Recognition of Service Providers
- 5.0 Responsibilities of the CLSAB and its accredited agencies
- 6.0 Responsibilities of the CFIA
- 7.0 Non-compliances
- 8.0 Appendices
This directive will be reviewed every 2 years unless otherwise needed. For further information or clarification, please contact the Canadian Food Inspection Agency (CFIA).
Chief Plant Health Officer
Amendments to this directive will be dated and distributed as outlined in the distribution below.
- Directive mail list (Regions, PHRA, USDA)
- Provincial Government, Industry (via Regions)
- National Industry Organizations (determined by Author)
- Facilities registered to issue the Certificate Of Debarking And Grub Hole Control
The European Community has established prohibitions for the entry of certain forest products from Canada. These are prescribed in Council Directive 2000/29/EEC. Derogations to permit the entry of certain regulated items, includes a provision to permit the entry of cedar forest products which is prescribed in Council Directive 77/93/EEC. The derogation has been established based on Canada's ability to ensure that cedar exports do not contain bark and holes caused by native Cerambycid beetles in the genus Monochamus. As such, the CFIA in the early 1990s established a certification program to oversee the production of cedar compliant with European Union requirements. The requirements were set out in policy directives T-93-10 and later in D-99-05.
Since the establishment of the program in the 1990s the CFIA has revised a number of certification programs to better reflect certification standards and to provide clarity to registered participants and to those conducting audits of the participants within the program.
This policy directive now summarizes the requirements which were contained within these two previous policy directives.
The information in this directive is intended for use by inspectors and program officers of the CFIA, the Canadian Lumber Standards Accreditation Board (CLSAB), Service Providers, and companies or facilities that export untreated cedar products to the European Union (EU).
- ISPM No. 5, Glossary of Phytosanitary Terms, 2007, FAO, Rome (updated annually)
- ISO Guide 8402, Quality Systems Terminology
- ISPM No. 7, Export certification system, 1997, FAO, Rome
- Canadian Lumber Standards Accreditation Board Regulations (January 1, 2005)
- T-93-10, Certification of Debarking and Grubhole Control for the Export of Unseasoned Debarked, Grubhole-Free Softwood Lumber
This policy directive replaces the requirements contained in Policy T-93-10, Certification of Debarking and Grub hole Control for the Export of Unseasoned Debarked, Grub hole-Free Softwood Lumber and supersedes policy directive D-99-05, Phytosanitary Certification Requirements For Pre-Fabricated Buildings And Log Houses Made Of Coniferous Wood To The European Union Countries. It also supersedes T-91-2-UK Use of EEC Derogation for Green Coniferous Lumber.
Definitions, Abbreviations and Acronyms
Definitions for terms used in the present document can be found in the Plant Health Glossary of Terms.
1.0 General Requirements
1.1 Legislative Authority
Plant Protection Act, S.C. 1990, c. 22
Plant Protection Regulations, SOR/95-212
Canadian Food Inspection Agency Fees Notice, Canada Gazette: Part I (as amended from time to time)
Council Directive of the European Communities No. 77/93/EEC
Council Directive of the European Communities No. 2000/29/EEC
SANCO Directive 1460 Rev. 17
The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice, as amended from time to time, for inspection and audit activities carried out under this program. The current fee payable is $300.00 per facility on an annual basis, payable on July 1st of each calendar year. Facilities currently registered under the CHTWPCP are not required to pay this additional fee. Exporters requiring more information on fee schedules may contact any CFIA Regional offices or visit our Fees Notice Web Site.
CFIA recognized Service Providers may also charge fees for service provided under this program. Facilities are encouraged to communicate with the Service Providers for information on these service fees.
1.3 Regulated Commodities
Cedar (Thuja spp.) forest products including lumber, logs, pre-fabricated homes, and log homes exported to EU countries listed in Appendix 1 are regulated.
Note: This directive applies to Thuja spp. only. The EU also regulates the importation of all other conifer wood products originating from Canada which includes lumber, logs, pre-fabricated homes and log-homes produced from conifer species. For these products, the requirements as specified under policy directive D-03-02, the Canadian Heat Treated Wood Products Certification Program must be met.
1.4 Commodities Exempt
- Manufactured wood
- Wood of 6 mm or less in thickness is exempt
1.5 Regulated Pests
Monochamus sp. and bark beetles not native to Europe.
2.0 Specific Requirements
2.1 Export Certification
All shipments of cedar products must be free of bark and holes produced by Monochamus beetles.
Shipments must be accompanied by:
- A Certificate of Debarking and Grub Hole Control as prescribed in Appendix 2 issued by a registered participant in the CDGHCP; or
- Heat Treatment Certificate in accordance with registration under policy directive D-03-02 as maintained on the CFIA web; or
- A Phytosanitary Certificate issued by the CFIA
Note: Ireland and Sweden require that shipments of prefabricated buildings or log houses be accompanied by a Phytosanitary Certificate only. These countries do not accept industry issued certificates.
2.1.1 Certificate of Debarking and Grub Hole Control
Only facilities registered under the Canadian Debarking and Grub Hole Control Program (CDGHCP) can issue these certificates provided the shipment only contains cedar (Thuja sp.). A registered facility may issue a Certificate of Debarking and Grub Hole Control.
Certificates may only be issued by an employee(s) of the facility who has been trained in this phytosanitary standard and who is familiar with the conditions for the storage, marking and identification of compliant cedar products. This employee (e.g. position title) should be specifically identified in the facility Quality Management System Manual.
The certificate must contain the following declarations:
"This document has been issued under the program officially approved by the Canadian Food Inspection Agency, and the products covered by this document are subject to occasional pre-shipment inspection by that agency, without financial liability to it or its officers".
"This lumber has been examined by a mill inspector, shipper, or other authorized person and found to have been stripped of its bark and to be free of grub holes to conform to the best of their knowledge and belief, with the import requirements of the receiving country".
Only one certificate per shipment is required.
Copies of certificates issued should be maintained in a specific location identified in the Quality Manual for a period of no less than two years.
2.1.2 Heat Treatment Certificates
A Heat Treatment Certificate may be issued if the cedar products were heat treated in a facility registered under the CHTWPCP. Treated bundles must be marked to facilitate their identification for relating to the certificates.
2.1.3 Phytosanitary Certificates
A Phytosanitary Certificate is an official document issued by the Plant Protection Organization of the exporting country to the Plant Protection Organization of the importing country. It certifies that the plants or plant products covered by the certificate have been inspected according to appropriate official procedures and are considered to be free from quarantine pests and that they are considered to conform to the current phytosanitary regulations of the importing country.
A Phytosanitary Certificate may be issued for shipments of cedar products, if the exporter or broker presents a valid Debarking and Grub Hole Control Program Certificate or upon inspection of the wood a CFIA Inspector determines that the wood complies with the conditions prescribed in Section 3.0 and is therefore free of bark and grub holes.
Where a shipment contains regulated species of wood (e.g. other conifers) including cedar, the exporter may request a Phytosanitary Certificate be issued for the entire consignment. A Phytosanitary Certificate can only be issued if the cedar products comply with the conditions of the CDGHCP and any other conifers must comply with the requirements specified in policy directive D-03-02.
However, a shipment of mixed conifer products (several conifer species) may also be exported using both Heat Treatment Certificates to verify that the non-cedar components of the shipment comply with requirements for heat treatment and Certificates of Debarking and Grub Hole Control to verify that the cedar components comply with the requirements of the CDGHCP.
2.2 Facility Registration
A facility intending to export cedar products to the countries listed in appendix 1 must be registered under the Canadian Debarking and Grub Hole Control Program (CDGHCP).
Registration requires that:
- the facility completes an Application for Registration (as contained in Appendix 4);
- the facility has developed a Quality Management System Manual outlining the facility's quality management system for complying with the standards prescribed in the CDGHCP;
- the completed Application and Quality Management System Manual has been provided to a Service Provider for review and that review and any required audits have confirmed that the application is complete and that the facility can comply with the requirements of the program.
Note: Facilities which are currently registered in the CHTWPCP and which are currently authorized to issue a Certificate of Debarking and Grub Hole Control does not need to register under the CDGHCP. These facilities must however comply with the requirements contained in this policy directive.
2.2.1 Applicants Eligible to participate as a Registered Facility
Eligible applicants include those Canadian facilities handling or producing cedar products ultimately destined for export to countries specified in Appendix 1. These include: sawmills, pre-fabricated building and log home producers, planer mills, re-manufacturing facilities, brokers, shippers, and facilities consolidating cedar products for export purposes.
The facility seeking registration must be located in Canada and, the applicant must be:
- a Canadian citizen or permanent resident; or
- a person authorized under the laws of Canada to reside in Canada for a period of six months or more and who will have possession, care or control of the thing to be treated or manufactured, distributed; or
- in the case of a corporation with a place of business outside of Canada, the applicant must be an agent or officer of the corporation who resides in Canada
The facility must also submit a Quality Management System Manual to a Service Provider clearly setting out the required elements as outlined in section 2.2.2.
Note: facilities currently registered under the requirements specified in policy T-93-10 may continue to operate as a registered participant until an agreement regarding a transfer date has been established in consultation with the CLSAB and member agencies. Once a date of transfer has been established it will be communicated to all registered facilities in writing and will require that facilities complete an application and a Quality Management System Manual within 6 months of the date of transfer.
2.2.2 Quality System
The facility must operate a Quality Management System that complies with the standards prescribed for the production, storage, documentation, and certification of cedar products in accordance with the import requirements of the European Union. As such, the facility must produce a Quality Management System Manual that outlines the facility's processes involved in meeting the phytosanitary requirements.
The Quality Management System Manual shall include:
- function and responsibilities of staff members involved in maintaining phytosanitary requirements;
- training procedures of staff in performing the duties related to the phytosanitary requirements;
- procedures for addressing non-conforming products;
- procedures used to amend the Quality Management System Manual must be identified;
- procedures for the identification or segregation of export wood and wood for domestic sales, and of compliant and non-compliant wood while it remains in the facility;
- procedures for maintaining documentation related to exported products (e.g. copies of certificates, volumes of exports, etc.);
- procedures for consolidation of wood products.
3.0 Product Requirements
All cedar products including any attached spacers (stickers) and/or attached dunnage, intended for export to the countries listed in Appendix 1 must be substantially free of bark and grub holes or tunnelling produced by Monochamus larvae (grub). Stickers or spacers made of other coniferous species are regulated to the countries listed in Appendix 1. These stickers should conform to the requirements specified in policy directive D-03-02 Canadian Heat Treated Wood Products Certification Program (CHTWPCP).
Freedom of bark includes ensuring that the wood does not contain any more than a single piece of bark less than the size of a credit card. Wane on the edges of the wood, ingrown bark, including those around knots; and bark pockets as described in and permitted by the National Grading Rules are permitted to be included in shipments to the EU.
Grub holes are insect bore holes and tunnelling present in the wood which may have been made by Monochamus (sawyer) beetles. The holes are generally oval or circular in cross section, are usually larger than 1/16 inch (1.5 mm) in diameter and average about ¼ inch (6.0 mm) or slightly more depending on the angle in cross section. They may occur as short channels in the wood.
Grub holes do not include: pin holes caused by Ambrosia beetles; Toredo holes made by marine boring molluscs; honeycombing made by carpenter ants or other defects not caused by wood boring insects.
4.0 Recognition of Service Providers
The grading of lumber requires that lumber grading agencies accredited by the CLSAB, perform activities in the auditing of facilities to comply with National Grading Rules. Although these rules are not specifically in relation to plant health concerns, they are comparable standards requiring that facilities consistently produce lumber meeting a performance based standard, which is very similar to the CDGHCP. Consequently, the CFIA has selected that the CLSAB and its accredited member grading agencies as the Service Provider for the CDGHCP. Each accredited agency must have a specific arrangement with registered facilities to permit the delivery of activities, audits as required to fulfill its role under this policy directive.
5.0 Responsibilities of the CLSAB and its accredited agencies
CLSAB accredited agencies shall:
- conduct minimum audits of facilities registered in the CDGHCP as prescribed in the CLSAB Regulations - Section 3.5.16 to determine their compliance with the requirements of this program. A specific audit guideline is provided in Appendix 3;
- review the facility's Quality Management System Manual to verify compliance with the standards set in the CDGHCP.
The CLSAB shall:
- maintain signed agreements with accredited agencies and a registry of all facilities who are participating in the CDGHCP;
- conduct a minimum of one annual audit of each accredited agency as specified in the CLSAB Regulations to verify compliance to the CDGHCP.
6.0 Responsibilities of the CFIA
Upon verification that a facility is capable of successfully meeting the requirements of this directive, the CFIA shall:
- issue a registration number to those facilities meeting the requirements under the CDGHCP. This registration number consists of facility identification numbers submitted by Service Providers;
- add the facility's name to the official CFIA list of registered facilities under the program;
- conduct random annual audits of registered facilities (a maximum of 20%) to determine if oversight being provided by the Service Provider is sufficient to ensure the integrity of the program using the Audit Checklist in Appendix 3;
- conduct audits of the Service Provider as outlined in the document CFIA Audit Guidelines for the CHTWPCP and the CWPCP, (QSM 06).
Export shipments of regulated wood products must meet the requirements of the importing country. The interception of non-compliant wood products by a foreign government may result in enforcement action by the foreign government. Non-compliant material will likely lead to delays in product delivery, treatment or disposal of non-compliant wood product including related costs.
Failure to meet the phytosanitary import requirements of a foreign importing country is also a violation of Canadian law, specifically, the Plant Protection Regulations, and may lead to enforcement actions by the CFIA and suspension from this program.
Appendix 1: List of EU Member Countries
- Czech Republic
- United Kingdom
Note: Countries listed with an (*) require shipments to be accompanied by a Phytosanitary Certificate. Industry-issued certificates are not accepted.
Appendix 2: Certificate of Debarking and Grub Hole Control
Appendix 3 : CFIA Audit Checklist of Facilities Registered in the CDGHCP
The following audit checklist is a guideline for CFIA inspection staff to verify compliance with this program. Facilities may use this checklist as an aid in the development of a facility Quality Management System Manual.
Registered Facility No.:
Audit Report No.:
Date of audit:
|Verification of the Quality Manual||Yes||No|
|1. Has the facility completed the application form?|
|2. Does the Quality Management System Manual contain criteria for debarking of cedar?|
|3. Does the Quality Management System Manual contain criteria for verifying that wood intended for export is free of grub holes?|
|4. Does the Quality Management System Manual contain specifications as to how employees conducting verification of lumber in compliance with the phytosanitary standard are trained?|
|5a. Does the manual identify procedures for segregating cedar intended for export from other cedar products?|
|5b. If segregation is not required, are one of the following specified?
|6. Are copies of certificates issued by the facility maintained for 2 years?|
|7. Has the facility specified where copies of certificates are to be maintained?|
|8. Has the person responsible for the issuance of certificates been identified?|
|Ongoing Verification of Compliance||Yes||No|
|1. Do facility employees have access to the facility Quality Management System Manual?|
|2. Do employees understand the activities to be performed under the CDGHCP (e.g. do graders understand the grading differences in export vs. non-export cedar products)?|
|3. Are segregation requirements (if required) being observed?|
|4. Do cedar products in the facility intended for export comply with the standards for debarking (substantially free of bark) and free of grub holes?|
|5. Are certificates maintained as prescribed in the Quality Management System Manual?|
|6. Are certificates completed accurately?|
|7. Do the authorities responsible for signing certificates prescribed in the facility Quality Management System Manual match those actually signing certificates?|
|8. Other observations:|
|1. Facility to notify CFIA and Service Provider of corrective action taken by the following date|
|2. Service Provider to verify corrective actions taken by the following date|
Reasons for Cancellation or Suspension:
Original to: Facility
Copy: Service Provider
Copy: Network Specialist
Appendix 4: Application for Registration in Canadian Debarking and Grub Hole Control Program (CDGHCP) – CFIA/ACIA 5578
Application for Registration under the Canadian Debarking and Grub Hole Control Program
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