Clean Plants Standard, Section 3.5

Clean Plants Internal Auditor
Basic Training
Internal Audit Procedures
1
Introduction to Auditing
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Please read the article titled, ‘Clean Plants Internal
Auditor Basic Training: General Overview’ before you
view this slide presentation.
The slides follow the order of the Clean Plants Manual
Slides alternate between the requirements stated in the
Clean Plants Standard and what you need to audit to
meet the standard
The Clean Plants Standard Sections are in the order
used for the Clean Plants Manual
Follow through your Manual as you view these slides
2
Clean Plants Manual Chapter &
Section
Clean Plants Standard, Section #
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The slides with yellow titles outline requirements of
the Clean Plants Certification Standard
The Manual Chapter is referenced at the top of the
slide
Review the methods used by your nursery to meet
the requirements of the Clean Plants Standard as
you move through this slide set
3
What you need to do as internal
auditor √
Audit Focus √
Slides with blue titles and a ‘√’ will explain what you need to do to ensure that the Clean Plants
requirements are met at your nursery
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Read each section in the Nursery Manual as you work
through the audit
Use Appendix 7c as your audit check list or create your own
check list
Investigate that the methods stated in the Manual are being
followed regularly
Note any discrepancies between stated Manual methods and
practice as non-compliances
Report the non-compliances to the Certification Manager for
correction
4
A: General Description of Nursery
Clean Plants Standard, Section 1.0
 Nursery name, address and contact information
 Addresses of other production locations
 Number of employees and key positions
 Type of production and plants grown
5
A: General Description of Nursery
Audit Focus √
 Review nursery description information and
verify that it is correct
 Review employee list and verify that it is up-todate
 Ensure that there is a current nursery catalogue
or inventory list attached to the nursery Manual
6
A: General Description of Nursery
Maps
Clean Plants Standard, Section 3.1
 Current maps of all production areas must be
included in the Manual
 All production locations included under the
same Certification ID number must have a map
7
A: General Description of Nursery
Maps
Audit Focus, Section 3.1 √
 Ensure there is a map for each production
location listed under your nursery Certification
ID number. Maps should be placed in the
Manual Appendix
 Ensure that the locations on each map are upto-date and that isolations areas, if used, are
clearly shown
8
A: General Description of Nursery
Plant Suppliers
Clean Plants Standard, Section 3.2.1
 A list of plant suppliers, including the name,
location and business address must be
maintained
 The type of plants purchased from each supplier
can also be listed (optional)
9
A: General Description of Nursery
Plant Suppliers
Audit Focus, Section 3.2.1 √
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Review the list of plant suppliers in the Manual
Appendix and insure that it is up-to-date
Note that the ‘list’ may be
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A file of supplier invoices if your nursery buys in
very little stock, or
A detailed list updated regularly if your nursery buys
from a large number of plant suppliers
10
B: Management Responsibilities
Clean Plants Standard, Section 2.0, 2.1
 Statement of management commitment
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2.1.1 Certification Manager
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Assign responsibilities and designate alternate
2.1.2 Crop Protection Manager
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Assign responsibilities and designate alternate
11
B: Management Responsibilities
Audit Focus, Section 2.0, 2.1 √
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Review the ‘Statement of Management Commitment’ and check
that the names listed are up-to-date
Ensure that the Certification Manager and the Crop Protection
Manager have been assigned, are listed in the Manual Workbook,
and are aware of the responsibilities listed
Employees that are Authorized Clean Plants Stamp Appliers and
Pest Scout Inspectors must be listed
Ensure that there are alternates for each position listed in the
Manual
12
B: Management Responsibilities
Nursery Staff Training
Clean Plants Standard, Section 2.2
 All staff that are responsible for specific areas
of the Clean Plants program must be trained
 Training (on-site or formal) must be
documented
13
B: Management Responsibilities
Nursery Staff Training
Audit Focus, Section 2.2 √
 Review Manual ‘Training’ Appendix and ensure that it
is up-to-date and includes all work related training that
supports the nursery (a file can be used rather than an
appended list, just state the location of the file in the Manual)
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Question staff in key positions (e.g. shipper, production
manager) to verify that they are implementing the area
of the Clean Plants for which they are responsible
14
C: Plant Identity and Certification
Status
Clean Plants Standard, Section 3.2.2
 The certification status of each group (Certified
and non-certified) of plants grown on the
nursery must be clearly shown (visually or within
the inventory system)
 The last growing location of each group of
plants must be recorded (required on shipping
documentation)
15
C: Plant Identity and Certification
Status
Audit Focus, Section 3.2.2 √
 The Certified and non-certified production areas must be clearly
identified (separated in different blocks or defined areas within
the nursery)
 The Certification status and last production location of each
group of plants must be visually clear or recorded in the
inventory database (or both)
Note that ‘non-certified’ refers to a ‘cannot ship as Certified’ status for these
plants until the defined time limit (120 days for outdoor stock and 28 days for
protected crops) has expired. After this time period, the plants are
automatically considered ‘Certified’ as long as they are free of regulated pests
and practically free of all other pests.
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C: Plant Identity and Certification Status
Inadequate Identification
Clean Plants Standard, Section 3.2.4
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When the certification status of a group of
plants is not clear at shipping, the plants must be
documented as ‘non-certified’
Reasons for confusion over certification status:
Not sure where plants were grown on the nursery
 Not sure how long the plants have been growing on the
nursery
Infested plants (more than practically free of pests) cannot
be shipped regardless of their certification status.
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17
C: Plant Identity and Certification Status
Inadequate Identification
Audit Focus, Section 3.2.4 √
 A designated employee must be responsible for
deciding on the certification status of a group
of plants (when in question)
 Check shipping invoices to ensure that plants
material was shipped as non-certified when the
certification status was uncertain
18
C: Plant Identity and Certification Status
Time Period Required for DCPC
Certification
Clean Plants Standard, Section 3.4
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Certified and non-certified plants must be clearly
labeled
Outdoor non-certified plants must be grown for
one season (120 days) to become Certified
Greenhouse-grown non-certified plants must be
grown for one growing cycle (28 days) to
become Certified
19
C: Plant Identity and Certification Status
Time Period Required for DCPC
Certification
Audit Focus, Section 3.4 √
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Ensure that Certified and non-certified plants
are clearly labeled (blocks or designated area)
Use the receiving shipping documentation to
follow a number* of non-certified shipments
through the nursery to ensure that the plants are
spending the appropriate period of time in the
non-certified production area
(* relate the number of examinations to the number of shipments
received at your nursery)
20
C: Plant Identity and Certification Status
Records and Documents
Clean Plants Standard, Section 3.7
 The records that track plant identity must be
stored for 7 years
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Propagation
Receiving/Shipping
Inventory
Other records must be stored for 3 years
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C: Plant Identity and Certification Status
Records and Documents
Audit Focus, Section 3.7 √
 Check that the office procedures are adequate to
store documents for the required period of time
as noted on the previous slide
22
D: Receiving Plants Inspection
Clean Plants Standard, Section 3.3
 Each incoming shipment of plants must be
inspected for regulated pests (free of) and other
pests (practically free of)
 Plants must be placed in either the Certified
production area or the non-certified production
area depending on the Certification status of the
supplier
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D: Receiving Plants Inspection
Audit Focus, Section 3.3 √
 Examine the incoming shipping documentation
for inspection details
 Ensure that Certified and non-certified plants
are placed in the appropriate production areas
 Follow a non-certified shipment of plants from
receiving to the non-certification production
area
24
E. Shipping Inspection
Clean Plants Standard, Section 3.5
 All shipments of plants leaving the nursery must be
inspected for regulated and non-regulated pests
regardless of certification status
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Free of Regulated pests
Practically free of non-regulated pests
Results of the inspection must be recorded
Plants that are infested beyond the ‘practically free’ definition must not be
shipped.
25
E. Shipping Inspection
Audit Focus, Section 3.5 √
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Review shipping documentation for inspections results
Include Certified and non-certified plant shipments
If pests were detected at levels above ‘practically free
of ’, follow the documentation to ensure that this was
reported and these plants were not shipped
26
E. Shipping Inspection
Special Requirements for CFIA
Domestic Regulated Areas
Clean Plants Standard, Section 3.5.1.1
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A nursery that is located within a regulated area
must comply with the requirements of the
associated CFIA Directives
The Manual must list the regulated pests in the
area where the nursery is located and the steps
that are required to permit shipment of the host
plants out of the regulated area
27
E. Shipping Inspection
Special Requirements for CFIA
Domestic Regulated Areas
Audit Focus, Section 3.5.1.1 √
 Ensure that there is an up-to-date list of
regulated pests and plant hosts for your nursery
location(s) and the corresponding CFIA
directives are easily accessible
 Review shipping documentation to verify that
plant hosts were shipped with the appropriate
Domestic Movement Certificate, if required
28
E. Shipping Inspection
Special Requirements for Other
Pest-Specific Modules
Clean Plants Standard, Section 3.5.1.2
 List the Clean Plants Pest Specific Modules in
which your nursery is qualified
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E. Shipping Inspection
Special Requirements for Other
Pest-Specific Modules
Audit Focus, Section 3.5.1.2 √
 Ensure that there is an up-to-date list of Clean
Plants Pest Specific Modules appended to your
Manual (only those that apply to your nursery)
 Ensure that the supporting documentation
verifying proper implementation of these
programs is attached
30
E. Shipping Inspection
Sale of Plants with Minor Pest
Infestations
Clean Plants Standard, Section 3.5.3
 Plant which have a higher number of non-regulated
pests than considered ‘practically free’ cannot be sold
as non-certified
 Only plants, in which the certification status of the
plant material is uncertain (unknown origin, growing
location, not sure how long the plants have been at the
nursery) can be shipped as non-certified
31
E. Shipping Inspection
Sale of Plants with Minor Pest
Infestations
Audit Focus, Section 3.5.3 √
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Check shipping documentation inspections
to ensure that whenever the number of
pests found is higher than ‘practically free’,
the plants are not shipped
32
F. Shipping Plants to CNCP Nurseries
Plant Identity for CNCP Customers
Clean Plants Standard, Section 3.2.3
 Groups of plants produced for CNCP
customers must be clearly identified
 Special growing requirements requested by the
CNCP customer must be followed (See Section
3.5.2)
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F. Shipping Plants to CNCP Nurseries
Plant Identity for CNCP Customers
Audit Focus, Section 3.2.3 √
 Review orders that are from CNCP nurseries to
ensure that growing directions were recorded
 Check that groups of plants reserved for CNCP
customers are clearly identified
34
F. Shipping Plants to CNCP Customers
Special Requirements for CNCP
Customers
Clean Plants Standard, Section 3.5.2
 The Manual must list the steps taken to ensure
that plants sold to CNCP customers are ‘export
ready’
 Source of the plant material, and specific pest
concerns must be documented
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F. Shipping Plants to CNCP Nurseries
Special Requirements for CNCP
Customers
Audit Focus, Section 3.5.2 √
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Review shipping documentation for CNCP
customers to ensure that it contains information
that verifies an ‘export ready’ status
Information may include:
 Monitoring records for specific pests
 Source of the plant material (supplier/in house)
 Date of purchase/ propagation dates
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G: Clean Plants Stamp
Clean Plants Standard, Section 3.6
 The Clean Plants Stamp must be stored securely
 Each use of the stamp on shipping
documentation must be documented
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G: Clean Plants Stamp
Audit Focus, Section 3.6 √
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Check that the Clean Plants Stamp is securely stored
Examine a selection of shipping documents to ensure
the stamp is being used consistently and there is a
record of each use of the Stamp
Examine shipping documentation for completeness of
information: shipping destination, genera and species
of plants, volume, Certification status
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H. Pest Management in Production
Regulated Pests
Clean Plants Standard, Section 5.1
 Your nursery must follow the requirements of
CFIA Directives that apply to the area where the
nursery is located
 Your nursery must follow the requirements of
the Clean Plants Pest Modules listed in your
Manual
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H. Pest Management in Production
Regulated Pests
Audit Focus, Section 5.1 √
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Ensure that the Directives that apply to your nursery
are up-to-date versions
Ensure that the Clean Plants Pest Specific Modules
listed in the Manual Workbook are up-to-date
Ensure that the requirements listed in the Directives
or/and Modules are being followed consistently
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H. Pest Management in Production
Pest Detections and Control
Clean Plants Standard, Section 5.2
 There must be documented pest control
strategies for commonly found pests at your
nursery
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Monitoring program
Government published pest control information
In-house methods of pest control
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H. Pest Management in Production
Pest Detections and Control
Audit Focus, Section 5.2 √
 Ensure that the Pest Management Plan is up-todate and complete
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Ensure that the monitoring records match the
frequency outlined in the Manual
Match pest finds from monitoring records to pest
control strategies in the Pest Management Plan to
ensure that pests are being controlled
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H. Pest Management in Production
Biosecurity
Clean Plants Standard, Section 5.3
 The biosecurity measures that are outlined either
in applicable CFIA directives or in attached
Clean Plants pest specific modules must be
followed
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H. Pest Management in Production
Biosecurity
Audit Focus, Section 5.3 √
 Review the biosecurity measures outlined in the
Manual and verify that they are being routinely
implemented at the nursery
44
Pest
Management Plan Records
H. Pest Management in Production
Clean Plants Standard, Section 5.4
 There must be complete pest management
records which record:
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Data
Pest name, numbers
Host plant(s)
Control actions
Other
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Pest
Management Plan Records
H. Pest Management in Production
Audit Focus, Section 5.4 √
 Review a selection of the monitoring records to
ensure that the information recorded is
complete
 Match pest finds with control actions unless
noted in the records (also in Sec 5.2)
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I: Detection of Regulatory Pests
Clean Plants Standard, Section 3.8
 CFIA and CNCI must be notified within 24
hours if a suspected regulated pest that is from
outside the known regulated area is detected on
your nursery
47
I: Detection of Regulatory Pests
Audit Focus, Section 3.8 √
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Verify that there is access to a current list of regulated
pests (CFIA website)
Ensure that there is a designated employee that is
responsible for contacting CFIA and CNCI if a
regulated pest find (outside its normal regulated area) is
made
The Certification Manager has the ultimate
responsibility for contacting CFIA
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J: Internal Audits
Clean Plants Standard, Section 4.1
 There must be two internal audits conducted per
year by the internal auditor
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growing season audit
shipping season audit
Non-compliances and corrective actions must
be communicated to the Certification Manager
49
J: Internal Audits
Audit Focus, Section 4.1 √
 Confirm that two internal audits have been (are
being) completed at the appropriate time of the
year (checklists completed)
 Ensure that the corrective actions have been
communicated to the Certification Manager
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L: Clean Plants Manual Workbook Updates
Up-dates and Changes to the Clean
Plants Manual Workbook
Clean Plants Standard, Section 6.0
 Substantive revisions to the Manual must be sent
to CNCI
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Major changes in procedures
Changes in the application information
Minor changes can be recorded in the Manual
and an updated version produced for the next
external audit
51
L: Clean Plants Manual Workbook Updates
Up-dates and Changes to the Clean
Plants Manual Workbook
Audit Focus, Section 6.0 √
 Review the Manual Workbook and check that
minor revisions are being recorded (last page of
Clean Plants Manual)
 Ensure that the new version prepared for an
external audit includes these changes
52
List of Manual Appendices
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Ensure that the list of Manual Appendices is upto-date and complete
53
Acknowledgments
Funding was provided by Agriculture and Agri-Food Canada
through their Advancing Agriculture and Agri-Food Program
Agriculture and Agri-Food Canada (AAFC) is pleased to participate
in this project. AAFC is committed to working with industry
partners to increase public awareness of the importance of the
agriculture and agri-food industry to Canada. Opinions expressed
in this document are those of Canadian Nursery Certification
Institute (CNCI) and not necessarily those of AAFC.
54