Clean Plants Internal Auditor Basic Training Internal Audit Procedures

Introduction to Auditing 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

Clean Plants Manual Chapter & Section Clean Plants Standard, Section # 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

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 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

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

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-to-date Ensure that there is a current nursery catalogue or inventory list attached to the nursery Manual

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

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 up-to-date and that isolations areas, if used, are clearly shown

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)

A: General Description of Nursery Plant Suppliers Audit Focus, Section 3.2.1 √ Review the list of plant suppliers in the Manual Appendix and insure that it is up-to-date Note that the ‘list’ may be 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

B: Management Responsibilities Clean Plants Standard, Section 2.0, 2.1 Statement of management commitment 2.1.1 Certification Manager Assign responsibilities and designate alternate 2.1.2 Crop Protection Manager

B: Management Responsibilities Audit Focus, Section 2.0, 2.1 √ 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

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

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) 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

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)

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.

C: Plant Identity and Certification Status Inadequate Identification Clean Plants Standard, Section 3.2.4 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.

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

Certified and non-certified plants must be clearly labeled C: Plant Identity and Certification Status Time Period Required for DCPC Certification Clean Plants Standard, Section 3.4 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

C: Plant Identity and Certification Status Time Period Required for DCPC Certification Audit Focus, Section 3.4 √ 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)

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 Propagation Receiving/Shipping Inventory Other records must be stored for 3 years

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

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

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

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 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.

E. Shipping Inspection Audit Focus, Section 3.5 √ 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

E. Shipping Inspection Special Requirements for CFIA Domestic Regulated Areas Clean Plants Standard, Section 3.5.1.1 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

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

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

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

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

E. Shipping Inspection Sale of Plants with Minor Pest Infestations Audit Focus, Section 3.5.3 √ Check shipping documentation inspections to ensure that whenever the number of pests found is higher than ‘practically free’, the plants are not shipped

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)

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

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

F. Shipping Plants to CNCP Nurseries Special Requirements for CNCP Customers Audit Focus, Section 3.5.2 √ 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

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

G: Clean Plants Stamp Audit Focus, Section 3.6 √ 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

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

H. Pest Management in Production Regulated Pests Audit Focus, Section 5.1 √ 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

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 Monitoring program Government published pest control information In-house methods of pest control

H. Pest Management in Production Pest Detections and Control Audit Focus, Section 5.2 √ Ensure that the Pest Management Plan is up-to-date and complete 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

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

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

H. Pest Management in Production Pest Management Plan Records Clean Plants Standard, Section 5.4 There must be complete pest management records which record: Data Pest name, numbers Host plant(s) Control actions Other

H. Pest Management in Production Pest Management Plan Records 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)

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

I: Detection of Regulatory Pests Audit Focus, Section 3.8 √ 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

J: Internal Audits Clean Plants Standard, Section 4.1 There must be two internal audits conducted per year by the internal auditor growing season audit shipping season audit Non-compliances and corrective actions must be communicated to the Certification Manager

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

Clean Plants Standard, Section 6.0 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 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

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

List of Manual Appendices Ensure that the list of Manual Appendices is up-to-date and complete

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. Read acknowledgements & disclaimer.