1. Clean Plants Internal Auditor Basic Training
Internal Audit Procedures

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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)

10. A: General Description of Nursery Plant Suppliers
Audit Focus, Section √
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

11. 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

12. 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

13. 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

14. 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

15. 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)

16. C: Plant Identity and Certification Status
Audit Focus, Section √
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.

17. 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.

18. C: Plant Identity and Certification Status Inadequate Identification
Audit Focus, Section √
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

19. 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

20. 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)

21. 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

22. 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

23. 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

24. 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

25. 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.

26. 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

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

28. E. Shipping Inspection Special Requirements for CFIA Domestic Regulated Areas
Audit Focus, Section √
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

29. E. Shipping Inspection Special Requirements for Other Pest-Specific Modules
Clean Plants Standard, Section
List the Clean Plants Pest Specific Modules in which your nursery is qualified

30. E. Shipping Inspection Special Requirements for Other Pest-Specific Modules
Audit Focus, Section √
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

31. 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

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

33. 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)

34. F. Shipping Plants to CNCP Nurseries Plant Identity for CNCP Customers
Audit Focus, Section √
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

35. 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

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

37. 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

38. 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

39. 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

40. 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

41. 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

42. 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

43. 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

44. 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

45. 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

46. 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)

47. 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

48. 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

49. 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

50. 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

51. 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

52. 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

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

54. 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.