Seed Program Quality System Procedure: Official Seed Sampler Certification

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QSP 132.4

Table of Contents

Date

This version of the Official Seed Sampler Certification Quality System Procedure (QSP) was issued August 1, 2017.

Contact

The contact for this Seed Program QSP 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 QSP is subject to periodic review. Amendments will be issued to ensure it continues to meet current needs.

Endorsement

This Seed Program QSP is hereby approved.

space for the signature of the Director, Field Crops & Inputs Division
Director, Plant Production Division

space for the date
Date

Distribution

The most current version of this document will be maintained on the Canadian Food Inspection Agency (CFIA) Intranet site (Merlin) and/or Internet site. The signed original will be maintained by the National Manager, Seed Section. A copy of the latest version is available upon request to SeedSemence@inspection.gc.ca.

0.0 Introduction

The certification of Canadian Food Inspection Agency (CFIA) inspectors for seed sampling verifies the competency of staff to obtain official seed samples and ensures national consistency.

This certification also facilitates the continued accreditation by the International Seed Testing Association (ISTA) of Canada's official seed testing laboratories to issue ISTA International Seed Analysis Certificates.

All CFIA seed inspectors must be trained and certified to draw official seed samples.

1.0 Scope

The procedures described in this Quality System Procedure (QSP) describe the standards and procedures required for a CFIA inspector to be certified as an official seed sampler, and the management of the Official Seed Sampler Certification Program. Section 6 of the Seeds Act provides the authority for a CFIA inspector to take seed samples.

2.0 Reference

The publications referred to in the development of this QSP are those identified in Seed Program Regulatory Authority (SPRA) 113 References for the Seed Program, as well as the most up-to-date versions of:

  • SPRA 131 Inspection Agency Requirements for the Delivery of the Seed Certification Program;
  • QSP 152.1 Implementation and Administration of the OECD Seed Schemes and EU Seed Directives;
  • the International Rules for Seed Testing, Chapter 2: Sampling (ISTA Rules); and
  • the ISTA Handbook on Seed Sampling.

3.0 Definitions

For the purposes of this QSP, the definitions given in SPRA 101 Definitions for the Seed Program and the following apply:

Candidate:
An individual seeking to become certified as an official domestic or an ISTA seed sampler.
Competency:
A cluster of related skills, knowledge and aptitudes required by a number of job categories for a very broad population, it applies to on-the-job performance and can be measured against well-accepted standards.
Critical Non-Conformance:
A deviation from the documented quality system such that compliance is absent and will have a consequential effect on the quality of the product or service (e.g., the sample is not accepted for testing).
Domestic Seed Sampler:
Certified to draw samples for domestic seed lots, requires on-site verification every 3 years.
ISTA Rules:
The International Rules for Seed Testing are ISTA's primary instrument to promote uniformity in seed testing. The ISTA Rules provide definitions and standardized methods to be used in, for example, sampling, testing seed lot quality and reporting results for international trade.
ISTA Seed Sampler:
Certified to draw samples according to the ISTA Rules for both domestic and export seed lots, requires on-site verification every year.
Major Non-Conformance:
A significant deviation from the documented requirements such that the program integrity or compliance with the requirements is absent, may result in the product or service not meeting the requirements.
Minor Non-Conformance:
A failure in the implementation of the documented quality system resulting in a decrease in confidence that the seed sample or sampler meets the requirements of the activity.
Non-Conformance:
The failure to comply with a requirement, standard, or procedure identified during an audit or a review of submitted documentation.
Official Seed SamplerFootnote 1:
An employee of the CFIA who is trained, evaluated and certified as a domestic and/or an ISTA seed sampler.
Official Seed Sampler EvaluatorFootnote 1:
An official seed sampler who has witnessed and carried out under one evaluation of a seed sampler.
Reserve Seed Sampler:
Certified but not currently active in the seed program, does not require on-site verification when on reserve status. Assessment, re-training and/or an on-site verification will be required to return reserve seed samplers to active status as applicable on a case-by-case basis.
Seed Testing Laboratories:
The two official CFIA seed laboratories - Ottawa Plant Laboratory (OPL) - (Fallowfield) and Seed Science and Technology Section (SSTS) - (Saskatoon), and other ISTA labs receiving samples from CFIA samplers.
Seed Sample Submission AssessorFootnote 1:
A seed testing laboratory employee who is responsible for assessing the acceptability of seed samples and sample submission forms received from official seed samplers.
Supervisor or ManagerFootnote 1:
The individual with supervisory responsibility for an inspector being trained and evaluated for seed sampling or who has been certified as an official seed sampler.
Technical Competency Grid:
A tool used to identify the skills and knowledge required by an individual to perform a specific task to a defined level of performance.
Work Year:
The period between April 1 and March 31 of any given year is considered to be the work year as referenced in this QSP.

4.0 Outline of the Official Seed Sampler Certification Program

The CFIA, under the authority of the Seeds Act, regulates the testing, inspection, quality and sale of seed in Canada. This legislation provides for the sampling of seed by the CFIA inspectors and the analysis of seed at Seed Laboratories. It is critical that each seed sample be drawn according to internationally accepted, science-based methods and procedures to ensure that the sample is representative of the seed lot.

The Official Seed Sampler Certification Program is administered jointly by the Programs, Operations and Science Branches of the CFIA. The sampler program was developed to ensure that approved methods and procedures for sampling are used by CFIA. For detailed instructions see SWI 132.1.1 Official Seed Sampling,which is based on Chapter 2 of the ISTA International Rules for Seed Testing.

There is surveillance of all ISTA seed sample submissions (both documents and samples), annual audits of ISTA seed samplers, and audits every third year for domestic seed samplers. Sampler audits are termed Quality Verifications (QVs) and are recorded within Operations Branch's Quality Management System (QMS). The processes, procedures and program documents for the Official Seed Sampler Certification Program are also reviewed as part of the annual QMS and QV processes.

To be certified to draw an official seed sample, candidates must:

  1. have adequate visual recognition skills;
  2. receive appropriate training;
  3. follow the seed sampling procedures described in SWI 132.1.1 Official Seed Sampling;
  4. demonstrate the knowledge, skills and abilities described in Technical Competencies for Official Seed Samplers (Appendix I); and
  5. successfully complete written and practical evaluations.

5.0 General Requirements

5.1 Seed Section Responsibilities

The responsibilities of the Seed Section are to:

  1. provide overall direction and interpretation of the Official Seed Sampler Certification Program
  2. develop, update, and amend this QSP in response to substantive changes to program policies and standards and/or to amendments to the ISTA Rules;
  3. communicate to the Seed Laboratories and Operations Branch changes made to this QSP
  4. certify official seed samplers and issue Official Seed Sampler certificates, issue suspensions, cancellations and reinstatements of certification;
  5. participate in an annual review of the QMS reports along with SSTS and Operations Branch;
  6. verify in QMS that QV audits have been completed and notify PASO accordingly;

    and

  7. classify unlisted non-conformities as they are identified.

5.2 Pre-market Application Submissions Office Responsibilities

The responsibilities of The Pre-market Application Submissions Office (PASO) are to:

  1. inform the candidate, supervisor, and/or individual who submitted the evaluation to PASO of results on a timely basis;

    and

  2. maintain the Ag Input List and List of Official Seed Samplers and inform impacted parties of any changes to either.

5.3 Operations Branch Responsibilities

The responsibilities of Operations Branch are to:

  1. implement and administer the Official Seed Sampler Certification Program as described in this QSP;
  2. provide candidates for seed sampler certification with the required training using approved training materials;
  3. ensure that candidates for seed sampler certification are evaluated by a designated official seed sampler evaluator;
  4. assess completed written evaluations when required;
  5. review and provide feedback of evaluation results at the request of a candidate, as outlined in section 6.2.3;
  6. develop, update, and amend SWI 132.1.1 Official Seed Sampling in response to substantive changes to program policies and standards and/or to amendments to the ISTA Rules (to be confirmed);
  7. communicate via ListServe changes made to SWI 132.1.1 Official Seed Sampling (to be confirmed);
  8. develop, maintain and update seed sampler written and practical evaluations as required (to be confirmed);
  9. provide seed sampler written and practical evaluations to invigilators and official seed sampler evaluators on a timely basis (to be confirmed);
  10. provide official seed samplers with approved sampling equipment, procedures documents and work instructions;
  11. communicate to official seed samplers any changes in procedures as identified by Seed Section and/or SSTS;
  12. ensure that only official seed samplers are assigned responsibility for taking official seed samples;
  13. ensure that any requests for information or documentation related to the official seed sampler certification program are addressed on a timely basis;
  14. ensure that quality verification audits are conducted for ISTA and domestic seed samplers, ensure that this information is retained within QMS, and inform PASO that the audit was completed;
  15. participate in an annual review of the QMS reports along with SSTS and Seed Section;
  16. ensure that any non-conformances are addressed within specified response times;

    and

  17. provide feedback and technical advice to the Seed Section regarding the Official Seed Sampler Certification Program in order to ensure continuous improvement of the system.

5.4 Science Branch Responsibilities

The responsibilities of Science Branch are to:

  1. ensure that CFIA official ISTA seed samplers receive the relevant annual updates to Chapter 2: Sampling of the current ISTA Rules and are updated on any changes in ISTA sampling procedures;
  2. accept official seed samples for testing under the Seed Program only from official seed samplers;
  3. identify deficiencies in sample submissions from official seed samplers and issue action request forms for follow-up action on ISTA samples;
  4. maintain a record of seed sample submissions for ISTA samples that are not in conformity with SWI 132.1.1 Official Seed Sampling and monitor the implementation of corrective actions;
  5. issue warning letters to official seed samplers as appropriate;
  6. maintain files of the action request forms issued to official seed samplers by SSTS for ISTA samples;
  7. participate in an annual review of QMS reports along with the Seed Section and Operations Branch;
  8. provide feedback and technical advice to the Seed Section regarding the Official Seed Sampler Certification Program in order to ensure continuous improvement of the system;

    and

  9. provide assistance and advice on official seed sampler training as required.

5.5 Official Seed Sampler Responsibilities

The responsibilities of an official seed sampler are to:

  1. follow the seed sampling procedures described in SWI 132.1.1 Official Seed Sampling;
  2. maintain sampling proficiency;
  3. comply with CFIA's policies on morals, ethics and conflict of interest;
  4. implement action requests as required; and
  5. review sampling procedure documents in detail prior to resumption of sampling when they have not taken and/or submitted a sample for an extended period.

5.6 Official Seed Sampler Evaluator Responsibilities

The responsibilities of an official seed sampler evaluator are to:

  1. administer practical evaluations to candidates;;
  2. forward marked exams to PASO and Seed Section;;
  3. provide feedback on examinations when requested (when applicable);

    and;

  4. provide retraining options where applicable.

6.0 Certification Requirements

Training and evaluation activities will be coordinated by Operations Branch in cooperation with the Area Training Officer.

Candidates for this training and certification should familiarize themselves with the content of SWI 132.1.1 Official Seed Sampling and complete the pre-study modules. It is an advantage if candidates also participate in two seed sampling activities under the supervision of an official seed sampler prior to the classroom session and/or attend a practical sampling session that may take place before the classroom session.

6.1 Training

Candidates are provided with self-study (ISTA seed samplers only), group or individual training and the necessary training materials. With the exception of self-study, training will be provided by a seed sampler trainer. Seed sampler training is designed to ensure that a candidate will achieve the performance objectives described in Technical Competencies for Official Seed Samplers (Appendix I). When amendments are made to this QSP and/or to documents referenced in this QSP, revisions to the training materials will be made and additional training sessions may be required depending upon the nature of the changes.

6.1.1 Theory Training

Theory training will provide candidates with the principles, methods and procedures for seed sampling and will familiarize candidates with the official reference documents for seed sampling (SWI 132.1.1 Official Seed Sampling and ISTA Rules).

6.1.2 Practical Training

Practical training must consist of demonstrations of the seed sampling process conducted. The candidate must practice the sampling procedure under the supervision of the trainer. This practical training can be done during formal training sessions or as part of on-the-job mentoring for ISTA sampling certification.

6.2 Evaluation

When a candidate, their supervisor or sampler trainer determines that a sufficient level of knowledge and skill has been attained, they may then request that the written and practical evaluations be administered. Both evaluations need not be administered together. However, the written portion will normally be completed first.

These evaluations will measure working knowledge and practical ability in sampling seed lots. The evaluations will be based on the established performance objectives described in Technical Competencies for Official Seed Samplers (Appendix I).

6.2.1 Written Evaluation

During the written evaluation, which can be conducted online or in person, the candidate will be permitted to consult the documents that would normally be available to an official seed sampler in the performance of their duties. These are listed in Documents That May Be Referenced During the Written Exam (Appendix II). All questions will be based on these references. Candidates may not communicate with one another or with individuals other than the invigilator during the written evaluation.

Operations Branch maintains a bank of questions, from which written evaluations are generated (to be confirmed).

Operations Branch will maintain administrative control over the written evaluations and will put in place a procedure to receive feedback and to incorporate improvements as required. The bank of evaluation questions will be updated as amendments are made to seed sampling reference documents, ISTA Rules, or Seed Program policies and procedures (to be confirmed).

Written evaluations must be invigilated by a CFIA employee. The invigilator is responsible for contacting PASO to arrange for access to the written evaluation. In order to maintain the integrity of the certification process, evaluations must not be copied or distributed and may only be provided to a candidate at the location, time, date and for the duration established for the evaluation. Copies of written evaluations will not be provided for study purposes. Invigilators will be required to complete and submit a Record of Invigilation Form, which is provided in the seed sampler training course documentation.

It is the responsibility of the invigilator to arrange a location for the written evaluation that has suitable lighting and is free from distractions. In the case where a hard copy of the written evaluation is used, the invigilator must mark the exam and forward the completed evaluations to PASO. Hard copy evaluations must be forwarded in a secure manner, such as by courier or registered mail, or via electronic means. In the case where the evaluation is completed online, the candidate will receive the results of the examination via email, and must forward their received results on to both seedsemence@inspection.gc.ca and paso-bpdpm@inspection.gc.ca. The candidate's supervisor must be copied on this communication..

6.2.2 Practical Evaluation

This step in the certification process is designed to evaluate a candidate's skill and ability to assess and respond to a specific sampling situation. The evaluation will be conducted by an official seed sampler evaluator at a seed establishment or in a similar environment using a marking scheme that is based on Technical Competencies for Official Seed Samplers (Appendix I). Evaluators can contact PASO for the examination forms. Candidates will not have access to the marking scheme during the practical evaluation. Points will be deducted for incorrect or incomplete answers or improper use of procedures, equipment, etc. The official seed sampler evaluator will not terminate the practical evaluation before its completion, even in situations where it becomes evident part way through the evaluation that the candidate will not meet the standard. The official seed sampler evaluator will forward the marked evaluations to Seed Section and PASO, by electronic means at seedsemence@inspection.gc.ca and paso-bpdpm@inspection.gc.ca. Alternatively, hard copy evaluations must be forwarded in a secure manner to PASO. The candidate's supervisor must be copied on this communication.

6.2.3 Results of Evaluations

A minimum standard of 80% on both the written and practical evaluations is required. The candidate will be officially notified of their actual marks on the evaluation. The candidate's supervisor will be notified only whether the candidate met or did not meet the evaluation standards.

Evaluation results are considered confidential information. Distribution ofinformation regarding the evaluations must be governed by the confidentiality guidelines regarding personal information established in the Privacy Act. All hardcopy correspondence related to results will be clearly marked as "Personal and Confidential".

No feedback will be provided for electronic evaluations. Feedback may be provided for practical evaluations or hard copy written evaluations. No feedback will be provided on an evaluation where the final mark is 95% or higher. Where the final mark is 80 - 94%, the candidate may make a written request to the official seed sampler evaluator for information on areas of weakness. Where the practical evaluation final mark is less than 80%, feedback on areas of weakness will be automatic.

6.2.4 Re-evaluation

An unsuccessful candidate will require additional training. A candidate may request information from the official seed sampler evaluator regarding specific areas where retraining would be beneficial. He/she may retake a written and/or practical evaluation on the recommendation of their supervisor.

7.0 Certification Process

An individual will be recognized as an official seed sampler provided the following criteria have been met:

  1. achievement of a minimum of 80% on both the written and practical evaluations;

    and

  2. issuance of Official Seed Sampler Certificate (Appendix III) signed by the National Manager, Seed Section. The date of certification must be the date on the certificate;

Upon certification, the inspector is added to the List of Official Seed Samplers.

8.0 Program Maintenance

8.1 Seed Sample Submission Surveillance (ISTA Samples Only)

SSTS and OPL will assess each ISTA submitted sample and accompanying documentation to verify that samples have been taken and submitted in a manner consistent with SWI 132.1.1 Official Seed Sampling. When non-conformances are identified, action requests will be initiated. SSTS and OPL will refuse to analyse any sample where a critical non-conformance exists.

8.1.1 Action Requests

Sampling activities required by the Seed Program must comply with the procedures and techniques set out in SWI 132.1.1 Official Seed Sampling. Where a non-conformance is found upon the receipt of an ISTA sample and/or documentation at SSTS or OPL, or as the result of an audit, an action request must be issued in writing using an Action Request Form (an example form is shown in Appendix V). Examples of non-conformances are listed in Classification of Non-conformances: 1) On-site QV Assessment of Official Seed Samplers, 2) Sample Documentation Surveillance (Appendix IV). Depending on the nature of the non-conformances, appropriate actions may include review of sampling procedure documents, retraining, and/or re-evaluation.

Action requests related to minor non-conformances will be sent directly to the official seed sampler. In cases where the issuance of action request forms leads to issuance of a warning letter or beyond to suspension or cancellation, SSTS or OPL will send to Seed Section a summary of all non-conformances leading up to the warning letter and/or suspension, cancellation, etc. Action requests sent to the official seed sampler related to major and critical non-conformances will also be copied to the official seed sampler's supervisor and the Area Program Specialist. SSTS is not required to send a copy of the closed action request to the Seed Section.

8.1.2 Response Times for Action Requests

The official seed sampler, and their supervisor in the case of major and critical non-conformances, must undertake follow-up actions within specified time frames to ensure performance standards are met. They must notify SSTS or OPL when the appropriate actions have been implemented. The maximum allowable response time and maximum time for closure that must be set for any specific action request is found in the following table:

Table 1. Action Request – Maximum Response Time and Maximum Time for Closure
Non-Conformity Type Maximum Response Time
(working days)
Maximum Time for Closure
(working days)
Critical 2 days 10 days
Major 4 days 15 days
Minor 10 days 30 days

8.2 Oversight and Assessment of Official Seed Samplers

The ISTA seed samplers are assessed annually as part of the Operations Branch QMS (Quality Management System) assessment process. The QMS process involves an on-site review of their practical sampling skills and includes records and reference documentation checks for example, that the official seed samplers have the most recent versions of the Seeds Act and the Seeds Regulations; ISTA International Rules for Seed Testing, Chapter 2: Sampling; SWI 132.1.1 Official Seed Sampling and QSP 152.1 Implementation and Administration of the OECD Seed Schemes and EU Seed Directives. The quality assessment is referred to as a Quality Verification (QV).

Domestic seed samplers undergo the same type of QMS quality assessment every third year.

The on-site QV assessments of ISTA seed samplers are conducted by qualified CFIA personnel who are official seed samplers. A CA20 (RDIMS 3075382) is required to be completed by an ISTA seed sampler. Note that a CA20 qualifies an ISTA seed sampler to take both ISTA and domestic samples. An additional CA24 is not required. ISTA seed samplers are not required to complete an additional CA20 in the same work year in which they were certified. A CA24 (RDIMS 1882451) can be completed by either an ISTA seed sampler or a domestic seed sampler.

Once the QV has been completed and recorded in QMS, the CFIA personnel who conducted the QV must inform PASO via email of the name of the official seed sampler assessed as well as the date of the assessment.

If during the QV assessment any critical non-conformances are identified, which would result in suspension or cancellation of the certification of an official seed sampler, Seed Section and SSTS will be immediately notified. Any other non-critical non-conformances will be identified and action requests initiated by the auditor. Any trends in non-conformance will be identified as part of the annual review of the QMS system reports and communicated to all regions. The annual review of the QMS report is a joint process between Seed Section, SSTS, and Operations Branch.

Should an ISTA seed sampler fail to complete their QV before the end of the work year, their sampler designation will be changed to a domestic seed sampler. Should a domestic seed sampler fail to complete their QV before the end of the work year, their sampler designation will be changed to a reserve seed sampler. Any changes to the List of Official Seed Samplers will be provided to SSTS and other ISTA labs receiving samples from CFIA samplers by PASO.

8.3 Program Review

The processes, procedures and program documents for the Official Seed Sampler Certification Program are reviewed as part of the annual QMS and QV processes. In addition, the ISTA audit team reviews ISTA sampling when they audit SSTS every third year (i.e. in 2016, 2019 etc.).

8.4 Records and Administration

Records must be maintained in support of the Official Seed Sampler Certification Program. All records must be maintained in accordance with the confidentiality guidelines regarding personal information established in the Privacy Act. All sampler records must be kept for a minimum of 10 years.

The following records must be maintained:

  1. Action Request Forms: must be retained by SSTS. In the case of action request forms related to major and critical non-conformances, the official seed sampler's supervisor must also be sent a copy.
  2. QV Records: QV information is entered into and retained by the QMS database which is maintained by Operations. Annual QV summary reports and related correspondence will be retained on file by SSTS.
  3. Certificates: a copy of an official seed sampler's certificate will be kept on file by PASO.
  4. Evaluation Records: must be kept in a confidential file by PASO.
  5. List of Official Seed Samplers: PASO must maintain the List of Official Seed Samplers. This list is accessible to all CFIA staff, including the CFIA inspection offices, SSTS, and OPL. The official seed sampler's name is entered on the list when Seed Section receives documentation indicating that the certification standards have been met and an Official Seed Sampler Certificate has been issued. Operations Branch will notify Seed Section and PASO of any changes in the employment status of an official seed sampler in their area.

    The List of Official Seed Samplers must contain the following information:

    1. the name of the official seed sampler;
    2. the date the list was last updated; and
    3. the classification of sampler (ISTA, domestic, reserve).
  6. Submitted Sample Assessment Records: submitted sample assessment records must be maintained by SSTS.
  7. Training Records: must be kept on file by a candidate's supervisor and the appropriate Area Training Officer.

9.0 Warning, Suspension, Cancellation and Re-Instatement

9.1 Warnings

A warning letter must be issued by SSTS, OPL, or Operations Branch to an official seed sampler when a specified number of non-conformances, pertaining to ISTA samples, have been identified. This warning letter must be copied to the official seed sampler's supervisor, and Seed Section. Warning letters will be issued to a sampler when as a result of seed sample submission surveillance and/or QV in a one year period (1 April to 31 March) a sampler has:

  1. 3 critical non-conformances;
  2. 5 major non-conformances; or
  3. 10 minor non-conformances.

9.2 Suspension

Seed Section will suspend the certification of an official seed sampler when, as a result of seed sample submission surveillance and/or QV, in a one year period (1 April to 31 March) a sampler has:

  1. 5 critical non-conformances;
  2. 8 major non-conformances; or
  3. 12 minor non-conformances.

Repeat errors resulting in repeated warning from year to year can also result in suspension.

In addition, an official seed sampler's certification can also be suspended when the seed sampler, or the sampler's supervisor, does not respond in writing to an action request related to a critical non-conformance within the specified time frame without good reason.

Once the criteria for suspension have been met, Seed Section will notify the official seed sampler within five working days. This letter will be copied to the sampler's supervisor, and/or manager, PASO, and SSTS. The certification of a sampler will not be suspended where the implementation of the action request is beyond their control (e.g. appropriate triers have not been provided to the sampler).

9.3 Cancellation

The certification of an official seed sampler will be cancelled when an official seed sampler:

  1. submits false or misleading documentation pertaining to a sample or the manner in which it was drawn;
  2. submits samples not drawn or documentation not prepared by the sampler or by an individualunder the supervision of the sampler;
  3. has already had their certification suspended twice within the previous five year period;
  4. has had their certification suspended for a period of two years and corrective action has not been implemented; or
  5. is no longer employed by CFIA.

Seed Section will notify the inspector within five working days of the cancellation, except for reason e). This letter will be copied to the inspector's supervisor and SSTS. The Seed Section will amend the List of Official Seed Samplers to reflect the cancellation.

9.4 Reinstatement

Following suspension, the certification of an official seed sampler will be reinstated when the sampler completes retraining and demonstrates to an official seed sampler evaluator that they have corrected the non-conformance(s) that led to suspension. The Seed Section will amend the List of Official Seed Samplers to reflect the reinstatement and will inform the official seed sampler, their supervisor, and Operations Branch of the change.

Following cancellation, the certification of an official seed sampler will be reinstated when the sampler successfully completes both a written and practical re-evaluation. The Seed Section will amend the List of Official Seed Samplers to reflect thereinstatement the reinstatement.

Similarly, after their designation has been changed from an ISTA seed sampler to a domestic seed sampler, the sampler in question can be reinstated as an ISTA seed sampler if a CA20 is completed and the ISTA training has been completed previously. After their designation has been changed from a domestic seed sampler to a reserve seed sampler, the sampler in question can be reinstated as a domestic seed sampler if refresher training and a CA24 is completed. Please note that retraining and/or mentoring may be required prior to attempting the QV. This will be determined on a case by case basis. Once retraining and completion of a CA24/CA20 has been entered into QMS by Operations Branch and both Seed Section and PASO have been informed, Seed Section will amend the List of Official Seed Samplers to reflect the reinstatement. Any changes to the List of Official Seed Samplers will be provided to SSTS and other ISTA labs receiving samples from CFIA samplers by PASO.

Appendix I: Technical Competency Grid for Official Seed Samplers

The following table describes the tasks and components along with the associated technical competencies that an official seed sampler will demonstrate in order to draw an official seed sample.

Task and Components Technical Competencies
Task: Identify what to sample
  • Determine specific lot to sample
  • Determine how seed is packaged
  • Determine crop kind
  • Determine size of lot
  • Verify lot identification
  • Check lot against Program work plan
  • Knowledge of how seed lot is defined and identified
  • Knowledge of seed industry (e.g. crop kinds, methods of processing, processing records, packaging options)
  • Knowledge of seed program objectives and sample codes
  • Demonstrate ability to obtain necessary information from seed records (e.g. blend sheet, seed analysis report, seed declarations, crop certificates)
Task: Decide whether or not to sample
  • Determine accessibility of seed lot to see if sample can be taken
  • Determine whether seed lot is being offered for sale as seed
  • Determine integrity of seed lot in terms of sealed, intact containers and appropriate tags/documentation
  • Knowledge of principles of sampling
  • Knowledge of conditions that must be met in order to ensure sample is representative, and how to determine the integrity of the seed lot
  • Knowledge of definition of a sealed container
  • Knowledge of import standards, grade designations and definition of sale
  • Knowledge of specific export requirement
  • Knowledge of when seed is exempt from standards
Task: Sample seed
  • Select appropriate sampling method/equipment
  • Determine and take required number of primary samples
  • Use proper procedures to take sample
  • Assess uniformity of primary samples
  • Knowledge of general principles of sampling
  • Knowledge of definition/criteria of seed lot uniformity
  • Knowledge of sampling equipment options
  • Knowledge of sampling method options
  • Knowledge of sampling equipment use
  • Knowledge and ability to follow proper sampling procedures (including those for treated seed)
  • Knowledge of cleaning procedures for sampling equipment
Task: Prepare sample for submission
  • If uniform, combine primary samples to form composite sample
  • Subdivide composite sample to obtain submitted sample, if permissible and warranted
  • Select the appropriate sample submission container
  • Label sample submission container
  • Properly close and seal sample submission container
  • Complete sample submission form
  • Attach tags, as required
  • Use investigation sample handling procedures, where continuity of evidence is required
  • Knowledge and ability to follow proper mixing procedures to form composite sample
  • Knowledge of which samples (crop kinds) must be submitted to the laboratory for subdivision
  • Knowledge and ability to follow proper procedure for dividing composite sample to obtain submitted samples
  • Knowledge of required minimum submitted sample size
  • Knowledge and ability to follow proper method for handling moisture samples
  • Knowledge of proper sample container based on crop kind, test or treated seed
  • Knowledge and ability to follow proper sample identification and sample sealing procedures
  • Knowledge and ability to properly complete sample submission form
  • Knowledge and ability to follow proper procedures for handling investigation samples
Task: Ship Sample
  • Pack samples into shipping container
  • Address shipping container correctly
  • Ship according to the priority of samples
  • For investigation samples, use appropriate procedures
  • Knowledge and ability to follow proper packaging methods and package identification
  • Knowledge of appropriate mode of transportation (timing)
  • Knowledge of appropriate laboratories for specific tests
  • Knowledge of protocols for legal samples

Appendix II: Documents That May Be Referenced During the Written Evaluation

The following documents will be made available to a candidate during the written evaluation for Official Seed Sampler Certification:

Domestic and ISTA Seed Sampler Evaluations:

  1. Seeds Act and Seeds Regulations
  2. SWI 132.1.1 Official Seed Sampling

For ISTA Sampler Evaluation Only:

  1. QSP 152.1 Implementation and Administration of the OECD Seed Schemes and EU Seed Directives
  2. ISTA International Rules for Seed Testing, Chapter 2: Sampling (current version)
  3. EU Council Directives on the marketing of seed and propagating material
  4. OECD List of Varieties Eligible for Certification

Any of the documents named above may be supplied to the candidate at the beginning of the workshop and as such, may contain highlighted or additional hand written comments made by the candidate. These documents would be acceptable to be referenced during the written evaluation.

Appendix III: Official Seed Sampler Certificate

The Canadian Food Inspection Agency (CFIA), in compliance with the standards of SPRA 131 Inspection Agency Requirements for the Delivery of the Seed Certification Program and acting in accordance with seed program quality system procedure 132.4 Official Seed Sampler Certification, hereby certifies space for the Official Seed Sampler Certification as an official seed sampler.

Inspector Number: space for the Inspector Number

Date Certificate Issued: space for the Date Certificate Issued

space for the National Manager, Seed Section
National Manager, Seed Section

Appendix IV: Classification of Non-Conformances: 1) On-Site QV Assessment of Official Seed Samplers, 2) Sample Documentation Surveillance

1) On-Site QV Assessment of Official Seed Samplers
Any non-conformance found during the on-site QV of the official seed sampler will be classified as follows:

Critical Non-Conformance: Any procedure that would require re-sampling the seed lot.

  1. use of unapproved trier
  2. use of unapproved dividing method
  3. use of trier too small for crop kind sampled
  4. use of an automated sampling device for export sampling not approved by CFIA
  5. drawing of a sample from an ISTA seed lot (to be tested according to ISTA Rules) that was not sealed as required
  6. failure to ensure cleanliness of sampling equipment prior to sampling the seed lot
  7. submission of seed sample that deviates from the required minimum sampling intensity
  8. removal of material from sample (e.g. weed seed/other crops when purity analysis is being requested from the lab)
  9. samples seed lot for export or grading purposes when primary samples are not uniform
  10. failure to check each primary sample for uniformity, e.g. seed size, colour or amount of chaffy material
  11. sample taken from a seed lot where a portion of the lot is not accessible (for ISTA sampling only)
  12. failure to follow the correct procedure when using the riffle divider
  13. submission of a submitted sample that does not meet the minimum sample size requirements for ISTA testing purposes
  14. submission of sample for ISTA certificate purposes from seed lot exceeding maximum ISTA seed lot size
  15. submission of sample for testing that is not properly sealed
  16. failure to check whether the variety is on the OECD List of Varieties Eligible for Certification (for ISTA sampling only)
  17. submission of a sample of a variety that is not on the OECD List of Varieties Eligible for Certification (for ISTA sampling only)
  18. failure to confirm that a crop kind is in the EU Directives when the applicant requests that the statement "this seed lot meets EC Rules and Standards insofar as they are known" be on the Variety Certificate (for ISTA sampling only)

Major Non-Conformance:Any procedure that would require correction and will result in a delay in testing a sample

  1. failure to label submitted sample sufficiently to allow traceability between the sample and the documentation (i.e. seed lot or sample number was not on the submitted sample label)
  2. failure to submit all required documentation with sample or re-sample
  3. failure to label treated or inoculated seed sample as treated or inoculated
  4. manipulates the trier in a manner not described in SWI 132.1.1
  5. failure to include or to accurately include, in the submitted documentation any of the following:
    1. trier information
    2. number of primary samples
    3. date of sampling
    4. lot number
    5. lot size
    6. number of containers in each lot
    7. size of each container
  6. failure to submit a properly packaged sample when moisture test requested or seed has been treated
  7. submission of sample and documentation for ISTA certification for a crop kind not listed in the ISTA Rules
  8. where a lot has been re-sampled for an ISTA Seed Lot Certificate, the re-sampling does not comply with the ISTA requirements
  9. use of inappropriate sample container for submitting sample
  10. the month of sealing for EC Rules and Standards on the tag does not correspond to the date of sampling

Minor Non-Conformance: When information submitted is clarified, testing may be initiated

  1. failure to provide information regarding seed treatment of a sample labeled as treated seed
  2. submission of conflicting information between the sample and the sample documentation
  3. failure to include one or more pieces of information on the submitted sample label
  4. failure to sign LSTS form

2) Sample Documentation Surveillance

Any non-conformance found when reviewing the sample and sample documentation will be classified as follows:

Critical Non-Conformance:Anything that would require re-sampling the seed lot

  1. use of unapproved trier
  2. use of unapproved dividing method
  3. use of trier too small for crop kind sampled
  4. use of an automated sampling device for export sampling not approved by CFIA
  5. submission of a submitted sample that does not meet the minimum sample size requirements for ISTA testing purposes
  6. submission of seed sample that deviates from the required minimum sampling intensity
  7. submission of sample for ISTA certificate purposes from seed lot exceeding maximum lot size
  8. submission of sample for testing that is not properly sealed

Major Non-Conformance:Any procedure that would require correction and will result in a delay in testing a sample.

  1. failure to label submitted sample sufficiently to allow traceability between the sample and the documentation (i.e. seed lot or sample number was not on the submitted sample label)
  2. failure to submit all required documentation with a sample or re-sample
  3. failure to label treated or inoculated seed sample as treated or inoculated
  4. failure to include or to accurately include, in the submitted documentation any of the following:
    1. trier information
    2. number of primary samples
    3. date of sampling
    4. lot number
    5. lot size
    6. number of containers in each lot
    7. size of each container
  5. failure to submit a properly packaged sample when moisture test requested or seed has been treated
  6. submission of sample and documentation for ISTA testing for a crop kind not listed in the ISTA Rules
  7. use of inappropriate sample container for submitting sample

Minor Non-Conformance: When information submitted is clarified, testing may be initiated.

  1. failure to provide information regarding seed treatment of a sample labelled as treated seed
  2. submission of conflicting information between the sample and the sample documentation
  3. failure to include one or more pieces of information on the submitted sample label
  4. failure to sign LSTS form.

Appendix V: Example Sample Submission Action Request Form

The following form is issued by the Seed Science and Technology Section and OPL to an official seed sampler to request corrective action on a non-conformance observed from sample submission.

For lab use only / Réservé à l'usage du laboratoire

  • Box Export Sampling / Échantillon de semences exportées.
  • Box Domestic Sampling / Échantillon de semences destinées au marché canadien.

Lab sample Number(s) / Numéro(s) de l'échantillon du laboratoire :space for the Lab sample Number (s)

Classification of non-conformity: checkbox Critical checkbox Major checkbox Minor

Catégorie de la non-conformité : case à cocher Critique case à cocher Majeure case à cocher Mineure

Action Request Number / Numéro de la demande de mesures correctives : space for the Action Request Number

Originator / Demandeur : space for the Originator

Inspector Number / Numéro de l'inspecteur : Inspector Number

Date: space for the date

Inspector Name and Location / Nom et lieu de travail de l'inspecteur : space for the Inspector Name and Location

Inspection Sample No.(s) / Numéro(s) de l'échantillon soumis : space for the Inspection Sample No.(s)

Lot number (as applicable) / Numéro de lot (s'il y a lieu) : space for the Lot number

Description of non-conformity (and related observations) requiring correction: space for the Description

Description de la non conformité (et des observations connexes) qu'il faut corriger : space for the Description

Reference / Référence : space for the reference

Date response required by / Date de la réponse requise : space for the Date response

Date closure required by / Date de clôture requise : space for the Date closure

Description of action taken to correct the non-conformity or to prevent recurrence:
(this section is to be completed by the sampler; for critical non-conformity, also the sampler's supervisor)
space for the Description of action taken

Description de la mesure prise pour corriger la non-conformité ou pour empêcher qu'elle ne se reproduise.
(La présente section doit être remplie par l'échantillonneur.) (Pour les cas de non-conformité critique, le superviseur de l'échantillonneur doit également remplir la présente section). espace pour la description

Signature of sampler / Signature de l'échantillonneur : space for the Signature of sampler

Date: space for the Date

Signature of sampler's supervisor (only required in the case of critical non-conformity) /
Signature du superviseur de l'échantillonneur (exigée seulement dans les cas de non-conformité critique) : space for the Signature of sampler's supervisor

Date: space for the Date

Verification of Implementation:
(only required in the case of critical non-conformity)

Vérification de la mise en œuvre : (Exigée seulement dans le cas de non-conformité critique)

  • Box Acceptable
  • Box Not (non) acceptable

space for the Signature of seed sample submission assessor
Signature of seed sample submission assessor / Signature de l'évaluateur de la soumission d'échantillon de semence

space for the Date
Date

Descriptive Text:

The following form is issued by the Seed Science and Technology Section to an official seed sampler to request corrective action on a non-conformance observed in a sample submission. The purpose of this sample submission surveillance is to ensure that inspectors are adhering to correct sampling and submission procedures. The form is filled out by the lab as follows: firstly, whether it is a sample resulting from export sampling or domestic sampling is indicated along with the lab sample number. The classification of the non-conformity is then specified i.e. whether it was critical, major or minor. The action request number, originator, inspector number, and date are filled out respectively. The next section requires the name of the inspector and their location, inspection sample no., lot number (as applicable) and the description of the non-conformity (and related observation) requiring correction. This is succeeded by the reference, the date the response is required by and the date closure is required by. The description of the action taken to correct the non-conformity or to prevent recurrence is completed afterwards, along with the remaining portions of the form. The signature of the sampler and the date are given along with the signature of the sampler's supervisor (only required in the case of a critical non-conformity) and the date. Lastly, the verification of implementation (which is only required in the case of critical non-conformity) whether acceptable or not acceptable is indicated. After which, the signature of the seed sample submission assessor and date is filled out.

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