CFIA has just released a new Questions and Answers document for the HT Program, to provide more details than is found in D-13-01.
This document provides information that all registered facilities should be aware of, including:
- Q11 - Production and Traceability: In D-13-01 there is currently no reference to the use of bundle tags and/or wrappers as one of the means to identify lumber as HT, which caused some difficulties at registered facilities. This is a reference that permits the use of bundle tags and/or wrappers to ensure traceability when a registered facility obtains HT material from another registered facility provided they meet the labeling requirements specified in section 2.1.2 of D-13-01.
- Q30 – Partially assembled vs completely unassembled packaging: Definitions have been added to better explain partially assembled wood packaging such as cable reels, crates, and fish boxes. Definitions of completely unassembled wood packaging have also been added with limitations on usage clarified.
- Q34 – Stamping dunnage: This section outlines marking requirement that each individual piece of dunnage must display the required IPPC mark on at least two sides and multiple marks be applied along the length of the wood in short intervals may ensure that the mark is present on all units after final alterations.
- Q35 - Dunnage vs crating: Definitions for dunnage and how dunnage is used are provided to prevent misuse of this material.
- Q36 - Dunnage stamp: CFIA requires that dunnage be identified with a dunnage stamp rather than the regular IPPC stamp. The additional mark: “DUN” must be placed outside the ISPM mark borders. Registered facilities were advised of this change in 2016.
- Q39 – Stamping: This section explains a requirement that the registered facility must re-mark any nonconforming wood packaging.
- Q47 – Enforcement and penalties: Reference is made to new enforcement actions by the CFIA under the Agriculture and Agri-Food Administrative Monetary Penalties Act against violations which include fraudulent misuse of stamps.
Should you have any questions about this document and the rules therein, please contact Brian Isard, Program Manager, at brian.isard@canadianpallets.com or 905-621-3409.