To all registered facilities
Beginning in 2013 changes will be taking place to the structure and operation of the Canadian Wood Packaging Certification Program, soon to be merged with the Canadian Heat Treated Products Certification Program to become one export certification program covering all wood products export activities. Most of these changes are structural and will not affect our inspection program or the requirements for conformance by registered facilities.
However, there are two specific changes that facilities will need to be aware of. The first is the need to tighten up requirements for the identification of heat treated lumber, the basis of the credibility of our certification program. The second is ensuring the effectiveness of our inspection program, which due to recent concerns has caused a review of the frequency of inspections in certain cases.
Lumber identification
The present (and proposed) policy documents require that heat treated lumber be stamped or tagged, or by identified by a means specified in facility quality manuals and accompanied by a domestic heat treat certificate. The continuing problem is that where a certificate is required, the accompanying lumber often does not bear any physical identification that links it to the certificate.
Beginning this year, all facilities will be required to ensure that all heat treated lumber is properly identified as such at the point of receipt. Lumber not bearing physical identification must be considered as non-conforming and must be returned to the supplier or declared non-HT and segregated for other uses.
To enable inspectors to verify conformance, all facilities buying HT lumber must keep a log of lumber purchases, showing quantities purchased (in board feet), type (hardwood or softwood) and treated or not treated. This log will start January 2013 and will be continuous. The log can be kept in any form that is convenient to the facility.
Inspectors will use this log to select purchase lots for physical inspection if present, and to review previous purchases to ensure traceability. The documentation must show a mill # or CA #, either on an HT certificate, or recorded by the facility if there is no certificate.
Frequency of inspections
As most facilities know there was a recent incident where a facility was found to be stamping non-conforming product. Concern was expressed that a significant quantity of non-conforming product could be shipped unless more frequent inspection could detect the problem sooner.
The key areas of risk are the presence of untreated lumber, the requirements for repair and remanufacture, and ensuring the effectiveness of heat treating. In order to ensure that any altered regime of inspections addresses real areas of risk, we wish to compile data to quantify risk and thus determine where frequency should be increased.
In June 2013 facilities will be asked to provide us with the total of their purchases by category listed above. This information will be confidential and will be plotted against risk categories to determine where inspection frequency might be increased. For example a facility that reports a high percentage of untreated lumber will be more likely to be considered for an increase, compared to a facility that buys only treated lumber.
In addition, repair facilities are asked to keep a log of the quantity of shipped product that has been repaired and recertified, or that has been manufactured from reclaimed HT lumber and certified. This log will be required only for the first six months of 2013 and will give an estimate of the size of this risk area.
Finally, heat treating facilities are asked to log the quantity of lumber and/or product that has been heat treated during this same six month period to determine which facilities may be visited more often.
Your cooperation in fulfilling these requirements will both enable our inspection process to be more effective and to ensure that the frequency inspection will be appropriate to the perceived risk. Please note that inspectors will be verifying these logs during our current cycle of inspections.
Doug Taylor
Lead Inspector CWPCP
January 2013
