Non-Conformances

A Non-Conformance (N/C) is described as a failure to comply with a specified requirement. These fall under three categories: major, minor, or in the form of an observation. All three are described below.

When a N/C has been identified, the Inspector will issue a written Record of non-conformance indicating: the non-conformance, the necessary corrective action(s), and if there is need for a re-inspection. A re-inspection is at the facility’s cost ($500) and applies only to major N/Cs.

Non-conformances can result in suspension from the HT Program or having registration cancelled if the N/Cs are repetitive or if they place the integrity of the HT Program in jeopardy.

Major Non-Conformances

Defined as non-conformances that compromise the integrity of the HT Program.

D-13-01 provides the following examples:

Facilities operating with significant changes to kiln operating conditions that have not been approved by a CLSAB Accredited Agency or a CFIA Approved Third Party Auditor.
Corrective actions identified for non-conformance from previous audits have not been implemented.
Regulated wood products destined to off-shore markets have not met the phytosanitary standard (i.e. 56°/30 minutes) or the registered facility fails to meet the treatment specifications in the approved manual.
Exported material or material designated or consigned for export fails to meet the phytosanitary import requirements of the importing country.
The facility has improperly issued certificates (e.g. failed to meet the specifications on the certificate or the certificate was issued by an unauthorized person, etc.)
Segregation of treated and untreated lots has not been maintained.
Records are significantly incomplete or do not allow the CSLAB Accredited Agency or the CFIA Approved Third Party Auditor to conduct trace-back of products exported (e.g. treatment records are missing, incomplete, etc. or export certificates not maintained, etc.)
A consolidated shipment has been assembled from wood products that have not been treated in accordance with the standards or has been obtained from a facility not registered in the HT Program.
Employees involved with implementing the quality procedures are not sufficiently trained.

Minor Non-Conformances

Defined as isolated incidents that do not affect the integrity of the WPM and can be corrected within the specified time frame.

Examples from D-13-01 include:

Facilities operating with minor changes to quality processes that have not been approved by the CLSAB Accredited Agency or the CFIA Approved Third Party Auditor.
Facility procedures for documentation or certificate issuances have not been followed or have been poorly followed. Procedures are unclear.
Facility employee involved with implementing the quality procedures is unaware of the phytosanitary specifications pertaining to activities performed by that employee.
Segregation or identification of treated and untreated wood is inadequate, but does not affect the integrity of products ready for export.
Staff training has not been completed or records of training have not been maintained.
Registered facility has failed to maintain records of audits.
Items identified as observations on previous audit are still left unaddressed.

Please note that 5 minors = 1 major

Observations

Observations are findings which constitute an issue but do not affect the phytosanitary requirements of the HT Program.

Examples include:

Manual page number missing.
Manual appendices are not labelled or numbered.
Facility record-keeping is inadequate but records essential to the integrity of the phytosanitary standard (e.g. treatment records are complete, traceability records maintained).
Facility’s organizational chart is not updated when staff changes are made