CGC QSP 1.1.0

(CIPRS, CIPRS + HACCP, CGC HACCP)

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5.0 Deferral, denial, suspension or withdrawal of certification

5.1 Deferral or denial of certification during an implementation audit

If a major non-conformance is found during an implementation audit, the Lead Auditor is authorized to stop the audit and propose three alternative actions:

• The audit may end, no audit report will be submitted to the PVA, and a full assessment may be rescheduled for a later date,

OR

• If it is an initial audit, it may be changed to a pre-assessment. The audit will be completed, a report will be prepared for the client, but not submitted to the PVA, and an implementation audit may be rescheduled for a later date.

OR

• The audit may be completed and the audit report will indicate that a major non-conformance was found and recommend that no certification be granted. Certification will be deferred until the correction action has been taken and confirmed.

If the third option is chosen, the client is required to submit their corrective action plan with respect to a major non-conformance to the auditor within 5 working days of the audit. The auditor shall accept the corrective action plan (if the actions are deemed acceptable) and submit the audit report, copies of CARs, and accepted corrective action plans to the PVA. The client is also responsible for implementing corrective action, scheduling and undergoing a follow-up visit within 40 working days of the auditor’s acceptance of the corrective action plan by the PVA.

After the follow-up visit, the auditor will submit a report to the PVA verifying he or she has collected objective evidence that effective corrective action has been taken and certification may be granted.

If the client fails to implement corrective action and undergo a follow-up visit within the 40 working days of the auditor’s acceptance of the corrective action plan, the certification will be denied and the certification process must be re-initiated by the client.

5.2 Suspension or withdrawal of certification during surveillance or recertification audit

If a major non-conformance is found during a surveillance or re-certification audit, the auditor will advise the PVA in writing of the major CAR within 24 hours of the audit. The PVA will formally advise the client in writing of their suspended status, and the requirement for a follow-up visit within 20 working days to determine if corrective action has been being taken.

If the company uses Canadian Grain Commission load certificates, the Lead Auditor will make note of the certificate number on the last load certificate issued by the client to allow for verification that no additional load certificates are issued during the period of suspension.

The client is required to submit their corrective action plan with respect to a major non-conformance to the auditor within 5 working days of the audit. The auditor will accept the corrective action plan if the actions are deemed appropriate. The client is also responsible for implementing corrective actions, scheduling and undergoing a follow-up visit within 20 working days of the auditor’s acceptance of the corrective action plan.

After the follow-up visit, the auditor shall submit the audit report, copies of CARs, and accepted corrective action plans to the PVA. The audit report must verify that he or she has collected objective evidence that effective corrective action has been taken. The suspension will be lifted or the re-certification will be granted.

If the client fails to take corrective action within the 20 working days of the auditor’s acceptance of the corrective action plan, the client’s certification will be withdrawn. The client has the right to appeal the withdrawal of their certification as described in section 6.0.

Suspension is defined as notice given to a client by the PVA that, effective immediately, the client can no longer use load certificates or any other representation of the certified program (e.g. certificate of recognition, tags) and that failure to take corrective action within the 20 working days of the auditor’s acceptance of the corrective action plan will result in a client’s certificate being withdrawn.

5.3 Critical Non-Conformances

If a critical non-conformance is found during any audit, the auditor will end the audit and advise the client that its certification is suspended effective immediately and that any contaminated product must be segregated. If there is an immediate threat to public health or safety, the auditor must advise the client to contact the PVA as soon as possible, but no later than 12 hours after the audit. If the auditor’s advice is verbal, it must be confirmed in writing within 24 hours of the audit.

Once advised of the critical non-conformance the PVA will provide the client with instruction on the disposition of any contaminated product. In addition, if the PVA believes there is a potential need for recall actions, it will contact the Canadian Food Inspection Agency (CFIA) to coordinate the recall.

The client must:

• take immediate corrective action to segregate any contaminated product and initiate a root cause analysis;
• dispose of any contaminated product as instructed by the PVA and/or CFIA;
• inform the PVA and the auditor of the results of the root cause analysis and the resulting corrective action plan within 5 working days of the audit; and
• implement corrective actions, schedule and undergo a follow-up visit to verify the implementation within 10 working days of the auditor’s acceptance of the corrective action plan.

After the follow-up visit, the auditor shall submit the audit report, copies of CARs, and accepted corrective action plans to the PVA. The audit report must verify that he or she has collected objective evidence that effective corrective action has been taken. The suspension will be lifted or the re-certification will be granted.

If the client fails to take corrective action within the 10 working days of the auditor’s acceptance of the corrective action plan, the client’s certification will not be granted or will be withdrawn.

5.4 Expiration

The Canadian Grain Commission will remind the company of the expiration of the certification agreement in writing six (6) months and one (1) month prior to the end of the certification period. If the company does not schedule a recertification audit within 2 months of the end of the certification agreement, the company’s certification will be considered to have expired. The Canadian Grain Commission will notify the company that certification has expired, the company name will be removed from the website, and the company will be prohibited from using the program certification mark or representing itself as a Canadian Grain Commission-certified company.

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