Q. If the requirements in the manual are not the same as federal/ provincial/municipal/territorial regulations/legislation, which are to be followed?
A. It depends. If the manual requirements are “more strict” then the manual must be followed. If the federal/provincial/municipal/territorial regulations/ legislation are “more strict” then the regulations must be followed.
Example 1: The manual requires that water be potable according to Canadian Guidelines for Drinking Water Quality. The producer/packer must receive test results that show 0 Total Coliforms and 0 E. coli. Some provincial regulations allow potable water test results to be 10 Total Coliforms and 0 E. coli. The manual requirement is more strict; therefore, producers/packers must follow the requirement in the manual showing a result of 0 Total Coliforms and 0 E. coli. [In such cases producers/packers will need to let their lab know to quantify the actual results in the lab report (i.e., number of Total Coliforms and E.coli found).]
Example 2: The manual requires that agricultural chemical applicators are certified/licensed or are trained or supervised by a licensed person.
a) The provincial regulations in Ontario ask that all agricultural chemical applicators are licensed/certified. The provincial regulation is more strict than the manual therefore Ontario applicators must follow the provincial regulation and be licensed/certified.
b) The provincial regulations in Alberta are not the same as Ontario and there is no requirement for licensing/certifying/training or supervising of applicators. Therefore, these applicators must use the more strict requirement within the manual and choose one of the options as stated above.
Q. Does the audit have to be done when the producer/packer is harvesting or packing? What do I do if I am assigned to audit a producer when they are out of season (e.g., auditing a producer in the winter or after their season is done)?
A. The audit needs to be done while the producer or packer is in production; the production season will depend on the activities and the commodities included within the scope of certification. The audit is best to be done during harvesting or packing or in the harvest/packing season, but there is some flexibility to meet the demand as long as they are still in production. It is the responsibility of the Certification Body (CB) to ensure that the audit is scheduled appropriately. If the CB assigns you to an audit at an inappropriate time, you can contact the CB and arrange to reschedule. It is also the CB’s responsibility to schedule subsequent audits to cover the various crops and production practices over time.
Q. What do I do if I am assigned an audit but have a potential conflict of interest with the client?
A. It is your responsibility to inform the Certification Body of any potential conflicts with an assigned client. There are different situations where a conflict of interest could occur. For example, if you as an auditor are also a producer/packer of the same crops as a client that you are assigned to audit, there may be potential to gain access to privileged or confidential information of a competitor. You are required to declare this possibility to the CB. In some cases you would have to be reassigned, or the client would be called and informed, and can request a different auditor.