Management Action Plan to Achieve an Effective Risk-based Management Approach to Plant Product Imports Responding to Chapter 4 of the Auditor General's December 2008 Report: "Managing Risks to Canada's Plant Resources"

The attached Canadian Food Inspection Agency (CFIA) Management Action Plan addresses all recommendations contained in the Auditor General’s December 2008 Report, Chapter 4: “Managing Risks to Canada’s Plant Resources”. It provides detailed actions, that once fully implemented, will help the Agency achieve an effective risk-based management approach to plant and plant product imports.

The report from the Office of the Auditor General (OAG) highlighted a number of significant vulnerabilities, including: a lack of appropriate inter-branch coordination; inadequate quality management systems; inadequate Agency support for the plant program in the area of Information Management and Information Technology (IM/IT); and the lack of quality management processes for import-related activities.

The CFIA agreed with all of the audit’s recommendations.

To address these recommendations, this action plan identifies initiatives, timelines, responsible senior executives, and progress to date. Where appropriate, the plan also highlights those activities requiring further analysis and/or consideration.

May 27, 2009

OAG Recommendation 4.45

The Agency should develop and implement a formal, risk-based approach to pest surveys. The approach should link identified risk of existing and potential pests and diseases with the priority of the survey.

CFIA management response

The Agency will examine ways in which pest surveys can be prioritized in a more formal manner to better balance trade and commerce needs with identifying new and existing pests and diseases.

Currently, pest survey design and prioritization are based on comprehensive risk assessments, the progress and outcomes of which are monitored informally during the survey season.

The Agency will align the conduct of surveys under a broader quality management system to better support accuracy and reliability of survey data.

CFIA actions	Status of implementation as of May 25, 2009	Areas of further analysis / consideration
The CFIA will review and apply risk criteria for pest surveys for use during the survey season of 2010-11 (Executive Director, Science Strategies Directorate).	Science Strategies Directorate will have in place by December 2009, a risk-based approach to setting survey priorities and allocation.	The CFIA needs to explore, with federal-provincial-territorial partners, ways to expand the scope of surveys.
Survey protocols for pest surveys are being audited and will be revised for the 2010-2011 survey season. (Executive Director, Science Strategies Directorate)	The Plant Health Surveillance Unit is working with Quality Management Service (QMS) officers in Operations on survey audits. Information from these audits will be used to revise survey protocols. The CFIA did 108 QMS Quality Verifications of pest surveys and 183 QMS Quality Verifications of Plant Import Inspections between April 01, 2008 and March 30 2009. A national team will begin evaluating this data in June 2009. The team will provide a report to help enhance and broaden the delivery and performance of these activities across the Agency.
The CFIA will eliminate its backlog of requests for risk assessments by March 2010. (Executive Director, Science Strategies Directorate).	The CFIA implemented a stream-lined process for risk assessment of plants as invasive species. It is developing a similar stream-lined process for insects and plant diseases. An electronic database of all previous risk assessments and in-progress assessments will be put on-line for staff to access.
The CFIA will work with its counterparts toward a harmonized risk assessment process for North America. This process will identify best management practices for all phases of risk analysis (Executive Director, Science Strategies Directorate).	The CFIA is meeting with US counterparts in May 2009 to discuss a harmonized risk analysis process, along with a number of other issues.

OAG Recommendation 4.91

To meet its plant protection mandate, the CFIA, in collaboration with CBSA, should formally define the performance information it requires from the CBSA, and it should develop an action plan for obtaining and monitoring the required information.

CFIA management response

The Agency intends to work cooperatively with the CBSA to fulfill both agencies’ responsibilities and develop an action plan to obtain required information.

CFIA actions	Status of implementation as of May 25, 2009	Areas of further analysis / consideration
The CFIA will revise the Memorandum of Understanding with the Canada Border Services Agency, to clearly articulate the information and reporting requirements needed for a risk-based approach to import controls (Executive Directors of Plant Health and Biosecurity Directorate, and Operations).	The CFIA and the CBSA meet regularly on a range of operational issues contained in the MOU. At a recent meeting of senior officials, they committed to address information management and reporting. The CFIA is defining its information and reporting requirement needs. To address concerns raised in the OAG report, the CFIA is reinforcing the importance of the current process for plant regulated products that are deemed to be high risk. Such shipments are referred to one of the CFIA Import Service Centres (ISC) for review of documentation and a release recommendation. If the product requires an inspection at its destination, the ISC will forward all documents related to the shipment to the appropriate plant health office for further action.	The CFIA needs to investigate, with the CBSA, quarantine facilities to receive all higher-risk products that require inspection.

OAG Recommendation 4.99

The CFIA should implement quality management systems to provide management with assurance that the Plant Health Program, as it relates to imports, is designed to effectively manage risks to Canada’s plant resources and that it operates as intended.

CFIA management response

Implement broader quality management and informatics systems within the Plant Health Program, similar to those in place for other CFIA programs which will better provide management with assurance that the import component of the Plant Health Program is designed and operates as intended.

The quality management system and national training program will build upon updated policies and procedures as outlined in the 2007 Plant Health Import Inspection Manual.

CFIA actions	Status of implementation as of May 25, 2009	Areas of further analysis / consideration
The CFIA has completed the Import Inspection Manual which will improve consistency in interpretation and application of regulations, policies, and procedures. (Executive Directors, Operations and Plant Health and Biosecurity).]	Revisions to the Import Inspection Manual were completed in May 2009. Training of inspectors began in May 2009 and will be completed by July 2009.
The CFIA will implement an integrated and comprehensive application of the quality management system approach across the Agency.	A Quality Management System, which includes assessment of plant program activities, has been developed and implemented in 08/09. In 09/10, quality verification data will be assessed to determine potential improvement areas and to develop and implement a comprehensive improvement plan.	Implementation of QMS will continue in 09/10 strengthening various components of the QMS.
The CFIA will implement a modernized Plant Health Import Policy that will shift the focus of “inspection at the border” into a risk-based approach, based on products and country of origin. (Executive Directors of Science Strategies, Plant Health and Biosecurity, and Operations).	Senior officials of the CFIA and the USDA met (Jan 2009) to re-confirm the mutual commitment to manage plant health risks to North America. Fifteen projects have been initiated under the North American Perimeter Approach including projects to manage risk at origin, use collective resources, harmonize import policies and share risk assessments.	This is a long-term initiative that integrates risk assessment and foreign country audits into the CFIA’s role in the import of plants and plant products.

OAG Recommendation 4.103

The Agency should complete its assessment of possible information management and information technology support for the Plant Health Program, and it should identify options for funding those needs.

CFIA management response

The Agency must implement a consistent approach to assess information management and information technology needs across the Agency.

As part of the approach, the CFIA is working towards identifying and meeting the business needs of the Plant Health Program as it relates to imports, and identifying funding options to meet these priorities.

The Agency will identify options for funding its overall information management and information technology priorities.

CFIA actions

Status of implementation
as of May 25, 2009

Areas of further analysis / consideration

The CFIA will complete an assessment of business service requirements and their corresponding information management needs for the Plant Health Program as it relates to imports, by April 2010 (Executive Director, Plant Health and Biosecurity, and the CIO).

The CFIA has begun its analysis and will provide options, costs and recommendations that will meet (in a sustainable manner) the long-term needs of the Plant Health Program as it relates to imports. This includes identifying options and approaches for funding.

The needs of the plant import program are being considered in the Agency’s review of Agency-wide systems.

The CFIA will make essential but limited investments in current tools and services such as its Import Control and Tracking System (ICTS). This will provide improved short-term capabilities to meet the needs of the Plant Health Program as it relates to imports (Chief Information Officer; and, Executive Director, Plant Health and Biosecurity).

The CFIA is working on modernizing information transactions between field offices and Import Service Centres.

The work underway by the Office of the Chief Information Officer on other fundamental Agency systems will benefit the Plant Health Program, including:

The Client Identity Data Project, which will improve the CFIA's client management database. Interim changes to the current client database (CMS) will benefit the program immediately;

The electronic certification (E-Cert) system for the import and export of plant products currently in development is an integral component of the Plant Health Control and Tracking System project; and

Plant health components are currently being added to the Laboratory Sample Tracking System (LSTS). This system, already in production for a number of other commodities, will enable the tracking of plant health samples from the point they are taken, through the testing process to the identification and communication of results to the interested parties.

OAG Recommendation 4.109

The Agency should define the level of science, policy, and operations necessary to fulfill its plant protection mandate as it relates to imports. It should then determine the level of funding needed to carry out these responsibilities.

CFIA management response

The CFIA recognizes the need to continuously review and assess its science, policies and operational requirements to update its current approach underlying the Plant Health Program.

A review is currently being conducted on the Invasive Alien Species (IAS) Program, which is a component of the Plant Health Program.

The results of this review, as well as other activities, will identify the level of science, policy and operational activities (and associated funding needs) for the import component of the Plant Health Program.

CFIA actions

Status of implementation
as of May 25, 2009

Areas of further analysis / consideration

The CFIA has established a senior-level governance structure that is accountable for implementing a risk-based approach to plant health programming. (Executive Directors of Science Strategies, Plant Health and Biosecurity, and Operations).

The planning and reporting for fiscal year 2009-2010 is under the guidance and stewardship of Plant Health Business Line Steering Committee. The business line has adopted a formal risk-based approach to program design, setting priorities, and allocating resources.

CFIA senior management to review resource allocations against expected program deliverables for the Plant Health Business Line, and determine adequacy of resourcing (Vice Presidents of Policy and Programs, Operations, Science, Finance Administration and Information Technology, and Corporate Affairs).

The CFIA will establish, a Program Management Office to plan, implement, resource, and monitor the Plant Health Program across the Agency, including invasive species (Executive Director, Plant Health and Biosecurity).

Work has begun on creating a Program Management Office, including identifying initial work the office will do. Two key priorities include:

the CFIA contribution to the next phase of the federal implementation of An Invasive Alien Species Strategy for Canada and

a pilot project considering a risk-based approach to horizontal emerging programs in the area of plant health.

RDIMS # 1959369

Revised May 27, 2009