Why has the formal name of the GCP changed from the Greenhouse Certification Program to the Greenhouse-Grown Plant Certification Program?
The GCP working group received feedback that it was not clear from the program’s name if certification applied to the plants or to the greenhouses. The formal name change makes clear that the plants are being certified. However, the program will retain the GCP acronym because it is well recognized by facilities that use the program.
What is the GCP?
The GCP or Greenhouse-grown Plant Certification Program authorizes facilities that meet the specific compliance elements to use an Export Certification Label for export of plants to Canada or the United States. GCP programs have existed in the United States and Canada since 1996.
Why is the GCP being changed?
The GCP is an 18 year old program that has remained essentially unchanged since its launch in 1996. The program is being updated to strengthen pest mitigation measures based on current risk, to improve clarity of program requirements and to provide consistent delivery in both Canada and the United States.
When will the changes to the GCP come into effect?
Facilities that are currently authorized under the GCP will have a 24 month transition period from December 15, 2016 to transition and adapt to the revised GCP. The length of the transition period may be adjusted by mutual agreement between USDA and CFIA.
What will happen during the transition period?
At the start of the transition period, U.S. Customs and Border Protection and the CFIA National Import Service Centre will be advised of the new program. Authorized Facilities can continue to use their existing CGCP and USGCP export certification labels through the transition period. At the end of the transition period, USDA and APHIS will collect the export certification labels and interfacility stamps of any facilities which have not completed the transition to the GCP.
What will facilities have to do differently?
It is anticipated that some facilities will notice very little change, while others may have to adjust some of their practices. Whether a facility will have to change its procedures significantly will vary between facilities. Under the revised GCP all facilities will be subject to a compliance agreement, pest management plan elements, and audit practices. The GCP goal of exporting plants that are free from regulated pests and practically free from other injurious pests is unchanged.
How will this affect my business?
This revision includes significant changes to the GCP. Some of these changes may have no impact and others may have some impact. It largely depends on the individual business. The main purpose of this stakeholder consultation is to give existing GCP participants the opportunity to evaluate their ability to adapt to the revised GCP and to identify any consequences that may not have been considered.
If I’m already in the GCP, will I need to re-apply?
Yes. All current program participants will need to apply to enter into a new compliance agreement with their NPPO. USDA and CFIA will have independent administrative processes although both countries’ compliance agreements will contain the same elements, as described in the GCP technical document.
All facilities, even those that already have a written pest management plan, will be required to submit a new one using the standardized format.
Is the GCP voluntary?
Yes. The GCP is a voluntary alternative for export certification of eligible greenhouse grown plants traded between the United States and Canada.
When will I need a phytosanitary certificate?
If a GCP facility produces plants that are not eligible for export with an Export Certification Label then a phytosanitary certificate must be requested. Plants that meet the import requirements of the destination country may still be inspected and issued a phytosanitary certificate by the appropriate government agency. Facilities that choose not to participate in the GCP may export plants but must request a phytosanitary certificate.
Soil is allowed to cross the border between Canada and the United States. Why aren't plants allowed to come into contact with soil under this program?
Even though plants in soil are shipped between Canada and the United States, the pests that are associated with soil require specific phytosanitary measures. To address the risks associated with soil-borne pests, the GCP requires that growing media may not contain soil. Plants grown in soil may be shipped between the United States and Canada with a phytosanitary certificate issued by the NPPO which includes certification for soil borne pests, or when produced in the Canadian or U.S. Nursery Certification Programs.
What plants can be shipped under the GCP?
Plants that can meet the import requirements of the United States and Canada are eligible to be produced and shipped under the GCP. Some plants are excluded from the GCP. This includes plants that are prohibited entry into the United States or Canada; regulated invasive plants and noxious weeds; as well as true seeds, grains and potatoes. The revised GCP requires the facility to indicate the types of plants they are growing and where they come from. This list of plants will be reviewed by the GCP auditor to verify that all the plants are eligible for the program.
Wasn’t there going to be a list of eligible plants?
Early drafts of the revised GCP incorporated a list of eligible plant taxa. Based on feedback from national industry associations, the GCP working group developed alternative pest risk management measures. In place of the list of eligible plants, the design of the revised GCP focuses on the pest management plan employed at the facility. Facilities are required to maintain a list of plant taxa in production and their origins. If facilities have included plant taxa or origins that are not eligible, these will be identified by the NPPO during the evaluation of the facility’s plant list.
The current U.S.-Canada Greenhouse Program has lists of plants excluded from the programs. Are these plants still excluded?
There will still be plant taxa and origins that are not eligible for the GCP. Rather than incorporating and maintaining lists of excluded plants, the GCP requires that plant taxa and origins be reviewed for eligibility against the current phytosanitary import requirements of the United States and Canada. This way, the eligibility of plants to be shipped under the GCP will remain current without the need to update the GCP each time there is a regulatory update.
Will I be able to continue exporting the same plants I do now?
It is expected that the vast majority of plants which are currently being certified using an Export Certification Label will continue to eligible for certification under the revised GCP. The focus of the GCP is on the pest management plan for plants that are propagated and grown in a greenhouse. There may be plants which were previously excluded from the program that are now eligible under the revised GCP. There may also be plants that are currently being exported that will not be eligible. Eligibility will be determined by the NPPO.
Does the GCP have restrictions of what types of plants may be certified?
The revised GCP is for plants that are greenhouse propagated and grown. In addition, plants must be eligible to enter both Canada and the United States. Plants that cannot be exported using a phytosanitary certificate cannot be exported using an Export Certification Label.
Are plants that I ship to another greenhouse still eligible to be exported using an Export Certification Label?
When plants are shipped between participating GCP facilities in the same country, an Interfacility Stamp may be used to demonstrate that the plants in the consignment are certified and ready for export. If the plants are shipped to a facility that is not registered in the GCP, the plants lose their certified status.
Can plants shipped through the GCP ever be grown outside?
The GCP is designed for plants which are propagated and grown in a greenhouse. There are limited exceptions; for example, there are provisions to allow greenhouse grown plants to be hardened-off in order to acclimatize to outdoor conditions prior to sale. Any other production practices involving outdoor growth will have to be presented to CFIA or APHIS in writing so both countries may assess the risk and determine whether they are acceptable under the GCP. Plants that are grown outside for a portion of their production may continue to be shipped between the United States and Canada when certified through the Canadian or U.S. Nursery Certification Programs or with a phytosanitary certificate issued by the NPPO.
What are the new traceability requirements for the program?
The revised GCP does not establish new traceability requirements; instead, it provides a common language for all facilities and auditors so there is a consistent approach to traceability. Authorized Facilities must have a system in place that allows eligible plants to be tracked from the time they enter the facility to the time they are shipped. There must be sufficient information available to substantiate eligibility and ensure that only eligible plants are certified under the GCP.
How will the audit process work?
The audit process is based on the compliance agreement between the facility and the NPPO. Audits will be conducted up to 4 times per year and will include at least one complete systems audit. Auditors will assess the practices of the greenhouse against the compliance agreement, as well as verify that plants are free from regulated pests and practically free from other injurious pests. The compliance agreements contain the same technical elements for facilities in Canada and the United States, improving consistency and equivalence between greenhouses.
What are the new training requirements for staff on the program?
The revised GCP does not establish new training requirements; instead, it provides a common language for all facilities and auditors so there is a consistent approach to staff training. Staff must have the knowledge, skills and ability to ensure that the GCP requirements are being met.
What will be the process for conflict resolution or for reviewing updates to procedures following audits?
Each NPPO is responsible for authorizing, auditing, suspending and removing facilities from the GCP in their country, including any procedures for conflict resolution. APHIS and CFIA have committed to regularly evaluate the performance of the GCP, including non-compliance information, to improve the GCP.
Who may I contact if I have further questions about the GCP?
Inquiries should be directed to RCC@aphis.usda.gov
If I want to participate in the GCP, how do I apply?
In the United States, please contact your state department of agriculture.