Sampling and testing protocol for flaxseed exported in containers to Brazil

On this page

  1. Objective
  2. Background
  3. Container loading logistics
  4. Container sampling options
  5. Commercial procedures
  6. Certified container sampling and accredited sampler program
  7. Requirements for testing laboratories
  8. Industry sampling procedures for exports
  9. Procedures for testing flaxseed exports
  10. Canadian Grain Commission documentation procedures for exports
  11. Information sharing, review and questions

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Sampling and testing protocol for flaxseed exported in containers to Brazil (PDF, 58 kb)

Objective

This protocol describes the system of sampling, testing and documentation for the control of FP967 (CDC Triffid) in flaxseed container shipments exported from Canada to Brazil. The sampling activities described will be performed by either certified or accredited companies, and testing activities will be conducted by approved laboratories. All will follow procedures determined and overseen by the Canadian Grain Commission.

Background

According to Brazilian Law No. 11.105 of March 24, 2005, the introduction and use of any genetically modified organism (GMO) in food, feed, processing or introduction into the environment depends on prior risk assessment and favorable opinion of the National Technical Biosafety Committee in Brazil, as well as specific authorization of the board of registration and inspection authority.

After detecting the presence of unauthorized GMO flaxseed in Brazil in shipments of flaxseed imported from Canada in 2009, Brazilian authorities established mandatory sampling of all flaxseed from Canada, with the rejection or destruction of lots with the detection of GMO presence.

In order to control the export of flaxseed to Brazil, the Canadian government, through the Canadian Grain Commission, proposes this protocol based on the sampling and analysis of lots of flaxseed exported to Brazil. These lots will be controlled by certified documentary evidence of the lack of detection of FP967 flaxseed in the shipment. This documentation will be sent to Brazil along with the exported goods.

Container loading logistics

Flaxseed may be shipped in containers in bags, totes or in bulk. The containers may be loaded at an inland location or at transload facilities near the ports of Montreal or Vancouver.

Commercial handling and movement of flax shipped in containers

Flaxseed can be shipped from inland locations to transload facilities in 3 ways:

  • bulk in hopper bottom grain railcars
  • bags in box railcars
  • bags in domestic intermodal containers by rail or by truck

When flaxseed arrives at transload facilities, there are 3 methods of transloading:

  • bulk from railcar to bulk container
  • bulk to bagging equipment and then bags to container
  • bags in railcar or domestic intermodal container to international containers

Container sampling options

Containers are loaded at many different locations and types of facilities. The following are options for sampling containers.

Bulk flaxseed

  • Stream sample taken prior to container loading, either into a bin or as the flaxseed is loaded from a bin into a container
  • Stream samples can be taken by a Canadian Grain Commission-approved automatic sample, or an approved manual method

Bagged flaxseed

  • Stream sample taken prior to bagging, either into a bin or as the flaxseed is moved from the container to the bagging equipment
  • Samples can be taken from randomly selected bags using a bag trier before or as the container is loaded, or from lots of bagged product stored on pallets

Commercial procedures

The following are sampling procedures for flaxseed deliveries into the commercial grain handling system.

Producer delivery samples

A sample will be taken by grain handling company personnel from each producer delivery into the commercial handling system. Samples will be retained for a period of no less than 6 months from the date of delivery. The Canadian Grain Commission provides guidance on sampling methods to the Canadian grain industry in its official Sampling Systems Handbook and Approval Guide.

Container sampling and testing

A sample will be taken by personnel of third-party accredited companies or personnel of grain companies that have been certified and trained by Canadian Grain Commission, following protocols set out in their Certified Container Sampling Program (see section 3).

These composite samples will be tested for the presence of FP967 by an ISO 17025-accredited laboratory on the list of laboratories approved for testing flaxseed shipments to the European Union and Brazil using the approved method. If a composite sample tests positive for the presence of FP967, all bins, bagged or container lots testing positive represented by that sample will be diverted from the non-GM flaxseed supply. Individual grain handling companies will retain documentation pertaining to each bin, bagged or container lot and test result.

Certified container sampling and accredited sampler program

The Canadian Grain Commission will certify grain handling companies’ sampling systems and sampling procedures of third-party accredited sampling companies provided they meet the requirements of the Canadian Grain Commission Sampling System Standard. Verification that grain companies’ sampling systems meet these requirements will be conducted by Canadian Grain Commission-accredited third-party auditing firms. Verification of third-party accredited sampling companies’ sampling systems will be conducted by Canadian Grain Commission officials. Verification audits will be conducted annually.

The Canadian Grain Commission will train grain company staff samplers, third-party samplers and third-party auditors on appropriate sampling methods for bins, bagged lots and containers based on the Sampling Methods and Procedures Guide. The competency of samplers and auditors will be verified by a written test and a practical evaluation.

The Canadian Grain Commission will oversee the accredited third-party auditors and samplers through annual audits that will verify the compliance with the requirements of the Canadian Grain Commission Sampling System Standard. The oversight of the third-party auditors will include a Canadian Grain Commission technical review of each audit report submitted to the Canadian Grain Commission. The Canadian Grain Commission will also require that third-party audit and sampling firms are accredited by an accreditation body which is a member of the International Accreditation Forum (IAF) to either ISO/IEC Guide 65:1996 or ISO/IEC 17011:2004.

Requirements for testing laboratories

Laboratories undertaking testing for the commercial handling system may only be approved if they operate and have been assessed in accordance with the ISO 17025 standard on "General requirements for competence and testing and calibration laboratories" and if the proposed test method falls within the scope of the above assessment.

The Canadian Grain Commission will maintain a list of laboratories approved for testing flaxseed shipments to the European Union and Brazil on its website. Laboratories designated on this list will handle and prepare samples in accordance with ISO accredited procedures. Laboratories will employ the construct-specific method verified by the European Union Reference Laboratory.

Industry sampling procedures for exports

Sampling method

All containers containing flaxseed destined for export under this protocol will be sampled by Canadian Grain Commission-trained staff of grain handling companies or third-party accredited sampling companies following documented and audited procedures that meet the requirements of the Canadian Grain Commission Sampling System Standard.

Sample size

For lots of flaxseed exceeding 500 metric tons, a minimum sample size of 50 kilograms will be taken. For lots between 50 metric tons and 500 metric tons, a sample equal to 0.01% of the lot size will be taken. For lots less than 50 metric tons, a minimum sample size of 5 kilograms will be taken. These sample sizes are in accordance with European Commission Recommendation 2004/787/EC (OJ L 348, 24/11/2004, p 0018- 0026).

Multiple container lots

Consignments up to a maximum of 10 individual containers may be combined into a single lot for sampling, testing, and documentation purposes.

Sample reduction, submission and retention

Samples will be divided using a Boerner-type divider for submission. Two 2.5-kilogram samples will be prepared. One 2.5-kilogram sample for testing will be expedited to a laboratory on the list of laboratories approved for testing flaxseed shipments to the European Union and Brazil.

Procedures for testing flaxseed exports

Approved laboratories will follow these procedures for preparing and testing flaxseed samples.

Testing preparation

Laboratory personnel will draw four 60-gram sub-samples from the single 2.5-kilogram laboratory sample. Each 60-gram sub-sample represents approximately 10,000 individual flax seeds, which is capable of achieving a level of detection of 0.01%.

Testing procedures

The approved laboratory will test four 60-gram sub-samples taken from the single 2.5-kilogram laboratory sample. One DNA extraction will be made from each sub-sample using the Fast ID Genomic DNA Extraction Kit. Two PCR analyses will be carried out for each DNA extraction. The construct-specific method, verified by the European Union Reference Laboratory, will be used for the qualitative PCR assay.

Testing results

A lot shall be considered negative when all four 60-gram sub-samples test negative.

Canadian Grain Commission documentation procedures for exports

The Canadian Grain Commission will prepare an official Letter of Analysis on Canadian Grain Commission letterhead based on an analysis report forwarded by an approved laboratory, which may include a Type 1 Submitted Sample Inspection Certificate. The Letter of Analysis will be presented to the Canadian flaxseed exporter, who will in turn provide it directly to the appropriate Brazilian authorities. The Letter of Analysis will include a statement as follows:

The tested sample was submitted to [Insert Laboratory Name] for testing on behalf of the shipper by a company that the Canadian Grain Commission recognizes as having met the requirements of a certified sampling program.

[Insert Laboratory Name] operates and has been assessed in accordance with the ISO 17025 standard on "General requirements for competence and testing and calibration laboratories", and the testing method employed falls within the scope of that assessment.

[Insert Laboratory Name], has tested the sample representing the container lot and determined it to be negative for the presence of FP967 (CDC Triffid) based on the verified testing procedures outlined in the Sampling and testing protocol for flaxseed exported in containers to Brazil. The lab report is attached.

If issued, the Type 1 Submitted Sample Inspection Certificate will include a statement that reads:

A sample said to be representative of the lot or consignment identified above has been submitted to the Canadian Grain Commission for grading on behalf of the shipper by a loading facility that the Canadian Grain Commission recognizes as having met the requirements of a certified sampling program.

Information sharing, review and questions

Canadian officials will regularly share information with Brazilian officials concerning the investigation into the presence of FP967 (CDC Triffid) in the Canadian flaxseed supply.

This protocol may be reviewed jointly upon the request of the Canadian or Brazilian government at any time.

Questions pertaining to this protocol should be directed to the Chief Grain Inspector for Canada at 204-983-2780 or 1-800-853-6705.

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