Under the voluntary Canadian Grain Sampling Program (CGSP) companies can collect and submit samples from consignments of seed, grain and grain products to support phytosanitary certification for export from Canada.
Amendments to this directive will be dated and distributed as outlined in the distribution below.
The Plant Protection Act and Regulations require that plants and plant products exported from Canada meet the phytosanitary requirements of the importing country. Most countries have phytosanitary import requirements that must be met prior to exportation to ensure that pest risks are effectively mitigated. Since 1991, the CFIA has approved companies to submit samples for phytosanitary certification under the Designated Inspector Sampling Program. This document is intended for use by the various branches of the CFIA, and by the companies approved, or seeking approval, to collect samples for phytosanitary certification. Under this program, samples could be collected from bulk and bagged shipments of cereals, pulses, oilseeds, and other specialty crops, for export from Canada and intended for any end use (e.g. Definitions of terms used in this document can be found in the Plant Health Glossary of Terms. The CFIA is charging fees in accordance with the Canadian Food Inspection Agency Fees Notice. Audit of facilities and third parties, as well as issuance of Phytosanitary Certificates are cost recovered according to the Plant Protection Fees.
Seed, grain and grain products are a pathway for the movement of a number of regulated pests. All seed, grain and grain products of cereals, pulses, oilseeds, and other specialty crops that require the issuance of a Phytosanitary Certificate prior to export are eligible to be sampled under this program. Commodities that do not require a CFIA Phytosanitary Certificate prior to export are exempt from this program.
Facilities, businesses or individuals drawing samples under this program will be referred to as company (ies), hereafter in this document.
Terminal and transfer elevators, flour mills and malt plants are not eligible to apply for participation in the CGSP. All samples drawn by approved companies will be analysed according to the phytosanitary requirements of the importing country.
It is possible that the phytosanitary import requirements of some countries may require that the CFIA conduct additional laboratory testing for certification. Please refer to D-99-06 "Policy on the Issuance of Phytosanitary Certificates" for further information on the CFIA's phytosanitary certification policy and procedures.
Material in storage intended for export can be approved by sampling and testing for pests regulated by the importing country, prior to the loading of conveyances and movement into export position.
It is the responsibility of the exporter to coordinate sample collection and submission between the company approved to draw samples and the CFIA. A company seeking approval under the CGSP is required to submit an "Application for Participation in the Canadian Grain Sampling Program" (Appendix 1), and a completed Quality Management System Manual, (hereafter referred to as the Manual) to the local office of the CFIA for review.
A company must operate under a Quality Management System that ensures consistent compliance with the phytosanitary principles of sampling. Businesses or individuals acting as third party samplers will be required to submit an application and Manual per office. The CFIA will review the application and assess the company's Manual according to the requirements of Section 4.0 and Appendix 3 outlined in this document.
During the evaluation audit, the CFIA will assess if the company can comply with the procedures outlined in their Manual and if those procedures conform to the goals of the CGSP. Companies successfully completing a Manual and evaluation audit will receive a copy of the approved application from the CFIA providing them with their unique identification number.
A Manual documenting the company's sampling procedures related to the CGSP program requirements must be developed and maintained. The management will ensure that methods and procedures described in the Manual are followed to ensure the integrity of the sampling process. The management must provide all employees involved in implementing the Manual with training related to those components for which each employee has responsibility. The management must provide assistance to CFIA staff during audits and allow the audit team to examine records and documents, collect samples, inspect product and interview employees who are identified in training records as being involved in the sampling process. Have the authority and responsibility for the development and implementation of a Manual that meets the requirements of the CGSP.
Be committed to ensuring compliance with the CGSP by managing the Quality Management System of the company, including the development and implementation of a record management and retention system.
Maintain detailed records that document internal audits, non-conformances, corrective actions taken, and follow-up audit. Understand the situations which require the CFIA to be notified and incorporate within the Manual a procedure for providing that notification. Ensure that employees conducting sampling have expertise in performing CGSP related tasks and are adequately trained.
The Manager, or a designated alternate, must be present at the facility during a CFIA audit. The Manual must provide information as to the function and responsibilities of staff members involved in maintaining the CGSP requirements. The company must describe the procedures for ensuring that records pertaining to every aspect of the CGSP are maintained and retrievable for a minimum of two years. The sampler should be familiar with the company's sampling and safety procedures prior to sampling the product. Good sanitation practices are the first steps in preventing infestations and keeping insect management costs to a minimum.
The companies participating in the program are encouraged to include a sanitation policy and procedures chapter in their Manual. It is the responsibility of exporters and participants in the CGSP to work cooperatively with each other and with the CFIA to verify commodity specific phytosanitary requirements of the importing country. The sampler plays a critical role in sampling lots for testing; thorough sampling and the information submitted with the sample are vital to the validity of any subsequent test results. Under this program, the CFIA will allow a single submitted sample to represent a maximum lot size of 300 metric tonnes (mt). It is mandatory to have proper equipment available to draw samples and the equipment must be kept clean to eliminate any cross contamination between samples from different lots. A primary sample represents a small portion of the product taken from a lot during one single sampling action. A composite sample of the entire lot is obtained by the combining of all primary samples that have been collected. In all cases, the submitted sample must weigh, at minimum 1 kg (for excessively bulky crops kinds, e.g.
The specific phytosanitary requirements of some importing countries may dictate that a larger submitted sample or more than one submitted sample is required to allow for additional testing. A Boerner-type divider is a gravity-operated dividing apparatus that reduces a grain sample.
A Riffle Divider consists of a hopper with attached channels or ducts, a frame to hold the hopper, four receiving pans and a pouring pan.
Where a Boerner-type or Riffle divider is not available, composite samples may be manually reduced to provide a sample for submission using the following procedure. An alternative method for manually reducing a composite sample allows for the hand mixing of the composite sample in a large container and then re-sampling to obtain a representative portion that will serve as the submitted sample.
Sample bags should be packed in a sturdy box or container with sufficient packing material to prevent damage during transit. Sampling records are required to ensure that the sample can be linked to the shipment intended to be exported.
If a sample has been taken and submitted prior to the transfer of the consignment between conveyances at a trans-loading facility, a Trans loading Facility Stuffing Report (Appendix 8) must be completed and made available to CFIA upon request. It is the exporter's responsibility to ensure that the phytosanitary integrity of the sampled lot is maintained prior to export.
If a company samples product being transferred into storage bins, the company must include a section in their Manual on the procedures being followed to ensure identity preservation of the product prior to shipment.
The company must describe the internal audit process to be conducted that will ensure the sampling processes are being conducted in a consistent manner. The company must specify procedures for addressing non-conformances and must include a plan for dealing with specific processes and activities that fail to comply with one or more of the specified elements. An evaluation audit must be conducted by the CFIA on a company prior to approval under the CGSP. However, if deficiencies are identified in the Manual or in the implementation of the Manual procedures; the company must address those deficiencies and inform the CFIA.
A system audit will be performed by the CFIA at a minimum of once a year but the frequency can be increased if compliance issues arise.
The overall objective of the system audit is to ensure the company is in compliance with the CGSP and that all commodities sampled and submitted for testing meet the criteria of the CGSP.
Audits of companies will be composed of two elements: documentation review and onsite review of sampling and preparation of samples for submission. For more specific audit information refer to R-006 "Canadian Grain Sampling Program Audit Manual". A Corrective Action Request (CAR) form (R-006 Appendix 2) will be generated by the CFIA for each non-conformance that is detected during the system audit of a company.
The number and type of non-conformances found will determine the status of the company and the subsequent auditing frequency. If two or more are detected during an audit, or if the company fails to carry out the required corrective actions within the specified time period, the non-conformance will be assessed as critical and the company will be immediately suspended. If three (3) minor non-conformances are detected in any one audit this is considered equivalent to one major non-conformance (e.g. Observations are points or practices, which also may be noted during audits and could be used to improve the company's Manual. When audits determine that a company no longer fully meets the requirements of the CGSP, its approval status will either be suspended or the frequency of audits increased dependent on the level of non-conformance.
A company, which has had its approval suspended, may re-apply for participation under the CGSP at any time, provided a detailed report of the corrective actions taken to address the previous non-conformances is included with the application form (Appendix 1). This form must be completed by companies interested in becoming approved under the Canadian Grains Sampling Program (CGSP).
Title of Form: Application for Participation in the CFIA Canadian Grain Sampling Program (CGSP). CGSP Identification Number: this number is added onto the form by the CFIA once a facility is approved under the CGSP. Types of Companies: the form requests that the applicant identify their company as either a facility or a 3rd party sampler. Name and contact information for person responsible for the manual if different from above; including their name, phone and e-mail. A note to applicant to refer to D-10-02 Section 3.1 regarding submitting a copy of the manual along with this application. Agreement and signature block indicating that as a participant in the CGSP, we (the company) agree to follow the guidelines and condition of the CGSP and to have our company name published on the CFIA website as a participate; including data fields for Manager's title, manager's signature and date.
A CFIA Use Only section is used by the CFIA Regional Program Officer to inform the Area Program Specialist that a company has completed their application, manual review, and evaluation audit requirements of the CGSP and should be considered for approval under the CGSP.

The company must describe the procedures for ensuring that written records pertaining to every aspect of the CGSP are maintained and retrievable for a minimum of two years. Appendix 9 is an automatic sampler checklist that each company must complete and include as an attachment to their Manual, and must then be reviewed and updated by the company as a part of their internal audits.
Calibration can be completed by the company or an outside party, following the Canadian Grain Commission's protocol detailed in Sampling System's Handbook and Approval Guideline found on their web site.
Facilities having valid CGC approval of their automatic sampling system will be recognized by the CFIA. Insert the trier gently into the centre of the container with the trier opening facing downwards and the trier tilted upwards at an angle of approximately 30 degrees to the horizontal.
When sampling from the end of a container, the opening of the trier must reach the centre of the container.
When sampling from the side, the opening of the trier must reach the opposite side of the container. When sampling from the end, withdraw with decreasing speed so that the quantity of product obtained from successive locations increases progressively from the centre to the container. This type of trier is suitable for sampling static bulk lots in standard or large containers of both small and large crop kinds.
With the trier in the closed position carefully insert it into the container until it reaches the opposite side. Pour out the sample onto a clean, long piece of paper or into a suitable clean container that is the same length as the trier to check for uniformity. Hand sampling of chaffy, non-free-flowing grasses that bunch in the trier, or hand sampling from the top of the bag during the bagging of grain or grain products prior to stitching, may be the only practical sampling alternatives in some situations.
Insert your open hand through the top of the container with fingers held tightly together, until the desired depth is reached. Close your hand with the fingers held tightly together to ensure that few, if any, particles escape, and slowly withdraw your hand. Repeat this process a number of times in different parts of the lot and at different depths, to obtain the required number of primary samples as specified in Appendix 5. Ensure that the equipment does not select or separate the product during sampling, due to size, buoyancy or chaffiness. The entire cross section of the stream must be sampled or various alternating points in the product flow. Sampling should be at regular intervals and should reflect the entire lot from the beginning of the flow to the end. A Pelican-type sampling tool is approved for hand-sampling dynamic flows of grain for export. When using a Pelican-type, draw the sampling tool once through the stream from back to front to ensure the entire cross-section of the stream is sampled. The hand scoop (See Figure 2) is a sampling device consisting of a rigid material scoop attached to a 50-100 centimetre handle which is stiff and durable.
When using a hand scoop, insert the sampling tool into the stream at an alternate point across the stream (left, middle, right) for each sampling action. For the trier, the more polished the inner surface of the trier is, the more freely the product will flow.
The method for cleaning will be based on the type of equipment and the purpose and test for which the sample is to be drawn. For further information on sampling tools and methodology, refer to Canadian Grain Commission web site. The sampling frequency is determined by how much time is needed to load the grain and the total lot size.
Example: The grain lot is 2 containers of 20 metric tones each, and will be loaded in about 30 minutes and will be stream sampled using a hand scoop.
This directive establishes the criteria that will be used by the Canadian Food Inspection Agency (CFIA) for approval of companies under the CGSP.
Phytosanitary Certificates are issued based on the model set out in the International Plant Protection Convention to indicate that consignments of plants, plant products or other regulated articles meet specified phytosanitary requirements of the importing country. International trade of seed, grain and grain products has been identified as a pathway for the introduction of regulated pests. This directive establishes the criteria and requirements allowing companies to collect official samples, the results of which will be used as the basis for issuance of Phytosanitary Certificates by the CFIA.
Exporting facilities not participating in this program or not using the services of an approved third party sampler can still opt to have official samples drawn by a CFIA inspector for phytosanitary certification. Anyone requiring other information regarding fees may contact any local CFIA office or visit our Fees Notice Web Site. Commodity specific regulated pests are generally listed in an importing country's phytosanitary requirements. Please contact a local office of the CFIA to obtain country specific phytosanitary requirements for the commodity intended to be exported. Eligible applicants include facilities which are involved in the processing, handling and export of seed, grain and grain products.
The phytosanitary certification of products shipped from these facilities is based on other CFIA inspection programs. As such, the test results obtained will be used as a basis for issuance of Phytosanitary Certificates by the CFIA. Facilities interested in such an approval must ensure that the sampled lot is kept segregated and its identity preserved until the product is exported. The exporter should allow for the time necessary to confirm freedom from pests in the submitted samples as it is this confirmation which forms the basis for phytosanitary certification. The company must document the procedures that they will be following in their quality system to meet the conditions of the CGSP. If the Manual does not meet the requirements, areas requiring changes will be identified to the applicant. For third party samplers, the CFIA's scheduling of the evaluation audit will involve an on-site visit at a client's facility. The management must designate qualified alternates capable of replacing the Manager or have a contingency plan in place, approved by the CFIA. Each company should have their own safety procedures which should be adhered to when sampling. Grain spillage, dust and old residues provide an available food source and can harbour insect populations that can continually spread to other areas of the facility.
Country specific phytosanitary import requirements should be taken into consideration prior to initiating sampling, as they may affect sample submission and testing requirements. The number of primary samples of a product required to be taken from a lot to ensure that a representative sample is obtained, is dependent on the number of bags or net weight of bulk shipments.
The sample is placed in the upper hopper and released by opening the valve in the hopper throat. Since the finer components of the sample are likely to settle to the bottom of a container during mixing, the composite sample should be poured in a shallow layer onto a clean surface (e.g. The sample submission form used by the company must be approved by the CFIA during Evaluation Audit. If samples cannot be sent immediately after collection they should be stored in a secure, climate-controlled location.
Phytosanitary certificates will not be issued if there is not a clear link between the submitted sample and the lot being exported.
This application is to be completed by or on behalf of the exporter and should be submitted to the CFIA in sufficient time to complete the laboratory analysis on the samples that would permit issuance of the Phytosanitary Certificate. This is to document the linkage between the submitted sample taken prior to transfer and the final export conveyance. Sampling consignments as near to the final point of export, where they can be safeguarded from potential infestation or contamination is recommended. It must describe the frequency of training, what was covered, who has been trained and how training records will be kept. Internal audit must be conducted on a quarterly basis the first year and a minimum of twice a year the following years.
Non-conformances can be detected either during internal audits conducted by the company or audits done by the CFIA. This audit will be scheduled by the CFIA when it is determined that the Manual submitted by the company meets all the criteria established in the CGSP. At that time the CFIA may schedule a second evaluation audit to determine if the company can be approved for the CGSP. The system audit will evaluate how well the company's practices correspond with the requirements of the CGSP. The audit will evaluate whether the company is implementing their Manual and facilitate continual improvement to the company's sampling procedures. Observations on suggested changes or improvements to a company's Manual will be documented in the CGSP Audit Report. Each CAR must be accompanied by an action plan that includes a detailed description of the measures that need to be implemented to prevent recurrences of the non-conformances.
Major - Isolated incidents of non-conformance, which do not immediately impact the integrity of the CGSP but may become a problem over time. Four (4) minor non-conformances are equal to one major non-conformance and one minor non-conformance and all four should be addressed in 10 business days. An observation may be used to identify a situation of concern that does not warrant a CAR, or to highlight, suggest or reinforce particular practices.
This may result in the company being removed from the list of approved companies maintained by the CFIA. The CFIA will conduct an evaluation audit to verify if the corrective actions are adequate. The options available will be either product sampling by the CFIA or by another CGSP company, the use of which must be approved by the CFIA.
It includes a section to be completed by the company, as well as a section to be completed by the CFIA to document when the company satisfactorily completes their quality manual and their evaluation audit and if the company is given final approval by the CFIA under the CGSP. If the Area Program Specialist agrees, they then sign the Application form and send it to the National Manager. Automatic samplers take the most representative sample from a lot because there is no human bias involved.
Part III of the checklist includes the requirement for calibration of the delivery system at a minimum frequency of once every three years or when changes are made to the sample delivery system. When selecting the appropriate sampling equipment, the sampler should consider the commodity being sampled, the size and type of the containers, whether one is sampling vertically or horizontally, the number of primary samples to be drawn and the required composite sample size.
Insert the trier at the bottom edge of the container such that the 30 degree angle is achieved. The double sleeve trier consists of a hollow tube with a solid pointed end and a close fitting inner tube such that the product cannot slip between the two sleeves. There is no possibility of varying the amount of product obtained from the inner and outer part of the container by adjusting the speed with which the trier is withdrawn as the trier draws the same size of sample in each sampling action.
It is used for sampling bulk commodities in railcars, trucks, containers, bins, or holds of ships. Each pass of the sampling tool through the stream is defined as one sampling action to obtain one primary sample.

The scoop should be placed into the flow of product "upstream" and matching the belt speed or fall of the grain (if possible).
The rough edges and points of double sleeve triers should be occasionally dressed (removing sharp edges) with a file, emery or very fine sandpaper. Recommended cleaning methods are: cleaning wipes, cleaning solutions such as hand or dish soap, citric acid, rubbing alcohol or water, compressed air, bottle cleaning or gun cleaning tools. During the loading of a truck, container, railcar, or bin, samples should be collected systemically at timed intervals, with at least one primary sample taken for every 4 metric tonnes loaded.
Local CFIA offices will be able to provide additional information and updates on available submission and testing options. In addition, this directive outlines the procedures that must be followed for the collection and submission of samples to the CFIA. The CFIA as the National Plant Protection Organization of Canada is responsible for the phytosanitary export certification of plants and plant products and for the development of certification programs to address phytosanitary requirements of importing countries.
As a major exporter of these commodities, Canada recognizes that trade in these products is only possible if this pathway is addressed to ensure there is a minimal risk of transporting pests to the importing country.
This program allowed exporting companies to submit samples to the Canadian Grain Commission (CGC) for phytosanitary analysis. All companies previously approved under these two programs must seek approval under the CGSP, should they wish to continue to submit samples for phytosanitary certification. The sampled lot must be kept segregated from other lots, and handled in such a manner to prevent potential introduction, development or reproduction of plant pests, until export.
Businesses or individuals samples of grain or grain products for export on behalf of an exporter are also eligible to apply under the program as "third party" samplers.
A Phytosanitary Certificate will only be issued when the test result(s) obtained from the representative sample(s) is compliant with the phytosanitary requirements of the importing country. It is the responsibility of the exporter to be aware of these requirements and to communicate them to their CGSP sampling company. Procedures to maintain the integrity and identity of the lot from which the sample has been drawn must be described in the Manual (see Section 4.0). As a general guideline, the lot should be sampled within one month of the intended date of export.
When these modifications to the manual are made it can be resubmitted, and if requirements of the program are met an initial evaluation audit will be scheduled by the CFIA. The approved company must maintain a current copy of its Manual and make it available to the CFIA upon request. Failure to meet this requirement will disqualify the company from consideration in the CGSP. A list of amendments must be maintained and a list of the manual locations should be included in the Manual. It is recommended that appropriate personal protective equipment be used in all situations.
Grain residues reduce the effectiveness of pesticide treatments by protecting insects from contact insecticides or by absorbing insecticides and thereby reducing the amount available for controlling insects. Prior to sampling, verify the correct lot to be sampled, determine the type of product, number of bags or containers, and lot number.
Appendix 5 summarizes the minimum required sampling intensities for bulk and bagged export lot shipments. Therefore, the composite sample must be reduced to an acceptable size that can be submitted. The sample flows downward and is evenly dispersed over a cone with evenly spaced separations.
If multiple samples are part of the same shipment they can be submitted using the same form, however all railcar, container, truck or lot identification numbers must be listed.
The local CFIA office must be notified in advance of sending chemically treated or fumigated samples. Sample integrity and identification must be maintained at all times following the completion of sampling.
A Phytosanitary Certificate can be issued up to one month from the time the representative sample(s) corresponding to that consignment is submitted for analysis.
If the sample cannot be linked to the export shipment, a Phytosanitary Certificate will not be issued. The Manual should be sufficiently detailed that it is possible to the CFIA to assess that people are adequately trained.
The evaluation audit is necessary to demonstrate to the CFIA that the company is able to follow the procedures outlined in their Manual and that those procedures conform to the goals of the CGSP. The audit may involve assessment of the program, including review of the company's Manual, sampling records, interviews and observation of company staff responsible for conducting CGSP activities. The auditor will review the documentation that the company is keeping for the Manual to ensure they are fulfilling the conditions of the CGSP. Corrective actions must be undertaken by the company within a time limit specified by the auditor. The company will be immediately suspended from the CGSP if any critical non-conformances are found. To maintain their approved status, corrective actions must be carried out within 10 business days of receiving the CAR.
Similarly, six (6) minor non-conformances are equal to two major non-conformances, which constitutes a critical and the company would be immediately suspended from the CGSP). If re-approved, the CFIA will re-list the company on the list of approved companies on the CFIA web site.
The suspended company should work closely with the CFIA to determine the best course of action for re-approval.
Areas to complete include Regional Program Officer name, Regional Program Officer signature, date, Program Specialist name, Program Specialist signature and date. As a minimum, the following information must be recorded: sampling date, sampler's name, commodity, lot number, number of bags sampled or frequency of stream samples for bulk product, date when the sample was sent and name of CFIA office or CFIA approved testing body that the sample was submitted to. They draw a sample automatically by removing a portion of the product from the flow at regular intervals. The sampling device should not select the product by size or damage the product being sampled.
Care must be taken to ensure that all the openings in both the inner and outer tubes are clean.
The trier must always be long enough to reach the opposite end of the container on the diagonal. If a larger composite sample is required, reduce the interval between primary sample collection, or use a larger sampling cup (only practical for manual stream sampling). Laboratory results from samples submitted by approved companies will be used as the basis for issuance of Phytosanitary Certificates by the CFIA.
Both programs have remained relatively unchanged since their initial implementation, and have recently undergone a review by the CFIA. The Manual must provide the company name, address, table of contents, and a list of where copies of the Manual were distributed.
The list must identify those individuals receiving copies of amendments, so the company is able to track versions of the Manual.
If the product has been chemically treated appropriate safety precautions as determined by the employer should be taken.
In addition, the presence of food may result in insects being able to recover from pesticide treatments. The sample should be collected with care, the choice of equipment and sampling method must ensure that samples are representative of the entire lot. This must be done in a way that ensures the final sample submitted to the CFIA is representative of the lot for export.
This ensures that a sufficient amount of product is available for the CFIA or a CFIA approved laboratory to analyze. The divided sample is reformed into two grain streams which empty into two collecting pans at the bottom. Riffle dividers are available with a range of channel sizes and those with large channels are approved for large crop kinds.
A "degas" certificate should accompany any submitted samples that have been previously fumigated.
The sample must be submitted to CFIA (or where recognized by CFIA, to the Canadian Grain Commission (CGC)) as soon as possible following sampling.
The company must notify the CFIA immediately when there is a critical or major non-conformance. Companies successfully completing an evaluation audit will receive a copy of the approved application with their unique identification number. A Nobbe trier is suitable for sampling free-flowing product in bags (legumes, timothy, rapeseed, mustard) but only where the trier can reach to the centre of the container. When closing the openings there is a risk of damaging the product trapped between the edges of the slots but this damage can be reduced by closing the openings slowly to the point where resistance is felt.
When sampling the containers vertically, a partitioned trier must be used and the trier must be long enough to reach the bottom of the container. Moving the scoop with the flow allows sampling of the appropriate location on the belt without splashing product or overflowing the scoop. Therefore cleaning of grain spillage, residues and dust should always be done prior to applying an insecticide.
Samples must be placed in a sturdy, sealed cloth or plastic bags that will not break or leak during shipping. Records of internal audits must be available for review during the annual CFIA systems audit. However, if the system audit reveals the company is not following their Manual, observation will be put in the Audit Report (R -006 Appendix 1).
As well, proper sanitation practices can also reduce human health and safety hazard issues. A completed sample submission form (Appendix 7) must be securely attached to the sample bag.
The CFIA will provide an Audit Report (R-006 Appendix 1) that summarizes the audit findings. It is advisable to print some unique information directly onto the bag, which corresponds to the sample submission form, in the event that the form and sample become separated during shipping. Follow-up audits may be required to verify corrective actions, if noted in the audit report. A lead sheet summarizing all submitted samples should also be included if sending multiple samples.

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