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Malaysian Fumigation Accreditation Scheme (MAFAS) |
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Fumigation is a treatment method extensively used in eradicating pests and diseases in agricultural produce in many countries. Although this method, especially the use of methyl bromide (CH3Br), is acknowledged to have the potential to negatively impact upon the environment, fumigation continues to be considered as the appropriate method to free agricultural produce from pests and diseases. The Montreal Protocol continues to provide for the use of methyl bromide in fumigation activities, particularly for pre-shipment treatment and quarantine purposes. Many countries require certain commodities to be fumigated prior to export. As evidence that the commodities have been fumigated, importing countries require the fumigation provider or an endorsing government authority to issue fumigation certificates that clearly details the treatment that has been undertaken on the commodity. Ineffective fumigations can impact severely on Malaysian export trade by putting in question the product integrity of Malaysian agricultural exports. Malaysia is committed to addressing the issue of ineffective quarantine fumigations on its exports. To this end, Malaysia has established a Fumigation Accreditation Scheme (to be known as the Scheme) for export fumigators with a view to ensuring that all quarantine fumigations are undertaken in accordance with world’s best practice as outlined in the Australian Methyl Bromide Fumigation Standard (to be known as the Standard). PURPOSE This article sets out the outcomes to be met by a fumigation company and an accredited fumigator when performing quarantine fumigation treatments on export goods using methyl bromide under the Scheme. SCOPE This article is limited to the treatment of goods, subject to quarantine, by methyl bromide fumigation. The classes of goods covered by this paper are:
Registration Protocols In order to be recognized under the Scheme, fumigation companies must have an accredited fumigator present at all fumigations. Fumigation companies with accredited fumigators will be allocated a unique identification number. Fumigation companies must record the number on all treatment certification and correspondence to Department of Agriculture Malaysia. Department of Agriculture Malaysia will maintain a central register of fumigation companies and accredited fumigators. Accreditation will be granted for a period of 1 year. Accredited fumigators are required to re-apply within three (3) months for approval prior to the end of their approval term. In considering a renewal application, Department of Agriculture Malaysia will conduct an assessment (announced audit) inline with the original approval process. The Department of Agriculture Malaysia is to be notified in writing of changes in arrangements either between the fumigation company and accredited fumigators or within the fumigation company. If the quarantine integrity cannot be guaranteed, Department of Agriculture Malaysia may cancel the accreditation. RESPONSIBILITIES Fumigation companies are responsible for:
Audit System The audit system outlined below has been designed to measure the performance of the fumigation company and the accredited fumigator against the requirements of the Scheme and the procedures outlined in the Standard. 1.1. Initial Audit An initial audit will occur once the accredited fumigator has undertaken accreditation training and is assessed as being competent. Initial audits will continue until the fumigation company and their accredited fumigators demonstrate competency in fulfilling the requirements of the Scheme and the Standard. 1.2. Announced Audits Announced audits will be scheduled by the Department of Agriculture Malaysia and will take at least every 12 months. An Inspecting Officer of the Department of Agriculture Malaysia will make contact with the fumigation company and arrange a convenient date for the audit. 1.3. Unannounced Audits Unannounced audits will take place at least once every three (3) month and will be conducted by the Department of Agriculture Malaysia. 1.4. Reinstatement Audits Reinstatement audits will be scheduled and conducted by the Department of Agriculture Malaysia following a period of suspension. The Department of Agriculture Malaysia will contact the fumigation company and arrange a convenient date for the audit. If, during the reinstatement audit, the fumigation company is unable to demonstrate compliance with the Scheme, the suspension will continue and the fumigation company will be asked to show cause as to why it should not be removed from the Scheme. 2. Audit Activity Audit criteria has been developed and onsite audit checklist is provided at Attachment 1. The audit criterion has been divided into three levels of non-conformities (major, minor and critical). Critical non-conformities will result in immediate suspension from the Scheme. Major and minor non-conformities will result in corrective actions and an additional announced audit. The Department of Agriculture Malaysia is to notify the fumigation company and the accredited fumigator, in writing, within 10 working days of the non-conformity and advise the fumigation company and the accredited fumigator of subsequent compliance action to be taken by the Department of Agriculture Malaysia. The issuance of a corrective action report will constitute the giving of a notification. A corrective action report is a formal document that records and details non-conformities, corrective action and the proposed date for rectification. As guide, non-conformities are defined as: Major Non-Conformity:
Minor Non-Conformity:
Critical Non-Conformity:
2.1. Auditing – Administrative Aspects 2.1.1. Licences A fumigation company must have all permits and licences from authorising institutions according to existing regulations. The licences and permits include:
A fumigation company must have an organisational chart with clear job descriptions. At a minimum, the organisational chart must include a general manager (or equivalent) who has the authority and resources to carry out his/her job, a technical manager (or equivalent) who is responsible for all fumigation technical activities. A fumigation company must have sufficient numbers of personnel to carry out its activities. For example, for one fumigation activity, at least two persons are required including an accredited fumigator. The management of any fumigation company and all persons designated as an accredited fumigator should be aware of and fully acquainted with: local legislation covering fumigation treatments in the country in which it operates; requirements of the Standard; their responsibilities as a fumigation treatment provider; the need to involve all other parties with an interest in the treatment; and the need to have access to a regular supply of methyl bromide. 2.2. Auditing – Technical Aspects 2.2.1. Technical Personnel The technical manager (or equivalent) must have the following qualifications:
The accredited fumigator must undergo the accreditation training and be assessed as being competent. In summary, the accredited fumigator should:
The following is a list of equipment required for methyl bromide treatments: Enclosure
The fumigation company must ensure that the Standard Operational Procedures are developed in line with the Standard, maintained and kept up to date. The fumigation company must ensure that the following categories of records and documents, relating to supervising, monitoring and testing compliance with the procedures for goods covered by the Scheme are maintained and kept up to date:
Fumigation companies and accredited fumigators that perform ineffective fumigations will be suspended immediately, will be subject to a reinstatement audit and will be asked to show cause as to why they should not be removed from the Scheme. If during an audit, one or more critical non-conformities and/or more than four minor non-conformities and/or more than two major non-conformities are found, fumigation company and accredited fumigators will be suspended immediately and will be subject to a reinstatement audit. Re-training of the accredited fumigators may be necessary. If during an audit, less than four minor non-conformities are found, the fumigation company and the accredited fumigators will be subject to an additional announced audit within six (6) weeks. If during the follow-up audit the non-conformities have not been improved, the fumigation company and the accredited fumigators will be subject to second announced audit and will be suspended immediately if there is no improvement and will be subject to a reinstatement within six (6) months. Reinstatement audits will continue until the fumigation company and their accredited fumigators demonstrate competency in fulfilling the requirements of the Scheme and the Standard. Re-training of the accredited fumigators may be necessary. Accreditation for fumigation companies and accredited fumigators will be cancelled, if:
APPEALS PROTOCOL It is accepted that there may be occasions where the detection of non-conformities and the subsequent actions may be the subject of some dispute, and in these situations there is a need for a process of appeal. The purpose of this appeals protocol is to set out the appeals mechanism that is available to the fumigation company and the accredited fumigator in such situations. 1. Appeals Process If the fumigation company and the accredited fumigator believes that there were extenuating circumstances in respect to the occurrence of a non-conformity, the fumigation company and the accredited fumigator may appeal against the decision. Compliance action will remain in place while the appeal is being considered. The fumigation company and the accredited fumigator must appeal in writing. The fumigation company and the accredited fumigator should clearly set out their reasons for appeal. Department of Agriculture Malaysia undertakes to:
Malaysian Fumigation Accreditation Scheme Assessment Committee  ONSITE AUDIT CHECKLIST The following checklist is provided as a guide for auditors undertaking onsite audits of fumigation companies and accredited fumigators.
Note: a “NO” answer will result in a non-conformity. |
Introduction Purpose Scope Registration Responsibilities Assessment and Audit Protocol Sanctions and Suspension Protocol Appeals Protocol Onsite Audit Checklist |
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